Mould (Mold) Remediation

[logojpg]Forensic Applications Consulting Technologies, Inc.

Mould Remediation, or just “Water Damage Restoration”?

Caoimhín P. Connell
Forensic Industrial Hygienist

1) Do I need a mould remediation company?

2) Who is qualified to do the work?

3) When do I need to address the situation?

4) How do I know when the work is completed?

These are some of the most common questions we receive concerning mould (mold) remediation (also called mould abatement). Almost daily our office receives phone calls from homeowners and property managers regarding reports of mould in their building or home. As a general rule, by the end of the conversation, the caller has usually learned:

1) The mould tests they had performed are invalid, and meaningless.

2) The health hazards associated with indoor moulds is not as serious as they were fooled into believing by their mould "expert."

3) As such, they probably don’t have a mould problem.

4) If they do have a problem, they probably don’t need to hire a legitimate mould assessment professional (such as an Industrial Hygienist) or any of the pseudo-“certified" mould inspectors.

5) They probably don’t need to spend any further time or money on the issue.

6) If remediation work is performed, the caller learns that they can probably do the work themselves, and can determine if it is completed correctly by conducting their own visual inspection.

Occasionally, of course, there are times, such as during catastrophic flooding, construction defects in multiple housing units and other times of overt fungal growth when professional expertise is needed. But, in the overwhelming vast majority of cases, the presence of mould in a structure is “inconsequential” and normal, everyday housekeeping is all that is necessary to address a mould "problem."

Usually, the homeowner’s concerns start with a frightening TV or newspaper report, or as a result of a home inspection during a real estate transaction. Usually, some poorly trained inspector, often bearing some kind of misleading title such as “Certified Mould Inspector” or “Certified Mould Professional” has collected some useless, misleading "screening samples" and has frightened the owner into thinking there is a problem.

Although occasionally, there is an actual water intrusion problem, and coincidentally, there is some mould growth, in the vast majority of cases, there is no mould problem, and no further action is needed.

Often, the project begins with complaints about illnesses, and indoor air quality and building related symptoms. Over the past 23 years, FACTs personnel have performed over 800 mould related projects – in just three of those cases, mould was determined to be a significant contributing factor. That is, 99.5% of the time, mould was not related to the indoor air quality complaints.

Mould is present in EVERY building, home, office, and work environment on the Planet Earth. There is no occupied space that is devoid of mould. Therefore, when someone performs mould “sampling” or mould “testing,” they will naturally find mould, and often the consultant will use the “laboratory report” as some kind of evidence of validation of their findings. In fact, the laboratory report has no validity beyond the intrinsic expertise of the consultant – and legitimate mould experts almost never collect samples. As we will discuss below, the exact same samples sent to different AIHA accredited laboratories is likely to produce wildly different results.

Since we know that mould is present in every structure, the objective of any mould assessment should be to determine the significance of the presence of mould. The characterization of the significance of the presence of the mould is the foundation for determining the most appropriate action regarding that presence. The most appropriate action will be a spectrum of responses incumbent on the characterization for each individual project or space, and will include everything from “no action required” to “removal of damaged materials.” Killing the mould is entirely unimportant and is never part of a legitimate mould remediation project.

All too often, charlatans and con-artists try to frighten property management companies or homeowners into unnecessarily complex and extremely expensive mould remediation (mold remediation) projects. Usually, such projects involve unnecessary “containments,” meaningless sampling and bogus testing, respiratory protection, anti-microbial agents and other unnecessary gimmicks. In fact, virtually none of these practices are ever warranted (except in extremely rare cases). This video shows mould colonization that was observed behind a mopboard following a water loss; and bids for remediation ranged from $20,000 to $57,000. In the video, an Industrial Hygienist with Forensic Applications, Inc. shows how to easily and safely remove the mould in under one minute for less than five dollars. No biocides, respirators, moon-suits, negative pressure machines, or “Post-remediation clearance testing” is required. Toxic mould consultants rely exclusively on fear to sell their services.

Video of Removal of "Toxic Mould"

The appropriateness of the response can be viewed with the intended end-point in mind, and then working toward that predetermined end point. So, any corrective actions (if at all), should be developed by first establishing the goals by which we will determine the adequacy of the corrective action(s).

No mould remediation project will ever remove all the mould from the remediated area. All mould remediation projects always leave some mould behind. The idea of leaving mould in buildings is not new, and it actually constitutes a standard industry decision making practice among legitimate mould experts. In 2001 the US EPA stated: 1

It is impossible to eliminate all mold and mold spores in the indoor environment.

Since it is impossible to remove all mould from any occupiable space, and all structures contain mould, and there is no evidence to demonstrate that “hidden” mould generally creates a problem; the legitimate remediation question becomes “How much mould should be removed and how much mould can be left behind before the area is ‘clean’?”

