Mold Problems Must Be Addressed

Many people believe that mold is not a significant problem since it exists in nature. In addition, since there are not rules or laws in all states and the EPA Guidelines one of the major tools to following in performing mold remediation, many people believe that mold is just not that dangerous to health or damaging to structures. The fact that there is no consensus regarding mold control and safe levels only fuels belief that mold is not something to be too worried about. This is simply not true-mold indoors must be dealt with.

The one thing most sources of mold information do address is the fact that mold growth indoors must be taken care of. Leviticus in the Bible even discussed mold remediation and stated that if the mold growth returned after the first purge, the building was to be dismantled and destroyed.

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Historic Mold Guidelines

For 3,500 years, since biblical times, mold has been recognized as a danger to human health. Leviticus, a book from the Bible, in Section 14 provides directions to Moses on how to address mold in a home.

Leviticus discussed that when mold was found in a home, the occupants should leave then a local priest would conduct a home inspection. If the mold appeared to have eaten into the walls, the home would be off limits to inhabitants for seven days. If the mold spread, contaminated stones were removed and replaced with non-contaminated ones. The interior was scraped down and re-plastered. If after all this, the mold returned, the home would be torn down.

While these were the biblical guidelines, if these are examined from a scientific standpoint, the following conclusions can be reached:

• Get help from an expert if mold is visible to the eye.( verse 35)
• Pack up the home contents when mold is discovered to avoid further contamination and airborne spore contamination (verse 36)
• Perform a complete visual inspection (verse 36)
• If the mold is a dangerous type, the inhabitants must evacuate (verse 37-38)
• Wait seven days (incubation period of most molds) to see if it will go dormant under the proper growing conditions of mold. ( verse 39)
• Remove and discard building materials with mold growth on them (verse 40)
• Clean interior surfaces with mold (verse 41)
• Replace discarded building materials with new ones. (verse 42)
• A person entering the building during mold remediation cannot go to other areas without being decontaminated. (verses 46-47)
• Wash clothing to remove mold spores.(verse 47)
• An independent third party must perform a post mold remediation inspection. (verse 48)
• The project is only completed if it passes a full inspection and finds no mold. (verse 48)
• The independent inspector will publicly document that the mold remediation is completed.(verses 49-53)
• Recurring mold post remediation indicated trouble identifying the source of the problem and requires a tear down of the structure. (verses 43-45)

It is very evident that the basic tenants of conducting a mold remediation have been understood and employed for thousands of years.

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OSHA Technical Manual

The OSHA Manual in Chapter 6, discusses indoor air quality issues. It discussed the major complaints registered by NIOSH (the National Institute for Occupational Safety and Health).

The major sources of problems are:

• Contamination from inside the building -16%
• Contamination from outside the building -16%
• Contamination from building fabric- 4%
• Microbial contamination-5%
• Unknown sources-13%
• Inadequate ventilation-52%

Air flow in a healthy building should always be at least 15 cubic feet per minute. It also provides definitions and descriptions of IAQ related diseases and sick building syndrome.

A list of indoor contaminants is provided:

• Formaldehyde
• Radon
• Asbestos
• Tobacco smoke
• Microbes and other Bioaerosols ( including mold)
• Fibers
• Ozone
• Carbon monoxide

The health risks of each contaminant are also provided in this manual.

The OSHA manual provides instruction on how to perform an IAQ investigation. Interviews with employees and employers, sampling, a visual inspection, and evaluation of all the information gathered are recommended.

It provides basic information in picking sampling equipment and the pros and cons of most sampling methods. It also provides steps on how to avoid IAQ problems. It discusses ventilation rates for healthy building and preventative maintenance for buildings.

The techniques detailed in the OSHA manual are supportive of the approaches documented by the EPA, ACGIH and other sources. All these sources recognize that the mold infested materials must be removed/remediated and the source of the moisture problem must be fixed to avoid recurrence of mold growth. The moisture control information is supplementary to the ILCRC standards. In addition, the signs of a mold problem are essential because these are one of the only standards for mold concern published by a federal regulatory agency.

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Bioaerosols Standards for Comparison

• Compare complaint/non-complaint/outside
• Contamination indications:
  • o OSHA guide-1,000 cru/m3 air
  • o OSHA guide-10,000 cfu/m3 surface
  • o OSHA guide-1,000, 000 cfu/m3 dust/soil
• Limited health research as a base for standards
• Emerging industry consensus for impaction cassettes
  • Non-toxic mold species
  • < 2,000 fungal counts per cubic meter
  • < 50 pollen c/m3
  • 5,000 skin cells c/m3

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OSHA Proposed Rule on IAQ

OSHA had proposed a rule on indoor air quality. However, at the present time, the standard is dead because no action has been taken on this in part due to the smoking provisions part of the document. It was 70 pages long.

