EPA Guidelines

EPA Guidelines

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EPA Guidelines

Mold Problems Must Not Be Neglected

While mold outdoors is naturally occurring, indoor mold in a confined environment can cause adverse health effects and cause extensive damage to a property. There are no rules on safe levels of mold. In fact, some types of mold produce endotoxins and can be carcinogenic. The Environmental Protection Agency Guidelines are one of the most prominent sources of information regarding how to perform a compliant mold remediation. Failure to address a mold problem in a structure, may result in extensive construction and rebuild issues, magnified rehab costs based on how long the progressing damage has been neglected, and adverse health consequences. Since different people react differently to mold exposure (some react more, some less so, and the dose/response reaction can magnify with each exposure based on individual reaction), it is best to take steps to remediate a mold problem.


Mold Remediation in a Historical Construct

As most people are aware, the Bible has been in existence for thousands of year. In the section of Leviticus, there is text on how to deal with a mold problem in a house.

The Levitius section of the Bible clearly discusses that if the presence of mold is discovered that a priest  from the church should come to the house and examine the interior. The priest would determineif the walls needed to be replastered or the stones replaced. If the walls were compromised, the inhabitants would be banned for seven days. If after replacing plaster or stone walls, the mold returned or was still present in some capacity, the building would be destroyed (torn  down).

The procedure documented in the Bible is not so different from how we deal with a mold problem today. Today in the EPA Guidelines, a person usually gets helps from a mold remediation company or industrial hygienist, gets an inspection of the property (visual and mold testing), determines which contents can be cleaned and which must be discarded, evacuates inhabitants if immuno compromised, ill, or molds with endo toxins or carcinigenic effects are present, or major living areas are under containment and inhabitants need adequate access to a bathroom, kitchen , sleeping quarters etc. In fact most molds can take up to a week to start growing and this can help asertain through lab testing if remediation has been adequate. Thorough cleaning and removal of  mold contaminated items and building materials is conducted with vacuuming and the post remediation testing beore normal living can be resumed in the structure. Like the Bible, if mold growth and contamination keep resuming, the structure will be torn down.

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



OSHa's Technical Manual addresses the issue of indoor air quality. This manual is set up in sections such as acute effects of major indoor air contaminants, investigation guidelines, sampling instrumentation and methods, recommendations for employers etc. This manual discussed causal factors in indoor air quality such as smoking, poor air circulation, humdiity, the work space design and more. NIOSH (the National Institute for Occupational Health and Safety) over 500 indoor air quality investigations over a period ofa decade determined the major causes of indoor air quality problems. Inadequate ventilation was listed as the major reason. In this manual it lists ASHARAE's (American Society of Heating, Refrigerating, and Air Conditioning Engineers) minimum value of 5 cubic feet oer minute per person for designing a building and 20 CFM for general office space, and 60 CFM per person for smoking areas with fan exhaust (mechanical ventilation) and no recirculation. Sick building syndrome and a list of the major indoor air contaminants such as ozone, radon, asbestos, formaldehyde, VOCs, and microbials including mold.

Investigation guidelines are privided in the format of questions. Some are questions about the HVAC system, ventilation changes, repair of water leaks, renovation history, and a number of other questions. Employee interview questions are another element of this manual and incorporate questions to ask occupants about symptoms and locations etc.

In addition, an overview of doing a walkaround inspection of the site and identification of possible problem areas. The pros and cons of sampling options are discussed in the manual. Like the EPA Guidelines, this recognizes that indoor air problems can cause adverse health consequences for the occupants and the problem must be solved. The technicval manual even discusses steps that can be taken for preventative maintenance and provides a summary on how to deal with microbial contamination similar to the EPA.


Bioaerosols Standards for Comparison

The OSHA Technical Manual states that it is important to identify fungi/mold and in the microbial sampling process to determine the number of colony forming units per cubic meter of air. It also states that in a growth season, spring, outdoor fungal levels can range from 1,000 to 100,000 cfu/cubic meter of air.

The OSHA Technical Manual references that it can be an indicator of fungal contamination if there are 1,000 viable cfus per cubic meter of air, 1,000,000 fungi per gram of material, or 100,000 fungi/bacteria per millileter of stagnant water. This manual also states that levels above this do not mean that conditions are unsafe but rather that the type of mold or fungi and the airborne concentrations determine the human risk.

Industry research has indicated that for air sampling tools such as impaction sampling, 2,000 cfu per cubic meter of air is desirable when dealing with non toxic mold/fungi.



