Re: Florida Poised to Pass Mold Legislation effective July 2010

May 9, 2007

,

You missed a couple of key points; the first being the effective date

of the law was changed from October 2007 to July 1st, 2010. Also the

money that was appropriated for staff positions for 2007/2008 was

removed from the final version. There is a liberal grandfathering

provision until the year 2010. There is also a long list of groups

that are exempt from the law including property owners, employees of

owners, maintenance workers, mobile home industry, private schools,

Division I & II contractors, architects, engineers, public employees

and pest control operators.

How do you feel about your bug guy doing the PRV on your next project?

Given that the law will not take effect for three years, I suspect

that some of the statutory definitions may change between now and July

1st 2010. There will also be interpretations of the law & departmental

rules implemented by the Florida DBPR that will affect how the law is

actually enforced. The department staff will ultimately determine

issues like which training programs meet the state standards and who

qualifies for a license under the grandfathering section.

I think that I will wait for the rest of the details before I

celebrate the new law.

Doug Summers MS CIEC

MoldDog Environmental

>

> Florida Poised to Pass Mold Legislation

> After 3 years of legislative negotiation, the Florida Legislature

passed a bill requiring the licensing of mold assessors and mold

remediators on May 4th, the last day of its session.

>

> IAQA was unsuccessful in its effort to have the bill exempt from

state licensing examinations only those persons certified by an

accredited certification body. However, the bill does still contain

provisions for those with voluntary certifications to be exempt from

state testing requirements if the voluntary programs meet the minimum

requirements to be defined by the state.

>

> The Florida action comes as almost half the states have ended their

legislative sessions for the year which saw some 30 bills introduced

that would affect IAQA members in a variety of ways. There were few

other bills that would have as significant impact on industry as the

Florida bill.

>

> ......

>

> Group,

>

> This law if not vetoed by the Governor will change the shape of mold

assessment and mold remediation in Florida and most likely by ripple

effect in many states.

>

> $1M mold E & O insurance for asessors and $1M mold insurance for

remediators plus GL. Formal training in water damage such as is a

prerequisite to sit for the IICRC AMRT/S course is required.

>

> I doubt anyone will be exempt if they got their training on-line.

>

> Mold assessment is defined as: " Mold assessment " means a process

performed by a

>

> 6 mold assessor that includes the physical sampling and detailed

>

> 7 evaluation of data obtained from a building history and

>

> 8 inspection to formulate an initial hypothesis about the

>

> 9 origin, identity, location, and extent of amplification of

>

> 10 mold growth of greater than ten square feet.

>

> The definition of mold assessment is important in several ways.

>

> #1. It is consistent with EPA and OSHA guidelines that emphasize

that the physical size of the growth is a key element in how one

formulates a remediation plan. The extent of a problem is NOT

determined by sampling.

>

> #2. If you do an investigation without sampling, it is not an

assessment.

>

> #3. Sampling alone without an inspection and without evaluating a

building's history (of water damage) and without inspection is not an

assessment.

>

> #4. Baseline testing, testing during remediation, post remediation

testing ... are not assessments and not regulated by this law. These

can be done by the remediation contractor.

>

> Training courses and insurance programs will need to be rethought in

light of these definitions. For example, the insurance available thru

IICRC states that strong training in water damage is a pre-requisite

for insurance coverage for mold remediation. The FLA law is

consistent with this perspective and the current mold training

programs both assessment and remediation will have to be " upgraded " to

include training in water damage.

>

> Training will have to encompass the " new responsibilities " of the

professional licensed mold remediator to be responsible for his own work.

>

> The mold assessor that thinks he can assess by taking a few samples

without knowing how to investigate a building (building science) most

likely not be able to be insured to work in FLA.

>

> As I see it, CIH's will be in a very good position to be exempt from

the state exam. I believe that current TX licensees will be exempt.

The TX program is sort of strange but they do have strong training

requirements and a tough state certification test.

>

> I also see home inspectors that take the CRMI 2 day training may

wind up dominating mold assessment in FLA due to their strong

knowledge of sampling, investigation and water damage.

