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Carl:

I appreciate your interest and participation in S520. I am still digesting

the document, and in my quest to be precise, I may not be able to review the

draft document, in entirety, and fully comment before tomorrow's

deadline....just not enuff hours in the day.

This said, my over-riding concern is the document's over-use of the word

" contamination. " S520 infers that all mold clean-up and restoration efforts

are based on contamination; because if it is not contaminated, it must be

normal?!?! I find the over-use of " contamination " to be inflammatory, hype,

and it is unnecessary. Moreover, the document's definition of normal mold

ecology, is normal mold ecology - circular reasoning here. Not good.

Condition 1, Condition 2, and Condition 3 are just not adequate. They are

vague, ambiguous and not practical; except maybe for single family

residential units. Bottom line....I feel that the S520 standard should

represent consensus guidance on the clean-up and restoration of structures

that have an unreasonable and/or intolerable concentration of mold; allow

building owners and IEPs to determine what constitutes an unreasonable

and/or intolerable concentration, or contamination. S520 should not do it

for them! If IICRC wants to try to define " contamination, " given all the

permutations that may exist in all structures, including industrial,

agricultural, food processing, construction, etc., where mold growth and

amplification may be NORMAL, ANTICIPATED and/or TOLERATED, then the IICRC

should save that for another standard and another document....not S520. In

my opinion, S520 should stick to the task at hand...the means and methods of

mold mitigation and restoration of structures. Based on S520, I feel that

the IICRC has fallen into a similar pattern as is ANSI and ASTM...the

standards are too verbose, too broad, and go far beyond the original scope.

S520 is 247 pages of stuff! Much of which detracts from the heart and sole

of the standard. However, my biggest problem with S520, as written, is the

inference that: if mold warrants mitigation, then the structure MUST be

contaminated. BULL!

The other issue I am seeing in the document are strong recommendations on

source removal, irrespective of the damaging and costly affects of source

removal. This recommendation needs to be tempered with reality, i.e., few

building owners (or their insurance carrier) can afford to completely gut a

building in the quest to removal all biomass in all wall cavities, between

each piece of dimensional timber, in all interstitial spaces, etc. It is

just not practical to do so. There needs to be a balance between removing

the biomass that may truly affect the occupant's habitable space and cause

harm, and the quest to removal all sources. There needs to be an

acknowledgement that structures cannot be made sterile, or mold-free, and

that leaving biomass in place is reasonable and tolerable. What is not

tolerable, is not mitigating the moisture sources that are root cause

triggering and promoting the growth of the biomass - and S520 mentions this

in brief. EVERY structure has biomass and mold in the substrates of the

building, and the older the building, the more biomass is present. In most

buildings, this causes no harm. S520 should acknowledge that source removal

is only reasonable to a practical and economic threshold, and that source

removal is invasive, destructive, costly, time-consuming, labor-intensive,

and the means need to justify the result. This said, I feel that too many

remediation contractors have their fingerprint on S520 to increase their

fees resulting from demolition and reconstruction mold mitigation. Also not

good.

Thanks for asking....

--

Geyer, PE, CIH, CSP

President

KERNTEC Industries, Inc.

Bakersfield, California

www.kerntecindustries.com

> - and a question for the group:

>

> Within your post on ethical issues for AIHA and CIHs, you have a

> statement about S520 that I'm curious about.

> " Molds respond to moisture in a way that they are genetically

> engineered to do. as: decay organisms.  It is a natural phenomenon.

> It is normal, and it does not necessarily represent " contamination; "

> which is contrary to what the IICRC S520 document wants you to

> believe. "

>

> How does S520 promote mold as contamination? The reason for my

> question is S520 is completing its IICRC peer review (this week),

> plus another couple of weeks to go for its ANSI public review. As a

> (future) ANSI document its accuracy and perception is important.

>

> I served on the original S520 committee and am also on the current

> one, so I may be too close to the document to see what you (and

> others?) are seeing. If this is a common perception it should be

> addressed and now is the time to do it.

>

> For the record, Condition 1 is specifically defined as " normal fungal

> ecology, " Condition 3 as active growth and Condition 2 as settled

> spores and fragments. Further, Chapter 1 of the Reference Guide is

> titled " The Fungal Ecology of Indoor Environments. " It contains a

> description of " normal fungal ecology " as " types and concentrations

> of molds typically found in non-water damaged, environmentally well-

> maintained structures, and reflective of the ecological and climatic

> elements of the geographical region in which the building is located.

> (page 37)

>

> Is this not clear or does the rest of the document overshadow? Other

> reasons?

>

> I'd like opinions from the group, pro and con, privately if you

> prefer.

>

> Carl Grimes

> Healthy Habitats LLC

>

> -----

>> Sharon:

>>

>> Oh how correct you are, i.e., skeletons are in the closet! The AIHA

>> has a big ethical issue that needs to be addressed regarding mold, and

>> my comments/observations to the AIHA regarding this ethical issue have

>> gone un-addressed, un-answered, and un-noticed.

>>

>> I began studying molds in structures back in 1979, while completing my

>> undergraduate studies and operating a small construction business -

>> specializing in remodels and renovations. (I sometime joke about how

>> my college education was paid for by replacing rotten bathroom floors

>> in off-campus student housing....but, it was a BIG part of my work.) I

>> got interested in the molds I was finding and I took a lot of biology

>> and mycology classes to support my interest. Back then, the plant

>> pathologists where the ones in the " know " about molds, and taking

>> air samples with stacked plates was a bloody chore! Multiple,

>> redundant, indoor and outdoor sampling was very limited. Moreover, few

>> people (in my construction projects) offered any horror stories

>> regarding how they lost their memory to mold, though allergy

>> complaints were frequent, and we contractors cleaned things up with

>> little personal protection, but used careful job-site protections,

>> e.g., we didn´t Now, fast forward 20 years. The media has hyped mold

>> as the root cause of so many IAQ problems, illnesses and injuries, the

>> attorneys are involved, and the AIHA see an opportunity. I recall an

>> AIHA meting in San Diego where a significant mucky-muck of the AIHA

>> gave a speech: " Mold is Gold. " Implying that there were a lot of

>> fees to be made by CIHs doing mold work. I was appalled, but, he was

>> right - there is, and there was, and science took a back-seat to the

>> money trail. Many CIHs stepped to the plate and marketed themselves as

>> mold experts; even though classic IH is all about chemical

>> contaminants, not biologicals; there are some profound differences.