Contrary to what the “Mould is Gold” industry would like to promote, according to the American Industrial Hygiene Association in Judging the Effectiveness of Remediation: 2

… the goal of mold remediation is to return material surfaces to a satisfactory condition. The goal is not to produce a near-sterile or abiotic condition.

The most recent document on dampness, moulds and indoor air is the globally accepted World Health Organization guidelines for indoor air quality: dampness and mould. The WHO document specifically addresses remediation; and specifically, WHO stresses remediation of moisture – not the elimination of mould. The WHO document recognizes that two primary factors control the decision making process in remediation of mould:

1) It is impossible to eliminate mould from the living space of humans

2) Whereas damp, (not mould) may have a causal association with adverse health effects, indoor mould, as commonly seen, has not been shown to have a causal association with adverse health effects.

In Section 3.9 of the WHO document, the WHO explicitly recognizes that moisture control, not the removal of building materials is the main method for controlling exposure to indoor contaminants. Throughout the WHO document, the organization stresses that mould has not been shown to be the problem, but rather, it is the entire combined problems associated with dampness. As such, the World Health Organization does not stress or advocate mould remediation, but rather damp remediation, control and prevention.

What Should Be Included?
Since it is patently infeasible to eliminate mould from buildings, what should be included and how should it be performed?

Mould remediation, in general, can be summed up in one sentence: “Fix the moisture issue, and restore building materials to an acceptable condition.”

WHO recognizes that it must necessarily be acceptable to leave mould in buildings. The concept of leaving contaminated materials in place is not only consistent with WHO guidelines, as already mentioned, it forms a central part of the decision making process. The World Health Organization explicitly states: 3

The main challenge of field investigations is to decide which contaminated materials should be removed and which can be left in building assemblies with a reasonably low risk of indoor climate problems.

In 2004, The National Academies Press issued an Institute of Medicine (IOM) 4 study that reflects both state of the art and overall consensus positions. The IOM committee found that there was insufficient evidence to demonstrate a causal association between the presence of moulds and many of the commonly reported health effects.

Although the 2004 IOM document does not address remediation in any great detail, it does state that future research should be done to determine whether “hidden mould” should even be addressed at all during remediation. As reported in the IOM document, visible mould had only been weakly associated with measured concentrations of fungi. Nevertheless, the IOM concluded that:

Visible mold, although not a precise measure of exposure, is probably the clearest risk indicator for potential exposure.

At FACTs, we define “fungal problems” as falling into one of four categories:

1) The fungus constitutes an health hazard
2) The fungus compromises structural integrity
3) The fungus compromises aesthetic qualities
4) The fungus compromises market value

If the presence of the fungi does not fit into one of these four categories, then, in the opinion of FACTs, one does not have a mould problem, and therefore, no remediation is necessary. If on the other hand, the fungi do fit into one of these categories, a remediation plan commensurate with that category and commensurate with the severity of the category should be developed.

The four categories are not necessarily mutually exclusive, and each exhibits a continuum of severity which must be considered during any remediation. Where a mould is present that does not meet one of these criteria, we refer to the presence of the mould as “inconsequential.”

The first two categories may be evaluated objectively, but the last two are subjective in nature. As industrial hygienists, FACTs personnel may competently address the first two issues. The third and fourth categories, however, are subjective and irrational.

We have adequately addressed the health issues associated with indoor mould here.

In general, and often times in spite of visual appearances, the presence of mould does not significantly increase exposures to mould. That is, just because the mould is present, doesn’t mean there is an exposure to that mould. If there is no increase in exposure to the moulds that are present, there is no increase in dose received, and there can be no quantifiable health problems.

A long standing myth amongst poorly trained consultants, such as “Certified Mould Inspectors” is that an increase in mould growth in a home or structure will result in an increase in airborne spores and an increase in exposure. However, this is a myth, and (for very good reasons), it is not uncommon to find very low airborne spore concentrations coming from structures with very large fungal blooms and very high airborne spore concentrations in properties with no mould problems at all.

Hidden Mould
We frequently hear complaints from contractors who claim that they must perform air sampling to identify “hidden” mould. The “hidden mould” argument is mostly an excuse to begin a fishing expedition into the client’s walls (and wallet) and is virtually never based in sound science. Generally, searches for hidden mould in a structure are not considered acceptable practice:

Finding hidden mold is difficult and expensive. An exhaustive search is justified only if there are good reasons. If there are no smells (sic), no complaints, and no indications of significant moisture damage, we can be reasonably sure that there is no problem and no reason for further investigation. 4a

This is reflected by other AIHA authors: 4b

Special requirements for remediation of hidden mold are triggered only when there is a reason to investigate more aggressively.

In our experience, we have only encountered a single project (out of over 600 mould related projects), where using air monitoring to track down hidden mould became a necessity. On the flip side, we have seen massive amounts of money needlessly spent on trying to find “hidden” mould that was presumed to exist in a structure based on a “mould consultant’s” junk science “air tests.” In fact, the presence of high spore counts in normal buildings is simply a normal occurrence, depending on the circumstances.

