Guest guest Posted May 4, 2007 Report Share Posted May 4, 2007 I am trying to locate the portion of the Florida Mold Inspection bill that permits a RC to perform assessments on his own project. I find the following sections in SB 2234 that would appear to prohibit an RC from performing a PRV on their own project, particularly subsections (d) quoted below: 468.8419 Prohibitions; penalties.-- 2 (1) A mold assessor, a company that employs a mold 3 assessor, or a company that is controlled by a company that 4 also has a financial interest in a company employing a mold 5 assessor may not: 6 (a) Perform or offer to perform any mold assessment 7 unless the mold assessor has documented training in water, 8 mold, and respiratory protection under s. 468.8414(2). 9 ( Perform or offer to perform any mold assessment 10 unless the person has complied with the provisions of this 11 part. 12 © Use the name or title " certified mold assessor, " 13 " registered mold assessor, " " licensed mold assessor, " " mold 14 assessor, " " professional mold assessor, " or any combination 15 thereof unless the person has complied with the provisions 16 this part. 17 (d) Perform or offer to perform any mold remediation 18 to a structure on which the mold assessor or the mold 19 assessor's company provided a mold assessment within the last 20 12 months. 21 (e) Inspect for a fee any property in which the 22 assessor or the assessor's company has any financial or 23 transfer interest. 24 (f) Accept any compensation, inducement, or reward 25 from a mold remediator or mold remediator's company for the 26 referral of any business to the mold remediator or the mold 27 remediator's company. 28 (g) Offer any compensation, inducement, or reward to a 29 mold remediator or mold remediator's company for the referral 30 of any business from the mold remediator or the mold 31 remediator's company. 26 CODING: Words stricken are deletions; words underlined are additions. CS for CS for CS for SB 2234 Second Engrossed (ntc) 1 (h) Accept an engagement to make an omission of the 2 assessment or conduct an assessment in which the assessment 3 itself, or the fee payable for the assessment, is contingent 4 upon the conclusions of the assessment. 5 (2) A mold remediator, a company that employs a mold 6 remediator, or a company that is controlled by a company that 7 also has a financial interest in a company employing a mold 8 remediator may not: 9 (a) Perform or offer to perform any mold remediation 10 unless the remediator has documented training in water, mold, 11 and respiratory protection under s. 468.8414(2). 12 ( Perform or offer to perform any mold remediation 13 unless the person has complied with the provisions of this 14 part. 15 © Use the name or title " certified mold remediator, " 16 " registered mold remediator, " " licensed mold remediator, " 17 " mold remediator, " " professional mold remediator, " or any 18 combination thereof unless the person has complied with the 19 provisions of this part. 20 (d) Perform or offer to perform any mold assessment to 21 a structure on which the mold remediator or the mold 22 remediator's company provided a mold remediation within the 23 last 12 months. 24 (e) Remediate for a fee any property in which the mold 25 remediator or the mold remediator's company has any financial 26 or transfer interest. 27 (f) Accept any compensation, inducement, or reward 28 from a mold assessor or mold assessor's company for the 29 referral of any business from the mold assessor or the mold 30 assessor's company. 31 27 , Is there a section that I missed? Which section were you referring to in your post? This bill is moving through the Florida legislature, but it looks like the effective date is going to be rolled back to 2010. The House version of the bill removes the appropriation of funds for a staff for 2007/2008. Best Regards, Doug Summers MS CIEC MoldDog Environmental > > Carl, > > That is pretty insightful! A gem. If testing your own work is a COI or potential COI does that make it is wrong or bad to do? > > Since I test my own work to improve the quality of my work (even though I eat the cost and it reduces my profit) I continue to do so. Clients want it done. They want me to take responsibility for the work I do. And this reduces their cost compared to hiring a consultant to test ... we are already there and it is very cheap to test. (I also am a CRMI & CIEC with $5M in mold E & O). No doubt many or perhaps most RC's are not trained to test ... but that can be added to an RC training program. > > Actually our training course for TX mold remediators includes training in testing since in TX if you do mold remedation work in schools you can also do assessment (the prohibition about doing both functions does not apply if you work in schools.) > > Some clients don't hire my firm because a consultant convinces them that they can't use the same company to both test the work and do the remediation work. But that is very very rare at least in S FLA. > > And I have never had an attorney in FLA object about testing our own work. Generally they will insist that this is how it should be done. > > If the FLA mold law passes, there is nothing in the law to keep an RC from testing their own work. > > Carl - thanks again for your little gem! > > Rosen, Ph.D. > www.Mold-Books.com > > > > Re: PRV by RC > > > > In a message dated 5/2/2007 1:18:42 PM Eastern Standard Time, > > garyrosen72652@ yahoo.com writes: > > If the Remediation Contractor follows the following protocol for post > > remediation testing ... does anyone believe there is a conflict of > > interest? > > > > > > > > Yes. > > > > > > 1.) Have the homeowner witness the sampling. > > > > > > > > They won't know what they are witnessing. > > > > 2.) Put the serial numbers of the cartridges on the COC. > > 3.) Have the home owner sign the COC along with the sampler. > > > > > > > > Who fills out the COC? The sample volume is something the homeowner > > does not know how to verify. Do they check the calibration and time > > the sample, too? > > > > 3.) Have the home owner mail in the cartridges (in the FedX envelop > > you give him) to a certified lab. > > 4.) Have the lab email both you and the client the results. > > > > It would be pretty hard to forge these results! > > > > > > > > What about the sample location and conditions during sampling? This > > will be a significant variable factor. Will the homeowner know how > > to interpret the results or will you be doing that? Why don't you > > just let the homeowner tell you where and how to sample or leave them > > the pump and cassettes and let them take them themselves. > > > > Sorry, . It's still a conflict of interest in my book to do your > > own PRV. If you want to do your own internal QC checking, I think > > doing your own sampling is a very good idea for that purpose. > > > > Steve Temes > > > > > > Rosen, Ph.D > > > > > > > > > > > > > > > > > > > __________________________________________________ > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted May 4, 2007 Report Share Posted May 4, 2007 , I interpret what you're saying as follows: You do a respectable amount of Quality Control (QC) sampling on your own projects. Nothing wrong with that, in fact it's commendable. Where the line is between QC and PRV though, is the remaining issue. And let me clarify, on MOST jobs, performed by an honest and ethical RC it DOESN'T matter! I grant you that. It's that one in a million though were no legal or health or both issues were anticipated, perhaps only a matter of doing your best for a BAD CLIENT, (yes, they are out there too, in addition to bad RCs and ECs), that could turn around and bite you in the posterior. There's no way to anticipate that in advance. I think the " no good deed goes unpunished " theory might apply there. To tie Steve's little gem in with Carl's, I don't see any possible way to be able to avoid the perception of possible C of I without the INDEPENDENT verification. A suggestion that might bring your previously stated proposals closer, but is still not perfect, is to have an EC, instead of the HO do the witnessing and verification process that you proposed. This would involve only paying an independent EC for the time necessary to get their feet on the ground with the project and to witness and verify your PRV procedures that they were performed acceptably. A loophole that THEN pops up is the interpretation of any sampling results by the RC, or paying the EC to further remain involved to perform that function. By the time you're done playing CYA on all of this, for that one in a million good job turned bad that might pop up, doesn't it really make more sense to just involve an honest, capable EC from the beginning, when appropriate? I'm posing the question. I don't presume to know all the answers for every situation. Again, . Keep plugging. Chuck Reaney Carl, That is pretty insightful! A gem. If testing your own work is a COI or potential COI does that make it is wrong or bad to do? Since I test my own work to improve the quality of my work (even though I eat the cost and it reduces my profit) I continue to do so. Clients want it done. They want me to take responsibility for the work I do. And this reduces their cost compared to hiring a consultant to test ... we are already there and it is very cheap to test. (I also am a CRMI & CIEC with $5M in mold E & O). No doubt many or perhaps most RC's are not trained to test ... but that can be added to an RC training program. Actually our training course for TX mold remediators includes training in testing since in TX if you do mold remedation work in schools you can also do assessment (the prohibition about doing both functions does not apply if you work in schools.) Some clients don't hire my firm because a consultant convinces them that they can't use the same company to both test the work and do the remediation work. But that is very very rare at least in S FLA. And I have never had an attorney in FLA object about testing our own work. Generally they will insist that this is how it should be done. If the FLA mold law passes, there is nothing in the law to keep an RC from testing their own work. Carl - thanks again for your little gem! Rosen, Ph.D. www.Mold-Books.com Re: PRV by RC > > In a message dated 5/2/2007 1:18:42 PM Eastern Standard Time, > garyrosen72652@ yahoo.com writes: > If the Remediation Contractor follows the following protocol for > post remediation testing ... does anyone believe there is a conflict > of interest? > > > > Yes. > > > 1.) Have the homeowner witness the sampling. > > > > They won't know what they are witnessing. > > 2.) Put the serial numbers of the cartridges on the COC. > 3.) Have the home owner sign the COC along with the sampler. > > > > Who fills out the COC? The sample volume is something the homeowner > does not know how to verify. Do they check the calibration and time > the sample, too? > > 3.) Have the home owner mail in the cartridges (in the FedX envelop > you give him) to a certified lab. 4.) Have the lab email both you > and the client the results. > > It would be pretty hard to forge these results! > > > > What about the sample location and conditions during sampling? This > will be a significant variable factor. Will the homeowner know how > to interpret the results or will you be doing that? Why don't you > just let the homeowner tell you where and how to sample or leave > them the pump and cassettes and let them take them themselves. > > Sorry, . It's still a conflict of interest in my book to do your > own PRV. If you want to do your own internal QC checking, I think > doing your own sampling is a very good idea for that purpose. > > Steve Temes > > > Rosen, Ph.D > > > > > > > __________________________________________________ Quote Link to comment Share on other sites More sharing options...
Guest guest Posted May 4, 2007 Report Share Posted May 4, 2007 Mold Dog, In the FLA law a mold assessor is defined as doing "initial" assessment. There are no restriction on doing an assessments other than initial. Rosen, Ph.D. www.Mold-Books.com Re: PRV by RC> > > > In a message dated 5/2/2007 1:18:42 PM Eastern Standard Time, > > garyrosen72652@ yahoo.com writes: > > If the Remediation Contractor follows the following protocol for post > > remediation testing ... does anyone believe there is a conflict of > > interest?> > > > > > > > Yes.> > > > > > 1.) Have the homeowner witness the sampling.> > > > > > > > They won't know what they are witnessing.> > > > 2.) Put the serial numbers of the cartridges on the COC.> > 3.) Have the home owner sign the COC along with the sampler.> > > > > > > > Who fills out the COC? The sample volume is something the homeowner > > does not know how to verify. Do they check the calibration and time > > the sample, too?> > > > 3.) Have the home owner mail in the cartridges (in the FedX envelop > > you give him) to a certified lab.> > 4.) Have the lab email both you and the client the results.> > > > It would be pretty hard to forge these results!> > > > > > > > What about the sample location and conditions during sampling? This > > will be a significant variable factor. Will the homeowner know how > > to interpret the results or will you be doing that? Why don't you > > just let the homeowner tell you where and how to sample or leave them > > the pump and cassettes and let them take them themselves.> > > > Sorry, . It's still a conflict of interest in my book to do your > > own PRV. If you want to do your own internal QC checking, I think > > doing your own sampling is a very good idea for that purpose.> > > > Steve Temes> > > > > > Rosen, Ph.D> > > > > > > > > > > > > > > > > > > ____________ _________ _________ _________ _________ __> Quote Link to comment Share on other sites More sharing options...
