Re: Arkansas mold law passed in April

[Guest guest]

I cant get my pdf working, was there a big problem in ar. with fly by night mold

investigators? I kind of fiqured that from something else i was looking into.

>

> On April 2, 2009, Arkansas passed a new law about licensing of mold

investigators, etc.

>

> http://www.arkleg.state.ar.us/assembly/2009/R/Acts/Act1467.pdf

>

> Another step in the right direction.

>

>

>

>

>

>

[Guest guest]

Thanks for posting the link to the Arkansas law. I agree that this

provides several steps in the right direction. However, there is a

very troubling provision because they use the word " or " instead of

" and. "

(2) A person licensed under this chapter shall not confirm or

25 refute the presence of mold in a residential or commercial

building without

26 having first:

27 (A) Performed an onsite investigation of the premises

28 conducted under the best practices set forth in the guidelines

established by

29 the American Conference of Governmental Industrial Hygienists

and the

30 American Industrial Hygiene Association, as they existed on

January 1, 2009;

31 or

32 ( If air samples or bulk samples of any kind are taken

33 from a residence or commercial building for culture or

appropriate

34 examination by a commercial laboratory, the analysis shall be

performed by a

35 laboratory accredited by and actively participating in the

American

36 Industrial Hygiene Association’s Environmental Microbiology

Laboratory

1 Accreditation Program.

As written, Confirmation or refuting mold can be determined either

with an assessment by a licensed inspector -or- by an accredited

lab with samples from a licensed inspector.

It is not ethical or even reasonable for a lab to intepret the

results. They can only provide the numbers based on their analysis

of the samples as sent. They have no idea where the samples were

taken or if they were collected properly. So they have no way of

knowing if a sample is from a contaminated area or from one

thought to be clean.

If they had used the word " and " then a licensed inspector would

have to be used AND the samples sent to an accredited lab.

There are other problems, esp with just what exactly are the

guidelines from ACGIH and AIHA? I'm familiar with both and neither

are considered " guidelines. " Guidance, yes, but that is not the

same as guidelines. If I were working in Arkansas I'd be stymied

by what to do.

Carl Grimes

Healthy Habitats LLC

-----

>> On April 2, 2009, Arkansas passed a new law about licensing of

>> mold investigators, etc.

>>

>> http://www.arkleg.state.ar.us/assembly/2009/R/Acts/Act1467.pdf

>>

>> Another step in the right direction.

[Guest guest]

Carl, it would be helpful if you would send your comments to the Arkansas State

Plant Board at:

info@...

They are responsible for enforcing this new law and establishing standards of

practice.

________________________________

From: Carl Grimes <grimes@...>

Sent: Tuesday, May 5, 2009 8:11:10 PM

Subject: Re: [] Re: Arkansas mold law passed in April

Thanks for posting the link to the Arkansas law. I agree that this

provides several steps in the right direction. However, there is a

very troubling provision because they use the word " or " instead of

" and. "

(2) A person licensed under this chapter shall not confirm or

25 refute the presence of mold in a residential or commercial

building without

26 having first:

27 (A) Performed an onsite investigation of the premises

28 conducted under the best practices set forth in the guidelines

established by

29 the American Conference of Governmental Industrial Hygienists

and the

30 American Industrial Hygiene Association, as they existed on

January 1, 2009;

31 or

32 ( If air samples or bulk samples of any kind are taken

33 from a residence or commercial building for culture or

appropriate

34 examination by a commercial laboratory, the analysis shall be

performed by a

35 laboratory accredited by and actively participating in the

American

36 Industrial Hygiene Association’s Environmental Microbiology

Laboratory

1 Accreditation Program.

As written, Confirmation or refuting mold can be determined either

with an assessment by a licensed inspector -or- by an accredited

lab with samples from a licensed inspector.