>> The mycology community also stepped in and said " We are the mold

>> experts! " And they are correct, but not in context.

>>

>> Mold is a symptom of a moisture issue; without sufficient moisture,

>> most molds will not grow and the species that cause injury will not

>> grow in dry conditions - but, I am preaching to the choir here.

>> Excessive moisture in the built environment is the root cause of the

>> problem that needs to be corrected. Molds respond to moisture in a way

>> that they are genetically engineered to do. as: decay organisms. It is

>> a natural phenomenon. It is normal, and it does not necessarily

>> represent " contamination; " which is contrary to what the IICRC

>> S520 document wants you to believe. While mycologists can

>> differentiate the species of mold (I can´t), I believe they don´t

>> have a clue how to mitigate causation. The same can be said of many

>> CIHs. Construction is a science. The means, methods and applications

>> of construction are NOT common sense; though I have been told this by

>> some CIHs. Mitigating moisture in the built environment is not common

>> What appalls me is the utter lack of knowledge by many " mold

>> experts " regarding the science of construction, and the purpose and

>> methods of moisture control. This knowledge is missing in most folks

>> who are conducting mold work today, and the arrogance by many CIHs in

>> saying that construction experience is unnecessary and/or it is common

>> sense.....BULL! Canon No. 5 of the AIHA states that CIHs must practice

>> within their area of competence, and that competence is determined by

>> education, training, and experience. Competence is not common sense!

>> However, when it comes to opining on mold within the built envelope,

>> few CIHs meet the criteria of Canon No. 5. This has been a very

>> disturbing issue for some CIHs who have been party litigation, as a

>> defendant, and I have been used by the plaintiff´s counsel to

>> demonstrate Professional Negligence by the CIH. In the cases I have

>> worked on, it has been VERY easy for me the assist counsel to

>> discredit the CIH usi Does the AIHA have skeletons?....Yes they do.

>> And AIHA needs to address this problem head-on. This said, I believe

>> many competent and worthy CIHs recognized the need and went out and

>> got themselves better educated in construction science (e.g., means,

>> methods and materials), and I hope they are continuing to do so.

>> Personally, I am a licensed contractor with over 30-yrs in the

>> business, and I only scratch the surface of construction knowledge.

>> Construction is broad and it is a science. Any person who speaks of

>> construction as " common sense " deserves to be a skeleton in a

>> closet! To say so is professional negligence, and demeaning to all of

>> us who spend our life´s work in construction attempting to better

>> the science.

>>

>> For what it is worth...

>> --

>> Geyer, PE, CIH, CSP

>> President

>> KERNTEC Industries, Inc.

>> Bakersfield, California

>> www.kerntecindustries.com

>

>

>

>

>

>

>

> FAIR USE NOTICE:

>

> This site contains copyrighted material the use of which has not always been

> specifically authorized by the copyright owner. We are making such material

> available in our efforts to advance understanding of environmental, political,

> human rights, economic, democracy, scientific, and social justice issues, etc.

> We believe this constitutes a 'fair use' of any such copyrighted material as

> provided for in section 107 of the US Copyright Law. In accordance with Title

> 17 U.S.C. Section 107, the material on this site is distributed without profit

> to those who have expressed a prior interest in receiving the included

> information for research and educational purposes. For more information go to:

> http://www.law.cornell.edu/uscode/17/107.shtml. If you wish to use copyrighted

> material from this site for purposes of your own that go beyond 'fair use',

> you must obtain permission from the copyright owner.

>

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I

haven’t seen the update of the S520 but I agree with and his

point about mass destruction to eliminate all mold contamination. The S500 on

water damage similarly suggests total rip out following a black water flood to

remove all possible biological and viral contaminates. How long will mold, bacteria,

virus or their endotoxins and mycotoxins be a threat after the building has

dried out? Left partly sealed in interstitial cavities away from fingers and

hand to mouth infection? I’m not suggesting that extensive contamination

or bio mass should be left to degrade but the smaller stuff that takes the real

money to remove.

Jeff Charlton

London

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Well spoken ...!!!

, CHMM, CMI, CMR

President

Environmental Mold Services, Inc

-----Original Message-----From: iequality [mailto:iequality ]On Behalf Of BantaSent: Wednesday, August 30, 2006 8:36 AMTo: iequalityyahooGroupsSubject: IICRC S520

I am concerned that this discussion is going down a path that is in afundamentally different direction than what is presented and intended by theIICRC S520. The S520 is a document for professional mold remediation. It hasbeen written to set a standard for the remediation industry not indoorenvironmental professionals. The diversity of backgrounds represented by this discussion groupdemonstrates the varied paths that each of us has followed to becomeprofessionals in this field. Remediation contractors have been looking to usfor clear answers regarding how they should perform their work. Thisfundamental concept has not changed between the first and second editions ofthe S520. Page 6 of the first edition states (in bold): "S520 is not intended toestablish procedures or criteria for assessing mold contamination in anindoor environment. These issues are most appropriately addressed byprofessional organizations that represent Indoor Environmental Professionals(IEPs). Since these professional organizations have not agreed uponthreshold exposure limits or levels of visible mold growth that constitute aconcern for occupant and worker safety, the IICRC Mold Remediation StandardCommittee decided not to establish action levels or procedures based uponthe quantity or size of the area of visible mold growth."The use of Condition 1, 2, and 3 is in my opinion the remediationcontractor's best way of dealing with the vagueness and disagreementsrepresented by IEPs. Remediation contractors should be commended for comingup with a standard and terms that allow them to communicate and performtheir work in the absence of IEPs developing a standard of care for IEPs. Banta, CAIH

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must they be mutually exclusive?

