Re: Acceptable Levels of Mould Spores

[Guest guest]

and :

Long post from the USEPA website regarding air sampling for mold.

Bottom line: The USEPA agrees with Health Canada that, because there

are no threshold values for airborne mold spores, microbial air

sampling should be used for health risk assessment.

Don

USEPA: Is sampling for mold needed? In most cases, if visible mold

growth is present, sampling is unnecessary. In specific instances,

such as cases where litigation is involved, the source(s) of the mold

contamination is unclear, or health concerns are a problem, you may

consider sampling as part of your site evaluation. Surface sampling

may also be useful in order to determine if an area has been

adequately cleaned or remediated. Sampling should be done only after

developing a sampling plan that includes a confirmable theory

regarding suspected mold sources and routes of exposure. Figure out

what you think is happening and how to prove or disprove it before

you sample!

If you do not have extensive experience and/or are in doubt about

sampling, consult an experienced professional. This individual can

help you decide if sampling for mold is useful and/or needed, and

will be able to carry out any necessary sampling. It is important to

remember that the results of sampling may have limited use or

application. Sampling may help locate the source of mold

contamination, identify some of the mold species present, and

differentiate between mold and soot or dirt. Pre- and post-

remediation sampling may also be useful in determining whether

remediation efforts have been effective. After remediation, the types

and concentrations of mold in indoor air samples should be similar to

what is found in the local outdoor air. Since no EPA or other Federal

threshold limits have been set for mold or mold spores, sampling

cannot be used to check a building's compliance with Federal mold

standards.

Sampling for mold should be conducted by professionals with specific

experience in designing mold sampling protocols, sampling methods,

and interpretation of results. Sample analysis should follow

analytical methods recommended by the American Industrial Hygiene

Association (AIHA), the American Conference of Governmental

Industrial Hygienists (ACGIH), or other professional guidelines (see

Resources List). Types of samples include air samples, surface

samples, bulk samples (chunks of carpet, insulation, wall board,

etc.), and water samples from condensate drain pans or cooling

towers.

A number of pitfalls may be encountered when inexperienced personnel

conduct sampling. They may take an inadequate number of samples,

there may be inconsistency in sampling protocols, the samples may

become contaminated, outdoor control samples may be omitted, and you

may incur costs for unneeded or inappropriate samples. Budget

constraints will often be a consideration when sampling; professional

advice may be necessary to determine if it is possible to take

sufficient samples to characterize a problem on a given budget. If it

is not possible to sample properly, with a sufficient number of

samples to answer the question(s) posed, it would be preferable not

to sample. Inadequate sample plans may generate misleading,

confusing, and useless results.

Keep in mind that air sampling for mold provides information only for

the moment in time in which the sampling occurred, much like a

snapshot. Air sampling will reveal, when properly done, what was in

the air at the moment when the sample was taken. For someone without

experience, sampling results will be difficult to interpret.

Experience in interpretation of results is essential.

> > >> >

> > >> > Right you are Bob,

> > >> >

> > >> > The EPA takes a much different approach than does Health

> Canada.

> > > The EPA clearly states that any indoor mold growth has the

> potential

> > > to cause health problems to some segment of the population.

> > > Although you can argue that the EPA has established a threshold

> and

> > > that is anything above zero.

> > >> >

> > >> > Rosen, Ph.D.

> > >> > www.Mold-Books. com

> > >> >

> > >> >

> > >> >

> > >> > RE: Re: " Acceptable " Levels of Mould

> Spores

> > >> >

> > >> > Sharon, et al;

> > >> >

> > >> > May I disagree for a moment (I may be confused for a

second)?

> The

> > > term running through this thread stated as follows: From the

> Health

> > > Canada Annex on Mould: ' " Further, in the absence of exposure

> limits,

> > > results from tests for the presence of fungi in air cannot be

> used to

> > > assess risks to the health of building occupants. "

> > >> >

> > >> > I can not find myself agreeing with the term " can not be use

to

> > > access … . " If the term were stated " May not " exclusively " be

> used to

> > > assess the risk to health of building occupants without first

> > > eliminating other causes/sources … " or " Can not be solely

relied

> upon

> > > to conclude the risk to health of building occupants without

> > > eliminating other causes/sources … " I could find myself

agreeing

> with

> > > these type of statements. To read it as it is causes one to

> believe

> > > that mold has no adverse health impact upon any building

occupant.

> > >> >

> > >> > All data is relative either to help in eliminating cause or

to

> > > acknowledge and/or confirm attributes of associations to adverse

> > > health affect and/or illness.

> > >> >

> > >> > I.e. If I receive a call that all office occupants are

> exhibiting

> > > adverse health affects and all other sampling/testing support no

> > > other contamination in the space except magnitudes of

elevations

> of

> > > mold, it's associated spores, and body fragments over the

outside

> > > conditions as well other office spaces in the local areas, are

> they

> > > saying that the air sampled are of no consideration to the EP

> and/or

> > > occupant as associated with potential (or genuine) adverse

health

> > > affects in which they suffer? We all know people who suffer from

> > > these conditions. If the document were even stating its

> relationship

> > > to SBS or BRI as not being the sole contributor until

confirmed;

> now

> > > that may be a different issue but to say it has no validity

> > > of " assessing " risk to the health of building occupants when we

> have

> > > been informed one or more of the occupants are immunocompromised

> > > (definition: Immunocompromised: Having an immune system that

has

> been

> > > impaired by disease or treatment) is beyond me. I

> > >> > just can see making linier statements in a non-linier world.

> This

> > > is why (my opinion) many are not getting the treatment they

> deserve

> > > and therefore are getting sicker as this debate continues.

> > >> >

> > >> > Your thoughts on this are welcome.

> > >> >

> > >> > EnviroBob

> > >> >

> > >> >

> >

>

>

>

>

> __________________________________________________

>

[Guest guest]

and :

Long post from the USEPA website regarding air sampling for mold.

Bottom line: The USEPA agrees with Health Canada that, because there

are no threshold values for airborne mold spores, microbial air

sampling should be used for health risk assessment.

Don

USEPA: Is sampling for mold needed? In most cases, if visible mold

growth is present, sampling is unnecessary. In specific instances,

such as cases where litigation is involved, the source(s) of the mold

contamination is unclear, or health concerns are a problem, you may

consider sampling as part of your site evaluation. Surface sampling

may also be useful in order to determine if an area has been

adequately cleaned or remediated. Sampling should be done only after

developing a sampling plan that includes a confirmable theory

regarding suspected mold sources and routes of exposure. Figure out

what you think is happening and how to prove or disprove it before

you sample!

If you do not have extensive experience and/or are in doubt about

sampling, consult an experienced professional. This individual can

help you decide if sampling for mold is useful and/or needed, and

will be able to carry out any necessary sampling. It is important to

remember that the results of sampling may have limited use or

application. Sampling may help locate the source of mold

contamination, identify some of the mold species present, and

differentiate between mold and soot or dirt. Pre- and post-

remediation sampling may also be useful in determining whether

remediation efforts have been effective. After remediation, the types

and concentrations of mold in indoor air samples should be similar to

what is found in the local outdoor air. Since no EPA or other Federal

threshold limits have been set for mold or mold spores, sampling

cannot be used to check a building's compliance with Federal mold

standards.

Sampling for mold should be conducted by professionals with specific

experience in designing mold sampling protocols, sampling methods,

and interpretation of results. Sample analysis should follow

analytical methods recommended by the American Industrial Hygiene

Association (AIHA), the American Conference of Governmental

Industrial Hygienists (ACGIH), or other professional guidelines (see

Resources List). Types of samples include air samples, surface

samples, bulk samples (chunks of carpet, insulation, wall board,

etc.), and water samples from condensate drain pans or cooling

towers.

A number of pitfalls may be encountered when inexperienced personnel

conduct sampling. They may take an inadequate number of samples,

there may be inconsistency in sampling protocols, the samples may

become contaminated, outdoor control samples may be omitted, and you

may incur costs for unneeded or inappropriate samples. Budget

constraints will often be a consideration when sampling; professional

advice may be necessary to determine if it is possible to take

sufficient samples to characterize a problem on a given budget. If it

is not possible to sample properly, with a sufficient number of

samples to answer the question(s) posed, it would be preferable not

to sample. Inadequate sample plans may generate misleading,

confusing, and useless results.

Keep in mind that air sampling for mold provides information only for

the moment in time in which the sampling occurred, much like a

snapshot. Air sampling will reveal, when properly done, what was in

the air at the moment when the sample was taken. For someone without

experience, sampling results will be difficult to interpret.

Experience in interpretation of results is essential.

> > >> >

> > >> > Right you are Bob,

> > >> >

> > >> > The EPA takes a much different approach than does Health

> Canada.

> > > The EPA clearly states that any indoor mold growth has the

> potential

> > > to cause health problems to some segment of the population.

> > > Although you can argue that the EPA has established a threshold

> and

> > > that is anything above zero.

> > >> >

> > >> > Rosen, Ph.D.

> > >> > www.Mold-Books. com

> > >> >

> > >> >

> > >> >

> > >> > RE: Re: " Acceptable " Levels of Mould

> Spores

> > >> >

> > >> > Sharon, et al;

> > >> >

> > >> > May I disagree for a moment (I may be confused for a

second)?

> The

> > > term running through this thread stated as follows: From the

> Health

> > > Canada Annex on Mould: ' " Further, in the absence of exposure

> limits,

> > > results from tests for the presence of fungi in air cannot be

> used to

> > > assess risks to the health of building occupants. "

> > >> >

> > >> > I can not find myself agreeing with the term " can not be use

to

> > > access … . " If the term were stated " May not " exclusively " be

> used to

> > > assess the risk to health of building occupants without first

> > > eliminating other causes/sources … " or " Can not be solely

relied

> upon

> > > to conclude the risk to health of building occupants without

> > > eliminating other causes/sources … " I could find myself

agreeing

> with

> > > these type of statements. To read it as it is causes one to

> believe

> > > that mold has no adverse health impact upon any building

occupant.