It is not ethical or even reasonable for a lab to intepret the

results. They can only provide the numbers based on their analysis

of the samples as sent. They have no idea where the samples were

taken or if they were collected properly. So they have no way of

knowing if a sample is from a contaminated area or from one

thought to be clean.

If they had used the word " and " then a licensed inspector would

have to be used AND the samples sent to an accredited lab.

There are other problems, esp with just what exactly are the

guidelines from ACGIH and AIHA? I'm familiar with both and neither

are considered " guidelines. " Guidance, yes, but that is not the

same as guidelines. If I were working in Arkansas I'd be stymied

by what to do.

Carl Grimes

Healthy Habitats LLC

-----

>> On April 2, 2009, Arkansas passed a new law about licensing of

>> mold investigators, etc.

>>

>> http://www.arkleg. state.ar. us/assembly/ 2009/R/Acts/ Act1467.pdf

>>

>> Another step in the right direction.

[Guest guest]

,

Thank you for the contact info. It will be even more powerful when

the professional organizations cited by the law send their

comments. For example, I've already received a response about

another flaw. The law requires that the lab be " accredited by and

actively participating in the American Industrial Hygiene

Association's Environmental Microbiology Laboratory Accreditation

Program. "

AIHA no longer has that program.

Carl Grimes

Healthy Habitats LLC

-----

On Tue May 05 23:23:42 CDT 2009,

<brianc8452@...> wrote:

> Carl, it would be helpful if you would send your comments to the

> Arkansas State Plant Board at:

>

> info@...

>

> They are responsible for enforcing this new law and establishing

> standards of practice.

>

>

>

>

> ________________________________

> From: Carl Grimes <grimes@...>

>

> Sent: Tuesday, May 5, 2009 8:11:10 PM

> Subject: Re: [] Re: Arkansas mold law passed in

> April

>

>

>

>

>

> Thanks for posting the link to the Arkansas law. I agree that

> this provides several steps in the right direction. However,

> there is a very troubling provision because they use the word

> " or " instead of " and. "

>

> (2) A person licensed under this chapter shall not confirm or

> 25 refute the presence of mold in a residential or commercial

> building without

> 26 having first:

> 27 (A) Performed an onsite investigation of the premises

> 28 conducted under the best practices set forth in the guidelines

> established by

> 29 the American Conference of Governmental Industrial Hygienists

> and the

> 30 American Industrial Hygiene Association, as they existed on

> January 1, 2009;

>

> 31 or

>

> 32 ( If air samples or bulk samples of any kind are taken

> 33 from a residence or commercial building for culture or

> appropriate

> 34 examination by a commercial laboratory, the analysis shall be

> performed by a

> 35 laboratory accredited by and actively participating in the

> American

> 36 Industrial Hygiene Association?s Environmental Microbiology

> Laboratory

> 1 Accreditation Program.

>

> As written, Confirmation or refuting mold can be determined

> either with an assessment by a licensed inspector -or- by an

> accredited lab with samples from a licensed inspector.

>

> It is not ethical or even reasonable for a lab to intepret the

> results. They can only provide the numbers based on their

> analysis of the samples as sent. They have no idea where the

> samples were taken or if they were collected properly. So they

> have no way of knowing if a sample is from a contaminated area or

> from one thought to be clean.

>

> If they had used the word " and " then a licensed inspector would

> have to be used AND the samples sent to an accredited lab.

>

> There are other problems, esp with just what exactly are the

> guidelines from ACGIH and AIHA? I'm familiar with both and

> neither are considered " guidelines. " Guidance, yes, but that is

> not the same as guidelines. If I were working in Arkansas I'd be

> stymied by what to do.

>

> Carl Grimes

> Healthy Habitats LLC

>

> -----

>>> On April 2, 2009, Arkansas passed a new law about licensing of

>>> mold investigators, etc.

>>>

>>> http://www.arkleg. state.ar. us/assembly/ 2009/R/Acts/

>>> Act1467.pdf

>>>

>>> Another step in the right direction.

>

>