Well spoken ...!!!

-----Original Message-----

From: iequality [mailto:iequality ]On Behalf Of Banta

I am concerned that this discussion is going down a path that is in a

fundamentally different direction than what is presented and intended by the

IICRC S520. The S520 is a document for professional mold remediation. It has been written to set a standard for the remediation industry not indoor

environmental professionals......

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,

Your points about purpose are well taken and I agree. Especially with

the fact that S520 is a Remediation standard, not an assessment

standard. However, I asked for *perceptions* and I think it

interesting that despite the precise wording and all the text in the

document, this is still an area of concern for bright, educated,

ethical professionals. It is important that the discussion goes down

this path. If the perception is wrong, it can't be corrected until it

is known and acknowledged.

I would also like to make a minor adjustment to who represents the

assessment side of the industry. You use only the term IEP, which is

an S520 term, and leave out all the designations and certifications

(good and bad) that currently exist, and which S520 acknowledges.

Further, the need to create the phrase " indoor environmental

professional " (IEP) was specifically to address the new terminology

of Condition 1, 2, 3 and fungal ecology.

Specifically, page 129, first (long) sentence, reads: " The IICRC S520

defines " IEP " as an individual who is qualified by knowledge, skill

education, training and/or experience to perform an assessment of the

fungal ecology of property, systems and contents at the job site,

create a sampling strategy, sample the indoor environemnt, interpret

laboratory data and determine Condition 1, 2, and 3 for the purpose

of establishing a scope of work and verifying the return of the

fungal ecology to a Condition 1 status. "

IEP is specific to S520. Yes, they can perform other work, but not as

an IEP. Being qualified to assess Conditons and fungal ecology

(nothing is written by anyone on this yet) does not necessarily

include qualifications for other issues of the indoor, occupational,

industrial, health care facility, school, residential environments.

(Per my previous posts).

Carl Grimes

Healthy Habitats LLC

-----

> I am concerned that this discussion is going down a path that is in a

> fundamentally different direction than what is presented and intended by the

> IICRC S520. The S520 is a document for professional mold remediation. It has

> been written to set a standard for the remediation industry not indoor

> environmental professionals.

>

> The diversity of backgrounds represented by this discussion group

> demonstrates the varied paths that each of us has followed to become

> professionals in this field. Remediation contractors have been looking to us

> for clear answers regarding how they should perform their work. This

> fundamental concept has not changed between the first and second editions of

> the S520.

>

> Page 6 of the first edition states (in bold): " S520 is not intended to

> establish procedures or criteria for assessing mold contamination in an

> indoor environment. These issues are most appropriately addressed by

> professional organizations that represent Indoor Environmental Professionals

> (IEPs). Since these professional organizations have not agreed upon

> threshold exposure limits or levels of visible mold growth that constitute a

> concern for occupant and worker safety, the IICRC Mold Remediation Standard

> Committee decided not to establish action levels or procedures based upon

> the quantity or size of the area of visible mold growth. "

>

> The use of Condition 1, 2, and 3 is in my opinion the remediation

> contractor's best way of dealing with the vagueness and disagreements

> represented by IEPs. Remediation contractors should be commended for coming

> up with a standard and terms that allow them to communicate and perform

> their work in the absence of IEPs developing a standard of care for IEPs.

>

> Banta, CAIH

>

>

>

>

>

>

>

>

>

> FAIR USE NOTICE:

>

> This site contains copyrighted material the use of which has not always been

specifically authorized by the copyright owner. We are making such material

available in our efforts to advance understanding of environmental, political,

human rights, economic, democracy, scientific, and social justice issues, etc.

We believe this constitutes a 'fair use' of any such copyrighted material as

provided for in section 107 of the US Copyright Law. In accordance with Title 17

U.S.C. Section 107, the material on this site is distributed without profit to

those who have expressed a prior interest in receiving the included information

for research and educational purposes. For more information go to:

http://www.law.cornell.edu/uscode/17/107.shtml. If you wish to use copyrighted

material from this site for purposes of your own that go beyond 'fair use', you

must obtain permission from the copyright owner.

>

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The use of Condition 1, 2, and 3 is in my opinion the remediation

contractor's best way of dealing with the vagueness and disagreements

represented by IEPs. Remediation contractors should be commended for coming

up with a standard and terms that allow them to communicate and perform

their work in the absence of IEPs developing a standard of care for IEPs.

Banta, CAIH

,

I do commend the IICRC for developing the Standard. It is very useful guidance for remediation contractors and will greatly help them to minimize their liability exposure. Your points about other organizations not providing IEPs with guidance are well taken.

How do remediation contractors use the term "Condition 1"? Its definition does not allow one to identify whether the condition exists or not. It is a useful term as an abstract concept, but useless in practice. In my opinion, the term does nothing to clear up vagueness. The term makes things more vague by giving a false impression that it has a meaningful definition.

Steve Temes

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To All,

The deadline is Sep 8 for the ANSI required 'public comment' period.

The internal IICRC 'peer review' deadline has just been extended to

that same day, Sep 8. So now you surely have time.

This has been confirmed by Larry (IICRC) and Bob Baker (Chair

S520 Committee).

As I understand the process, all comments will be distributed to the

appropriate subcommittee for review. In the end, all comments should

have a response from that subcommittee.

So, with that in mind, get to it! Read all or just part of the doc,

whatever you have time and energy for. Write some notes and send in

your comments - don't forget you MUST use the excel spreadsheet

distributed with the pdf file of the S520 draft. And if you critique

it, PLEASE offer suggested language for improvement.

>

> > - and a question for the group:

> >

> > Within your post on ethical issues for AIHA and CIHs, you have a

> > statement about S520 that I'm curious about.

> > " Molds respond to moisture in a way that they are genetically

> > engineered to do. as: decay organisms.  It is a natural

phenomenon.