Guest guest Posted May 4, 2007 Report Share Posted May 4, 2007 - please clarify, you say you do alot of sampling on your jobs to "check progress". If you have an area contained and you have done all your manual cleaning so that no visible mold is left behind and run your air scrubbing equipment and done all the other necessary remediation steps, you should be ready for clearance testing. Why do air samples to check your progress. Or do your failed clearance tests then become "QA/QC progress samples" ? Just curios. Sherry Chuck Reaney wrote: ,I interpret what you're saying as follows:You do a respectable amount of Quality Control (QC) sampling on your own projects. Nothing wrong with that, in fact it's commendable. Where the line is between QC and PRV though, is the remaining issue.And let me clarify, on MOST jobs, performed by an honest and ethical RC it DOESN'T matter! I grant you that. It's that one in a million though were no legal or health or both issues were anticipated, perhaps only a matter of doing your best for a BAD CLIENT, (yes, they are out there too, in addition to bad RCs and ECs), that could turn around and bite you in the posterior. There's no way to anticipate thatin advance. I think the "no good deed goes unpunished" theory might apply there.To tie Steve's little gem in with Carl's, I don't see any possible way tobe able to avoid the perception of possible C of I without the INDEPENDENT verification.A suggestion that might bring your previously stated proposals closer, but is still not perfect, is to have an EC, instead of the HO do the witnessing and verification process that you proposed. This would involve only paying an independent EC for the time necessary to get their feet on the ground with the project and to witness and verify yourPRV procedures that they were performed acceptably.A loophole that THEN pops up is the interpretation of any sampling results by the RC, or paying the EC to further remain involved to perform that function.By the time you're done playing CYA on all of this, for that one in a million good job turned bad that might pop up, doesn't it really make more sense to just involve an honest, capable EC from the beginning, when appropriate?I'm posing the question. I don't presume to know all the answers for every situation.Again, . Keep plugging.Chuck ReaneyCarl,That is pretty insightful! A gem. If testing your own work is a COIor potential COI does that make it is wrong or bad to do?Since I test my own work to improve the quality of my work (eventhough I eat the cost and it reduces my profit) I continue to do so. Clients want it done. They want me to take responsibility for thework I do. And this reduces their cost compared to hiring a consultantto test ... we are already there and it is very cheap to test. (Ialso am a CRMI & CIEC with $5M in mold E & O). No doubt many or perhapsmost RC's are not trained to test ... but that can be added to an RCtraining program.Actually our training course for TX mold remediators includes trainingin testing since in TX if you do mold remedation work in schools youcan also do assessment (the prohibition about doing both functionsdoes not apply if you work in schools.)Some clients don't hire my firm because a consultant convinces themthat they can't use the same company to both test the work and do theremediation work. But that is very very rare at least in S FLA.And I have never had an attorney in FLA object about testing our ownwork. Generally they will insist that this is how it should be done.If the FLA mold law passes, there is nothing in the law to keep an RCfrom testing their own work.Carl - thanks again for your little gem! Rosen, Ph.D.www.Mold-Books.com----- Original Message ----From: Carl E. Grimes <grimeshabitats>To: iequality Sent: Thursday, May 3, 2007 2:32:35 PMSubject: Re: PRV by RCSteve,You made a critical point in your first 4 words by saying the COI wasINHERENT. That means a couple of things. 1. The COI was not caused by an action of the RC (or EC), it wasalready there. 2. A COI is not always the same as an immoral orillegal act. A very honest, ethical person can be in a COI.Which begs the question, if you are in a COI is it always wrong to goahead and perform the task? What makes it wrong? Or right?Carl GrimesHealthy Habitats LLC-----> > ,> > The conflict is INHERENT in a contractor, or anyone for that matter,> checking their own work. Everyone should check their own work to be> satisfied for themselves that it was done sufficiently. That isn't> the same as PRV which really needs to be performed by a qualified> professional who is INDEPENDENT of the contractor that performed the> work.> > I'm not saying that every project needs to have a PRV performed, or> that an EC is necessary in many basic remediation situations. But> when a PRV is needed, it can't be done by the contractor who did the> work.> > PRV testing/sampling is something that should be performed only> after a visual/white glove test is performed. Does the homeowner get> to inspect all surfaces for dust, too, and fail the project on you> when he finds a spot of dust?> > Here's a question for you. Is there a conflict of interest in the> homeowner having the ability to fail your project until s/he is> satisfied that there is no dust and the results of air samples are> acceptable according to their interpretation? Who gets to say when> you are finished, you or the homeowner?> > Checks and balances.... an independent, objective verification by a> qualified professional with a duty to the building owner that the> work was performed adequately on a given unique project (and they> are all unique in some respects). The contractor, no matter how well> intentioned, is not in a position to be objective when the findings> of the PRV will directly impact his profitability on the job. It's> the nature of the beast. You can't get around it. The way I see it> is that if it isn't done by an independent party, it can't really be> a PRV.> > An analogy might be when you proof and edit your own writing but> don't catch the spelling or grammatical errors that get through even> though we know which spelling or phrasing is correct. We all do it.> When it really has to be perfect, we prefer that someone else> proofread what we have written because another set of eyes can see> something we have overlooked or become blind to, even though we> genuinely tried to find our own mistakes.> > You can check your own work to confirm that it meets your own > internal standards, but it can never be equivalent to an independent> PRV.