For example in one case in which we were involved, extremely elevated concentrations of Stachybotrys was observed in the air samples of a consultant involved in a water damage restoration project. The consultant’s air tests revealed that there was over 1,000 CFUs/m3 of Stachybotrys spores in the indoor air of the building. A massive witch-hunt was initiated to find the hidden mould; walls were removed, ceilings opened, and enormous effort (and money) was spent trying to find this insidious danger lurking somewhere in the building. Eventually, the mould consultant gave up and decided legitimate expertise was needed to find the mould; our personnel became involved.

Within seconds upon entering the structure, we had solved the mystery – and we did it without opening a single wall, or collecting a single sample. Upon entry into the building, we saw a air sampling device running in the front hallway at the entrance of the structure. In the same location, we observed several stacks of normal, clean, drywall sheets that were being brought into the building as part of the renovation activities. We pointed out that that the paper of drywall is loaded with Stachybotrys spores and by handling the nice clean drywall, the surfaces were being disturbed, and releasing the spores into the air and those were the spores being detected by the air monitoring device in the vicinity. Mystery solved.

To date, there is no evidence that the presence of such “hidden” mould in anyway results in a significant exposure, or degrades the indoor air. In general regarding the mere presence of mould: 5

However, removal based on the mere fact of its presence, or based on nonspecific symptoms that are not related to mold exposure, is often not appropriate.

Similarly, other notable researchers have also concluded the same: 6

…it is reasonable to infer that small amounts of mold enclosed in walls, floors, or ceilings will not have a large impact on the indoor air quality.

Researchers with the Wisconsin Department of Health and Family Services investigated the relationship between mould on surfaces of oriented strand board siding and mould levels inside the home; the results of the study indicated mould levels in the affected homes were not significantly higher than those measured in non-exposed homes. 7 Studies and investigations performed by FACTs, consistent with other researchers, have not observed a correlation between mould hidden in walls and a degradation of indoor air quality or a correlation between mould hidden in walls and an increase in spore counts in occupied spaces. Regarding hidden moulds, the American Industrial Hygiene Association Field Guide for the Determination of Biological Contaminants in Environmental Samples, explicitly states: 8

In order for airborne microbial contaminants to be dispersed from the amplification sites to other locations, there must be a significant driving force present.

Elsewhere, the AIHA states: 9

Not all hidden mold growth results in fungal exposure; each situation represents a unique combination of proximity, pressure relationships, and other factors that determine potential exposures.

So, even if mould is present in wall cavities, there are no forces known to reasonably exist in homes with sufficient force to result in significantly dislodging colonized mould from surfaces. We have seen structures with tens of thousands of square feet of mould hidden in walls cavities, whose air tests have revealed no increase in spore counts in the occupied space. If it is not a problem, (i.e. you can’t see it, and you are not exposed to it) why waste the time and effort to address a non-issue?

In a normal, healthy, home or office building, we would expect the structure to contain several billions of mould spores; and to some extent, evidence of some vegetative masses (mould colonization), at least to some degree somewhere in the structure; that position is well established science and reflects that which is found in accepted literature. 10 The 2009 document from the World Health Organization11 states:

Fungi are therefore found in the dust and surfaces of every house, including those with no problems with damp.

In twenty years, after over 600 mould assessments, we have only encountered three cases wherein the mould constituted an health concern; and only two cases where the mould responsible for the health problems was “hidden.” (In fact, in one of those cases, the “hidden” mould was actually in plain sight, but not recognized for what it was.)

Structural Integrity
In general, the presence of moulds do not compromise the structural integrity of building materials. Occasionally, the mould may be so heavy that the surface of the substrate material is marred or pitted, and needs to be removed – but that is the exception, not the rule.

Frequently a “certified mould inspector” will confuse a mould with a wood destroying fungus. Wood destroying fungi such as the brown-rot fungus Serpula lacrymans and Fibroporia vaillantii or the common "cellar fungus” Coniophora can cause catastrophic structural failure in only a matter of a couple of years. The wood destroying fungi are outside the context of this discussion.

Therefore, in general, often times, the affected building materials can merely be HEPA vacuumed or wiped with a damp cloth and restored to an acceptable condition.

Aesthetic Qualities
In general, mould is unsightly, and most building occupants don’t want to see mould growing on surfaces in the occupied space. However, mould that has colonized building materials surfaces in attics, wall cavities, crawlspaces, and other inaccessible areas is not readily visible, does not constitute an exposure issue and won’t compromise structural integrity. As such, unless there is some compelling reason to address these kinds of colonization, then such colonization is largely inconsequential. Very often, after the moisture issue has been addressed, the colonized surface can be merely wiped with a cloth, or HEPA vacuumed to restore the surface to an acceptable condition. Although many “toxic mould” restoration companies may draw a gasp of collective horror at the concept, in many cases, the colonized surfaces can be merely repainted.