> > >> >

> > >> > All data is relative either to help in eliminating cause or

to

> > > acknowledge and/or confirm attributes of associations to adverse

> > > health affect and/or illness.

> > >> >

> > >> > I.e. If I receive a call that all office occupants are

> exhibiting

> > > adverse health affects and all other sampling/testing support no

> > > other contamination in the space except magnitudes of

elevations

> of

> > > mold, it's associated spores, and body fragments over the

outside

> > > conditions as well other office spaces in the local areas, are

> they

> > > saying that the air sampled are of no consideration to the EP

> and/or

> > > occupant as associated with potential (or genuine) adverse

health

> > > affects in which they suffer? We all know people who suffer from

> > > these conditions. If the document were even stating its

> relationship

> > > to SBS or BRI as not being the sole contributor until

confirmed;

> now

> > > that may be a different issue but to say it has no validity

> > > of " assessing " risk to the health of building occupants when we

> have

> > > been informed one or more of the occupants are immunocompromised

> > > (definition: Immunocompromised: Having an immune system that

has

> been

> > > impaired by disease or treatment) is beyond me. I

> > >> > just can see making linier statements in a non-linier world.

> This

> > > is why (my opinion) many are not getting the treatment they

> deserve

> > > and therefore are getting sicker as this debate continues.

> > >> >

> > >> > Your thoughts on this are welcome.

> > >> >

> > >> > EnviroBob

> > >> >

> > >> >

> >

>

>

>

>

> __________________________________________________

>

[Guest guest]

Carl and Jim:

Thank you for your posts. You have stated better than I could what

is the concern with a reliance on microbial air sampling only, the

issue of threshold values, and the disconnection from the microbial

air sampling results to health risk assessments. I really appreciate

your thoughts on this matter.

I am distressed that thinks I am performing a 'disservice' to

those with illness from exposure to damp buildings, mold and the

mycotoxins that cause the illnesses. These individuals have been my

life's work, and I will continue to help these individuals by all

means possible.

Just one further thought to : IF we could measure airborne

indoor mycotoxins (and not just the mold spores that generate these

toxigenic organisms) in an exact, accurate and replicable manner by

instrumentation that was easy to use and relatively inexpensive, and

IF we could know, specifically, at what airborne level the vast

majority of people would have adverse health effects from airborne

exposure to this mycotoxin, then all of us who have been doing this

work (as I have for the past 32 years) would embrace this technology

and the threshold. However, as Carl and Jim point out, we are not

there yet, and we may never be there.

IMHO, An informed, thorough building inspection is the best means

available to assist those in need.

Don

[Guest guest]

Carl and Jim:

Thank you for your posts. You have stated better than I could what

is the concern with a reliance on microbial air sampling only, the

issue of threshold values, and the disconnection from the microbial

air sampling results to health risk assessments. I really appreciate

your thoughts on this matter.

I am distressed that thinks I am performing a 'disservice' to

those with illness from exposure to damp buildings, mold and the

mycotoxins that cause the illnesses. These individuals have been my

life's work, and I will continue to help these individuals by all

means possible.

Just one further thought to : IF we could measure airborne

indoor mycotoxins (and not just the mold spores that generate these

toxigenic organisms) in an exact, accurate and replicable manner by

instrumentation that was easy to use and relatively inexpensive, and

IF we could know, specifically, at what airborne level the vast

majority of people would have adverse health effects from airborne

exposure to this mycotoxin, then all of us who have been doing this

work (as I have for the past 32 years) would embrace this technology

and the threshold. However, as Carl and Jim point out, we are not

there yet, and we may never be there.

IMHO, An informed, thorough building inspection is the best means

available to assist those in need.

Don

[Guest guest]

Carl and Jim:

Thank you for your posts. You have stated better than I could what

is the concern with a reliance on microbial air sampling only, the

issue of threshold values, and the disconnection from the microbial

air sampling results to health risk assessments. I really appreciate

your thoughts on this matter.

I am distressed that thinks I am performing a 'disservice' to

those with illness from exposure to damp buildings, mold and the

mycotoxins that cause the illnesses. These individuals have been my

life's work, and I will continue to help these individuals by all

means possible.

Just one further thought to : IF we could measure airborne

indoor mycotoxins (and not just the mold spores that generate these

toxigenic organisms) in an exact, accurate and replicable manner by

instrumentation that was easy to use and relatively inexpensive, and

IF we could know, specifically, at what airborne level the vast

majority of people would have adverse health effects from airborne

exposure to this mycotoxin, then all of us who have been doing this

work (as I have for the past 32 years) would embrace this technology

and the threshold. However, as Carl and Jim point out, we are not

there yet, and we may never be there.

IMHO, An informed, thorough building inspection is the best means

available to assist those in need.

Don

[Guest guest]

I like the Canadian document. But I think people are interpreting and adding more to what it says or does not say than it really does.

"However, the large number of mould species and strains growing in buildings and the large inter-individual variability in human response to mould exposure preclude the derivation of exposure limits."

"Further, in the absence of exposure limits, results from tests for the presence of fungi in air cannot be used to assess risks to the health of building occupants."

1. In several places it acknowledges molds within structures are known to be a cause of human illness.

2. It references rodent studies that show mold toxins impact rodents.

3. It acknowledge that because of everything going on in a wdb, one can't establish true exposure limits. (which is different from needed pel guidelines)

3. It does not say to test or not to test when trying to understand building/human illness.

4. It does not say anywhere that air testing has no value whatsoever. Nor does it say it does have value. (we all know, sometimes it does, sometimes it doesn't)

5. It only says that because large number of mould species and strains growing in buildings and the large inter-individual variability in human response to mould exposure preclude the derivation of exposure limits. And in the absence of exposure limits, results from tests for the presence of fungi in air cannot be used to assess risks to the health of building occupants."...but it doesn't say "cannot be used to assess risks to the health of building".

Basically, it's just saying that moldy buildings cause illness, but based on air testing alone, one cannot determine is someone will get sick or not. That's it. Nothing more. Nothing less.

Sharon

Pursuant to subsection 55(3) of the Canadian Environmental Protection Act, 1999, the Minister of Health hereby gives notice of the issuance of a residential indoor air quality guideline for moulds. After reviewing the most recent scientific evidence regarding moulds and their effects on health, the Minister recommends

to control humidity and diligently repair any water damage in residences to prevent mould growth; and to clean thoroughly any visible or concealed mould growing in residential buildings. These recommendations apply regardless of the mould species found to be growing in the building.

March 12, 2007

PAUL GLOVER Director General Safe Environments Programme

On behalf of the Minister of Health

ANNEX

RESIDENTIAL INDOOR AIR QUALITY GUIDELINE

MOULDS

Physical and chemical properties

The word "mould" is a common term referring to fungi that can grow on building materials in homes or other buildings. Mould growth can influence air quality because both spores and mycelial fragments are dispersed into the air and can be inhaled. Their penetration into the bronchial tree depends on their size. The smaller particles penetrate deeper into the lungs.

Three features of mould biochemistry are of special interest in terms of human health:

Mould cell walls contain (1->3)-ß-D-glucan, a compound with inflammatory properties; Mould spores and mycelial fragments contain allergens; and The spores of some species contain low molecular weight chemicals that are cytotoxic or have other toxic properties (e.g. satratoxins and atranones produced by Stachybotrys chartarum). Causes of mould growth

Mould growth in a house requires the presence of nutrients, an adequate temperature, and a sufficient amount of water. The first two requirements being usually met in indoor environments, fungal growth usually results from a moisture problem (CMHC 2003). Major causes of mould growth are

condensation of moisture on surfaces due to excessive humidity, lack of ventilation, or low temperature; water leakage, e.g. from a broken pipe; infiltration of water from the outside, e.g. from a leaking roof or a cracked basement; and a flood. Health effects

Health Canada has carried out two reviews of the scientific literature pertaining to the health effects of indoor moulds (Health Canada 1995; 2004). The Institut national de santé publique du Québec also published a review on this subject (d'Halewyn et al. 2003). The following conclusions were drawn:

Exposure to indoor mould is associated with an increased prevalence of asthma-related symptoms such as chronic wheezing, irritation symptoms, and non-specific symptoms; and In laboratory animal studies, instillation of fungal antigens (Penicillium sp. and Aspergillus sp.) and fungal cell components [(1->3)-ß-D-glucan] resulted in an inflammatory response in the lungs of rodents, while instillation of Stachbotrys chartarum spores resulted in severe histological and biochemical changes. These conclusions have been supported by more recent findings. In two cohort studies (Wickman et al. 2003; Jaakkola et al. 2005), significant associations were found between home dampness and the risk of developing asthma. In experimental studies, asthma-like responses were observed in mice following exposure to a typical building-associated fungus, Penicillium chrysogenum (Chung et al. 2005), and inflammatory responses were seen in rats exposed to low doses of toxins from the same species (Rand et al. 2005).

Residential Indoor Air Quality Guideline

Health Canada considers that mould growth in residential buildings may pose a health hazard. Health risks depend on exposure and, for asthma symptoms, on allergic sensitization. However, the large number of mould species and strains growing in buildings and the large inter-individual variability in human response to mould exposure preclude the derivation of exposure limits. Therefore, Health Canada recommends

to control humidity and diligently repair any water damage in residences to prevent mould growth; and to clean thoroughly any visible or concealed mould growing in residential buildings. These recommendations apply regardless of the mould species found to be growing in the building.