> > It is normal, and it does not necessarily

represent " contamination; "

> > which is contrary to what the IICRC S520 document wants you

to

> > believe. "

> >

> > How does S520 promote mold as contamination? The reason for my

> > question is S520 is completing its IICRC peer review (this week),

> > plus another couple of weeks to go for its ANSI public review. As

a

> > (future) ANSI document its accuracy and perception is important.

> >

> > I served on the original S520 committee and am also on the current

> > one, so I may be too close to the document to see what you (and

> > others?) are seeing. If this is a common perception it should be

> > addressed and now is the time to do it.

> >

> > For the record, Condition 1 is specifically defined as " normal

fungal

> > ecology, " Condition 3 as active growth and Condition 2 as settled

> > spores and fragments. Further, Chapter 1 of the Reference Guide is

> > titled " The Fungal Ecology of Indoor Environments. " It contains a

> > description of " normal fungal ecology " as " types and

concentrations

> > of molds typically found in non-water damaged, environmentally

well-

> > maintained structures, and reflective of the ecological and

climatic

> > elements of the geographical region in which the building is

located.

> > (page 37)

> >

> > Is this not clear or does the rest of the document overshadow?

Other

> > reasons?

> >

> > I'd like opinions from the group, pro and con, privately if you

> > prefer.

> >

> > Carl Grimes

> > Healthy Habitats LLC

> >

> > -----

> >> Sharon:

> >>

> >> Oh how correct you are, i.e., skeletons are in the closet! The

AIHA

> >> has a big ethical issue that needs to be addressed regarding

mold, and

> >> my comments/observations to the AIHA regarding this ethical

issue have

> >> gone un-addressed, un-answered, and un-noticed.

> >>

> >> I began studying molds in structures back in 1979, while

completing my

> >> undergraduate studies and operating a small construction

business -

> >> specializing in remodels and renovations. (I sometime joke about

how

> >> my college education was paid for by replacing rotten bathroom

floors

> >> in off-campus student housing....but, it was a BIG part of my

work.) I

> >> got interested in the molds I was finding and I took a lot of

biology

> >> and mycology classes to support my interest. Back then, the plant

> >> pathologists where the ones in the " know " about molds, and taking

> >> air samples with stacked plates was a bloody chore!

Multiple,

> >> redundant, indoor and outdoor sampling was very limited.

Moreover, few

> >> people (in my construction projects) offered any horror stories

> >> regarding how they lost their memory to mold, though allergy

> >> complaints were frequent, and we contractors cleaned things up

with

> >> little personal protection, but used careful job-site

protections,

> >> e.g., we didn´t Now, fast forward 20 years. The media has hyped

mold

> >> as the root cause of so many IAQ problems, illnesses and

injuries, the

> >> attorneys are involved, and the AIHA see an opportunity. I

recall an

> >> AIHA meting in San Diego where a significant mucky-muck of the

AIHA

> >> gave a speech: " Mold is Gold. " Implying that there were a lot of

> >> fees to be made by CIHs doing mold work. I was appalled, but, he

was

> >> right - there is, and there was, and science took a back-seat to

the

> >> money trail. Many CIHs stepped to the plate and marketed

themselves as

> >> mold experts; even though classic IH is all about chemical

> >> contaminants, not biologicals; there are some profound

differences.

> >> The mycology community also stepped in and said " We are the mold

> >> experts! " And they are correct, but not in context.

> >>

> >> Mold is a symptom of a moisture issue; without sufficient

moisture,

> >> most molds will not grow and the species that cause injury will

not

> >> grow in dry conditions - but, I am preaching to the choir here.

> >> Excessive moisture in the built environment is the root cause of

the

> >> problem that needs to be corrected. Molds respond to moisture in

a way

> >> that they are genetically engineered to do. as: decay organisms.

It is

> >> a natural phenomenon. It is normal, and it does not necessarily

> >> represent " contamination; " which is contrary to what the IICRC

> >> S520 document wants you to believe. While mycologists can

> >> differentiate the species of mold (I can´t), I believe they don´t

> >> have a clue how to mitigate causation. The same can be said of

many

> >> CIHs. Construction is a science. The means, methods and

applications

> >> of construction are NOT common sense; though I have been told

this by

> >> some CIHs. Mitigating moisture in the built environment is not

common

> >> What appalls me is the utter lack of knowledge by many " mold

> >> experts " regarding the science of construction, and the purpose

and

> >> methods of moisture control. This knowledge is missing in most

folks

> >> who are conducting mold work today, and the arrogance by many

CIHs in

> >> saying that construction experience is unnecessary and/or it is

common

> >> sense.....BULL! Canon No. 5 of the AIHA states that CIHs must

practice

> >> within their area of competence, and that competence is

determined by

> >> education, training, and experience. Competence is not common

sense!

> >> However, when it comes to opining on mold within the built

envelope,

> >> few CIHs meet the criteria of Canon No. 5. This has been a very

> >> disturbing issue for some CIHs who have been party litigation,

as a

> >> defendant, and I have been used by the plaintiff´s counsel to

> >> demonstrate Professional Negligence by the CIH. In the cases I

have

> >> worked on, it has been VERY easy for me the assist counsel to

> >> discredit the CIH usi Does the AIHA have skeletons?....Yes they

do.

> >> And AIHA needs to address this problem head-on. This said, I

believe

> >> many competent and worthy CIHs recognized the need and went out

and

> >> got themselves better educated in construction science (e.g.,

means,

> >> methods and materials), and I hope they are continuing to do so.

> >> Personally, I am a licensed contractor with over 30-yrs in the

> >> business, and I only scratch the surface of construction

knowledge.

> >> Construction is broad and it is a science. Any person who speaks

of

> >> construction as " common sense " deserves to be a skeleton in a

> >> closet! To say so is professional negligence, and demeaning to

all of

> >> us who spend our life´s work in construction attempting to better

> >> the science.

> >>

> >> For what it is worth...