>

> This bill is very good for our citizens and it will be good in the

long run for the professionals in our industry.

>

> Rosen, Ph.D.

> www.Mold-Books.com

>

> __________________________________________________

>

May 9, 2007

Mold Dog,

There is certainly no liberal grandfathering. You need to precisely meet the state requirements and have passed an approved certification test. The only people grandfathered in would be people licensed in other states with similar programs like TX.

I doubt the pest control guy can get mold insurance unless he is qualified. That is a non-issue.

Rosen, Ph.D.

www.mold-books.com

Re: Florida Poised to Pass Mold Legislation effective July 2010

,You missed a couple of key points; the first being the effective dateof the law was changed from October 2007 to July 1st, 2010. Also themoney that was appropriated for staff positions for 2007/2008 wasremoved from the final version. There is a liberal grandfatheringprovision until the year 2010. There is also a long list of groupsthat are exempt from the law including property owners, employees ofowners, maintenance workers, mobile home industry, private schools,Division I & II contractors, architects, engineers, public employeesand pest control operators.How do you feel about your bug guy doing the PRV on your next project?Given that the law will not take effect for three years, I suspectthat some of the statutory definitions may change between now and July1st 2010. There will also be interpretations of the law & departmentalrules implemented by the Florida DBPR that will affect how the

law isactually enforced. The department staff will ultimately determineissues like which training programs meet the state standards and whoqualifies for a license under the grandfathering section. I think that I will wait for the rest of the details before Icelebrate the new law.Doug Summers MS CIECMoldDog Environmental>> Florida Poised to Pass Mold Legislation> After 3 years of legislative negotiation, the Florida Legislaturepassed a bill requiring the licensing of mold assessors and moldremediators on May 4th, the last day of its session. > > IAQA was unsuccessful in its effort to have the bill exempt fromstate licensing examinations only those persons certified by anaccredited certification body. However, the bill does

still containprovisions for those with voluntary certifications to be exempt fromstate testing requirements if the voluntary programs meet the minimumrequirements to be defined by the state.> > The Florida action comes as almost half the states have ended theirlegislative sessions for the year which saw some 30 bills introducedthat would affect IAQA members in a variety of ways. There were fewother bills that would have as significant impact on industry as theFlorida bill.> > ...... > > Group,> > This law if not vetoed by the Governor will change the shape of moldassessment and mold remediation in Florida and most likely by rippleeffect in many states.> > $1M mold E & O insurance for asessors and $1M mold insurance forremediators plus GL. Formal training in water damage such as is aprerequisite to sit for the IICRC AMRT/S course is required.> >

I doubt anyone will be exempt if they got their training on-line.> > Mold assessment is defined as: "Mold assessment" means a processperformed by a> > 6 mold assessor that includes the physical sampling and detailed> > 7 evaluation of data obtained from a building history and> > 8 inspection to formulate an initial hypothesis about the> > 9 origin, identity, location, and extent of amplification of> > 10 mold growth of greater than ten square feet.> > The definition of mold assessment is important in several ways. > > #1. It is consistent with EPA and OSHA guidelines that emphasizethat the physical size of the growth is a key element in how oneformulates a remediation plan. The extent of a problem is NOTdetermined by sampling.> > #2. If you do an investigation without sampling, it is not anassessment.> > #3.

Sampling alone without an inspection and without evaluating abuilding's history (of water damage) and without inspection is not anassessment.> > #4. Baseline testing, testing during remediation, post remediationtesting ... are not assessments and not regulated by this law. Thesecan be done by the remediation contractor.> > Training courses and insurance programs will need to be rethought inlight of these definitions. For example, the insurance available thruIICRC states that strong training in water damage is a pre-requisitefor insurance coverage for mold remediation. The FLA law isconsistent with this perspective and the current mold trainingprograms both assessment and remediation will have to be "upgraded" toinclude training in water damage.> > Training will have to encompass the "new responsibilities" of theprofessional licensed mold remediator to be responsible for his own

work.> > The mold assessor that thinks he can assess by taking a few sampleswithout knowing how to investigate a building (building science) mostlikely not be able to be insured to work in FLA.> > As I see it, CIH's will be in a very good position to be exempt fromthe state exam. I believe that current TX licensees will be exempt.The TX program is sort of strange but they do have strong trainingrequirements and a tough state certification test.> > I also see home inspectors that take the CRMI 2 day training maywind up dominating mold assessment in FLA due to their strongknowledge of sampling, investigation and water damage.> > This bill is very good for our citizens and it will be good in thelong run for the professionals in our industry. > > Rosen, Ph.D.> www.Mold-Books. com> > ____________ _________ _________ _________ _________ __> Do