> > Steve Temes> > In a message dated 5/2/2007 4:50:19 PM Eastern Standard Time, > garyrosen72652@ yahoo.com writes: > Where exactly is the "conflict of interest"? No doubt it is not> ideal. Ideal would have a "professional" take and analyze the> samples. > > But I am missing what makes the "conflict". Earlier people said the> the RC could falsify the data. And that was shy there was a conflict> of interest.> > It would be pretty hard for an RC to falsify data with the procedure> I listed.> > Rosen, Ph.D.> www.Mold-Books. com> > > > > > Re: PRV by RC> > In a message dated 5/2/2007 1:18:42 PM Eastern Standard Time, > garyrosen72652@ yahoo.com writes: > If the Remediation Contractor follows the following protocol for> post remediation testing ... does anyone believe there is a conflict> of interest?> > > > Yes.> > > 1.) Have the homeowner witness the sampling.> > > > They won't know what they are witnessing.> > 2.) Put the serial numbers of the cartridges on the COC.> 3.) Have the home owner sign the COC along with the sampler.> > > > Who fills out the COC? The sample volume is something the homeowner> does not know how to verify. Do they check the calibration and time> the sample, too?> > 3.) Have the home owner mail in the cartridges (in the FedX envelop> you give him) to a certified lab. 4.) Have the lab email both you> and the client the results.> > It would be pretty hard to forge these results!> > > > What about the sample location and conditions during sampling? This> will be a significant variable factor. Will the homeowner know how> to interpret the results or will you be doing that? Why don't you> just let the homeowner tell you where and how to sample or leave> them the pump and cassettes and let them take them themselves.> > Sorry, . It's still a conflict of interest in my book to do your> own PRV. If you want to do your own internal QC checking, I think> doing your own sampling is a very good idea for that purpose.> > Steve Temes> > > Rosen, Ph.D> > > > > > > __________________________________________________ Quote Link to comment Share on other sites More sharing options...
Guest guest Posted May 4, 2007 Report Share Posted May 4, 2007 - please clarify, you say you do alot of sampling on your jobs to "check progress". If you have an area contained and you have done all your manual cleaning so that no visible mold is left behind and run your air scrubbing equipment and done all the other necessary remediation steps, you should be ready for clearance testing. Why do air samples to check your progress. Or do your failed clearance tests then become "QA/QC progress samples" ? Just curios. Sherry Chuck Reaney wrote: ,I interpret what you're saying as follows:You do a respectable amount of Quality Control (QC) sampling on your own projects. Nothing wrong with that, in fact it's commendable. Where the line is between QC and PRV though, is the remaining issue.And let me clarify, on MOST jobs, performed by an honest and ethical RC it DOESN'T matter! I grant you that. It's that one in a million though were no legal or health or both issues were anticipated, perhaps only a matter of doing your best for a BAD CLIENT, (yes, they are out there too, in addition to bad RCs and ECs), that could turn around and bite you in the posterior. There's no way to anticipate thatin advance. I think the "no good deed goes unpunished" theory might apply there.To tie Steve's little gem in with Carl's, I don't see any possible way tobe able to avoid the perception of possible C of I without the INDEPENDENT verification.A suggestion that might bring your previously stated proposals closer, but is still not perfect, is to have an EC, instead of the HO do the witnessing and verification process that you proposed. This would involve only paying an independent EC for the time necessary to get their feet on the ground with the project and to witness and verify yourPRV procedures that they were performed acceptably.A loophole that THEN pops up is the interpretation of any sampling results by the RC, or paying the EC to further remain involved to perform that function.By the time you're done playing CYA on all of this, for that one in a million good job turned bad that might pop up, doesn't it really make more sense to just involve an honest, capable EC from the beginning, when appropriate?I'm posing the question. I don't presume to know all the answers for every situation.Again, . Keep plugging.Chuck ReaneyCarl,That is pretty insightful! A gem. If testing your own work is a COIor potential COI does that make it is wrong or bad to do?Since I test my own work to improve the quality of my work (eventhough I eat the cost and it reduces my profit) I continue to do so. Clients want it done. They want me to take responsibility for thework I do. And this reduces their cost compared to hiring a consultantto test ... we are already there and it is very cheap to test. (Ialso am a CRMI & CIEC with $5M in mold E & O). No doubt many or perhapsmost RC's are not trained to test ... but that can be added to an RCtraining program.Actually our training course for TX mold remediators includes trainingin testing since in TX if you do mold remedation work in schools youcan also do assessment (the prohibition about doing both functionsdoes not apply if you work in schools.)Some clients don't hire my firm because a consultant convinces themthat they can't use the same company to both test the work and do theremediation work. But that is very very rare at least in S FLA.And I have never had an attorney in FLA object about testing our ownwork. Generally they will insist that this is how it should be done.If the FLA mold law passes, there is nothing in the law to keep an RCfrom testing their own work.Carl - thanks again for your little gem! Rosen, Ph.D.www.Mold-Books.com----- Original Message ----From: Carl E. Grimes <grimeshabitats>To: iequality Sent: Thursday, May 3, 2007 2:32:35 PMSubject: Re: PRV by RCSteve,You made a critical point in your first 4 words by saying the COI wasINHERENT. That means a couple of things. 1. The COI was not caused by an action of the RC (or EC), it wasalready there. 2. A COI is not always the same as an immoral orillegal act. A very honest, ethical person can be in a COI.Which begs the question, if you are in a COI is it always wrong to goahead and perform the task? What makes it wrong? Or right?Carl GrimesHealthy Habitats LLC-----> > ,> > The conflict is INHERENT in a contractor, or anyone for that matter,> checking their own work. Everyone should check their own work to be> satisfied for themselves that it was done sufficiently. That isn't> the same as PRV which really needs to be performed by a qualified> professional who is INDEPENDENT of the contractor that performed the> work.