Further, in the absence of exposure limits, results from tests for the presence of fungi in air cannot be used to assess risks to the health of building occupants.

References

CHMC 2003. Clean-up Procedures for Mold in Houses. Revised ed. Ottawa: Canada Mortgage and Housing Corporation. ISBN 0-660-19227-6.

Chung, Y. J., Coates, N. H., Viana, M. E., Copeland, L., Vesper, S. J., Selgrade, M. K., Ward, M. D. W. 2005. Dose-dependent allergic responses to an extract of Penicillium chrysogenum in BALB/c mice. Toxicology 209: 77-89.

d'Halewyn, M. A., Leclerc, J. M., King, N., Bélanger, M., Legris, M. and Frenette, Y. 2002. Les risques à la santé associés à la présence de moisissures en milieu intérieur. Québec: Institut national de santé publique du Québec. 105 p. + appendices.

Health Canada 1995. Fungal Contamination in Public Buildings: a Guide to Recognition and Management. Ottawa: Health Canada.

Health Canada 2004. Fungal Contamination in Public Buildings: Health Effects and Investigation Methods. Ottawa: Health Canada. ISBN 0-662-37432-0. 47 p.

Jaakkola, J. J. K., Hwang, B. F., Jaakkola, N. 2005. Home dampness and molds, parental atopy, and asthma in childhood: a six-year population-based cohort study. Environmental Health Perspectives 113: 357-361.

Rand, T. G., Giles, S., Flemming, J., , J. D., Puniani, E. 2005. Inflammatory and cytotoxic responses in mouse lungs exposed to purified toxins from building isolated Penicillium brevicompactum Dierckx and P. chrysogenum Thom. Toxicological Sciences 87: 213-222.

Wickman, M., Melen, E., Berglind, N., Lennart Nordvall, S., Almqvist, C., Kull, I., Svartengren, M., Pershagen, G. 2003. Strategies for preventing wheezing and asthma in small children. Allergy 58: 742-747.

[13-1-o] See what's free at AOL.com.

[Guest guest]

you got my attention when you said: “EPA mold

guielines stress dealing with water problems but unfortunately S520 does not.

S520 does not have the remediator take responsiblity for making sure the water

source has been fixed. Nor does S520 recommend any water damage training for remediators...

at least not that I have seen.”

As one of the task force members that worked on the 1st

edition of the standard, we felt moisture control was so important it was established

as the 5th principle for mold remediation. Not only that but

moisture control had its own standard which was referenced as follows:

“To prevent recontamination or future contamination,

the moisture problem that contributed to the mold growth must be identified and

corrected or controlled. It is highly recommended that affected salvable

materials be dried to acceptable moisture content following ht current IICRC Standard

and Reference Guide for Professional Water Damage Restoration (S500).”

(S520 - 4.5 page 16)

Banta

[Guest guest]

you got my attention when you said: “EPA mold

guielines stress dealing with water problems but unfortunately S520 does not.

S520 does not have the remediator take responsiblity for making sure the water

source has been fixed. Nor does S520 recommend any water damage training for remediators...

at least not that I have seen.”

As one of the task force members that worked on the 1st

edition of the standard, we felt moisture control was so important it was established

as the 5th principle for mold remediation. Not only that but

moisture control had its own standard which was referenced as follows:

“To prevent recontamination or future contamination,

the moisture problem that contributed to the mold growth must be identified and

corrected or controlled. It is highly recommended that affected salvable

materials be dried to acceptable moisture content following ht current IICRC Standard

and Reference Guide for Professional Water Damage Restoration (S500).”

(S520 - 4.5 page 16)

Banta

[Guest guest]

you got my attention when you said: “EPA mold

guielines stress dealing with water problems but unfortunately S520 does not.

S520 does not have the remediator take responsiblity for making sure the water

source has been fixed. Nor does S520 recommend any water damage training for remediators...

at least not that I have seen.”

As one of the task force members that worked on the 1st

edition of the standard, we felt moisture control was so important it was established

as the 5th principle for mold remediation. Not only that but

moisture control had its own standard which was referenced as follows:

“To prevent recontamination or future contamination,

the moisture problem that contributed to the mold growth must be identified and

corrected or controlled. It is highly recommended that affected salvable

materials be dried to acceptable moisture content following ht current IICRC Standard

and Reference Guide for Professional Water Damage Restoration (S500).”

(S520 - 4.5 page 16)

Banta

[Guest guest]

,

I though the S520 stated the water (or

moisture) issue must be addressed although did not put the responsibility on

the contractor (due to who is paying for the cost).

EnviroBob

From: iequality

[mailto:iequality ] On Behalf

Of Banta

Sent: Tuesday, April 17, 2007 3:35

PM

To: iequality

Subject: Re:

" Acceptable " Levels of Mould Spores

you got my

attention when you said: “EPA mold guielines stress dealing

with water problems but unfortunately S520 does not. S520 does not have the

remediator take responsiblity for making sure the water source has been fixed.

Nor does S520 recommend any water damage training for remediators... at

least not that I have seen.”

As one

of the task force members that worked on the 1st edition of the

standard, we felt moisture control was so important it was established as the 5th

principle for mold remediation. Not only that but moisture control had its own

standard which was referenced as follows:

“To

prevent recontamination or future contamination, the moisture problem that

contributed to the mold growth must be identified and corrected or controlled.

It is highly recommended that affected salvable materials be dried to

acceptable moisture content following ht current IICRC Standard and Reference

Guide for Professional Water Damage Restoration (S500).” (S520 - 4.5 page

16)

Banta

[Guest guest]

,

I though the S520 stated the water (or

moisture) issue must be addressed although did not put the responsibility on

the contractor (due to who is paying for the cost).

EnviroBob

From: iequality

[mailto:iequality ] On Behalf

Of Banta

Sent: Tuesday, April 17, 2007 3:35

PM

To: iequality

Subject: Re:

" Acceptable " Levels of Mould Spores

you got my

attention when you said: “EPA mold guielines stress dealing

with water problems but unfortunately S520 does not. S520 does not have the

remediator take responsiblity for making sure the water source has been fixed.

Nor does S520 recommend any water damage training for remediators... at

least not that I have seen.”

As one

of the task force members that worked on the 1st edition of the

standard, we felt moisture control was so important it was established as the 5th

principle for mold remediation. Not only that but moisture control had its own

standard which was referenced as follows:

“To

prevent recontamination or future contamination, the moisture problem that

contributed to the mold growth must be identified and corrected or controlled.

It is highly recommended that affected salvable materials be dried to

acceptable moisture content following ht current IICRC Standard and Reference

Guide for Professional Water Damage Restoration (S500).” (S520 - 4.5 page

16)

Banta

[Guest guest]

,

I though the S520 stated the water (or

moisture) issue must be addressed although did not put the responsibility on

the contractor (due to who is paying for the cost).

EnviroBob

From: iequality

[mailto:iequality ] On Behalf

Of Banta

Sent: Tuesday, April 17, 2007 3:35

PM

To: iequality

Subject: Re:

" Acceptable " Levels of Mould Spores

you got my

attention when you said: “EPA mold guielines stress dealing

with water problems but unfortunately S520 does not. S520 does not have the

remediator take responsiblity for making sure the water source has been fixed.

Nor does S520 recommend any water damage training for remediators... at

least not that I have seen.”

As one

of the task force members that worked on the 1st edition of the

standard, we felt moisture control was so important it was established as the 5th

principle for mold remediation. Not only that but moisture control had its own

standard which was referenced as follows:

“To

prevent recontamination or future contamination, the moisture problem that

contributed to the mold growth must be identified and corrected or controlled.

It is highly recommended that affected salvable materials be dried to

acceptable moisture content following ht current IICRC Standard and Reference

Guide for Professional Water Damage Restoration (S500).” (S520 - 4.5 page

16)

Banta

[Guest guest]

Don,

I agree with what you have said concerning

sampling having its limitations and can not always be considered all-inclusive

in evaluations of environmental environments. I agree that sampling can have

some limitations and exposure limits have not been established due to various

non-linier impacts although I also agree that sampling can provide valuable

information as well, i.e. when all other potential impacts have been ruled out,

samples evidence pathogens, and symptoms are in line with know pathogens i.e. Aspergillosis.

My only issue was the linier statement from

Health Canada.

If the statement said one may not “solely” rely upon air samples but

must consider other potential impacts prior to making conclusions associated with

risk to health of building occupants, I would be able to agree.

Another issue of sampling:

Has anyone used or presently own the

SpinCon or Omni 3000 units. The SpinCon pulls 450 liters per minute. The Omni

3000 pulls 300 liters per minute. It may still be considered a snapshot in time

yet surely is a larger snapshot sample.

EnviroBob

From:

iequality [mailto:iequality ] On Behalf Of Weekes

Sent: Tuesday, April 17, 2007 3:24

PM

To: iequality

Subject: Re:

" Acceptable " Levels of Mould Spores

Carl and Jim:

Thank you for your posts. You have stated better than I could what

is the concern with a reliance on microbial air sampling only, the

issue of threshold values, and the disconnection from the microbial

air sampling results to health risk assessments. I really appreciate

your thoughts on this matter.

I am distressed that thinks I am performing a 'disservice' to

those with illness from exposure to damp buildings, mold and the

mycotoxins that cause the illnesses. These individuals have been my

life's work, and I will continue to help these individuals by all

means possible.

Just one further thought to : IF we could measure airborne

indoor mycotoxins (and not just the mold spores that generate these

toxigenic organisms) in an exact, accurate and replicable manner by

instrumentation that was easy to use and relatively inexpensive, and

IF we could know, specifically, at what airborne level the vast

majority of people would have adverse health effects from airborne

exposure to this mycotoxin, then all of us who have been doing this

work (as I have for the past 32 years) would embrace this technology

and the threshold. However, as Carl and Jim point out, we are not

there yet, and we may never be there.