> >> --

> >> Geyer, PE, CIH, CSP

> >> President

> >> KERNTEC Industries, Inc.

> >> Bakersfield, California

> >> www.kerntecindustries.com

> >

> >

> >

> >

> >

> >

> >

> > FAIR USE NOTICE:

> >

> > This site contains copyrighted material the use of which has not

always been

> > specifically authorized by the copyright owner. We are making

such material

> > available in our efforts to advance understanding of

environmental, political,

> > human rights, economic, democracy, scientific, and social justice

issues, etc.

> > We believe this constitutes a 'fair use' of any such copyrighted

material as

> > provided for in section 107 of the US Copyright Law. In

accordance with Title

> > 17 U.S.C. Section 107, the material on this site is distributed

without profit

> > to those who have expressed a prior interest in receiving the

included

> > information for research and educational purposes. For more

information go to:

> > http://www.law.cornell.edu/uscode/17/107.shtml. If you wish to

use copyrighted

> > material from this site for purposes of your own that go

beyond 'fair use',

> > you must obtain permission from the copyright owner.

> >

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Hello Jeff,

If there was a black water flood in my house, I would not be interested in leaving wetted porous materials in place (ie sheetrock). If for some reason strange reason they were left, I would want considerable PRV to document there wouldn't be future health or property stigma issues. I'm sure the lab costs would be more than the removal, cleaning and replacement costs, not to mention the stress of my wife beating on me.

Bradley Harr MS,CMC,CHMMSr. Environmental ScientistSummit Environmental, Inc.bdharr@...

-----Original Message-----From: iequality [mailto:iequality ]On Behalf Of J CharltonSent: Wednesday, August 30, 2006 1:02 AMTo: iequality Subject: RE: IICRC S520

I haven’t seen the update of the S520 but I agree with and his point about mass destruction to eliminate all mold contamination. The S500 on water damage similarly suggests total rip out following a black water flood to remove all possible biological and viral contaminates. How long will mold, bacteria, virus or their endotoxins and mycotoxins be a threat after the building has dried out? Left partly sealed in interstitial cavities away from fingers and hand to mouth infection? I’m not suggesting that extensive contamination or bio mass should be left to degrade but the smaller stuff that takes the real money to remove.

Jeff Charlton

London

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I agree that IICRC 520 is written for mold remediator, and we do have to work with all professionals to make it a feasible "standard". Those four (or maybe more) factors shall determine how the remediation job will be performed. (1) Conditions/Density: The only way to determine the 3 conditions (normal fungal ecology, settled spores, actual mold growth) and the mold population density (NOT IICRC S520 terms: high, medium, low, etc.) is to examine the samples under a microscope. The consultants/contractors can not do it without using a microscope plus years of training. The labs have to make the call on those. (2) Extent: The assessment of the extent (size/area) of mold growth is done by consulants' building inspection. The labs or the contractors can not do that. There is big difference between a 1-2 square

inch (that's all the lab can see) and a 10 square foot of "actual mold growth". (3) Individual health conditions The consultants will have to determine the probable cause (only when necessary and capable) for the compliants and the necessary final acceptable condition according to the occupants' health conditions. A "normal fungal ecology" might be fine for many people, but not for some sensitized individuals. (4) Cost The buliding owner, manager, insurance company, etc. will determine how much cost will be spent on the remediation. IMHO, the consultants should have most of the saying in determining the remediation scope. We just need to have the common language "defined" so the contractors can follow the scope better, or if there is anything discovered during the remediaiton, contractors can communicate

with consultants more efficiently. Wei Tang QLAB "Carl E. Grimes" wrote: ,Your points about purpose are well taken and I agree. Especially with the fact that S520 is a Remediation standard, not an assessment standard. However, I asked for *perceptions* and I think it interesting that despite the precise wording and all the text in the document, this is still an area of concern for bright, educated,

ethical professionals. It is important that the discussion goes down this path. If the perception is wrong, it can't be corrected until it is known and acknowledged.I would also like to make a minor adjustment to who represents the assessment side of the industry. You use only the term IEP, which is an S520 term, and leave out all the designations and certifications (good and bad) that currently exist, and which S520 acknowledges. Further, the need to create the phrase "indoor environmental professional" (IEP) was specifically to address the new terminology of Condition 1, 2, 3 and fungal ecology. Specifically, page 129, first (long) sentence, reads: "The IICRC S520 defines "IEP" as an individual who is qualified by knowledge, skill education, training and/or experience to perform an assessment of the fungal ecology of property, systems and contents at the job site, create a sampling strategy, sample the

indoor environemnt, interpret laboratory data and determine Condition 1, 2, and 3 for the purpose of establishing a scope of work and verifying the return of the fungal ecology to a Condition 1 status."IEP is specific to S520. Yes, they can perform other work, but not as an IEP. Being qualified to assess Conditons and fungal ecology (nothing is written by anyone on this yet) does not necessarily include qualifications for other issues of the indoor, occupational, industrial, health care facility, school, residential environments. (Per my previous posts).Carl GrimesHealthy Habitats LLC-----> I am concerned that this discussion is going down a path that is in a> fundamentally different direction than what is presented and intended by the> IICRC S520. The S520 is a document for professional mold remediation. It has> been written to set a standard for the remediation industry not

indoor> environmental professionals. > > The diversity of backgrounds represented by this discussion group> demonstrates the varied paths that each of us has followed to become> professionals in this field. Remediation contractors have been looking to us> for clear answers regarding how they should perform their work. This> fundamental concept has not changed between the first and second editions of> the S520. > > Page 6 of the first edition states (in bold): "S520 is not intended to> establish procedures or criteria for assessing mold contamination in an> indoor environment. These issues are most appropriately addressed by> professional organizations that represent Indoor Environmental Professionals> (IEPs). Since these professional organizations have not agreed upon> threshold exposure limits or levels of visible mold growth that constitute a> concern for