The major components of the proposed rules were:

• Requirement of a written IAQ compliance program
• Designation of someone to implement the program
• Regular inspection and maintenance of HVAC systems
• Records of employee complaints and symptoms of building related illness
• Establishment of enclosed negative pressure smoking areas vented directly to the outside.

In addition to these major components of the proposed rule, there are other provisions:

• It would have broad application beyond industrial facilities.
• Information related to equipment and procedures that affect IAQ must be organized
• Carbon dioxide testing should be utilized to check ventilation adequacy.
• Potentially hazardous materials in areas where they can enter the HVAC system must be identified andcontrolled.(this would probably cover interior fungal growth in HVAC systems or return air plenums)
• Problems with equipment that are detected in surveys by qualified professionals must be corrected
• Owners are required to adjust air intakes if their position substantially contributes to an IAQ problem
• Solutions for potential IAQ problems must be built into construction planning
• Education to reduce IAQ problems caused by inappropriate maintenance activities must be conducted. "

While the OSHA information is directed to indoor air quality problems in a general sense rather than directly to mold control, it is still valuable for mold remediation professionals. Requirements for records of employee complaints and control of contamination sources will spark increased demand for mold remediation work if the proposed regulation ever resurfaces in OSHA’s standard setting agenda.

Even though the OSHA proposal was for IAQ, it indirectly hit on the issue of mold remediation because indoor air quality issues can intersect the mold issue (ie: humidity levels, bioaerosols etc.)

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Environmental Health Directorate of Canada Publication

"Fungal Contamination in Public Buildings: a Guide to Recognition and Management" was published by the Environmental Health Directorate of Health Canada published. It is a very detailed publication covering the following topics.

• The purpose of a mold investigation
• How to perform a building investigation
• Hoe to perform a visual inspection for mold
• Air sampling basics
• Examination for fungi in pooled water and other mediums
• Pros and cons of vacuum sampling
• Microscopic analysis techniques and pros/cons
• Cultures plates and swab samples
• Hidden mold areas
• Mold location and remediation process
• Stachybotrys mold sourcing and remediation process
• Ergosterol and glucan sampling
• Mycotoxins sampling
• Miscroscopy of pooled water items such as humidifiers
• Humidifier water culture testing
• Cytotoxicity

Key sections of the book address the following:

• Identification of Stachybotrys, Aspergillus and Penicillium and Cryptococcus neoformans mold spores as special contaminants that pose health risksgreater than other pathogens.
• Sets a 1% acceptance level in air samples for individual mold types except Stachybotrys and Aspergillus, which are subject to stricter standards (i.e. essentially a zero tolerance).
• Provides written definitions for "minimal Stachybotrys" and " low to high "Stachybotrys levels.
• A detailed appendix a which discusses fungal health effects, but is quite technical
• A description of "normal" Cladosporium, Alternaria, and basidiospores as 40 cfu/m3 in appendix B
• An indicator of "concerns" if more than 50 cfu/m3 of fungal spores are recovered from indoor air unless summer levels of Cladosporium push the indoor totals up (500cfu/m3 maximum_.
• An" abbreviated" Stachybotrys algorithm which summarizes mold investigation steps and conditions requiring remediation is included on page 28 ( appendix D)"

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American Conference of Governmental Industrial Hygienists

The ACGIH book, "Bioaerosols: Assessment and Control", was extensively updated in 1999. This was done because people have been demanding more factual data on mold. The book has 26 chapters. It contains basic mold information, definitions of mold and how it grows, and then there is a section that describes the different types of mold. It is an extremely helpful book for mold remediation personnel. It also covers inspection techniques, the health effects of mold, and how to take and interpret sample results.

This book also discusses the basics of risk assessment. It recommends that remediation professionals utilize health surveys for occupants in conjunction with visual inspections and mold sampling techniques. The samples need to be collected to validate or invalidate a theory on mold in a building not just to have extra data. This is consistent with the idea that theorized the endpoint be known before samples are gathered.

This book ties together the topic of IAQ with fungal/mold contamination. It also summarized the EPA’s inspection techniques’ recommending source, mold growth pathway ID, and any adverse health effects on individuals. The book states that care with these 3 factors helps in setting up adequate engineering controls, the proper PPE, and careful remediation techniques to result in a successful post remediation inspection and project closure.