You Yahoo!?> Tired of spam? Yahoo! Mail has the best spam protection around > http://mail. yahoo.com>

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May 9, 2007

,

The bug guy won't be required to have mold insurance because he is

exempt from the law. My point is that the law is not likely to be the

major regulatory break-through that you were predicting for consumers

and the industry. The groups that are exempt from the law won't be

burdened by insurance or training requirements that will be required

for license holders.

In fact, we are looking at status quo for the next three years. RC's

will continue to perform their own PRVs & uninsured mold inspectors

with self printed certificates will continue to operate without

regulation.

I still don't see a reason to perform any high fives at the moment. I

will simply hope that the glitches (like the failure to define a PRV

or effectively regulate conflicts of interest) that are contained in

this law are fixed before it is implemented in 2010.

Best Regards,

Doug Summers MS CIEC

> >

> > Florida Poised to Pass Mold Legislation

> > After 3 years of legislative negotiation, the Florida Legislature

> passed a bill requiring the licensing of mold assessors and mold

> remediators on May 4th, the last day of its session.

> >

> > IAQA was unsuccessful in its effort to have the bill exempt from

> state licensing examinations only those persons certified by an

> accredited certification body. However, the bill does still contain

> provisions for those with voluntary certifications to be exempt from

> state testing requirements if the voluntary programs meet the minimum

> requirements to be defined by the state.

> >

> > The Florida action comes as almost half the states have ended their

> legislative sessions for the year which saw some 30 bills introduced

> that would affect IAQA members in a variety of ways. There were few

> other bills that would have as significant impact on industry as the

> Florida bill.

> >

> > ......

> >

> > Group,

> >

> > This law if not vetoed by the Governor will change the shape of mold

> assessment and mold remediation in Florida and most likely by ripple

> effect in many states.

> >

> > $1M mold E & O insurance for asessors and $1M mold insurance for

> remediators plus GL. Formal training in water damage such as is a

> prerequisite to sit for the IICRC AMRT/S course is required.

> >

> > I doubt anyone will be exempt if they got their training on-line.

> >

> > Mold assessment is defined as: " Mold assessment " means a process

> performed by a

> >

> > 6 mold assessor that includes the physical sampling and detailed

> >

> > 7 evaluation of data obtained from a building history and

> >

> > 8 inspection to formulate an initial hypothesis about the

> >

> > 9 origin, identity, location, and extent of amplification of

> >

> > 10 mold growth of greater than ten square feet.

> >

> > The definition of mold assessment is important in several ways.

> >

> > #1. It is consistent with EPA and OSHA guidelines that emphasize

> that the physical size of the growth is a key element in how one

> formulates a remediation plan. The extent of a problem is NOT

> determined by sampling.

> >

> > #2. If you do an investigation without sampling, it is not an

> assessment.

> >

> > #3. Sampling alone without an inspection and without evaluating a

> building's history (of water damage) and without inspection is not an

> assessment.

> >

> > #4. Baseline testing, testing during remediation, post remediation

> testing ... are not assessments and not regulated by this law. These

> can be done by the remediation contractor.

> >

> > Training courses and insurance programs will need to be rethought in

> light of these definitions. For example, the insurance available thru

> IICRC states that strong training in water damage is a pre-requisite

> for insurance coverage for mold remediation. The FLA law is

> consistent with this perspective and the current mold training

> programs both assessment and remediation will have to be " upgraded " to

> include training in water damage.

> >

> > Training will have to encompass the " new responsibilities " of the

> professional licensed mold remediator to be responsible for his own

work.