occupant and worker safety, the IICRC Mold Remediation Standard> Committee decided not to establish action levels or procedures based upon> the quantity or size of the area of visible mold growth."> > The use of Condition 1, 2, and 3 is in my opinion the remediation> contractor's best way of dealing with the vagueness and disagreements> represented by IEPs. Remediation contractors should be commended for coming> up with a standard and terms that allow them to communicate and perform> their work in the absence of IEPs developing a standard of care for IEPs. > > Banta, CAIH> > > > > > > > > > FAIR USE NOTICE:> > This site contains copyrighted material the use of which has not always been specifically authorized by the copyright owner. We are making such material available in our efforts to advance understanding of

environmental, political, human rights, economic, democracy, scientific, and social justice issues, etc. We believe this constitutes a 'fair use' of any such copyrighted material as provided for in section 107 of the US Copyright Law. In accordance with Title 17 U.S.C. Section 107, the material on this site is distributed without profit to those who have expressed a prior interest in receiving the included information for research and educational purposes. For more information go to: http://www.law.cornell.edu/uscode/17/107.shtml. If you wish to use copyrighted material from this site for purposes of your own that go beyond 'fair use', you must obtain permission from the copyright owner. >

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Q uick logical question:

Page 6 of the first edition states (in bold): "S520 is not intended toestablish procedures or criteria for assessing mold contamination in anindoor environment. These issues are most appropriately addressed byprofessional organizations that represent Indoor Environmental Professionals(IEPs).

How does one determine the criteria of completness of remediation if one does not assess?

........................................................................... "Tony" Havics, CHMM, CIH, PEpH2, LLCPO Box 34140Indianapolis, IN 46234 cell90% of Risk Management is knowing where to place the decimal point...any consultant can give you the other 10%â„ This message is from pH2. This message and any attachments may contain legally privileged or confidential information, and are intended only for the individual or entity identified above as the addressee. If you are not the addressee, or if this message has been addressed to you in error, you are not authorized to read, copy, or distribute this message and any attachments, and we ask that you please delete this message and attachments (including all copies) and notify the sender by return e-mail or by phone at . Delivery of this message and any attachments to any person other than the intended recipient(s) is not intended in any way to waive confidentiality or a privilege. All personal messages express views only of the sender, which are not to be attributed to pH2 and may not be copied or distributed without this statement.

-----Original Message-----From: iequality [mailto:iequality ] On Behalf Of Sent: Wednesday, August 30, 2006 12:47 PMTo: iequality Subject: RE: IICRC S520

Well spoken ...!!!

, CHMM, CMI, CMR

President

Environmental Mold Services, Inc

-----Original Message-----From: iequality [mailto:iequality ]On Behalf Of BantaSent: Wednesday, August 30, 2006 8:36 AMTo: iequalityyahooGroupsSubject: IICRC S520

I am concerned that this discussion is going down a path that is in afundamentally different direction than what is presented and intended by theIICRC S520. The S520 is a document for professional mold remediation. It hasbeen written to set a standard for the remediation industry not indoorenvironmental professionals. The diversity of backgrounds represented by this discussion groupdemonstrates the varied paths that each of us has followed to becomeprofessionals in this field. Remediation contractors have been looking to usfor clear answers regarding how they should perform their work. Thisfundamental concept has not changed between the first and second editions ofthe S520. Page 6 of the first edition states (in bold): "S520 is not intended toestablish procedures or criteria for assessing mold contamination in anindoor environment. These issues are most appropriately addressed byprofessional organizations that represent Indoor Environmental Professionals(IEPs). Since these professional organizations have not agreed uponthreshold exposure limits or levels of visible mold growth that constitute aconcern for occupant and worker safety, the IICRC Mold Remediation StandardCommittee decided not to establish action levels or procedures based uponthe quantity or size of the area of visible mold growth."The use of Condition 1, 2, and 3 is in my opinion the remediationcontractor's best way of dealing with the vagueness and disagreementsrepresented by IEPs. Remediation contractors should be commended for comingup with a standard and terms that allow them to communicate and performtheir work in the absence of IEPs developing a standard of care for IEPs. Banta, CAIH

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Jeff,

Your comments about leaving sealed interstitial cavities alone is

something that reflects real world experience and what actually happens

to a building as it ages.

We have a case right now of a CIH who recommended a $1,000,000

remediation to remove drywall that was buried under a concrete floor,

because the drywall paper has mold growing on it from when the concrete

was drying years ago.

Air testing showed normal mold spore levels and genera.

Bob

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Thanks Carl,

I understand your reason for requesting perceptions, and feel I have a duty to answer those perceptions with clarifications. As you know I have been involved with the S520 from the beginning so I need to clarifiy another perception that continues to propigate. The term Indoor Environmental Professional (IEP) has always been intended to refer in general to professional practioners in the indoor environment. Some of these professionals may specialize in lead, or asbestos, or energy conservation etc. We wanted to use a general term for individuals practicing in the environmental field and not be exclusionary for just the mold industry. The S520 was not trying to set a standard of care for practioners in mold - again that is up to the Indoor Environmental Professionals that practice in mold just like it has been up to the Indoor Environmental Professional practicing any other area of specialization to determine their standard of care.