IMHO, An informed, thorough building inspection is the best means

available to assist those in need.

Don

[Guest guest]

You did not make this the reponsibility of the mold remediation contractor! If you read the EPA guidelines, moisture control has top billing. In S520 it is a footnote compared to EPA guidelines.

Rosen, Ph.D.

www.Mold-Books.com

Re: "Acceptable" Levels of Mould Spores

you got my attention when you said: “EPA mold guielines stress dealing with water problems but unfortunately S520 does not. S520 does not have the remediator take responsiblity for making sure the water source has been fixed. Nor does S520 recommend any water damage training for remediators. .. at least not that I have seen.”

As one of the task force members that worked on the 1st edition of the standard, we felt moisture control was so important it was established as the 5th principle for mold remediation. Not only that but moisture control had its own standard which was referenced as follows:

“To prevent recontamination or future contamination, the moisture problem that contributed to the mold growth must be identified and corrected or controlled. It is highly recommended that affected salvable materials be dried to acceptable moisture content following ht current IICRC Standard and Reference Guide for Professional Water Damage Restoration (S500).” (S520 - 4.5 page 16)

Banta

Ahhh...imagining that irresistible "new car" smell? Check out

new cars at Yahoo! Autos.

[Guest guest]

Jim,

You might wish to have Wei comment on this issue. The new PCR technology plus careful analysis of visible spore counts holds promise of providing a better level of testing that should have a higher correlation with sick people. The EPA RMI index correlelates very well with sick people but a consultant can do much better interpreting the results than by simply using their standard screen.

Rosen, Ph.D

www.Green-Buildings.org

RE: Re: "Acceptable" Levels of Mould Spores> >> > > >> > Sharon , et al;> >> > > >> > May I disagree for a moment (I may be confused

for a second)? The> > term running through this thread stated as follows: From the Health> > Canada Annex on Mould: '"Further, in the absence of exposure limits,> > results from tests for the presence of fungi in air cannot be used to> > assess risks to the health of building occupants."> >> > > >> > I can not find myself agreeing with the term "can not be use to> > access … ." If the term were stated "May not "exclusively" be used to> > assess the risk to health of building occupants without first> > eliminating other causes/sources …" or" Can not be solely relied upon> > to conclude the risk to health of building occupants without> > eliminating other causes/sources …" I could find myself agreeing with> > these type of statements. To read it as it is causes one to believe> > that mold has no adverse

health impact upon any building occupant.> >> > > >> > All data is relative either to help in eliminating cause or to> > acknowledge and/or confirm attributes of associations to adverse> > health affect and/or illness.> >> > > >> > I.e. If I receive a call that all office occupants are exhibiting> > adverse health affects and all other sampling/testing support no> > other contamination in the space except magnitudes of elevations of> > mold, it's associated spores, and body fragments over the outside> > conditions as well other office spaces in the local areas, are they> > saying that the air sampled are of no consideration to the EP and/or> > occupant as associated with potential (or genuine) adverse health> > affects in which they suffer? We all know people who suffer from> > these conditions.

If the document were even stating its relationship> > to SBS or BRI as not being the sole contributor until confirmed; now> > that may be a different issue but to say it has no validity> > of "assessing" risk to the health of building occupants when we have> > been informed one or more of the occupants are immunocompromised> > (definition: Immunocompromised: Having an immune system that has been> > impaired by disease or treatment) is beyond me. I> >> > just can see making linier statements in a non-linier world. This> > is why (my opinion) many are not getting the treatment they deserve> > and therefore are getting sicker as this debate continues.> >> > > >> > Your thoughts on this are welcome.> >> > > >> > EnviroBob> >> > > >>

>>

See what's free at AOL.com.

Ahhh...imagining that irresistible "new car" smell? Check out

new cars at Yahoo! Autos.

[Guest guest]

,

I also served on the committee that wrote the 1st edition of S520,

along with , and until December 2006 served on the 2nd edition

committee. I don't understand how you come to your conclusion. As

so accurately pointed out, moisture control is one of the

PRINCIPLES of S520.

The only way I can understand your point is to disconnect S520

from S500. But they should not be disconnected and are not to my

knowledge disconnected. Each references the other. As for the the

" footnote " reference being less than EPA's emphasis, that

" footnote " is to a comprehensive standard (S500)with ANSI

accreditation. The criticism is more likely to be that it is too

comprehensive.

Specifically, S500 is for water damage and addresses the three

categories of water. Category 2 and 3 water are contaminated. If

that contamination is, or includes, mold then the specialized

expert for remediation of the mold contamination is one familiar,

trained and experienced with assessing Condition 1, 2 and 3 and

fungal ecology as described in S520. (similar to a specialized

expert for asbestos or engineering evaluation of structures).

S520 principles and text complete the cross-reference by

acknowledging and specifically referencing S500 as the document

for the standard of care for addressing the moisture component

that created the mold growth contamination necessitating S520.

If the connection and cross-referencing is contradicted in either

document point it out and suggest language for correction. You can

post it here and (I believe) on the IICRC Web site.

Carl Grimes

Healthy Habitats LLC

-----

On Tue Apr 17 19:44:34 PDT 2007, gary rosen

wrote:

> You did not make this the reponsibility of the mold

> remediation contractor! If you read the EPA guidelines,

> moisture control has top billing. In S520 it is a footnote

> compared to EPA guidelines.

>

> Rosen, Ph.D.

> www.Mold-Books.com

>

>

>

> Re: " Acceptable " Levels of Mould Spores

>

> you got my attention when you said: EPA mold guielines

> stress dealing with water problems but unfortunately S520 does

> not. S520 does not have the remediator take responsiblity for

> making sure the water source has been fixed. Nor does S520

> recommend any water damage training for remediators. .. at least

> not that I have seen.

> As one of the task force members that worked on the 1st edition

> of the standard, we felt moisture control was so important it was

> established as the 5th principle for mold remediation. Not only

> that but moisture control had its own standard which was

> referenced as follows:

> To prevent recontamination or future contamination, the

> moisture problem that contributed to the mold growth must be

> identified and corrected or controlled. It is highly recommended

> that affected salvable materials be dried to acceptable moisture

> content following ht current IICRC Standard and Reference Guide

> for Professional Water Damage Restoration (S500). (S520 - 4.5

> page 16)

> Banta

>

[Guest guest]

and :

Typo alert!

My statement below should read: 'The USEPA agrees with Health Canada

that, because there are no threshold values for airborne mold spores,

microbial air sampling should NOT be used for health risk

assessment.' I am sorry for the missing word.

: further note (developed in my sleep) - Please provide an USEPA

document that states: 'The USEPA recommends microbial air sampling

as a measurement methodology to determine the risk to the health of

building occupants.' Thanks!

Don

> > > >> >

> > > >> > Right you are Bob,

> > > >> >

> > > >> > The EPA takes a much different approach than does Health

> > Canada.

> > > > The EPA clearly states that any indoor mold growth has the

> > potential

> > > > to cause health problems to some segment of the population.

> > > > Although you can argue that the EPA has established a

threshold

> > and

> > > > that is anything above zero.

> > > >> >

> > > >> > Rosen, Ph.D.

> > > >> > www.Mold-Books. com

> > > >> >

> > > >> >

> > > >> >

> > > >> > RE: Re: " Acceptable " Levels of Mould

> > Spores

> > > >> >

> > > >> > Sharon, et al;

> > > >> >

> > > >> > May I disagree for a moment (I may be confused for a

> second)?

> > The

> > > > term running through this thread stated as follows: From the

> > Health

> > > > Canada Annex on Mould: ' " Further, in the absence of exposure

> > limits,

> > > > results from tests for the presence of fungi in air cannot be

> > used to

> > > > assess risks to the health of building occupants. "

> > > >> >

> > > >> > I can not find myself agreeing with the term " can not be

use

> to

> > > > access … . " If the term were stated " May not " exclusively " be

> > used to

> > > > assess the risk to health of building occupants without first

> > > > eliminating other causes/sources … " or " Can not be solely

> relied

> > upon

> > > > to conclude the risk to health of building occupants without

> > > > eliminating other causes/sources … " I could find myself

> agreeing

> > with

> > > > these type of statements. To read it as it is causes one to

> > believe

> > > > that mold has no adverse health impact upon any building

> occupant.

> > > >> >

> > > >> > All data is relative either to help in eliminating cause

or

> to

> > > > acknowledge and/or confirm attributes of associations to

adverse

> > > > health affect and/or illness.

> > > >> >

> > > >> > I.e. If I receive a call that all office occupants are

> > exhibiting

> > > > adverse health affects and all other sampling/testing support

no

> > > > other contamination in the space except magnitudes of

> elevations

> > of

> > > > mold, it's associated spores, and body fragments over the

> outside

> > > > conditions as well other office spaces in the local areas,

are

> > they

> > > > saying that the air sampled are of no consideration to the EP

> > and/or

> > > > occupant as associated with potential (or genuine) adverse

> health

> > > > affects in which they suffer? We all know people who suffer

from

> > > > these conditions. If the document were even stating its

> > relationship

> > > > to SBS or BRI as not being the sole contributor until

> confirmed;

> > now

> > > > that may be a different issue but to say it has no validity

> > > > of " assessing " risk to the health of building occupants when

we

> > have

> > > > been informed one or more of the occupants are

immunocompromised

> > > > (definition: Immunocompromised: Having an immune system that

> has

> > been

> > > > impaired by disease or treatment) is beyond me. I

> > > >> > just can see making linier statements in a non-linier

world.