The section on how to interpret sample results is essential. It discusses comparisons of indoor and outdoor samples and how indicator (precursor species) species can be useful in determining if mold contamination is present. It lists precautions to take if mold and bacteria co-exist on a project. Most experts agree that if bacterial and mold contamination co-exist, that the remediator use the worst case scenario precautions.

This section also describes mold toxins and states that the observation of indoor mold growth does not mean that mycotoxins are present all the time. Mycotoxin production depends on the type of mold present, the amount of water available, the nutrient source, the ambient pH level, temperature and more. It is essential to test contaminants to prove/disprove that mycotoxins are in the building. However, almost all molds visibly growing have the capacity to produce mycotoxins.

A latter chapter focuses on preventing mold contamination. A great deal of discussion is given to water damage in building and HVAC systems. The pros and cons of biocides, encapsulants, and anti microbial agents are discussed. This is helpful to the remediation profession in deciding what type of cleaning product is best for any of the following:

• Treat sewage floods
• Treating Legionella in water-cooling towers
• Remediating mold growth

It also addresses conducting the actual mold remediation and what should be discarded. It discusses the effects that water damage have on mold growth and the degradation of the materials. It recommends that porous items with mold growth be discarded and non-porous items be cleaned thoroughly and dried.

In another section, PPE (personal protective equipment) and engineering controls are addressed. Levels of contamination from minimal, moderate, to extensive are correlated with increasing levels of PPE and engineering controls. To a degree, the remediator must use his/her judgment as to which level of containment to use.

The book does state what most other mold experts agree with:

• Moldy porous material must be cleaned o discarded
• Porous materials can still harbor spores that can grow even if there is not yet visible mold growth.
• Containment barriers consisting (2 sealed plastic coverings) should cover HVAC equipment and ducts.
• A decontamination unit should be used (HEPA filtered).
• Moldy materials should be double bagged and thrown out.
• HEPA vacuuming and damp wiping should be used in all mold remediation projects. The use of lots of water in cleaning is not advisable.
• A final post remediation inspection should be conducted to confirm that there is no evident mold and all debris has been properly disposed.
• A post remediation air/surface sampling is an essential tool in determining the success of a remediation project.
• An N-95 filter and face piece are the minimum level of protection to be used for mold remediation work

Fungi, mycotoxins, and microbial volatile organic compounds (VOCs) are discussed in another chapter. This is also essential reading for the mold remediation professional.

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IICRC Standard

The Institute of Inspection Cleaning and Restoration Certification (IICRC) was revised again in 1999 because a number of industry changes had occurred. It addresses industry requirements for dealing with water losses in its introductory section. The following material serves as explanation.

The beginning of the document deals with clean water of no threat to people, water with significant amounts of contamination and the potential to cause illness, and grossly unsanitary water with high levels of pathogens to cause illness in humans.

It states that the first 2 categories of water will become the latter grossly unsanitary category because of bacteria/fungus that occur in wet areas. Therefore, the requirements of how to deal with grossly unsanitary water are much stricter due to the risk of illness from such water sources.

The ILRC standard is critical knowledge for all mold remediation professionals since water and mold growth go hand in hand. The EPA Guide, the NYC Guidelines, and the ACGIH guide all concur that fixing the cause of the moisture problem is an essential means of dealing with mold growth. This must be combined with the mold remediation itself. The ILRC standard only increases the legal liability for mold remediators who do not follow the guidelines.

It provides information on water removal and how to dry particular types of materials. It provides guidelines on how to assess the degree of water damage and whether particular water damaged items can be restored. PPE, engineering controls, how to perform the actual cleaning, how to dispose of waste, evacuation considerations, and product tips are contained in this document.

General Guidelines for Remediation from IICRC

• Gray, black or old while water require disposal of carpet pad and gypsum board
• Sanitize and encapsulate studs
• Post-remediation testing is recommended
• Post-remediation should include:
  • visual inspection
  • clearance testing post remediation, but prior to remodeling

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NYC Guidelines

The New York City Department of Health has issued guidelines for dealing with fungal contamination in buildings (Appendix C).Their recommendations are summarized in the table at the end of this section.

The NYC document, which is officially known as "Guidelines on Assessment and Remediation of Fungi in Indoor Environments", is an April 2000 revision of a 1993 document that was developed specifically for Stachybotrys contamination. The revision, which totals 21 pages, is now designed to address all types of fungal contamination. The NYC guidelines are divided into four basic sections:

• Health issues
• Environmental assessment
• Remediation
• Hazard communication

The chapter of the health effects of molds, makes a definitive statement that most of the adverse health case studies came from occupational or farming exposures (often ODTS). It discussed the symptoms of organic dust toxic syndrome (ODTS) and states that mycotoxins are produced by many types of mold. The chapter covers toxic effects, symptoms of mold exposure, diseases caused by mold exposure(s), physician role in diagnosis and treatment, and occupant relocation.