> > I'm not saying that every project needs to have a PRV performed, or> that an EC is necessary in many basic remediation situations. But> when a PRV is needed, it can't be done by the contractor who did the> work.> > PRV testing/sampling is something that should be performed only> after a visual/white glove test is performed. Does the homeowner get> to inspect all surfaces for dust, too, and fail the project on you> when he finds a spot of dust?> > Here's a question for you. Is there a conflict of interest in the> homeowner having the ability to fail your project until s/he is> satisfied that there is no dust and the results of air samples are> acceptable according to their interpretation? Who gets to say when> you are finished, you or the homeowner?> > Checks and balances.... an independent, objective verification by a> qualified professional with a duty to the building owner that the> work was performed adequately on a given unique project (and they> are all unique in some respects). The contractor, no matter how well> intentioned, is not in a position to be objective when the findings> of the PRV will directly impact his profitability on the job. It's> the nature of the beast. You can't get around it. The way I see it> is that if it isn't done by an independent party, it can't really be> a PRV.> > An analogy might be when you proof and edit your own writing but> don't catch the spelling or grammatical errors that get through even> though we know which spelling or phrasing is correct. We all do it.> When it really has to be perfect, we prefer that someone else> proofread what we have written because another set of eyes can see> something we have overlooked or become blind to, even though we> genuinely tried to find our own mistakes.> > You can check your own work to confirm that it meets your own > internal standards, but it can never be equivalent to an independent> PRV.> > Steve Temes> > In a message dated 5/2/2007 4:50:19 PM Eastern Standard Time, > garyrosen72652@ yahoo.com writes: > Where exactly is the "conflict of interest"? No doubt it is not> ideal. Ideal would have a "professional" take and analyze the> samples. > > But I am missing what makes the "conflict". Earlier people said the> the RC could falsify the data. And that was shy there was a conflict> of interest.> > It would be pretty hard for an RC to falsify data with the procedure> I listed.> > Rosen, Ph.D.> www.Mold-Books. com> > > > > > Re: PRV by RC> > In a message dated 5/2/2007 1:18:42 PM Eastern Standard Time, > garyrosen72652@ yahoo.com writes: > If the Remediation Contractor follows the following protocol for> post remediation testing ... does anyone believe there is a conflict> of interest?> > > > Yes.> > > 1.) Have the homeowner witness the sampling.> > > > They won't know what they are witnessing.> > 2.) Put the serial numbers of the cartridges on the COC.> 3.) Have the home owner sign the COC along with the sampler.> > > > Who fills out the COC? The sample volume is something the homeowner> does not know how to verify. Do they check the calibration and time> the sample, too?> > 3.) Have the home owner mail in the cartridges (in the FedX envelop> you give him) to a certified lab. 4.) Have the lab email both you> and the client the results.> > It would be pretty hard to forge these results!> > > > What about the sample location and conditions during sampling? This> will be a significant variable factor. Will the homeowner know how> to interpret the results or will you be doing that? Why don't you> just let the homeowner tell you where and how to sample or leave> them the pump and cassettes and let them take them themselves.> > Sorry, . It's still a conflict of interest in my book to do your> own PRV. If you want to do your own internal QC checking, I think> doing your own sampling is a very good idea for that purpose.> > Steve Temes> > > Rosen, Ph.D> > > > > > > __________________________________________________ Quote Link to comment Share on other sites More sharing options...
Guest guest Posted May 5, 2007 Report Share Posted May 5, 2007 , On a medium to big job you remove a bunch of walls. Rebuild the walls. And clean. We take a few samples before we start to know the baseline. We then start taking a few samples during remediation to see if anything got out and extra cleaning needs to be done. During the rebuilding we are scrubbing the air and we clean the floors as the walls go up. And we are taking a few samples to see how the cleaning is doing. If there is some residual mold spores then we leave the scrubbers in (moving them around) and clean some more. By the time it comes to the final testing which is more extensive than the few taken each day during rebuild and cleaning ... we usually know we are clean. The client is shown a graph of the count as it goes down each day and compares it to the outside. It is easy to understand. Don't let anyone tell you that a client cannot understand test results if you test over time and the sample count goes to (close) to zero. If you use this approach clients will think you are very professional and refer other clients to you. I hope that helps. Rosen, Ph.D. www.Mold-Books.com Re: PRV by RC> > In a message dated 5/2/2007 1:18:42 PM Eastern Standard Time, > garyrosen72652@ yahoo.com writes: > If the Remediation Contractor follows the following protocol for> post remediation testing ... does anyone believe there is a conflict> of interest?> > > > Yes.> > > 1.) Have the homeowner witness the sampling.> > > > They won't know what they are witnessing.> > 2.) Put the serial numbers of the cartridges on the COC.> 3.) Have the home owner sign the COC along with the sampler.> > > > Who fills out the COC? The sample volume is something the homeowner> does not know how to verify. Do they check the calibration and time> the sample, too?> > 3.) Have the home owner mail in the cartridges (in the FedX envelop> you give him) to a certified lab. 4.) Have the lab email both you> and the client the results.> > It would be pretty hard to forge these results!> > > > What about the sample location and conditions during sampling? This> will be a significant variable factor. Will the homeowner know how> to interpret the results or will you be doing that? Why don't you> just let the homeowner tell you where and how to sample or leave> them the pump and cassettes and let them take them themselves.> > Sorry, . It's still a conflict of interest in my book to do your> own PRV. If you want to do your own internal QC checking, I think> doing your own sampling is a very good idea for that purpose.> > Steve Temes> > > Rosen, Ph.D> > > > > > > ____________ _________ _________ _________ _________ __ Quote Link to comment Share on other sites More sharing options...