> > This

> > > > is why (my opinion) many are not getting the treatment they

> > deserve

> > > > and therefore are getting sicker as this debate continues.

> > > >> >

> > > >> > Your thoughts on this are welcome.

> > > >> >

> > > >> > EnviroBob

> > > >> >

> > > >> >

> > >

> >

> >

> >

> >

> > __________________________________________________

> >

[Guest guest]

Bob:

I am sure you have read the posts from Jim, Steve and Sharon on this

matter. Sharon included the Health Canada Annex in her post, and

extended the 'quote' from the text, which should clarify this issue a

bit more. I want to thank Jim, Sharon and Steve for their posts, and

say that I agree with them wholeheartedly.

Air sampling has its place in the spectra of tools I use to evaluate

a building where mold growth is suspected. It supplements greatly

the informed inspection that I perform of the building, looking for

the areas where mold growth is to be found. I recognize its

limitations, and, like all sampling (tape lift; swab; bulk), I

prepare my clients for those limits by a thorough explanation of what

the results may, or may not, mean.

Air sampling, in particular, has connotations to individuals with

illnesses related to the building, since it would appear to be a

means by which a device can 'breathe' in the same contaminants as

they are breathing. The problem, of course, is the sampling

apparatus is NOT the same as an individual breathing due to its

limitations, including the limitations of the sampling media.

We as a field are constantly trying to improve our ability to collect

the 'snapshot' in time of the mold spores that are in the air. The

two devices you mentioned in your post may collect a greater volume

of air, but the higher air flow rate concerns me since it may effect

what contaminants, including microbial material, are collected on the

media. When I get the time (!), I will attempt to find out more

about these devices.

Bottom line: air sampling, carefully explained with a caveat, is a

useful tool in the arsenal when evaluating a building for mold

contamination and water damage. But the air sampling results alone

at the current time, due to the impossibility of established

thresholds for airborne mold spores and mycotoxins for the specific

individuals who occupy the building, should not be used (with the

possible exception of the hospital case mentioned by Steve and

yourself) to define the health risk of these specific occupants in a

building.

Don

>

> Don,

>

>

>

> I agree with what you have said concerning sampling having its

limitations

> and can not always be considered all-inclusive in evaluations of

> environmental environments. I agree that sampling can have some

limitations

> and exposure limits have not been established due to various non-

linier

> impacts although I also agree that sampling can provide valuable

information

> as well, i.e. when all other potential impacts have been ruled out,

samples

> evidence pathogens, and symptoms are in line with know pathogens

i.e.

> Aspergillosis.

>

>

>

> My only issue was the linier statement from Health Canada. If the

statement

> said one may not " solely " rely upon air samples but must consider

other

> potential impacts prior to making conclusions associated with risk

to health

> of building occupants, I would be able to agree.

>

>

>

> Another issue of sampling:

>

> Has anyone used or presently own the SpinCon or Omni 3000 units.

The SpinCon

> pulls 450 liters per minute. The Omni 3000 pulls 300 liters per

minute. It

> may still be considered a snapshot in time yet surely is a larger

snapshot

> sample.

>

>

>

> EnviroBob

>

>

>

> _____

>

> From: iequality [mailto:iequality ]

On Behalf

> Of Weekes

> Sent: Tuesday, April 17, 2007 3:24 PM

> To: iequality

> Subject: Re: " Acceptable " Levels of Mould Spores

>

>

>

> Carl and Jim:

>

> Thank you for your posts. You have stated better than I could what

> is the concern with a reliance on microbial air sampling only, the

> issue of threshold values, and the disconnection from the microbial

> air sampling results to health risk assessments. I really

appreciate

> your thoughts on this matter.

>

> I am distressed that thinks I am performing a 'disservice'

to

> those with illness from exposure to damp buildings, mold and the

> mycotoxins that cause the illnesses. These individuals have been my

> life's work, and I will continue to help these individuals by all

> means possible.

>

> Just one further thought to : IF we could measure airborne

> indoor mycotoxins (and not just the mold spores that generate these

> toxigenic organisms) in an exact, accurate and replicable manner by

> instrumentation that was easy to use and relatively inexpensive,

and

> IF we could know, specifically, at what airborne level the vast

> majority of people would have adverse health effects from airborne

> exposure to this mycotoxin, then all of us who have been doing this

> work (as I have for the past 32 years) would embrace this

technology

> and the threshold. However, as Carl and Jim point out, we are not

> there yet, and we may never be there.

>

> IMHO, An informed, thorough building inspection is the best means

> available to assist those in need.

>

> Don

>

[Guest guest]

EnviroBob: Excuse me for jumping in here, buuut... It's the RC's responsibility to assist in determining the cause of the moisture issue. Should he (she) not be able to make the determination, then that is precisely the point to call in an EC with the proper tools and understanding who can. Even if the RC is able to pinpoint the cause, say a plumbing leak, unless the RC is also a plumber, he cannot take responsibility for the repair. An RC can only take responsibility for what he can control, and then make any necessary recommendations - the owner is ultimately responsible for the maintenance and repair, as well as for the quality of the Professionals he hires. RC's cannot be held responsible for conditions beyond what they've been hired to correct, which should have been defined by the contractor &

agreed to by the owner at the outset. (See IICRC S520 Section's 1 & 8) - Pete EnviroBob wrote: , I though the S520 stated the water (or moisture) issue must be addressed although did not put the responsibility on the contractor (due to who is paying for the cost). EnviroBob From: iequality [mailto:iequality ] On Behalf Of BantaSent: Tuesday, April 17, 2007 3:35 PMTo: iequality Subject: Re: "Acceptable" Levels of Mould Spores you got my attention when you said: “EPA mold guielines stress dealing with water problems but unfortunately S520 does not. S520 does not have the remediator take responsiblity for making sure the water source has been fixed. Nor does S520 recommend any water damage training for remediators... at least not that I have seen.” As one of the task force members that worked on the 1st edition of the standard, we felt moisture control was so important it was established as the

5th principle for mold remediation. Not only that but moisture control had its own standard which was referenced as follows: “To prevent recontamination or future contamination, the moisture problem that contributed to the mold growth must be identified and corrected or controlled. It is highly recommended that affected salvable materials be dried to acceptable moisture content following ht current IICRC Standard and Reference Guide for Professional Water Damage Restoration (S500).” (S520 - 4.5 page 16) Banta

Ahhh...imagining that irresistible "new car" smell? Check out

new cars at Yahoo! Autos.

[Guest guest]

: Perhaps you didn't see Wei Tang's previous post on this very

issue. Here it is again. Please read.

Also, regarding ERMI: as we discussed before, this relates to dust

samples, NOT air sampling. Vesper has related the dust sample data

to specific illnesses in children, NOT to all illnesses potentially

caused by exposure to airborne mold spores. Please read carefully.

Don

MSQPCR

Dear Group,

(1) 36 species Mold-Specific Quantitative PCR (MSQPCR) vs. EPA

Relative Moldiness Index (ERMI)

We do 36 species MSQPCR, but we don't provide ERMI. ERMI still needs

to be validated and evaluated. MSQPCR is a good tool but it is not a

magic bullet. Of course, paid commercials always makes things a lot

better than they really are. Don't be fooled.

(2) Group II? Normal?

Acremonium strictum, Alternaria alternata, Aspergillus ustus,

Cladosporium cladosporioides v1, Cladosporium cladosporioides v2,

Cladosporium herbarum, Epicoccum nigrum, Mucor & Rhizopus group,

Penicillium chrysogenum, Rhizopus stolonifer

All species in Group II can grow and be found commonly in water-

damaged indoor environment except Cladosporium herbarum. I don't

think it is a good idea to lower the score/index if you find a lot of

them in indoor environment. That's why we list all 36 species, not

separated as Group I and Group II.

(3) PCR vs. direct exam

MSQPCR for 36 species of fungal DNA only detect 36 species. On the

other hand, microscopic direct exam cover all species (hundreds and

more). We are making it mandatory to do direct exam together with

MSQPCR. For example, we have a sample today that has over a million

of Dicyma spores/hyphal fragments per in2 identified by direct exam.

If you ony do 36 species MSQPCR, you get ZERO of that because it is

not one of those 36 species. Same thing with culture method. You

could miss as much as 99.9% (or more) of non-viable (or non-

culturable on media) spores/hyphal fragments. Please also do

quantitative direct exam with the swabs or bulk that you sent for

culure analysis.

Wei Tang

QLab

> > >> >

> > >> > Right you are Bob,

> > >> >

> > >> > The EPA takes a much different approach than does Health

> Canada .

> > > The EPA clearly states that any indoor mold growth has the

> potential

> > > to cause health problems to some segment of the population.

> > > Although you can argue that the EPA has established a threshold

> and

> > > that is anything above zero.

> > >> >

> > >> > Rosen, Ph.D.

> > >> > www.Mold-Books. com

> > >> >

> > >> >

> > >> >

> > >> > RE: Re: " Acceptable " Levels of Mould

> Spores

> > >> >

> > >> > Sharon , et al;

> > >> >

> > >> > May I disagree for a moment (I may be confused for a

second)?

> The

> > > term running through this thread stated as follows: From the

> Health

> > > Canada Annex on Mould: ' " Further, in the absence of exposure

> limits,

> > > results from tests for the presence of fungi in air cannot be

> used to

> > > assess risks to the health of building occupants. "

> > >> >

> > >> > I can not find myself agreeing with the term " can not be use

to

> > > access … . " If the term were stated " May not " exclusively " be

> used to

> > > assess the risk to health of building occupants without first

> > > eliminating other causes/sources … " or " Can not be solely

relied

> upon

> > > to conclude the risk to health of building occupants without

> > > eliminating other causes/sources … " I could find myself

agreeing

> with

> > > these type of statements. To read it as it is causes one to

> believe

> > > that mold has no adverse health impact upon any building

occupant.

