Digest 4 - Re: Was Re: ASTM Conference on Mold - now Tony on GAO

[Guest guest]

Hi, Tony:

As Editor of the AIHA Green Book, I have had the opportunity to hear

from the AIHA's legal counsel the issue of 'No Formal' policy vs. 'de

facto' policy. In his legal view, the AIHA publications on a

particular issue (such as mold) are considered 'de facto' AIHA

policies because the review process of the publications includes

other Technical Committees as well as the AIHA Board of Directors.

Technical guidance on an issue like mold, when it is subject to the

rigorous review that AIHA undertakes BEFORE it publishes, does lend

itself to the creation of 'de facto' policy for the association.

More AIHA publication quotes on this matter:

Field Guide for the Determination of Biological Contaminants

(1996): 'Interpretation of the results of biocontaminant sampling is

confounded by the lack of universally accepted exposure limits or

guidelines. ACGIH has in fact stated that the development of

exposure guidelines based on the enumeration of viable or total

(viable plus nonviable) fungi or bacteria in air is not feasible.'

Final Report of AIHA Microbial Growth Task Force

(2001): 'Occupational exposure limits or guidelines do not exist for

microorganisms or agents derived from these organisms, so that

comparisions to airborne levels are not interpretable'.

Assessment, Remediation, and Post-Remediation Verification of Mold in

Buildings (AIHA Guideline 2-2004): 'AIHA doesn't believe it is

currently possible to define, or set, a single occupational exposure

level for mold, due largely to the current state of scientific study

in this area. AIHA also does not believe it's possible for any

single study to accurately delineate levels of exposure to mold or

mold by-products that may be harmful to human health'.

Recognition, Evaluation, and Control of Indoor Mold (The Green Book)

(2008): 'Most epidemiological studies have not been able to find an

association between the concentration of airborne fungal spores and

the health effects except under a few circumstances outside the scope

of this publication. This is the view of the U.S. National Academy

of Sciences panel on asthma, Health Canada, the World Health

Organization, and AIHA, among others'.

All in all, as you can see, AIHA has been remarkably consistent on

this issue. However, it is always 'possible' that there may be a new

sampling method for airborne mold spores that will be scientifically

valid, and that can be related by scientists to the health effects

experienced by the building's occupants. But over the last dozen

years, no such sampling or analytical method has come to light.

Perhaps it will come to light in the future.

Don

>

> Hey Don:

>

> 1. Regarding:

>

> " guidelines for indoor mold exposure levels is difficult and may not

> be practical.' "

>

> Response:

>

> Yep, that clears up AIHA since " NOT POSSIBLE " (by Sharon's

interpretation)

> is not the same as " DIFFICULT " and " MAY NOT BE PRACTICAL " (in the

AIHA

> webpage).

>

> 2. Regarding:

>

> " In effect, they become AIHA's policy statement on mold,

> since there is no 'formal' AIHA position statement on mold. "

>

> Response:

>

> Maybe you should ask AIHA if No Formal Policy equates to a de facto

policy.

> I believe AIHA counsel would likely disagree.

>

>

> Tony

>

> Ps Technical Guidance does not necessarily equal Policy.

>

>

> ....................................................................

...

> " Tony " Havics, CHMM, CIH, PE

> pH2, LLC

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