Banta

1e. Re: IICRC S520 Posted by: "Carl E. Grimes" grimes@... grimeshh Date: Wed Aug 30, 2006 3:37 pm (PDT),Your points about purpose are well taken and I agree. Especially with the fact that S520 is a Remediation standard, not an assessment standard. However, I asked for *perceptions* and I think it interesting that despite the precise wording and all the text in the document, this is still an area of concern for bright, educated, ethical professionals. It is important that the discussion goes down this path. If the perception is wrong, it can't be corrected until it is known and acknowledged.I would also like to make a minor adjustment to who represents the assessment side of the industry. You use only the term IEP, which is an S520 term, and leave out all the designations and certifications (good and bad) that currently exist, and which S520 acknowledges. Further, the need to create the phrase "indoor environmental professional" (IEP) was specifically to address the new terminology of Condition 1, 2, 3 and fungal ecology. Specifically, page 129, first (long) sentence, reads: "The IICRC S520 defines "IEP" as an individual who is qualified by knowledge, skill education, training and/or experience to perform an assessment of the fungal ecology of property, systems and contents at the job site, create a sampling strategy, sample the indoor environemnt, interpret laboratory data and determine Condition 1, 2, and 3 for the purpose of establishing a scope of work and verifying the return of the fungal ecology to a Condition 1 status."IEP is specific to S520. Yes, they can perform other work, but not as an IEP. Being qualified to assess Conditons and fungal ecology (nothing is written by anyone on this yet) does not necessarily include qualifications for other issues of the indoor, occupational, industrial, health care facility, school, residential environments. (Per my previous posts).Carl GrimesHealthy Habitats LLC-----> I am concerned that this discussion is going down a path that is in a> fundamentally different direction than what is presented and intended by the> IICRC S520. The S520 is a document for professional mold remediation. It has> been written to set a standard for the remediation industry not indoor> environmental professionals. > > The diversity of backgrounds represented by this discussion group> demonstrates the varied paths that each of us has followed to become> professionals in this field. Remediation contractors have been looking to us> for clear answers regarding how they should perform their work. This> fundamental concept has not changed between the first and second editions of> the S520. > > Page 6 of the first edition states (in bold): "S520 is not intended to> establish procedures or criteria for assessing mold contamination in an> indoor environment. These issues are most appropriately addressed by> professional organizations that represent Indoor Environmental Professionals> (IEPs). Since these professional organizations have not agreed upon> threshold exposure limits or levels of visible mold growth that constitute a> concern for occupant and worker safety, the IICRC Mold Remediation Standard> Committee decided not to establish action levels or procedures based upon> the quantity or size of the area of visible mold growth."> > The use of Condition 1, 2, and 3 is in my opinion the remediation> contractor's best way of dealing with the vagueness and disagreements> represented by IEPs. Remediation contractors should be commended for coming> up with a standard and terms that allow them to communicate and perform> their work in the absence of IEPs developing a standard of care for IEPs. > > Banta, CAIH> >

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My guess would be that the

IEP has to determine that by which ever amulet they choose. “Not the contractor’s

job, dude, develop your own standards and get back to us.â€

I think this plays into Carl’s question

and comments about the concerns of bright and ethical professionals.  I don’t see this as the fault of the IICRC.  That’s why there are a plethora of

certifications that aren’t worth bunk. Unless we as professionals take this

issue on directly, it will remain a grey area.

Mark Doughty

IICRC S520

I am concerned that this discussion is going down a path that is in a

fundamentally different direction than what is presented and intended by the

IICRC S520. The S520 is a document for professional mold remediation. It has

been written to set a standard for the remediation industry not indoor

environmental professionals.

The diversity of backgrounds represented by this discussion group

demonstrates the varied paths that each of us has followed to become

professionals in this field. Remediation contractors have been looking to us

for clear answers regarding how they should perform their work. This

fundamental concept has not changed between the first and second editions of

the S520.

Page 6 of the first edition states (in bold): " S520 is not intended to

establish procedures or criteria for assessing mold contamination in an

indoor environment. These issues are most appropriately addressed by

professional organizations that represent Indoor Environmental Professionals

(IEPs). Since these professional organizations have not agreed upon

threshold exposure limits or levels of visible mold growth that constitute a

concern for occupant and worker safety, the IICRC Mold Remediation Standard

Committee decided not to establish action levels or procedures based upon

the quantity or size of the area of visible mold growth. "

The use of Condition 1, 2, and 3 is in my opinion the remediation

contractor's best way of dealing with the vagueness and disagreements

represented by IEPs. Remediation contractors should be commended for coming

up with a standard and terms that allow them to communicate and perform

their work in the absence of IEPs developing a standard of care for IEPs.

Banta, CAIH

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Carl,

Good points. 

I think it is important to remember that

one of the strengths of the S520 is that it was written as a consensus

document, and trades on that fact.  IMHO

it is because the IH side of the industry was afraid to take a stance on their

own because of the complexity of the issues and the lack of a “complete

picture” by anyone.  Even today, we

read all of the horror stories on this list about this or that certified person

that doesn’t know the left side from the right side of a flounder.  Back up a few years ago, when the S520 was

first crafted and it was much worse.  Prior to 2000 it was the Stone Age.  My hat’s off to the IICRC for having the

fortitude to tackle the problem (although they really had no choice).  What’s really important to remember,

and what we should be truly thankful for is the wide scope of the document and

its general acceptance in the industry. 

Like it or not, this document has defined conditions and terms that are relevant

beyond the scope of the IICRC, such as IEP.  It has provided safe harbor for many, many

people: hopefully.

I asked for *perceptions* and I think it

interesting that despite the precise wording and all the text in the

document, this is still an area of concern for bright, educated,

ethical professionals. It is important that the discussion goes down

this path. If the perception is wrong, it can't be corrected until it

is known and acknowledged.

This is huge and should be well taken. 

The courts will ultimately use opinions of those bright, educated and

maybe even ethical professionals to decide cases.  I know of no one practicing at this level

that doesn’t have concerns about certifications and many other issues.  If those concerns are overlooked by the

industry then the courts will get them. 

It is easier and more practical to handle these concerns at the

developmental stage rather than reacting to them in litigation.

IEP is specific to S520. Yes, they can perform other work, but not as

an IEP.

I have to disagree here.  IMHO the term has become generic.  So has Bob’s term “post

remediation verification”.  They

are both good terms that better defined their function than anything in the

industry.

Mark Doughty

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Hi Dr. Tang:

you bring up several excellent points, and a couple that I must

respectfully amend, regarding this process.

(beware: soapbox ahead)

1. conditions/density: the density of microbial growth must be

determined MACROSCOPICALLY (i.e., visually), but only once we

understand what's happening at the microscopic level. that's why

our graduate microbiologist continues to study fungal ID as part of

his Master's program, and why we bring an Olympus CH-2 scope to the

site.