Market Value
Market value is an irrational matrix of parameters. The issue of how moulds may impact market value is simply too large to handle in a brief discussion such as this.

However, FACTs has been involved in cases where some relocations companies have a “zero-tolerance” policy on Stachybotrys and have written policies that state that they will not purchase an house that contains Stachybotrys. Considering that all houses contain Stachybotrys, this written policy will ultimately result in a law suit that the relocation company will lose.

Biocides and Fungicides
The use of biocides, bleach, fungicides and/or other disinfectants should be prohibited on mould remediation projects. In the mould remediation business there is a prevailing myth surrounding the use of fungicides and disinfectants. In particular, the prevailing myth is that their use is necessary. In fact, there is no valid scientific evidence that the application of bleach, fungicides or disinfectants has any benefit during a mould remediation project. If the mould remediation project is performed correctly, the mould will not come back even if a fungicide is not used – if the water intrusion is not corrected, the mould will come back, even if a fungicide is used. Frequently, mould remediation companies claim that because their product is “EPA Registered” that proves that the product is effective and appropriate for the application proposed by the remediation company. This is not true, and EPA Registration is not a carte blanc statement of efficacy or appropriateness for a general application in a specific situation. In fact, the EPA strongly recommends against using disinfectants such as bleach during mould remediation projects. 12

The use of a biocide, such as chlorine bleach, is not recommended as a routine practice during mold remediation, although there may be instances where professional judgment may indicate its use (for example, when immuno-compromised individuals are present). In most cases, it is not possible or desirable to sterilize an area, as a background level of mold spores comparable to the level in outside air will persist. However, the spores in the ambient air will not cause further problems if the moisture level in the building has been corrected.

Nobody denies that fungicides kill moulds. What is being argued is that fungicides have no known or provable appropriate application in moisture remediation and mould remediation projects.

Peer reviewed articles13,14 have demonstrated that a variety of disinfectants and follow-up treatments on wallboard that had been colonized with a variety of moulds were not effective. The disinfectants included amines, stabilized high-oxygen solutions, chlorine dioxide solutions, etc. In every case, mould growth returned to wet wallboard sections that had been treated with each of the disinfectants.

Publications from the American Industrial Hygiene Association recommend against the use of fungicides during mould remediation projects, and the World Health Organization recommends against the use of fungicides during mould remediation projects. 15 FACTs has been writing mould remediation scopes-of-work for almost 20 years. In all that time, we have automatically prohibited the use of all disinfectants, biostats and fungicides. In 20 years, we have not seen a single project where the moisture problem was properly addressed and mould returned.

FACTs is of the opinion that ALL fungicides and disinfectants are virtually worthless in the realm of indoor moulds and the indoor mould remediation issue. The applications of such products is almost exclusively within the realm of the “toxic mould is gold” industry, not within the legitimate water restoration/mould abatement industry.

Many paints normally contain some kind of disinfectant, and many paints normally have some kind of sealant properties. These kinds of products are useful and should be permitted, if they would normally be used for any other kind of surface, even where mould growth was not identified. A professional painter should be consulted to determine the most appropriate products for application at each location.

Another trick of the mould con-man is the application of ozone. FACTs has been involved in several cases where the “toxic mould” charlatan has duped someone into filling the house with ozone. Ozone treatments are almost exclusively the hallmark of the snake-oil sales man and fraud. In addition to being particularly toxic to humans, and capable of damaging household items, ozone has no beneficial effect during mould remediation, over and above normal, appropriate remediation practices.

Occasionally, the mould trickster will try to frighten the building owner with nonsensical assertions that dangerous mycotoxins will remain unless the property is ozonated – there is no science or objective data to support this argument. There is no objective data or scientific support that can be drawn upon to demonstrate that ozone has ever been successfully used to reduce dangerous levels of mycotoxins to safe levels. If your mould consultant uses or has ever engaged in the use of ozone as a mould remediation practice, this should serve as a warning to find another, properly trained, remediation consultant.

Encapsulants and Sealants
The use of encapsulants and sealants should be explicitly prohibited.

Commonly, the “Toxic Mould is Gold” industry attempts to sell property owners on various magic sealants and encapsulants. These products can adversely affect the hygric buffering capacity of the structure by reducing the hygric buffering capacity. The net result is that frequently a mould problem will occur in a structure where these materials have been used, where otherwise no mould problem would have occurred.

A professional painter should be consulted to determine the best products for the desired finish. Products that incidentally happen to contain high vehicle paints or incidentally happen to exhibit “barrier” effects should not be prohibited.

How do we know that the work has been completed?
Unless the moisture problem that facilitated the mould growth has been addressed, the work has not been completed. Once the moisture problem has been addressed, and the building materials have been restored to a dry state, the determination of completion is relatively simple.