Environmental Health Directorate of Canada Publication

 LIke the EPA in the United States, the Canadian government has published its own resource tool on mold remediation. This document is titled " Fungal Contamination in Public Buildings: A Guide to Rcognition and Management." The Environmental Health Directorate of Canada published this resource. It covers the following topics: the goals of conducting a mold investigation, how to conduct a mold investigation, visual inspection, conducting air sampling, contaminated water and water sampling, pros and cons of sampling methds such as vaccum/swab, microscopy pros and cons, culture plate samples, swab/bulk samples,  location for hidden mold, how to perform a compliant remediation, toxic molds such as Stachybotrys and special considerations for their remediation, sampling glucans and mycotoxins, cytotoxicity, health issues, and water/bacterial testing.

This reference identifies the major species that have toxins and are of greater health risks than non toxic molds. It reviews Stachybotrys, Aspergillus, Penicillium, and Cryptocossis neoformans are more risky to human health. Zero tolerance species such as Stachybotrys are discussed and it defines low to high Stachybotrys contamination levels. A detailed section exists on how to investigate and remediate Stachybotrys contamination is included. In addition, it reviews each type of mold and its associated health concerns. 40 cfu per cubic meter of air is considered ordinary for Cladosporium, Alternaria, and basidiospores while a level of concern is considered 50 cfu/cubic meter of air or greater. The exception is if seasonal levels increase the indoor air totals.


American Conference of Governmental Industrial Hygienists Mold Resource

The book "Bioaerosols: Assessment and Control" is an essential reading assignment for mold remediations. Like many of the other mold remediation resource tools, it addresses mold investigation, inspection, types of mold (inclusing precursor species and implications) and their health effects, endotoxins, how mold growth starts, assessing the risk, occupant surveys for health consideration, visual inspection, types of sampling equipment, interpreting sampling results, and the importance of fixing the source of the moisture intrusion. This book is very comprehensive and combines the type of information deal with in the other soruces mentioned herein. Pre and post mold testing and projec closure consideration and techniques are discussed. Project closure is also tied into the initial project premise and goals.

In addition, dealing with bacterial contamination on a mold remediation project is reviewed-you must use the most stringent controlls and lab testing of the water/bacterial samples. Pre and post remediation sampling results are discussed regarding sample comparison.

There is a section that addresses mycotoxins and their health effects. It discussed the types of mold that produce toxins and VOCs, growth requirements for endotoxin production, and the importance of mold testing and/or occupant evaluation.

A latter chapter discusses the pros and cons of encapsultants, bleach, biocides, and antimocrobial treatments for mold. Extensive information on how to determine whether to remediate or discard items in the property is provided. The basic recommendation is that non porous items can be cleaned and dried. PPE, containment zone set up, and the importance of negative pressure is reviewed. As the size of the remediation zone increases so do the PPE and engineering control requirements.

Overall, these sources do seem to agree that:

  • A visual inspection and pre remediation mold testing should be conducted.
  • The project manager should understand occupant complaints/symptoms.
  • Project goals should be clearly set
  • Moldy materials should be cleaned or discarded according to category of porous, non-porous, or semi porous.
  • Containment zone should be set up utilizing negative pressure system(s)
  • HEPA vacuuming of the remediation zone should occur post cleaning.
  • Post mold remediation testing should be conducted to determine the success of the remediation project.
  • An N-95 respirator should be used.


IICRC Standard


The IICRC stands for the Institute of Inspection, Cleaning, and Restoration Certification. This resources deals with how to deal with water damaged items-can they be salvaged or not, how to clean items, waste disposal, PPE requirements, evacuation, and assessing the damage. Much of this resources addresses determining the level of contaminated water and the need for human safety. It is an essential resource to be familiar with because water intrusions and mold damage to material goods and property are inextricably linked.

The IICRC Standards review information such as gray, black or dirty white water on carpets, insultation, wallboard and cellulose based based materials should be disposed of properly. However, studs and other structual elements that are not strength compromised can be cleaned and sanitized. The IICRC recommends post remediation clearance testing to include both a visual inspection and air/physical samples to be taken before building repairs.

NYC Guidelines

One of the other major sources of information regarding conducting compliant mold remediations are the New York City Department of Health Guidelines. This literature is called "Guidelines on Assessment and Remediation of Fungi in Indoor Environments". This document addresses all aspects of conducting mold remediation much as the EPA Guidelines do in that it covers major topics like health effects of mold, risk assessment, how to conduct a mold remediation in terms of containment and cleaning, and communicating hazards (and worker awareness).

Much like the EPA Guidelines do, it covers health effects of mold, endotoxins, symptoms of mold exposure, and the many types of mold. The role of physician diagnosis, immuno compromised people, and relocation of occupants are discussed in this document. It also reviews the types of  mold sampling and differences between the various types of samples. It reviews the interpretation of sample results and why a person should be trained in sampling. It is important that the sampler be trained as errors in sampling interpretation can adversely impact the outcome of a remediation.