Bulk and surface sampling is discussed as a main means of discovering the degree of mold contamination. It provides tips on when air monitoring can be used such as a contaminated HVAC system or people with health symptoms and states that only a trained person should take an air sample. Interpretation of sample results is discussed.

The main goals of a mold remediation, as defined in the NYC guidelines, are the removal and cleaning of mold from the structure, prevention of mold spores/dust from leaving the remediation zone, and the safety of the remediation workers and occupants. It is essential that the source of the water damage is fixed in 24-48 hours because mold growth starts thereafter. In addition, all water logged and damp items should be removed and the humidity levels should be under 60%.

These guidelines were the first published guidelines on mold remediation to be accepted. Common sources of mold such as bathroom mold are discussed separately from building mold such as support beams and the HVAC system (often much more serious). The guidelines for how to conduct a mold remediation are determined by size as follows:

• Small areas, also known as Level- I not to exceed 10 square feet
• Midsize areas, also known as Level II 10 to 30 square feet.
• Large areas, also known as Level III 30 to 100 square feet
• Extensive contamination, also known as Level IV- greater than 100 square feet

There are 2 more levels of care to be used in the remediation of mold in HVAC systems.

The NYC fungal guidelines build the precautions required for remediation in a progressive manner in regards to:

• Project oversight
• Respiratory protection
• Personal protective equipment
• Work in occupied areas
• Removal of personnel from adjacent areas
• Installation of barriers
• Utilization of negative pressure
• Waste packaging ‘cleaning techniques
• Post-remediation testing

This document emphasizes the importance of communicating effectively with the customer and the building inhabitants.

Summary of New York City Department of Health Fungal Remediation Protocols April 2000

Remediation Parameter	Level 1	Level 2	Level 3	Level 4	Level 5A	Level 5B
Description	Small isolated areas (10 sq.ft.)	Mid-sized isolated areas(10 sq.ft.)	Large isolated areas(10 sq.ft.)	Extensive contamination(greater than 100 contiguous sq.ft)	HVAC systems (less than 10 sq.ft.)	HVAC system (greater than 10 sq.ft.)
Examples	Ceiling tilesSmall areas on wall	Individual wall board Panels	Several wall board panels	Multiple wall board panels
Minimum Requirements For Remediation Oversight	Trained building staff	Trained building Staff	Qualified health and safety professional	Qualified health and safety professional	Trained building staff	Qualified health and safety professional
OSHA Regulatory Standards	29 CFR 1910.1200 29CFR 1910.134	29 CFR 1910.1200 29CFR 1910.134	29 CFR 1910.1200 29CFR 1910.134	29 CFR 1910.1200 29CFR 1910.134	29 CFR 1910.1200 29CFR 1910.134	29 CFR 1910.1200 29CFR 1910.134
Respiratory Protection	N-95 disposable respirator	N-95 disposable respirator	N-95 disposable respirator	Full-face respirator with HEPA cartridges	N-95 disposable respirator	Full-face respirator with HEPA cartridges
Gloves	Yes	Yes	Yes	Yes	Yes	Yes
Eye protection	Yes	Yes	Yes	Yes	Yes	Yes
Protective Clothing	No	No	No	Yes	No	Yes
Remediation While Unoccupied	Yes	Yes	Yes	Yes	Yes	Yes
Vacation of Adjacent spaces Recommended	if occupied by susceptible groups*	Recomm- ended if occupied by susceptible groups*	Recomm- ended if occupied by susceptible groups*	Recommended if occupied by susceptible groups*	Recomm- ended if occupied by susceptible groups*	Recommended if occupied by susceptible groups*
Containment Required	No	No	No	Yes	No	Yes
Dust Suppression	Misting	Misting	Misting	Misting	Misting	Misting
Bag Contaminated Materials	Yes	Yes	Yes	Yes	Yes	Yes
Post Remediation of Cleaning of Work Area and Egress	Clean with Damp cloth And/or mop with a cleaning Detergent solution	HEPA vacuum And clean With damp cloth and/or mop with a cleaning detergent solution	HEPA vacuum And clean With damp cloth and/or mop with a cleaning detergent solution	HEPA vacuum And clean With damp cloth and/or mop with a cleaning detergent solution	HEPA vacuum And clean With damp cloth and/or mop with a cleaning detergent solution	HEPA vacuum And clean With damp cloth and/or mop with a cleaning detergent solution
Clearance Testing	No	No	No	Yes	No	Yes