Generally speaking, those individuals involved in collecting “clearance samples” are engaged in junk science, and are not able to actually defend the data with confidence. In our experience, only consultants with no legitimate knowledge in indoor moulds or aerobiology perform such sampling, which is a throwback from those individuals who are engaged in asbestos and lead abatement.

A recent (March, 2011) draft NIOSH document 15a addresses the issue thusly:

Building consultants often recommend and perform “clearance” air sampling after remediation work has been completed in an attempt to demonstrate that the building is safe for occupants. However, NIOSH does not recommend this practice, as there is no scientific basis for the use of air sampling for this purpose.

This is not a “new” perspective, but rather, this has been the central opinion of the knowledgeable body of science for approximately 20 years. We typically only see “Certified Mold Inspectors” (CMIs) and other poorly trained individuals performing these misleading sampling schemes.

Like the World Health Organization, US EPA, and the US Centers for Disease Control, the AIHA concurs that, similar to an initial assessment, a visual assessment, by a cognizant authority, will virtually always be adequate to determine the adequacy of remediation or corrective actions.

The aforementioned AIHA publication cites the Guidelines on Assessment and Remediation of Fungi in Indoor Environment; (New York City Department of Health, Bureau of Environmental & Occupational Disease Epidemiology, 2000) and Health Canada, and the Canadian Construction Association Mould Guidelines and states:

The primary objective of mold remediation, based on guidelines published between 199316 and 200417,18 is to remove visible mold growth and return material surfaces to a satisfactory condition.

The 2008 AIHA document continues with:

Current mold remediation guidelines support the concept that project success depends on verification primarily through inspection that visible mold growth and associated debris and dust were appropriately removed. 19,20, 21

In general, the completion of a mould remediation project can be adequately determined with a moisture meter and a visual inspection. Air “testing” or surface “testing” provides no beneficial information over and above that that can be provided by a visual inspection by a legitimate mould expert.

Essentially, the only mould consultants who think a laboratory report has some intrinsic value, are those who don’t understand aerobiology. What virtually every certified mould inspector does not know is that their laboratory results are not reproducible by another laboratory.

If a “mould consultant” were to collect ten air samples from a property to “clear” the project, and sent those samples to an AIHA Accredited Laboratory for analysis, but didn’t like the analytical results, that consultant could have the samples sent to another AIHA accredited laboratory and receive a new laboratory report with completely different results. If the consultant was happy with those results, he could use them, or, otherwise, he could send the same samples to another and yet another laboratory until he finally received results he liked. Those results would be in the form of a legitimate laboratory report from an accredited laboratory.

This is because the interlaboratory variability is huge, and the exact same samples sent to different accredited laboratories can result in analytical results that span greater than an order of magnitude difference. 20a

It has been known for over 20 years, that spore counting is an subjective art and laboratories cannot reliably analyze the samples to within a reasonable degree of confidence. One study from 2011,20a revealed that only 75% of the accredited laboratories could consistently identify Cladosporium, the most common mould in the environment. Furthermore, Aspergillus/Penicillium-like spores, the most common mould category related to water intrusion, were identified by only 50% of the accredited laboratories.

The authors concluded:

This research reveals that precision of spore trap analyses, even among laboratories involved with analytical proficiency testing, lack precision and should be interpreted with caution.

In every case, involving FACTs personnel, without exception, where we have reviewed “clearance” air monitoring, and “clearance” testing, we have found the following:

1) The “testing” was based on junk science.

2) The "data" from the "testing" was meaningless numbers, "mould scores," ERMI score,20b colorful graphs and bars and fancy Latin names but was otherwise not interpretable.

3) The "data" could not be used to “find hidden mould.”

4) The results of the "testing" did not provide any reliable information that could be used for decision making.

5) The results of the "testing" were entirely incapable of being used to determine adequacy of completion.

6) The "tests" did not provide any information that wasn’t already available by a properly conducted visual inspection.

7) The "testing" invariably consists of a nonsensical and untenable indoor-to-outdoor comparison.

8) The "test" did not conform to any known data quality objectives.

9) In light of the above, the "testing" was entirely a waste of money.

It is recognized that in some very special cases, for very unusual circumstances, legitimate testing may be needed. However, legitimate testing is very expensive, and almost never performed. The Colorado Department of Public Health and the Environment, Division of Disease Control and Environmental Epidemiology, has made a statement about air testing that is reflected by most other States. The Colorado Department of Health reports 21a,

Reliable air sampling for mold can be expensive and requires expertise and equipment that is not available to the general public.

Legitimate air sampling, for a single story, single family residence would be approximately $2,500 for each day needed, and approximately three days would be needed, (depending on the Industrial Hygienist’s data quality objectives). In this manner, the testing alone could exceed the cost of the remediation, and still not provide any better data than derived from a properly conducted visual inspection. In general, in our experience, the only consultants who regularly perform such “clearance testing” are those who have no legitimate knowledge or expertise in indoor moulds. They perform junk science “testing” since they gain their entire credibility from a fancy looking laboratory report full of mysterious names and numbers; but a report they cannot interpret, and know the client can’t interpret. Not surprising, we have seen such testing performed mostly by “certified” individuals who have “credentials” such as CMRI, CMI and other forms of alphabet soup after their names.