> > >> >

> > >> > All data is relative either to help in eliminating cause or

to

> > > acknowledge and/or confirm attributes of associations to adverse

> > > health affect and/or illness.

> > >> >

> > >> > I.e. If I receive a call that all office occupants are

> exhibiting

> > > adverse health affects and all other sampling/testing support no

> > > other contamination in the space except magnitudes of

elevations

> of

> > > mold, it's associated spores, and body fragments over the

outside

> > > conditions as well other office spaces in the local areas, are

> they

> > > saying that the air sampled are of no consideration to the EP

> and/or

> > > occupant as associated with potential (or genuine) adverse

health

> > > affects in which they suffer? We all know people who suffer from

> > > these conditions. If the document were even stating its

> relationship

> > > to SBS or BRI as not being the sole contributor until

confirmed;

> now

> > > that may be a different issue but to say it has no validity

> > > of " assessing " risk to the health of building occupants when we

> have

> > > been informed one or more of the occupants are immunocompromised

> > > (definition: Immunocompromised: Having an immune system that

has

> been

> > > impaired by disease or treatment) is beyond me. I

> > >> > just can see making linier statements in a non-linier world.

> This

> > > is why (my opinion) many are not getting the treatment they

> deserve

> > > and therefore are getting sicker as this debate continues.

> > >> >

> > >> > Your thoughts on this are welcome.

> > >> >

> > >> > EnviroBob

> > >> >

> > >> >

> >

>

>

>

>

>

>

> See what's free at AOL.com.

>

>

> __________________________________________________

>

[Guest guest]

Don,

I do not disagree with you and/or Steve

concerning the limits of air sapling. To this point, we understand it is all we

have. We all understand the challenges due to lack of PEL’s, and TLV’s

surrounding mold exposure are constantly before us. Notice that we also agree concerning

unusual conditions i.e. hospitals conditions, and when the sample exhibit pathogens,

etc; and “that is my main point.” We do not need TLV’s and

PEL’s to understand pathogens are health risk. Therefore under such conditions

the statement is false. In the Health Canada statement there is no room for the

exception, which we have all agreed exist. IMHO the statement is not

scientifically based because these conditions exist and are confirmed in

various medical journals and documents.

A defense lawyer would have a heyday having

you quote that statement on the witness stand without taking into affect the

balance of the report and/or other documents and the exceptions that exist. As

we know, each side enjoys limiting information to best suit its position. I

guess I have dealt with enough attorneys over the years and see how they work

and pick and choose what they want to present to the juries. If a questions is

asked “it is true” and there is a portion (even 1%) that it is not

true, the answer is not yes, the answer should be “it depends” or “no”.

Because there is a condition that it is not true.

Don, Steve I agree with the challenges and

limitations although the statement is not always true as we have agreed. Exceptions

exist and all-inclusive linier statement do not allow for the exception. Let me

state clearly, I understand the document it’s not the statement that I

disagree with. I understand the conclusion and agree with the conclusion. I

just feel the statement that hangs in the middle of the document can be misconstrued

(that is all). I am with you on the balance of the statements offered.

As formally stated in my earlier post, if

a pathogen is recovered in my sampling results I must consider the sample(s) as

to what potential the results may reflect that a risk to health to building

occupants may exist or is less than likely (not absolute). Lets face it, when I

go to work a degree of risk to health exist.

If there were no risk to health of

building occupants related to mold (determined by sampling) no valuable

building would be raised. No investor would raise a building unless samples

were taken to confirm mold is an issue. The samples were relied upon to

determine degree of risk to health exists to potential occupant and that is why

the building is raised.

Are A. fumigatus, A. flavus, and A.

versicolor fungi? Are they not pathogens? Are they considered risk to health of

building occupants? Am I wrong here? If I am not wrong here than the statement ' " Further, in the absence of exposure limits, results from

tests for the presence of fungi in air cannot be used to assess risks to the

health of building occupants. " is not

always true (which has been my only point). The statement appears to be

scientific based although is not based on all scientific facts because the

statement excludes other known conditions that contradict the very statement

offered as scientific. There are samples that have and may present evidence

that risk to building occupants exist, these can not be ignored in the

statement offered. A sound scientific conclusion can be reproduced, supported,

and new information does not impede the conclusion if the conclusion is true. I

have offered information that impedes the conclusion of the statement. I have

said enough.

EnviroBob

“Truth is supported by science and

science is supported by Truth?”

From: iequality [mailto:iequality ] On Behalf Of Weekes

Sent: Wednesday, April 18, 2007

6:50 AM

To: iequality

Subject: Re:

" Acceptable " Levels of Mould Spores

Bob:

I am sure you have read the posts from Jim, Steve and Sharon on this

matter. Sharon

included the Health Canada Annex in her post, and

extended the 'quote' from the text, which should clarify this issue a

bit more. I want to thank Jim, Sharon and Steve for their posts, and

say that I agree with them wholeheartedly.

Air sampling has its place in the spectra of tools I use to evaluate

a building where mold growth is suspected. It supplements greatly

the informed inspection that I perform of the building, looking for

the areas where mold growth is to be found. I recognize its

limitations, and, like all sampling (tape lift; swab; bulk), I

prepare my clients for those limits by a thorough explanation of what

the results may, or may not, mean.

Air sampling, in particular, has connotations to individuals with

illnesses related to the building, since it would appear to be a

means by which a device can 'breathe' in the same contaminants as

they are breathing. The problem, of course, is the sampling

apparatus is NOT the same as an individual breathing due to its

limitations, including the limitations of the sampling media.

We as a field are constantly trying to improve our ability to collect

the 'snapshot' in time of the mold spores that are in the air. The

two devices you mentioned in your post may collect a greater volume

of air, but the higher air flow rate concerns me since it may effect

what contaminants, including microbial material, are collected on the

media. When I get the time (!), I will attempt to find out more

about these devices.

Bottom line: air sampling, carefully explained with a caveat, is a

useful tool in the arsenal when evaluating a building for mold

contamination and water damage. But the air sampling results alone

at the current time, due to the impossibility of established

thresholds for airborne mold spores and mycotoxins for the specific

individuals who occupy the building, should not be used (with the

possible exception of the hospital case mentioned by Steve and

yourself) to define the health risk of these specific occupants in a

building.

Don

>

> Don,

>

>

>

> I agree with what you have said concerning sampling having its

limitations

> and can not always be considered all-inclusive in evaluations of

> environmental environments. I agree that sampling can have some

limitations

> and exposure limits have not been established due to various non-

linier

> impacts although I also agree that sampling can provide valuable

information

> as well, i.e. when all other potential impacts have been ruled out,

samples

> evidence pathogens, and symptoms are in line with know pathogens

i.e.

> Aspergillosis.

>

>

>

> My only issue was the linier statement from Health Canada. If the

statement

> said one may not " solely " rely upon air samples but must

consider

other

> potential impacts prior to making conclusions associated with risk

to health

> of building occupants, I would be able to agree.

>

>

>

> Another issue of sampling:

>

> Has anyone used or presently own the SpinCon or Omni 3000 units.

The SpinCon

> pulls 450 liters per minute. The Omni 3000 pulls 300 liters per

minute. It

> may still be considered a snapshot in time yet surely is a larger

snapshot

> sample.

>

>

>

> EnviroBob

>

>

>

> _____

>

> From: iequality

[mailto:iequality ]

On Behalf

> Of Weekes

> Sent: Tuesday, April 17, 2007 3:24 PM

> To: iequality

> Subject: Re: " Acceptable " Levels of Mould Spores

>

>

>

> Carl and Jim:

>

> Thank you for your posts. You have stated better than I could what

> is the concern with a reliance on microbial air sampling only, the

> issue of threshold values, and the disconnection from the microbial

> air sampling results to health risk assessments. I really

appreciate

> your thoughts on this matter.

>

> I am distressed that thinks I am performing a 'disservice'

to

> those with illness from exposure to damp buildings, mold and the

> mycotoxins that cause the illnesses. These individuals have been my

> life's work, and I will continue to help these individuals by all

> means possible.

>

> Just one further thought to : IF we could measure airborne

> indoor mycotoxins (and not just the mold spores that generate these

> toxigenic organisms) in an exact, accurate and replicable manner by

> instrumentation that was easy to use and relatively inexpensive,

and

> IF we could know, specifically, at what airborne level the vast

> majority of people would have adverse health effects from airborne

> exposure to this mycotoxin, then all of us who have been doing this

> work (as I have for the past 32 years) would embrace this

technology

> and the threshold. However, as Carl and Jim point out, we are not

> there yet, and we may never be there.

>

> IMHO, An informed, thorough building inspection is the best means

> available to assist those in need.

>

> Don

>

[Guest guest]

Pete,

You are correct. I believe whether you are

acting as the PE or the RC you do not have control of the money, the

owner/manager does. I also understand that was a contention during the development

of the S520. The S520 was careful not to compromise the RC by implying the RC

must pay for the water/moisture intrusion repairs which could become more than

the remediation cost.

EnviroBob

From: iequality [mailto:iequality ] On Behalf Of Pete Carkhuff

Sent: Wednesday, April 18, 2007

10:09 AM

To: iequality

Subject: RE: Re:

" Acceptable " Levels of Mould Spores

EnviroBob:

Excuse me for jumping in here, buuut...

It's the RC's responsibility to assist in determining the cause of the

moisture issue. Should he (she) not be able to make the

determination, then that is precisely the point to call in an EC with the

proper tools and understanding who can.