* Susceptible groups include infants less than 12 months old, persons recovering from recent injury, immune suppressed people or people with chronic inflammatory lung disease (e.g. asthma, hypersensitivity neumonitis and severe allergies)

Refer to http:// www.ci.nyc.us/html/doh/html/epi/moldrpt1/html

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AIHA Microbial Task Force

The American Industrial Hygiene Association developed a number of questions that are essential for mold remediation professional to ask in developing their remediation plan and in assessing whether the remediation is successful. The questions they developed are as follows:

1. When should microbial growth found in occupied buildings be remediated?
2. What amount of mold should indicate what degree of remediation?
3. What remediation methods should be used?
4. Should biocides be used in remediation?
5. Under what circumstances should building be evacuated and work areas isolated?
6. How should remediation work areas be isolated?
7. How should water-damaged content items be treated?
8. What quality assurance principles should be follow dot ensure that mold remediation is successful?
9. What PPE is recommended during bioremediation?
10. Is personal air sampling appropriate to determine worker exposure during mold remediation?
11. What medical evaluation is recommended for remediators?

The report reflects a summary of current writings and reflects the views on the importance of mold remediation from the NYC Guidelines and other sources. Its main points that are as follows:

• There is a need to remediate a building contaminated with mold regardless of the type of mold.
• The amount of visible mold growth can help determine what engineering controls will be employed on a project.
• Porous materials contaminated with mold need to be removed and properly disposed of.
• The importance of employing correct cleaning techniques rather than simply relying on a biocide application to do the work.
• Few mold remediations require a complete building evacuation.
• Each mold remediation project must be treated as unique with a risk assessment and plan that takes this into consideration.
• PPE and the correct safety gear should be worn for mold remediation using an N-95 respirator at least.
• Medical exams for people involved in conducting mold remediations.

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Environmental Protection Agency: "Mold Remediation in Schools and Commercial Buildings"

In the spring of 2001, the EPA published its guidelines on mold remediation. These are guidelines not rules. They are voluntary but recommended procedures for safely addressing mold in buildings. This seems to be following the pattern of documentation similar to that of lead and asbestos. Several states already have regulations that mold remediators and professionals are required to follow including licensing requirements. The requirements and regulations related to mold remediation seem to be increasing due to more knowledge about the adverse health effects of mold. Many experts are surmising that mandatory EPA regulations on mold are a short time period away form being set.

The EPA guidelines educate the reader about the causal link between moisture/water damage and mold growth. It also discussed how to conduct a mold remediation and safety precautions to take. It concurs with many of the points of the NYC, IICRC, and ACGIH. Like the EPA’s indoor air quality publications, a major focus is on water damage and the length of time water sits or moisture is evident.

This document ties its recommended actions to levels of mold contamination and the cubic area of mold contamination. At each increasing size, the health and safety precautions are more stringent. The 3 categories for mold remediation projects are how they are dealt with are:

• Small-less than 10 square feet
• Medium-10 to 100 square feet
• Large-greater than 100 square feet

The NYC guidelines appear to be more detailed as it pertains to the steps of performing a mold remediation. However, the EPA provides great detail on how to clean specific materials and household items. It also focuses on how to address clean water and less sanitary water sources. The EPA Guidelines, like the other major sources, state that water must be dried up within 24 to 48 hours to prevent mold growth.

The EPA places significant emphasis on the importance of sampling pre and post remediation as a means of reducing the likelihood of litigation provided all steps of remediation have been followed properly and a thorough risk assessment and plan done. The EPA supports the fact that visual inspections, common sense, a remediation plan, and sampling combined with a proper mold remediation are the major factors in handling a thorough mold remediation.

This source has a myriad of charts to allow the reader to look up a concept. This helps in planning a remediation. It has charts on each scope of project and charts on how to clean materials.

Other Safety and Health Regulations

When a mold remediation contractor is performing a job, it is important to remember that OSHA, 29CFR 1926, governs many health and safety regulations such as fall protection, hazard communication, eye and face protection, electrical safety, ladder safety and more. It is essential that a contractor review OSHA requirements and that they comply with these to both protect the organization and its workers’ health and safety.

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Conclusion

Standards do apply to mold remediation. Several states, such as Texas and Florida, have already passed mandatory regulations on mold remediation. These include licensing and educational requirements and often contain fines for non-compliance. In addition, the mold remediation industry has a great deal of consensus on how to correctly remediate mold. There is indeed a level of care that must be taken with mold remediation. Mold remediators that do not follow the standards may assume a great deal of liability as mold is shaping up like asbestos did a decade ago. Remember, that if an asbestos remediator did not follow the protocols, that a great deal of legal liability could occur and not necessarily in their favor.