The aforementioned AIHA publication concludes with:

A difficulty associated with using air sampling as the primary means of achieving final clearance is the absence of numerical guidelines for airborne fungi and for bioaerosols in general. 22, 23, 24 IOM25 concluded that, although there is an association between respiratory health effects and dampness, the exact causal agents of irritation and respiratory disease are obscure. Thus, from a health effects viewpoint it remains uncertain whether the EHS investigator should sample during final clearance for total spores, culturable spores, hyphal fragments, specific allergens, glucans, endotoxins, or other agents.

The practice of conducting a mitigation based on visual inspections, in the absence of other subjective or objective indicators is not new. The AIHA states that:

… the basic practice for identifying mould damage and the process of remediation has been stable since the appearance of the New York City Guidelines in1993 and all cognizant authorities since then have endorsed those approaches.

Professional judgment is stressed by other authors as the key factor in understanding completion of a moisture remediation project:

There is general agreement that professional judgment should play a key part in both assessment and remediation. 26 … Typically professional judgment is employed to determine the most effective endpoint for a specific project. 27

Therefore, consistent with scientifically valid, global practices and procedures, FACTs begins the recommendations of establishing appropriate remediation activities by recognizing the end point is to address: 1) moisture, and 2) visible vegetative masses of mould growth.

Explicit here, with regard to all of our recommendations, is the stated goal that the source of moisture that facilitated the growth of mould has been identified and corrected.

“Remediation” therefore is primarily to return the surfaces of the occupied spaces to an acceptable visible condition. In some cases, the structural integrity of the building materials has been severely compromised due to water damage. In those cases, the building materials should be removed.

Who is Qualified to Do the Work?
In general, any contractor that is competent in performing building renovations, fire and smoke or water damage restoration is adequately trained to perform “mould remediation” activities.

A prevailing myth is that specialized equipment, specialized training, and special protections must be employed. Although this may be the case for large multi-housing units, or large commercial facilities with a catastrophic water loss issue, for the most part, general maintenance personnel, and renovation contractors already have sufficient knowledge and training to perform the necessary work.

Mould Assessment Personnel
In general, personnel bearing alphabet soup after their names (CMI, CRMI) and who claim to be “certified” are the least desirable contractors, since most of their “training” has been based on myth, fear and hyperbole. Such contractors virtually never possess legitimate science-based training, and instead rely on pseudo standards and erroneous but commonly employed techniques (nonsensical testing and sampling and the prescription of asbestos abatement style corrective actions.) Because of the unscientific hyperbole generated by media, a plethora of self-certified “certified mould remediators” and “certified mould inspectors” have entered the newly recognized market feeding off the public’s fear and providing wildly inaccurate and unscientific consultation regarding mould, its occurrence, remediation, assessment and significance of human exposures. 28 Misleading sampling protocols, pseudoscientific “laboratories” and untrained (but certified) “mould inspectors” stand ready to separate frightened home owners/property managers from their money, in return for nonsensical and meaningless “mould tests” and unnecessary, but expensive mould remediation.

Many “mould inspectors” refer to themselves as “certified mould inspectors” or “environmental scientists” or similar meaningless terms; however, although recently two states, have passed state regulations that inappropriately place misguided confidence in such personnel, there are no valid or recognized certifications for “mould inspectors” in other states.

Essentially, anyone with a computer may merely declare themselves as “certified” and then print out their own “certificate” to prove their “certification.” Furthermore, although there are several “mould remediation” companies on the internet that identify themselves as “licensed mould remediators,” most states do not have any such licensing requirements. (It is interesting to note that these are also the companies that usually discuss the dangers of “toxic mould.”) In our experience, virtually none of the “certified mould inspectors” have legitimate specialized knowledge in mould, mycology, toxicology or sampling theory. In our experience, virtually all “certified mould remediation” companies similarly have no legitimate specialized knowledge in mould, mycology or toxicology, but tend to attempt to make mould remediation appear to be something much more complex, dangerous, and costly than necessary.

FACTs has never encountered a legitimate or valid indoor assessment of moulds by individuals bearing the initials “CMI” or “CMRI” or any of the many other “credentials” used by these practitioners.

Industrial Hygienists
For many decades, the practice of Industrial Hygiene has been the traditional profession that deals with human exposure issues. Over the course of the last two decades, the scientific role of the Industrial Hygienist has expanded beyond the traditional workplace, and the Industrial Hygienist, because of our role in human exposure assessments, hazard assessments, and risk reduction, has become the leading recognized authoritative profession for indoor mould assessments. Issues surrounding the assessment and control of residential biological assessments, indoor air contaminants, their generation, migration and effects, are squarely within both the defined role and globally accepted realm of the professional Industrial Hygienist. Nowhere in most state regulations, scientific or medical literature do we find credible references to “Certified Mold Remediators,” “Certified Mold Inspectors,” “CRMIs,” “CRIs” or any of the other common titles used by mould remediators.