Guest guest Posted May 6, 2007 Report Share Posted May 6, 2007 aha?!? even when you're wrong, you're right. amazing..... <><><><><><><><><><><> Wane A. Baker, P.E., CIH Division Manager, Indoor Air Quality MICHAELS ENGINEERING"Real Professionals. Real Solutions." St. , La Crosse, Milwaukee Phone , ext. 484 Cell Fax mailto:wab@... On the web at: http://www.michaelsengineering.com "To love what you do and feel that it matters - how could anything be more fun?" - Graham >> Steve,> > Aha. A key issue is your last statement. If you do your own testing it can never be an INDEPENDENT PRV.> > No doubt.> > Rosen, Ph.D.> www.Mold-Books.com> > > > Re: PRV by RC> > ,> > The conflict is INHERENT in a contractor, or anyone for that matter, checking their own work. Everyone should check their own work to be satisfied for themselves that it was done sufficiently. That isn't the same as PRV which really needs to be performed by a qualified professional who is INDEPENDENT of the contractor that performed the work.> > I'm not saying that every project needs to have a PRV performed, or that an EC is necessary in many basic remediation situations. But when a PRV is needed, it can't be done by the contractor who did the work.> > PRV testing/sampling is something that should be performed only after a visual/white glove test is performed. Does the homeowner get to inspect all surfaces for dust, too, and fail the project on you when he finds a spot of dust?> > Here's a question for you. Is there a conflict of interest in the homeowner having the ability to fail your project until s/he is satisfied that there is no dust and the results of air samples are acceptable according to their interpretation? Who gets to say when you are finished, you or the homeowner?> > Checks and balances.... an independent, objective verification by a qualified professional with a duty to the building owner that the work was performed adequately on a given unique project (and they are all unique in some respects). The contractor, no matter how well intentioned, is not in a position to be objective when the findings of the PRV will directly impact his profitability on the job. It's the nature of the beast. You can't get around it. The way I see it is that if it isn't done by an independent party, it can't really be a PRV.> > An analogy might be when you proof and edit your own writing but don't catch the spelling or grammatical errors that get through even though we know which spelling or phrasing is correct. We all do it. When it really has to be perfect, we prefer that someone else proofread what we have written because another set of eyes can see something we have overlooked or become blind to, even though we genuinely tried to find our own mistakes.> > You can check your own work to confirm that it meets your own internal standards, but it can never be equivalent to an independent PRV.> > Steve Temes Quote Link to comment Share on other sites More sharing options...
Guest guest Posted May 6, 2007 Report Share Posted May 6, 2007 Don, Steve: some people just don't get it, because they're incapable of 'getting it'. your attempts are laudable, but it's the old "blood from a turnip" metaphor. everyone else gets it. then again, not everyone insists that they are right/better qualified/smarter/more clever all of the time and in every circumstance. at some point, it's OK to save your breath. Wane <><><><><><><><><><><> Wane A. Baker, P.E., CIH Division Manager, Indoor Air Quality MICHAELS ENGINEERING"Real Professionals. Real Solutions." St. , La Crosse, Milwaukee Phone , ext. 484 Cell Fax mailto:wab@... On the web at: http://www.michaelsengineering.com "To love what you do and feel that it matters - how could anything be more fun?" - Graham > >> > ,> > > > The conflict is INHERENT in a contractor, or anyone for that > matter, checking > > their own work. Everyone should check their own work to be > satisfied for > > themselves that it was done sufficiently. That isn't the same as > PRV which > > really needs to be performed by a qualified professional who is > INDEPENDENT of the > > contractor that performed the work.> > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted May 6, 2007 Report Share Posted May 6, 2007 Don, Steve: some people just don't get it, because they're incapable of 'getting it'. your attempts are laudable, but it's the old "blood from a turnip" metaphor. everyone else gets it. then again, not everyone insists that they are right/better qualified/smarter/more clever all of the time and in every circumstance. at some point, it's OK to save your breath. Wane <><><><><><><><><><><> Wane A. Baker, P.E., CIH Division Manager, Indoor Air Quality MICHAELS ENGINEERING"Real Professionals. Real Solutions." St. , La Crosse, Milwaukee Phone , ext. 484 Cell Fax mailto:wab@... On the web at: http://www.michaelsengineering.com "To love what you do and feel that it matters - how could anything be more fun?" - Graham > >> > ,> > > > The conflict is INHERENT in a contractor, or anyone for that > matter, checking > > their own work. Everyone should check their own work to be > satisfied for > > themselves that it was done sufficiently. That isn't the same as > PRV which > > really needs to be performed by a qualified professional who is > INDEPENDENT of the > > contractor that performed the work.> > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted May 7, 2007 Report Share Posted May 7, 2007 Group, Am I smoking something funny, or should PRV (or QC whatever...) be done BEFORE rebuild is started? Maybe I am missing something here... > > Carl, > > That is pretty insightful! A gem. If testing your own work is a COI > or potential COI does that make it is wrong or bad to do? > > Since I test my own work to improve the quality of my work (even > though I eat the cost and it reduces my profit) I continue to do so. > Clients want it done. They want me to take responsibility for the > work I do. And this reduces their cost compared to hiring a consultant > to test ... we are already there and it is very cheap to test. (I > also am a CRMI & CIEC with $5M in mold E & O). No doubt many or > perhaps > most RC's are not trained to test ... but that can be added to an RC > training program. > > Actually our training course for TX mold remediators includes training > in testing since in TX if you do mold remedation work in schools you > can also do assessment (the prohibition about doing both functions > does not apply if you work in schools.) > > Some clients don't hire my firm because a consultant convinces them > that they can't use the same company to both test the work and do the > remediation work. But that is very very rare at least in S FLA. > > And I have never had an attorney in FLA object about testing our own > work. Generally they will insist that this is how it should be done. > > If the FLA mold law passes, there is nothing in the law to keep an RC > from testing their own work. > > Carl - thanks again for your little gem! > > Rosen, Ph.D. > www.Mold-Books. com > > Re: PRV by RC > > > > In a message dated 5/2/2007 1:18:42 PM Eastern Standard Time, > > garyrosen72652@ yahoo.com writes: > > If the Remediation Contractor follows the following protocol for > > post remediation testing ... does anyone believe there is a conflict > > of interest? > > > > > > > > Yes. > > > > > > 1.) Have the homeowner witness the sampling. > > > > > > > > They won't know what they are witnessing. > > > > 2.) Put the serial numbers of the cartridges on the COC. > > 3.) Have the home owner sign the COC along with the sampler. > > > > > > > > Who fills out the COC? The sample volume is something the homeowner > > does not know how to verify. Do they check the calibration and time > > the sample, too? > > > > 3.) Have the home owner mail in the cartridges (in the FedX envelop > > you give him) to a certified lab. 4.) Have the lab email both you > > and the client the results. > > > > It would be pretty hard to forge these results! > > > > > > > > What about the sample location and conditions during sampling? This > > will be a significant variable factor. Will the homeowner know how > > to interpret the results or will you be doing that? Why don't you > > just let the homeowner tell you where and how to sample or leave > > them the pump and cassettes and let them take them themselves. > > > > Sorry, . It's still a conflict of interest in my book to do your > > own PRV. If you want to do your own internal QC checking, I think > > doing your own sampling is a very good idea for that purpose. > > > > Steve Temes > > > > > > Rosen, Ph.D > > > > > > > > > > > > > > > > ____________ _________ _________ _________ _________ __ > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted May 7, 2007 Report Share Posted May 7, 2007 : Yes, PRV is done before the rebuild occurs. Otherwise, if you have an elevated airborne concentration when new walls are in place, you may have to tear them down again to get at the active mold growth. A thorough visual inspection is the first step in the PRV, then any sampling (including air) is completed, then rebuild. Don > > > > Carl, > > > > That is pretty insightful! A gem. If testing your own work is a COI > > or potential COI does that make it is wrong or bad to do? > > > > Since I test my own work to improve the quality of my work (even > > though I eat the cost and it reduces my profit) I continue to do > so. > > Clients want it done. They want me to take responsibility for the > > work I do. And this reduces their cost compared to hiring a > consultant > > to test ... we are already there and it is very cheap to test. (I > > also am a CRMI & CIEC with $5M in mold E & O). No doubt many or > > perhaps > > most RC's are not trained to test ... but that can be added to an RC > > training program. > > > > Actually our training course for TX mold remediators includes > training > > in testing since in TX if you do mold remedation work in schools you > > can also do assessment (the prohibition about doing both functions > > does not apply if you work in schools.) > > > > Some clients don't hire my firm because a consultant convinces them > > that they can't use the same company to both test the work and do > the > > remediation work. But that is very very rare at least in S FLA. > > > > And I have never had an attorney in FLA object about testing our own > > work. Generally they will insist that this is how it should be done. > > > > If the FLA mold law passes, there is nothing in the law to keep an > RC > > from testing their own work. > > > > Carl - thanks again for your little gem! > > > > Rosen, Ph.D. > > www.Mold-Books. com > > > > Re: PRV by RC > > > > > > In a message dated 5/2/2007 1:18:42 PM Eastern Standard Time, > > > garyrosen72652@ yahoo.com writes: > > > If the Remediation Contractor follows the following protocol for > > > post remediation testing ... does anyone believe there is a > conflict > > > of interest? > > > > > > > > > > > > Yes. > > > > > > > > > 1.) Have the homeowner witness the sampling. > > > > > > > > > > > > They won't know what they are witnessing. > > > > > > 2.) Put the serial numbers of the cartridges on the COC. > > > 3.) Have the home owner sign the COC along with the sampler. > > > > > > > > > > > > Who fills out the COC? The sample volume is something the > homeowner > > > does not know how to verify. Do they check the calibration and > time > > > the sample, too? > > > > > > 3.) Have the home owner mail in the cartridges (in the FedX > envelop > > > you give him) to a certified lab. 4.) Have the lab email both you > > > and the client the results. > > > > > > It would be pretty hard to forge these results! > > > > > > > > > > > > What about the sample location and conditions during sampling? > This > > > will be a significant variable factor. Will the homeowner know how > > > to interpret the results or will you be doing that? Why don't you > > > just let the homeowner tell you where and how to sample or leave > > > them the pump and cassettes and let them take them themselves. > > > > > > Sorry, . It's still a conflict of interest in my book to do > your > > > own PRV. If you want to do your own internal QC checking, I think > > > doing your own sampling is a very good idea for that purpose. > > > > > > Steve Temes > > > > > > > > > Rosen, Ph.D > > > > > > > > > > > > > > > > > > > > > > > > > ____________ _________ _________ _________ _________ __ > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted May 7, 2007 Report Share Posted May 7, 2007 , The counts should go down if you’re taking the microbial samples during the restorative portion; and again after the restorative is completed. This would be true because you may be sealing up the reservoir. BTW that is called encapsulation not remediation. EnviroBob From: iequality [mailto:iequality ] On Behalf Of Sent: Monday, May 07, 2007 10:23 AM To: iequality Subject: Re: PRV by RC Group, Am I smoking something funny, or should PRV (or QC whatever...) be done BEFORE rebuild is started? Maybe I am missing something here... > > Carl, > > That is pretty insightful! A gem. If testing your own work is a COI > or potential COI does that make it is wrong or bad to do? > > Since I test my own work to improve the quality of my work (even > though I eat the cost and it reduces my profit) I continue to do so. > Clients want it done. They want me to take responsibility for the > work I do. And this reduces their cost compared to hiring a consultant > to test ... we are already there and it is very cheap to test. (I > also am a CRMI & CIEC with $5M in mold E & O). No doubt many or > perhaps > most RC's are not trained to test ... but that can be added to an RC > training program. > > Actually our training course for TX mold remediators includes training > in testing since in TX if you do mold remedation work in schools you > can also do assessment (the prohibition about doing both functions > does not apply if you work in schools.) > > Some clients don't hire my firm because a consultant convinces them > that they can't use the same company to both test the work and do the > remediation work. But that is very very rare at least in S FLA. > > And I have never had an attorney in FLA object about testing our own > work. Generally they will insist that this is how it should be done. > > If the FLA mold law passes, there is nothing in the law to keep an RC > from testing their own work. > > Carl - thanks again for your little gem! > > Rosen, Ph.D. > www.Mold-Books. com > > Re: PRV by RC > > > > In a message dated 5/2/2007 1:18:42 PM Eastern Standard Time, > > garyrosen72652@ yahoo.com writes: > > If the Remediation Contractor follows the following protocol for > > post remediation testing ... does anyone believe there is a conflict > > of interest? > > > > > > > > Yes. > > > > > > 1.) Have the homeowner witness the sampling. > > > > > > > > They won't know what they are witnessing. > > > > 2.) Put the serial numbers of the cartridges on the COC. > > 3.) Have the home owner sign the COC along with the sampler. > > > > > > > > Who fills out the COC? The sample volume is something the homeowner > > does not know how to verify. Do they check the calibration and time > > the sample, too? > > > > 3.) Have the home owner mail in the cartridges (in the FedX envelop > > you give him) to a certified lab. 4.) Have the lab email both you > > and the client the results. > > > > It would be pretty hard to forge these results! > > > > > > > > What about the sample location and conditions during sampling? This > > will be a significant variable factor. Will the homeowner know how > > to interpret the results or will you be doing that? Why don't you > > just let the homeowner tell you where and how to sample or leave > > them the pump and cassettes and let them take them themselves. > > > > Sorry, . It's still a conflict of interest in my book to do your > > own PRV. If you want to do your own internal QC checking, I think > > doing your own sampling is a very good idea for that purpose. > > > > Steve Temes > > > > > > Rosen, Ph.D > > > > > > > > > > > > > > > > ____________ _________ _________ _________ _________ __ > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted May 9, 2007 Report Share Posted May 9, 2007 Don: I'm very sorry if my message seemed to suggest that you shouldn't contribute. by all means, post away. my intent was to point out that certain list members won't hear what we're saying, and aren't able to change their ways despite the urging of more experienced professionals. although I've largely given up on this list, I always make a point of reading everything I can if it's written by you. regards, Wane > > > > > > Don, Steve: > > > > some people just don't get it, because they're incapable of 'getting > > it'. > > > > your attempts are laudable, but it's the old " blood from a turnip " > > metaphor. > > > > everyone else gets it. then again, not everyone insists that they > are > > right/better qualified/smarter/more clever all of the time and in > every > > circumstance. > > > > at some point, it's OK to save your breath. > > > > Wane > > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted May 10, 2007 Report Share Posted May 10, 2007 Wane: Thanks for your support and kind words. I agree with what you are saying. My concern is not just with the list members who are not listening, but with the list members who ARE listening to others that are making erroneous statements about matters that they obviously know little or nothing about. I post to those who do read the posts, both mine and others, that refute those posts that are misleading and just plain wrong. When I read something that I know is not true, or based on faulty judgment, I do respond as best and politely as I can, in order to make sure others know that there is an alternative view they may wish to consider. I hope that makes somewhat of a difference to the overall audience on this list serve. Don > > > > > > > > > Don, Steve: > > > > > > some people just don't get it, because they're incapable of 'getting > > > it'. > > > > > > your attempts are laudable, but it's the old " blood from a turnip " > > > metaphor. > > > > > > everyone else gets it. then again, not everyone insists that they > > are > > > right/better qualified/smarter/more clever all of the time and in > > every > > > circumstance. > > > > > > at some point, it's OK to save your breath. > > > > > > Wane > > > > Quote Link to comment Share on other sites More sharing options...
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