> >

> > The mold assessor that thinks he can assess by taking a few samples

> without knowing how to investigate a building (building science) most

> likely not be able to be insured to work in FLA.

> >

> > As I see it, CIH's will be in a very good position to be exempt from

> the state exam. I believe that current TX licensees will be exempt.

> The TX program is sort of strange but they do have strong training

> requirements and a tough state certification test.

> >

> > I also see home inspectors that take the CRMI 2 day training may

> wind up dominating mold assessment in FLA due to their strong

> knowledge of sampling, investigation and water damage.

> >

> > This bill is very good for our citizens and it will be good in the

> long run for the professionals in our industry.

> >

> > Rosen, Ph.D.

> > www.Mold-Books. com

> >

> > ____________ _________ _________ _________ _________ __

> >

May 10, 2007

Doug, et al:

The thing that bothers me the most about this bill is that it will

limit the individuals from outside Florida to conduct mold

assessments in the state.

An example in Florida: one of the most famous of mold contamination

cases is the county courthouse in Stuart, Florida, which Phil Morey

investigated in the late 1990's. The courthouse had been built only

a few years prior to the investigation, but it was not built to

withstand the hot and humid conditions in southeast Florida (example

of public low bidding, but that's another story). The vapor barrier

on all the exterior walls was placed erroneously, so that the

moisture was trapped inside the building's walls, resulting in mold

growth throughout the interior of the walls, throughout the entire

building.

The building cost $42 million to build. The remediation, which

included cleaning every single piece of paper in the building (none

of it could be thrown out, since these were irreproducible legal

documents), cost approximately $43 million.

Now, I am not advocating this type and level of mold cleanup at this

time, and I don't think Phil would handle this type of situation in

the same way now. But it will be interesting to see what happens in

Florida (hotbed for mold contamination) when a Phil Morey (one of the

most famous of all mold investigators, and one of the earliest (late

1980's)) is not allowed to conduct a mold assessment at a large

public building without a state issued license, and a state-licensed

five-day wonder will conduct the mold assessment. What fun!

All of the issues on 'grandfathering' and the rules as to how can be

licensed will be decided at the state agency level, not in this piece

of legislation. The interpretative documents between now and 2010

(when the provisions of the law will go into effect) will be

interesting to read.

Don

>

> Mold Dog,

>

> There is certainly no liberal grandfathering. You need to

precisely meet the state requirements and have passed an approved

certification test. The only people grandfathered in would be people

licensed in other states with similar programs like TX.

>

> I doubt the pest control guy can get mold insurance unless he is

qualified. That is a non-issue.

>

> Rosen, Ph.D.

> www.mold-books.com

>

> Re: Florida Poised to Pass Mold Legislation

effective July 2010

>

> ,

>

> You missed a couple of key points; the first being the effective

date

> of the law was changed from October 2007 to July 1st, 2010. Also the

> money that was appropriated for staff positions for 2007/2008 was

> removed from the final version. There is a liberal grandfathering

> provision until the year 2010. There is also a long list of groups

> that are exempt from the law including property owners, employees of

> owners, maintenance workers, mobile home industry, private schools,

> Division I & II contractors, architects, engineers, public employees

> and pest control operators.

>

> How do you feel about your bug guy doing the PRV on your next

project?

>

> Given that the law will not take effect for three years, I suspect

> that some of the statutory definitions may change between now and

July

> 1st 2010. There will also be interpretations of the law &

departmental

> rules implemented by the Florida DBPR that will affect how the law

is

> actually enforced. The department staff will ultimately determine

> issues like which training programs meet the state standards and who

> qualifies for a license under the grandfathering section.

>

> I think that I will wait for the rest of the details before I

> celebrate the new law.

>

> Doug Summers MS CIEC

> MoldDog Environmental

May 10, 2007

Don,

Anyone will be able work under the direct supervision of a license

holder under the proposed law.

There are a number of loopholes in the law that were detailed in

's earlier post that would likely allow Mr. Morey to contribute

his expertise to a public project after 2010 without a license.

There are exemptions for employees of property owners and maintenance

workers. Contractors, engineers & architects are exempt along with all

public employees. Private & public schools are exempt from the

regulations as well. Persons working on behalf of an insurer are

listed as an exempt group.