By contrast, the U.S. Institute of Medicine specifically identifies the Industrial Hygienist as the professional of choice for individual patients with suspected indoor-related health problems. 29 Nowhere in the IOM report or within the U.S. Institute of Medicine is a “CMRI” or other pseudo certified mould individual identified, recognized or even mentioned.

Similarly, the recent World Health Organization report30 specifically refers to standard Industrial Hygiene technical manuals for in-depth discussions for sampling and assessment; the majority of US States, and the WHO does not recognize or even mention a “CMRI” or any of the other instant mould “certifications.”

The US Environmental Protection Agency31 specifically recommends the field of Industrial Hygiene for consultation, sampling and assessment in schools and commercial buildings; we are not aware of any EPA document that recognizes “CMRI” or other mould “certifications.” The US Centers for Disease Control32 specifically recommends that homeowners and business owners alike follow the recommendation and guidelines of the American Conference of Governmental Industrial Hygienists in mould related issues.

Other authors33 charitably recognize the poor training of “mould consultants” and the important role of the Industrial Hygienist in the decision making process to bring a sense of evidence based balance to the project.

A current problem in North America is the involvement of persons without appropriate training and experience in the management of mold and moisture problems. Such individuals often have difficulty in distinguishing small from large problems and are often criticized for applying solutions not matched to problem size. In such situations, public health or financial resources may be sacrificed.

A good industrial hygienist knows when his or her expertise is necessary and counsels clients about efficient use of resources. Society as a whole looses when efforts are not directed where they do the most good at the least cost. For this reason, it is important that industrial hygienists balance all competing interests in resolving mold and moisture issues.

However, this is not to say that all Industrial Hygienists are equal and have competency in mould assessments. Recently, many Industrial Hygienists, have violated our professional code of ethics and engage in services for which they have no known expertise. In these cases, the consultant is no better than any other poorly trained CMRI or CMI.


1 Mold Remediation in Schools and Commercial Buildings U.S. Environmental Protection Agency (EPA 402-K-01-001, March 2001 updated June 25, 2001)

2 Morey PR, Prezant B, Weekes D, Judging the Effectiveness of Remediation (Section 18.5.3) Recognition, Evaluation, and Control of Indoor Mold, Prezant E; Weekes, DM; Miller JD (Eds.) American Industrial Hygiene Association 2008

3 World Health Organization Guidelines For Indoor Air Quality Dampness And Mould (ISBN 798 92 890 4168 3) WHO Regional Office for Europe, Scherfigsvej 8, DK-2100 Copenhagen Ø, Denmark, July 2009

4 Institute of Medicine (IOM), National Academy of Sciences Damp Indoor Spaces and Health, Section 3, EXPOSURE ASSESSMENT Washington DC, IOM, 2004

4a D’Andrea CP, Prezant B, Accountability of the Industrial Hygienist: Constituencies and Co-Investigators (Section 3.1.1) Recognition, Evaluation, and Control of Indoor Mold, Prezant E; Weekes, DM; Miller JD (Eds.) American Industrial Hygiene Association 2008

4b Reynolds SJ, Baker R, Haisley P, Remediation: Procedural Considerations (Section 17.5.1) Recognition, Evaluation, and Control of Indoor Mold, Prezant E; Weekes, DM; Miller JD (Eds.) American Industrial Hygiene Association 2008

5 Burge, H. Can Mold Be Safely Left Inside Walls? The Environmental Reporter, Vol. 3, No. 11, November 2005

6 Robbins C, Morrell J; Mold, Housing and Wood (Article prepared for the Western Wood Products Association), Jan 2006.

7 Daggett DA, Chamberlain M, Smith W. Effects of Exterior Decay and Mold on Indoor Mold and Air Quality. Proceedings of the 2nd Annual Conference on Durability and Disaster Mitigation: November 6, 2000; Madison, WI (Cited by Robbins as referenced here, but not reviewed by this author (Connell))

8 American Industrial Hygiene Association Field Guide for the Determination of Biological Contaminants in Environmental Samples, Second Ed., (Hung, Miller, and Dillon, Eds., 2005 ISBN 1-931504-62-8)

9 On-Site Considerations (Chapter 6) Recognition, Evaluation, and Control of Indoor Mold, Prezant E; Weekes, DM; Miller JD (Eds.) American Industrial Hygiene Association 2008

10 Recognition, Evaluation and Control of Indoor Mold (Prezant B, Weekes DM, Miller JD – Editors), American Industrial Hygiene Association, August 2008)