Even if the RC is able to pinpoint the cause, say a plumbing leak,

unless the RC is also a plumber, he cannot take responsibility for the

repair. An RC can only take responsibility for what he can control, and

then make any necessary recommendations - the owner is ultimately responsible

for the maintenance and repair, as well as for the quality of the Professionals

he hires.

RC's cannot be held responsible for conditions beyond what they've

been hired to correct, which should have been defined by the contractor

& agreed to by the owner at the outset. (See IICRC S520 Section's 1

& 8)

- Pete

EnviroBob

<BobEnvironmentalAirTechs> wrote:

,

I though the S520 stated the water

(or moisture) issue must be addressed although did not put the responsibility on

the contractor (due to who is paying for the cost).

EnviroBob

From: iequality [mailto:iequality ] On Behalf Of Banta

Sent: Tuesday, April 17, 2007 3:35

PM

To: iequality

Subject: Re:

" Acceptable " Levels of Mould Spores

you got my attention when you said: “EPA mold

guielines stress dealing with water problems but unfortunately S520 does not.

S520 does not have the remediator take responsiblity for making sure the water

source has been fixed. Nor does S520 recommend any water damage training for

remediators... at least not that I have seen.”

As one of the task force members that worked on the 1st

edition of the standard, we felt moisture control was so important it was

established as the 5th principle for mold remediation. Not only that

but moisture control had its own standard which was referenced as follows:

“To prevent recontamination or future contamination,

the moisture problem that contributed to the mold growth must be identified and

corrected or controlled. It is highly recommended that affected salvable

materials be dried to acceptable moisture content following ht current IICRC

Standard and Reference Guide for Professional Water Damage Restoration (S500).”

(S520 - 4.5 page 16)

Banta

Ahhh...imagining that irresistible " new car " smell?

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cars at Yahoo! Autos.

[Guest guest]

Bob,

You are correct – the water needs to be addressed, but

in the real world the ultimate decision is rarely made by the remediator

(although they hopefully provide input. Recognizing these real world issues was

one of the reasons the S520 has Chapter 5 Limitations, Complexities,

Complications and Conflicts which states that limitations are:

“Restrictions that are placed upon the remediator by

another party that results in a limit on the scope of work or on the remediation

activities may include the following examples: the source of the water has not

been corrected…”

,

There is no reason to be divisive. In my opinion EPA’s,

Mold Remediation in Schools and Commercial Buildings and S520 are both valuable

documents. They are both in agreement that the water issues need to be

addressed. Of course the audiences are different. EPA’s document “has

been designed primarily for building managers, custodians, and others who are

responsible for commercial buildings and schools.” S520 is aimed at

the professional mold remediator.

From a practical standpoint I have to defend the S520’s

decision to reference the S500 and not to repeat large amounts of material that

are already published in the S500.

I can’t find anywhere that EPA says the remediator is

responsible for the water mitigation either.

Banta

[Guest guest]

Steve,

You wrote:

The risk of coming to the wrong conclusion

that mold is not the cause of symptoms because levels were not " high

enough " , or that mold was the cause simply because test results show

" elevated levels " , without consideration of other potential causes,

is why air sampling for mold is not a reliable indicator of health risk or

causation.

My reply: OK, are you saying the document is saying that the

risk of health to building occupants can not be determined due to the samples

being inconclusive at best?

You wrote: No one has said that mold exposure is not a health risk. This

seems to be your interpretation.

My reply: Steve, I am saying that if all other conditions

have been ruled out and my sampling regiment has exhibited A. species that are

known pathogens and the client exhibits Aspergillosis, here is a condition that

contradicts the statement.  I understand the limits and faults results that one

may reply upon i.e. Wei makes this clear in that PCR only detects 36 species

while ignoring other species. The same is likely when sampling depending on at

what elevation one samples i.e. lighter spores will be higher, and heavier

spores will be lower. A well the Bioaerosols clearly states that absent of a contaminant

in the sample does not mean the area is safe and free of the contaminant, it

only can be concluded that the contaminant was not detected. This could be due

to where and when the samples were taken. I have argued that conclusion for

years with CIH’s.

You stated: EPA and Health Canada are saying the opposite of

this. They are saying that air sampling for mold cannot be used as a

reliable indicator of whether mold poses a health risk or has caused an

illness. The unreliability of sampling and subjective interpretation of

results are the basis for the quoted statement, not that mold is not considered

a health risk.

My reply: if the statement said something like the following

I could agree: “Further, in the absence of exposure limits, results from

tests for the presence of fungi in air cannot be used to assess risks to the

health of building occupants due its limitations and a false negative may

exist.

And add as per the Bioaerosols: An absence of fungi in the

sample may not indicate that the fungi were not present, just not detected therefore

the air samples may not be deem reliable to assess risk to health of building

occupants due to its limitations.

On the other hand consider this, even if we had TLV’s and or PEL’s

associated with mold, due to the sampling complications the samples would most

likely still be unreliable. At best (IMHO) sampling only provides a snapshot of

the minimal condition(s) at the time the samples were extracted. How the

results play into the whole picture depends on the results (providing

everything is as is should be).

EnviroBob

From: iequality [mailto:iequality ] On Behalf Of AirwaysEnv@...

Sent: Tuesday, April 17, 2007 8:34

PM

To: iequality

Subject: Re: Re:

" Acceptable " Levels of Mould Spores

In a message dated 4/17/2007 6:36:14 PM

Eastern Standard Time, BobEnvironmentalAirTechs writes:

To make the statement

that ' " Further, in the absence of exposure limits, results from tests for

the presence of fungi in air cannot be used to assess risks to the health of

building occupants. "

still amazes me unless one has an agenda.

EnviroBob,

Health Canada's

agenda was to use the best information available from a building study to

determine health risk. Air sampling is highly unreliable. A

thorough building assessment performed by a skilled investigator is a better

means of determining whether there is a mold problem or whether symptoms are

likely to have been caused by mold contamination or something else.

The risk of coming to the wrong conclusion

that mold is not the cause of symptoms because levels were not " high

enough " , or that mold was the cause simply because test results show

" elevated levels " , without consideration of other potential causes,

is why air sampling for mold is not a reliable indicator of health risk or

causation.

No one has said that mold exposure is not a health risk. This seems to be

your interpretation. EPA and Health Canada are saying the opposite of

this. They are saying that air sampling for mold cannot be used as a

reliable indicator of whether mold poses a health risk or has caused an

illness. The unreliability of sampling and subjective interpretation of

results are the basis for the quoted statement, not that mold is not considered

a health risk.

Don, Carl and Jim have each explained this very well.

Your points about the incorporation of testing in a building study to confirm

an hypothesis about the presence of contamination that may pose a health risk

are valid. It still cannot be used to say that it will or won't or did or

didn't cause health effects. (Perhaps your example of pathogenic fungi in

a hospital setting is an exception.) I think that Health Canada recognizes that

there is a lot of testing being done that, when interpreted by some, leaves

hypersensitive people in an unhealthful environment (for them) and that

unnecessary remediation services being performed on the basis of air sample

results alone.

Air sampling is useful in that it helps document building conditions, not

health risk to individuals. The overarching concept here is that

INDIVIDUAL health risk can't be determined by levels of mold spores one way or

the other (low or high levels -- whatever that means).

Steve Temes

In a message dated 4/17/2007 6:36:14 PM Eastern Standard Time,

BobEnvironmentalAirTechs writes:

, et al,

Though I respect those on this list and Don

presents good understanding of the various issues, although I do not find

myself agreeing with the position as stated in my earlier response. Don, this

is NOT about you nor against you. It is against the Health Canada statement: ' " Further,

in the absence of exposure limits, results from tests for the presence of fungi

in air cannot be used to assess risks to the health of building occupants. " Don, I

understand that only a clean condition is respected at this juncture although I

disagree with the fact that sampling is not valid to assess “Risk”

of health to building occupants (see below) nor can it be used. The statement

is a definitive statement and does not allow for various circumstances or

conditions i.e. known pathogens.

Although the link

associated with mold and it toxins to disease have not been determined it has

been confirmed to have an association with adverse health affects, i.e.

minimally those already immunocompromised (asthma, the elderly, young children,

those who have had recent surgeries, those with allergies, etc.). To make the

statement that ' " Further, in the absence of exposure

limits, results from tests for the presence of fungi in air cannot be used to

assess risks to the health of building occupants. " still

amazes me unless one has an agenda.

The unknown does not mean it does not exist. If samples are

being taken to minimally determine the limit and/or extent of dissemination and

building are being raised, what purpose are these valuable building coming down

if it has not already been determined that the mold contamination is a BIG

issue as relating to illness. Has anyone ever undertaken the time to consider

the value of these buildings? I assure you the building are not being

demolished just to get a new one. Take a look at the school that was in the

news recently. The school was almost completed and now has to be destroyed and

not one child has entered a classroom to enjoy the newly built facility.

Are any of us so foolish to think we just have all of this

money to build and rebuild the same building for the purpose of learning to

build? It took the contractor almost three years to build the school and now it

has to come down further delaying the occupancy of the children and loss of

revenue to the contractor. Fire departments, schools, libraries, police

departments and other buildings are being demolished for no reason. If there

were no actual causation these building would still be up and running.

All said, I do understand the link has not been discovered

although it doesn’t take a rocket scientist to understand that the

building suffered a water and/or moisture problem. The buildings mold problems

did not exist prior to the water damage. The occupants are getting adverse

health affect when they enter the building and conditions subside when they

exit the dwelling for extended periods of time (say over night). Now that

brings us to the difference between SBS and BRI.

Paraphrased:

Sick Building Syndrome (SBS) are when one

suffers from (short term) illness related to (or during) building occupancy,

when they leave the building environment the symptoms begin to diminish;

whereas,

Building Related Illness (BRI) is an

illness (long term) one suffered due to the occupancy of the building; symptoms

do not diminish after exiting the building environment.