There are a number of serious glitches in the law as it is currently

written. We can add the lack of a provision for qualified out of state

consultants to the list of problems. However, I do not find any

residency requirements like those contained in the Texas law that

would prohibit an out of state person from becoming licensed in Florida.

My point is simply that we need to lobby the Florida Legislature to

amend the proposed law before it becomes effective in 2010 so that it

meets the needs of both our industry and consumers in a fair and

effective manner.

My hope is that the law will be amended to close some of the gaping

loopholes that have been pointed out by Dr Rosen.

We need a definition for post remediation verification (PRV) testing

in the law along with an effective ban for conflicts of interest in

conducting a PRV or a mold assessment. The definition of mold

assessment needs to be extended beyond the formation of an initial

hypothesis to include PRVs. There are a number of issues that need to

be addressed before this law can be implemented to achieve the goals

that the legislature had in mind when this bill was written.

Doug Summers MS CIEC

> >

> > Mold Dog,

> >

> > There is certainly no liberal grandfathering. You need to

> precisely meet the state requirements and have passed an approved

> certification test. The only people grandfathered in would be people

> licensed in other states with similar programs like TX.

> >

> > I doubt the pest control guy can get mold insurance unless he is

> qualified. That is a non-issue.

> >

> > Rosen, Ph.D.

> > www.mold-books.com

> >

> > Re: Florida Poised to Pass Mold Legislation

> effective July 2010

> >

> > ,

> >

> > You missed a couple of key points; the first being the effective

> date

> > of the law was changed from October 2007 to July 1st, 2010. Also the

> > money that was appropriated for staff positions for 2007/2008 was

> > removed from the final version. There is a liberal grandfathering

> > provision until the year 2010. There is also a long list of groups

> > that are exempt from the law including property owners, employees of

> > owners, maintenance workers, mobile home industry, private schools,

> > Division I & II contractors, architects, engineers, public employees

> > and pest control operators.

> >

> > How do you feel about your bug guy doing the PRV on your next

> project?

> >

> > Given that the law will not take effect for three years, I suspect

> > that some of the statutory definitions may change between now and

> July

> > 1st 2010. There will also be interpretations of the law &

> departmental

> > rules implemented by the Florida DBPR that will affect how the law

> is

> > actually enforced. The department staff will ultimately determine

> > issues like which training programs meet the state standards and who

> > qualifies for a license under the grandfathering section.

> >

> > I think that I will wait for the rest of the details before I

> > celebrate the new law.

> >

> > Doug Summers MS CIEC

> > MoldDog Environmental

>

May 10, 2007

Don,

We have some of the best consultants in the country in our state. Just also some of the worse. If a realtor, builder, lawyer, mortgage broker and now a mold guy wants to work in this state and they live out of state then they need to be licensed to work in this state. If they are licensed in TX or other state with similar program to FLA they will be grandfathered in.

Rosen, Ph.D.

www.Mold-Books.com

Re:

Florida Poised to Pass Mold Legislation effective July 2010> > ,> > You missed a couple of key points; the first being the effective date> of the law was changed from October 2007 to July 1st, 2010. Also the> money that was appropriated for staff positions for 2007/2008 was> removed from the final version. There is a liberal grandfathering> provision until the year 2010. There is also a long list of groups> that are exempt from the law including property owners, employees of> owners, maintenance workers, mobile home industry, private schools,> Division I & II contractors, architects, engineers, public employees> and pest control operators.> > How do you feel about your bug guy doing the PRV on your next project?> > Given that the law will not take effect for three years, I suspect> that some of the statutory definitions may change

between now and July> 1st 2010. There will also be interpretations of the law & departmental> rules implemented by the Florida DBPR that will affect how the law is> actually enforced. The department staff will ultimately determine> issues like which training programs meet the state standards and who> qualifies for a license under the grandfathering section. > > I think that I will wait for the rest of the details before I> celebrate the new law.> > Doug Summers MS CIEC> MoldDog Environmental

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

new cars at Yahoo! Autos.