11 Damp, Indoor Spaces and Health World Health Organization Guidelines For Indoor Air Quality Dampness And Mould (ISBN 798 92 890 4168 3), 2009 WHO Regional Office for Europe, Scherfigsvej 8, DK-2100 Copenhagen Ø, Denmark

12 US EPA “Mold Remediation in Schools and Commercial Buildings” (2001)

13 Price DL; Ahearn DG; Sanitation of Wallboard Colonized with Stachybotrys chartarum; Current Microbiology Vol 39 (1999), p.21-26

14 Recognition, Evaluation, and Control of Indoor Mold, Prezant E; Weekes, DM; Miller JD (Eds.) American Industrial Hygiene Association 2008

15 World Health Organization Guidelines For Indoor Air Quality Dampness And Mould (ISBN 798 92 890 4168 3) WHO Regional Office for Europe, Scherfigsvej 8, DK-2100 Copenhagen Ø, Denmark, July 2009

15a Preventing Occupational Respiratory Disease from Exposures caused by Dampness in Office Buildings, Schools, and Other Nonindustrial Buildings, DRAFT March 30, 2011

16 Guidelines on Assessment and Remediation of Fungi in Indoor Environment; New York City Department of Health, Bureau of Environmental & Occupational Disease Epidemiology, 2000

17 Health Canada: Fungal Contamination in Public Buildings: Health Effects and Investigation Methods. Health Canada, Ottawa, ON (2004)

18 Canadian Construction Association; Mould Guidelines for the Canadian Construction Industry; CCA; Ottawa, ON; 2004

19 Health Canada: Fungal Contamination in Public Buildings: Health Effects and Investigation Methods. Health Canada, Ottawa, ON (2004)

20 Canadian Construction Association; Mould Guidelines for the Canadian Construction Industry; CCA; Ottawa, ON; 2004

20a Robertson LD, et al A multi-laboratory comparative study of spore trap analyses Mycologia, 103(1), 2011, pp. 226–231. DOI: 10.3852/10-017

20b The "Environmental Relative Moldiness Index" is an interpretive score developed by one person in the EPA. The ERMI is not accepted by the body of science as a definitive tool, and has never been validated or demonstrated to be conclusive. The ERMI has never been shown to be more reliable than a visual inspection.

21 Guidelines on Assessment and Remediation of Fungi in Indoor Environment; New York City Department of Health, Bureau of Environmental & Occupational Disease Epidemiology, 2000

21a Colorado Department of Public Health and Environment, Mold Information Sheet, August 2002

22 US Environmental Protection Agency, in its booklet “Mold Remediation in Schools and Commercial Buildings, EPA 402-K-01-001 March 2001 (updated 6/25/01)

23 American Conference of Governmental Industrial Hygienists, (ACGIH), Data Interpretation, In Bioaerosols: Assessment and Control, Macher J (Ed), Cincinnati OH, 1999

24 Storey E; et al Guidance for Clinicians on the Recognition and Management of Health Effects Related to Mold Exposure and Moisture Indoors, Farmington CT, University of Conn. Health Center, 2004

25 Institute of Medicine (IOM) Damp Indoor Spaces and Health, DC, IOM, 2004

26 Kolb L, McNeel SV, Guidance for Assessment and Remediation of Indoor Microbial Growth; Section 2.5) Recognition, Evaluation, and Control of Indoor Mold,, Prezant E; Weekes, DM; Miller JD (Eds.) American Industrial Hygiene Association 2008

27 Kolb L, McNeel SV, Guidance for Assessment and Remediation of Indoor Microbial Growth; Section 2.5.1) Recognition, Evaluation, and Control of Indoor Mold, Prezant E; Weekes, DM; Miller JD (Eds.) American Industrial Hygiene Association 2008

28 Bardana, E.J. The environment and allergic disease: Annals of Allergy Asthma Immunology 2001; 87(Supp l):52-56

29 Institute of Medicine (IOM), National Academy of Sciences Damp Indoor Spaces and Health, Section 3, EXPOSURE ASSESSMENT Washington DC, IOM, 2004

30 World Health Organization Guidelines For Indoor Air Quality Dampness And Mould (ISBN 798 92 890 4168 3) WHO Regional Office for Europe, Scherfigsvej 8, DK-2100 Copenhagen Ø, Denmark, July 2009

31 Mold Remediation in Schools and Commercial Building EPA 402-K-01-001 March 2001 (updated 6/25/01)

32 MOLD: Prevention Strategies and Possible Health Effects in the Aftermath of Hurricanes Katrina and Rita, The CDC Mold Work Group, National Center for Environmental Health, National Center for Infectious Diseases, National Institute for Occupational Safety and Health. Centers for Disease Control and Prevention October 2005

33 D’Andrea CP, Prezant B, Accountability of the Industrial Hygienist: Constituencies and Co-Investigators (Section 3.1.1) Recognition, Evaluation, and Control of Indoor Mold, Prezant E; Weekes, DM; Miller JD (Eds.) American Industrial Hygiene Association 2008

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