Minimally we can agree that there may be reasonable

conditions that can or are more likely than not associated with SBS. Would I

sample for this purpose, surely I would as a competent IEP attempting to prove

my hypothesis. Will I use the results to aid in my assessments, surely I would.

I will use all information gathered. Will I have disclaimers attached to the

report, yes I will (like … it is more likely than not…). But to say

I can not use the samples to assess the “RISK” to health of

building occupants is unsupported and unscientific in my opinion. Minimally the

samples could rule out conditions or chemicals. Keep in mind, I am not

diagnosing the occupant for illness, I am diagnosing the environment of

“potential” or known associated risk to the health of the

presenting occupant(s) (mold or otherwise).

Now, did I say I will tell them to leave the building (it

depends). What did the samples produce? Lets say the samples produced 1,000,000

CFU/m3 of stacky or aspergillus species such as A. flavus, A. versicolor, or A.

fumigatus. Are we saying by our silence that we agree with the above statement ' " Further,

in the absence of exposure limits, results from tests for the presence of fungi

in air cannot be used to assess risks to the health of building

occupants. " knowing what we do know about various species and

the impact upon human health? Keep in mind everything is subjective and

relative therefore all information including sampling is relative in our

evaluations and may offer vital information to assess impact upon building

occupant health risk, i.e. stay in the building and your health risk increases,

leave and the risk to health is reduced.

I do not believe the former statement is scientifically based

nor can such a linier statement be made in a non linier world (everything is

relative). Again, the fact that science has not proven what may be the link does

not mean the link does not exist (only that a link is not known). Consider the

Bioaerosols Assessment and Controls, in chapter 14.2.5 - Begins here (for those

who can’t see color): Failure

to find a biological agent or related environmental conditions is not absolute

assurance of their absence nor of the absence of exposure and risk… and

… Investigators can never definitively conclude or prove that an

environment is " safe " and presents no risk of exposure to biological

agents. (ends here).

What we can prove by sampling is the more

likely-than-not scenario or the less likely than scenario. To relate

this concept to my earlier statements one can not prove scientifically that

absence of understanding means no link. What it may conclude is more

understands is require and that means more money is needed. Now consider that

if Canada is similar to the US it also has

in its profile numerous homes that are mold contaminated. Now the statement

that ' " Further, in the absence of exposure

limits, results from tests for the presence of fungi in air cannot be used to

assess risks to the health of building occupants” makes

sense. It’s all about the (clean-up) money. Much like the potential ACOEM

situation that Ms. Champion is confronting. This may be another head off the

pass statement attempting to gain ground.

Today we can fly (the brothers were scoffed at), years

before the world was though to be flat (Columbus

was scoffed at). It only takes money but no money will be likely spent if the

purse that is supplying the dough is the one the results will come back and

bite. The insurance industry is not likely and our government is also not

likely until they get some conditions fixed (they cover their backsides first)

before it spends the money to further seek out the link. It’s when

someone challenges the status quo is when discoveries begin to move forward. As

we begin to understand, so our understanding begins.

Like Chuck, I am not one to take everything hook line and

sinker especially when my common sense confronts the offered (or purposed)

conflicting concept or opinion. Today we believe differently on many levels due

to someone taking the though or challenge of understandings a bit beyond where

we presently find ourselves. Let’s not shoot the messenger(s),

let’s take the time and think it out before we shoot.

There is one thing that baffles me, how is it one study

produces this result, and a similar study supported by a different purse finds

conclusions more beneficial to their interest? Who do we believe anymore? I do

know one thing; common sense can play a part if we don’t put our heads in

the sand.

Yah know, I think maybe that is why my clients request my

services, because something in them doesn’t believe everything spoken or

offered to them and they want another opinion. I am sure they also understand I

do not believe everything presented to me as fact. I am not saying the info is

wrong, but let’s see if the offered statement or position is able to

stand on its own merits scientifically (when all of the benefits to each side

has been removed). Truth is truth and it will always stand on its own merits.

It doesn’t attempt to benefit one or another, it only sustains itself.

EnviroBob

From: iequality

[mailto:iequality ]

On Behalf Of bobbinsbiomedaol

Sent: Monday, April 16, 2007 3:00

PM

To: iequality

Subject: Re: Re:

" Acceptable " Levels of Mould Spores

" Further, in the absence of exposure limits,

results from tests for the presence of fungi in

air cannot be used to assess risks to the health of building

occupants. "

Don,

Your interpretation of this Health Canada statement to mean

that air sampling results cannot be utilized to perform health assessments for

mold exposure is misleading. You have stated before as well that without

exposure limits, sampling for mold should only be used for purposes of a scope

of work when remediation becomes necessary, and not health related issues. You

are simply encouraging this industry to throw out the baby with the bath water,

leaving the sick occupant even more vulnerable. It is not surprising then

that this has only been challenged by a few here on this list. How sad

that those usually active here are not speaking up either way regarding this

most important issue.

There is a need to differentiate between the use of microbial

sampling for mold to assess whether occupants will

become ill from a [sick] building, versus the use of sampling to

help determine [present condition]

a causal relationship to an occupants ill health and an indoor environment,

versus the use of microbial sampling for mold as part of an evaluation process

in understanding the relationship to the health of a building and the health of

the occupants. To simply state that air sampling for mold should not be

used in relationship to health issues of occupants, is a disservice to those

whose health, safety and finances may be dependent upon the results of such

testing in seeking out further help and or leaving that environment and or

litigation of the matter.

So where are all the voices of these environmental consultants here?

Silence is not golden to those whose lives have been or may become permanently

altered through indoor exposure to mycotoxins.

Bobbins, RN, L.Ac, QME

In a message dated 4/16/2007 9:58:16 AM Pacific Daylight Time,

donweek@....com writes:

Hi, :

I agree with you that, practically speaking, there are no

environments (with the possible exception of the South Pole) where

there are no mold spores. And, even at the South Pole in the

interior environments, a friend of mine, Ed Light, found 'elevated'

mold spore levels (in comparison to levels back in the States -

no 'outdoor' comparison samples could be collected at the South Pole

for obvious reasons. )

Anyway, the reason I phrase this statement - 'So the only environment

(that) can considered 'safe' for all individuals is one where there

are no mold spores' - was to emphasize again that there is no

threshold level for airborne mold spores. Individuals can react at

virtually any level of mold, and sensitized individuals in particular

will react at extremely 'low' levels. So, in any given environment,

you will find individuals that are having adverse health effects,

even if the mold spore counts are extremely low.

This again reinforces the current EPA and Health Canadastatements

that air sampling results cannot be utilized to perform health

assessments for mold exposure.

Don

>>>

>>Bob and :

>>

>>What Health Canada

is saying is that the absence of exposure

limits

>>for mold precludes the possibility that one can 'know' that a

certain

>>level of mold spores triggers a certain adverse health reaction in

>>the population. It does not mean that mold spores may be the

cause

>>of the illnesses experienced by the occupants. It just means

that no

>>one currently knows exactly what levels of airborne mold spores

cause

>>illness, much less a specific disease. This has not been proven

>>scientifically to date. So air sampling results, without a

>>threshold, cannot be used to 'prove' that the mold spores cause

this

>>specific illness in an individual in this environment.

>>

>>In effect, Health Canadais agreeing with the USEPA, in that

there is

>>no current scientifically-based threshold known that will prevent

>>adverse health effects from mold spores. So the only environment

can

>>be considered 'safe' for all individuals is one where there are no

>>mold spores.

>>

>>Hope this clarifies this.

>>

>>Don

[Guest guest]

,

TX law requires the following certification on all projects.

"I further certify with reasonable certainty that the underlying cause or causes of the mold that were identified for this project in the mold management plan or remediation protocol have been remediated. A copy of the written evaluation that forms the basis for my certification has been provided to the person named in this certificate."

If the remediator and/or consultant does not deal with causation in a straightforward way you have a real conflict of interest. Fixing a mold problem that will then come back. S520 can learn something from the TX law about avoiding conflicts of interest in this regard.

, you are right that the EPA doc is written for the consumer and S520 for remediator. People should understand that. S520 is written to protect the remediator and is not always in the interest of the consumer/client. The way causation is handled is a good example. Causation is handled in a way to protect the remediator rather than protect the consumer.

IMO, the IICRC mold remediation training should be upgraded to provide better training in this area including the requirement that all contactors own and know how to use IR cameras.

Rosen, Ph.D.

www.Green-Buildings.org

Re: "Acceptable" Levels of Mould Spores

Bob,

You are correct – the water needs to be addressed, but in the real world the ultimate decision is rarely made by the remediator (although they hopefully provide input. Recognizing these real world issues was one of the reasons the S520 has Chapter 5 Limitations, Complexities, Complications and Conflicts which states that limitations are:

“Restrictions that are placed upon the remediator by another party that results in a limit on the scope of work or on the remediation activities may include the following examples: the source of the water has not been corrected…”

,

There is no reason to be divisive. In my opinion EPA’s, Mold Remediation in Schools and Commercial Buildings and S520 are both valuable documents. They are both in agreement that the water issues need to be addressed. Of course the audiences are different. EPA’s document “has been designed primarily for building managers, custodians, and others who are responsible for commercial buildings and schools.” S520 is aimed at the professional mold remediator.

From a practical standpoint I have to defend the S520’s decision to reference the S500 and not to repeat large amounts of material that are already published in the S500.

I can’t find anywhere that EPA says the remediator is responsible for the water mitigation either.

Banta

Ahhh...imagining that irresistible "new car" smell? Check out

new cars at Yahoo! Autos.