The NYS Guidelines. like the EPA Guidelines, confirm that mold growth should be cleaned up within 24-48 hours and the source of the water intrusion fixed. Mold growth can start after 24-48 hours. It discussed removing mold, cleaning the moldy environment after setting up a proper containment zone, removal/disposal of contaminated materials, and training and safety of remediation workers/safety of occupants.

This source discussed common moldy areas such as under kitchen sinks, bathrooms etc. It also addresses compromised structural integrity in elements such as joists or moldy HVAC systems (must be cleaned). The NYC Guidelines state that how a remediation is conducted be determined by size of the project. Small remediation areas are defined as 10 or  fewer square feet, medium remediation areas as 10 to 30 square feet, large areas as 30 to 100 square feet, and very extensive areas as over 100 square feet. The NYS Guidelines address the specifics of project management, complying with OSHA's respiratory protection standard for workers, PPE (such as eye protection etc.), determining waste from salvageable materials and proper containment for disposal, pre and post remediation testing,setting up the containment zone (flap containments etc.) with a negative pressure system, and cleaning. The project management overview discusses the importance of communicating well with occupants and building ownership.



American Industrial Hygiene Association

This organization devised a task force which reported on mold remediation techniques. The report basically supports the NYC and EPA Guidelines. Basically, it notes that mold must be remediated or people can get sick and the property degrade, mold growth. It also reviews the following: the importance of respirator fit testing and medical exams for remediation workers, increased obvious mold growth over larger and larger areas means increasing PPE and engineering controls, disposal of moldy porous items, and following the proper steps for the actual remediation (containment, neg. pressure, cleaning, and HEPA vacuuming). It states that  in the development of each mold remediation project, the investigation and mold testing will help devise the project plan that is unique to each job. It states that occupants do not always have to be evaluated from the site but rather this determination is based on the scope, type of mold, scope of the mold, and health status of the occupants, and location of the containment zone.



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

 The EPA Guidelines on how to conduct mold remediation are not a law. These are recommended guidelines to follow in conducting  a safe mold remediation. Thus far, mold remediation seems to be following a similar trajectory as did asbestos. However, to date, only a handful of state have passed regulations on this topic.

In summary, the EPA Guidelines educate the reader on many of the same/similar facts as to the NYC Guidelines and other sources mentioned herein. The EPA Guidelines emphasize that water intrusions and the resulting damage should be addressed within 24-48 hours or mold growth can commence. It focuses on pre and post remediation sampling, conducting a risk assessment, following all steps of an EPA compliant remediation plan, and how to clean/dispose of various materials. The EPA Guidelines break mold remediation projects down by size: Small is less than 10 squre feet, medium is 10 to 100 square feet, and large is over 100 square feet. The larger the mold remediation zone the stricter the health and safety guidelines. This booklet published by the EPA has charts and a great deal of very useful information. It is a must read for mold remediators.

Other Safety and Health Regulations

 Mold remediators should be complying with OSHA regulations. This can be found at www.osha.gov. 1926 is the section pertaining to safety regulations. Conducting the appropriate and required safety training is essential. Topics such as eye, hand, foot, electrical, ladder, LO/TO, hazard communication, and others are very important. Respirator fit testing and training are essential in the mold remediation field. It is essential to understand what requirementsmust be met in the industry and job and to be able to show that you have met these requirements by taking the proper actions. This protects the company and its workers.



The key thing to remember regarding mold remediation is that for the majority of locations the EPA Guidelines are the key reference to utilize in conducting a compliant remediation. However, it is always important to check your state to see if it has recently passed any rules regarding mold remediation. Florida and Texas are two states that did pass regulations that must be complied with. Regarding states with mold remediation rules, it is common to also have educational requirements, licensing requirements, and fines for not conducting a remediation according to the rules of the state.

Basd on extensive research over decades, there is now consensus on how to properly conduct mold remediation. It is very important that mold remediators follow the EPA Guidelines and any applicable standards of his/her state because the liability of conducting a non-compliant mold remediation can be quite high. Discussion from newspaper articles and popular press have shown that mold remediation has been shaping up similarly to asbestos. For this reason and good professional practice, it is essential to follow the proper pre and post mold remediation testing and clearance procedures, set up compliant containment zones, HEPA vacuum, properly dispose of waste, and perform respirator fit testing for your remediation employees (and ensure they are trained in and wear the proper PPE).




Click the links below to download the latest EPA guidlines for mold remediation.