May 10, 2007

,

It turns out that your bug guy may already have mold insurance.

Florida law considers fungi to be a wood destroying organism (WDO),

like termites. Many pest control operators already have mold coverage

as part of their insurance package.

You were complaining that air duct cleaners could perform sampling in

a post recently & I thought you would be interested in the range of

groups that are empowered under the new law.

Best Regards,

Doug Summers MS CIEC

> > >

> > > Florida Poised to Pass Mold Legislation

> > > After 3 years of legislative negotiation, the Florida Legislature

> > passed a bill requiring the licensing of mold assessors and mold

> > remediators on May 4th, the last day of its session.

> > >

> > > IAQA was unsuccessful in its effort to have the bill exempt from

> > state licensing examinations only those persons certified by an

> > accredited certification body. However, the bill does still contain

> > provisions for those with voluntary certifications to be exempt from

> > state testing requirements if the voluntary programs meet the minimum

> > requirements to be defined by the state.

> > >

> > > The Florida action comes as almost half the states have ended their

> > legislative sessions for the year which saw some 30 bills introduced

> > that would affect IAQA members in a variety of ways. There were few

> > other bills that would have as significant impact on industry as the

> > Florida bill.

> > >

> > > ......

> > >

> > > Group,

> > >

> > > This law if not vetoed by the Governor will change the shape of mold

> > assessment and mold remediation in Florida and most likely by ripple

> > effect in many states.

> > >

> > > $1M mold E & O insurance for asessors and $1M mold insurance for

> > remediators plus GL. Formal training in water damage such as is a

> > prerequisite to sit for the IICRC AMRT/S course is required.

> > >

> > > I doubt anyone will be exempt if they got their training on-line.

> > >

> > > Mold assessment is defined as: " Mold assessment " means a process

> > performed by a

> > >

> > > 6 mold assessor that includes the physical sampling and detailed

> > >

> > > 7 evaluation of data obtained from a building history and

> > >

> > > 8 inspection to formulate an initial hypothesis about the

> > >

> > > 9 origin, identity, location, and extent of amplification of

> > >

> > > 10 mold growth of greater than ten square feet.

> > >

> > > The definition of mold assessment is important in several ways.

> > >

> > > #1. It is consistent with EPA and OSHA guidelines that emphasize

> > that the physical size of the growth is a key element in how one

> > formulates a remediation plan. The extent of a problem is NOT

> > determined by sampling.

> > >

> > > #2. If you do an investigation without sampling, it is not an

> > assessment.

> > >

> > > #3. Sampling alone without an inspection and without evaluating a

> > building's history (of water damage) and without inspection is not an

> > assessment.

> > >

> > > #4. Baseline testing, testing during remediation, post remediation

> > testing ... are not assessments and not regulated by this law. These

> > can be done by the remediation contractor.

> > >

> > > Training courses and insurance programs will need to be rethought in

> > light of these definitions. For example, the insurance available thru

> > IICRC states that strong training in water damage is a pre-requisite

> > for insurance coverage for mold remediation. The FLA law is

> > consistent with this perspective and the current mold training

> > programs both assessment and remediation will have to be " upgraded " to

> > include training in water damage.

> > >

> > > Training will have to encompass the " new responsibilities " of the

> > professional licensed mold remediator to be responsible for his own

> work.

> > >

> > > The mold assessor that thinks he can assess by taking a few samples

> > without knowing how to investigate a building (building science) most

> > likely not be able to be insured to work in FLA.

> > >

> > > As I see it, CIH's will be in a very good position to be exempt from

> > the state exam. I believe that current TX licensees will be exempt.

> > The TX program is sort of strange but they do have strong training

> > requirements and a tough state certification test.

> > >

> > > I also see home inspectors that take the CRMI 2 day training may

> > wind up dominating mold assessment in FLA due to their strong

> > knowledge of sampling, investigation and water damage.

> > >

> > > This bill is very good for our citizens and it will be good in the

> > long run for the professionals in our industry.

> > >

> > > Rosen, Ph.D.

> > > www.Mold-Books. com

> > >

> > > ____________ _________ _________ _________ _________ __

> > >

May 10, 2007

Doug,

I doubt a pest control guy in insured to take mold samples.

Rosen, Ph.D.

www.Mold-Books.com

Re: Florida Poised to Pass Mold Legislation effective July 2010

,It turns out that your bug guy may already have mold insurance.Florida law considers fungi to be a wood destroying organism (WDO),like termites. Many pest control operators already have mold coverageas part of their insurance package. You were complaining that air duct cleaners could perform sampling ina post recently & I thought you would be interested in the range ofgroups that are empowered under the new law.Best Regards,Doug Summers MS CIEC> > >> > > Florida Poised to Pass Mold Legislation> > > After 3 years of legislative negotiation, the Florida

Legislature> > passed a bill requiring the licensing of mold assessors and mold> > remediators on May 4th, the last day of its session. > > > > > > IAQA was unsuccessful in its effort to have the bill exempt from> > state licensing examinations only those persons certified by an> > accredited certification body. However, the bill does still contain> > provisions for those with voluntary certifications to be exempt from> > state testing requirements if the voluntary programs meet the minimum> > requirements to be defined by the state.> > > > > > The Florida action comes as almost half the states have ended their> > legislative sessions for the year which saw some 30 bills introduced> > that would affect IAQA members in a variety of ways. There were few> > other bills that would have as significant impact on industry as

the> > Florida bill.> > > > > > ...... > > > > > > Group,> > > > > > This law if not vetoed by the Governor will change the shape of mold> > assessment and mold remediation in Florida and most likely by ripple> > effect in many states.> > > > > > $1M mold E & O insurance for asessors and $1M mold insurance for> > remediators plus GL. Formal training in water damage such as is a> > prerequisite to sit for the IICRC AMRT/S course is required.> > > > > > I doubt anyone will be exempt if they got their training on-line.> > > > > > Mold assessment is defined as: "Mold assessment" means a process> > performed by a> > > > > > 6 mold assessor that includes the physical sampling and detailed> > > > > > 7 evaluation

of data obtained from a building history and> > > > > > 8 inspection to formulate an initial hypothesis about the> > > > > > 9 origin, identity, location, and extent of amplification of> > > > > > 10 mold growth of greater than ten square feet.> > > > > > The definition of mold assessment is important in several ways. > > > > > > #1. It is consistent with EPA and OSHA guidelines that emphasize> > that the physical size of the growth is a key element in how one> > formulates a remediation plan. The extent of a problem is NOT> > determined by sampling.> > > > > > #2. If you do an investigation without sampling, it is not an> > assessment.> > > > > > #3. Sampling alone without an inspection and without evaluating a> > building's history (of water

damage) and without inspection is not an> > assessment.> > > > > > #4. Baseline testing, testing during remediation, post remediation> > testing ... are not assessments and not regulated by this law. These> > can be done by the remediation contractor.> > > > > > Training courses and insurance programs will need to be rethought in> > light of these definitions. For example, the insurance available thru> > IICRC states that strong training in water damage is a pre-requisite> > for insurance coverage for mold remediation. The FLA law is> > consistent with this perspective and the current mold training> > programs both assessment and remediation will have to be "upgraded" to> > include training in water damage.> > > > > > Training will have to encompass the "new responsibilities" of the> > professional

licensed mold remediator to be responsible for his own> work.> > > > > > The mold assessor that thinks he can assess by taking a few samples> > without knowing how to investigate a building (building science) most> > likely not be able to be insured to work in FLA.> > > > > > As I see it, CIH's will be in a very good position to be exempt from> > the state exam. I believe that current TX licensees will be exempt.> > The TX program is sort of strange but they do have strong training> > requirements and a tough state certification test.> > > > > > I also see home inspectors that take the CRMI 2 day training may> > wind up dominating mold assessment in FLA due to their strong> > knowledge of sampling, investigation and water damage.> > > > > > This bill is very good for our citizens and it will be

good in the> > long run for the professionals in our industry. > > > > > > Rosen, Ph.D.> > > www.Mold-Books. com> > > > > > ____________ _________ _________ _________ _________ __> > >

May 10, 2007