2. there is no way any lab can " make the call " RE: density and

extent based on a few samples. it's up to the consultant to combine

on-site microscopy (or lab analysis) with thorough field

observations in order to make this determination.

3. health concerns/conditions: this is the biggest reason why

industrial hygienists migrated into work with wet buildings. let's

face it, the term " industrial hygiene " has out-lived its

usefulness. IHs are HEALTH & SAFETY professionals, and

the " industrial " part of that title needs to be changed. a few

folks on this list still don't get it, but health & safety concerns -

- and solutions! -- are applicable to ALL settings: industrial,

occupational, and residential.

4. costs: " how much...will be spent " is topic for another day's

discussion.

[bEGIN SOAPBOX]

and yes, TRULY QUALIFIED consultants should be coordinating the

overall effort by defining the required scope of work, overseeing

the activities of the remediation contractor, and providing

verification.

to be clear, by " truly qualified " I'm talking about someone with the

appropriate education, training and experience needed to understand

this complex field of study. e.g., an undergrad in political

science, philosophy, or underwater basketweaving just doesn't cut

the mustard when we're dealing with the health of children in our

schools or in their homes.

and as you probably know, it is ILLEGAL in three states for the same

firm to perform the assessment work (consultant's job) and the

remediation work (contractor's job) on the same project. because of

the underlying conflict of interest, this just makes sense! those

who continue to sell themselves as a turn-key operation (including

assessment, remediation AND post-remediation verification) are, IMO,

the bane of this industry.

[END SOAPBOX]

with my regards,

Wane

<><><><><><><><><><><>

Wane A. Baker, P.E., CIH

Division Manager, Indoor Air Quality

MICHAELS ENGINEERING

" Real Professionals. Real Solutions "

Phone , ext. 484

Cell

Fax

mailto:wab@...

On the web at: http://www.michaelsengineering.com

" To love what you do and feel that it matters - how could anything

be more fun? "

- Graham

>

> I agree that IICRC 520 is written for mold remediator, and we do

have to work with all professionals to make it a

feasible " standard " . Those four (or maybe more) factors shall

determine how the remediation job will be performed.

>

> (1) Conditions/Density:

> The only way to determine the 3 conditions (normal fungal

ecology, settled spores, actual mold growth) and the mold population

density (NOT IICRC S520 terms: high, medium, low, etc.) is to

examine the samples under a microscope. The consultants/contractors

can not do it without using a microscope plus years of training.

The labs have to make the call on those.

>

>

> (2) Extent:

> The assessment of the extent (size/area) of mold growth is done

by consulants' building inspection. The labs or the contractors can

not do that. There is big difference between a 1-2 square inch

(that's all the lab can see) and a 10 square foot of " actual mold

growth " .

>

> (3) Individual health conditions

> The consultants will have to determine the probable cause (only

when necessary and capable) for the compliants and the necessary

final acceptable condition according to the occupants' health

conditions. A " normal fungal ecology " might be fine for many

people, but not for some sensitized individuals.

>

> (4) Cost

> The buliding owner, manager, insurance company, etc. will

determine how much cost will be spent on the remediation.

>

> IMHO, the consultants should have most of the saying in

determining the remediation scope. We just need to have the common

language " defined " so the contractors can follow the scope better,

or if there is anything discovered during the remediaiton,

contractors can communicate with consultants more efficiently.

>

> Wei Tang

> QLAB

>

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Hi Wane, Please do amend/revise/comment. Even a "standard" need that, not to mention my 15 min writing. I think we agree on the major issues here, but our term might be defined differently. Let me explain mine a little further. (1) Conditions and Microscopic Density: It's pretty much established that Condition 1 to 3 can only be determined under microscope. We have different definitions on "density". How "thick" the mold biomass on the site can only be determined by consultants because the tape-lift can only lift the top one lay of spores/hyphae (maybe 2 or 3 layers) unless a well preserved bulk piece is sent to the lab (not just in a zip lock bag). What I meant "density" (as in population density) is microscopic density determined under microscope to indicate the "peak" degree of mold growth on the samples

examined (high, medium, low). Some labs use other semi-quantitative descriptions. It's better than just "Mold Growth: Yes or No". As you know already, when you look at the samples under microscope, those mold-like substance can be (a) mostly mold and some debris (B) some mold and mostly debris © no mold and just debris, etc. The way we tell our clients is to report the microscopic density of mold observed, which can't be done macroscopically due to possible different degree of background debris. (2) Extent and Macroscopic Density: Yes, it's consultants' job. Please share your definition of "macroscopic density" with us. (3) Consultants/Contractors Yes, due to potential conflicts of interest, they should be separate parties. I have some clients who do both inspection and

remediation, but they refer jobs to others and do not do them both for the same job. If you do your job well, they will refer business back to you. Does this have any potential conflicts of interest? Wei Tang QLAB "Wane A. Baker, P.E., CIH" wrote: Hi Dr. Tang:you bring up several excellent points, and a couple that I must respectfully amend, regarding this process. (beware: soapbox

ahead)1. conditions/density: the density of microbial growth must be determined MACROSCOPICALLY (i.e., visually), but only once we understand what's happening at the microscopic level. that's why our graduate microbiologist continues to study fungal ID as part of his Master's program, and why we bring an Olympus CH-2 scope to the site. 2. there is no way any lab can "make the call" RE: density and extent based on a few samples. it's up to the consultant to combine on-site microscopy (or lab analysis) with thorough field observations in order to make this determination. 3. health concerns/conditions: this is the biggest reason why industrial hygienists migrated into work with wet buildings. let's face it, the term "industrial hygiene" has out-lived its usefulness. IHs are HEALTH & SAFETY professionals, and the "industrial" part of that title needs to be changed. a few folks on this list

still don't get it, but health & safety concerns -- and solutions! -- are applicable to ALL settings: industrial, occupational, and residential. 4. costs: "how much...will be spent" is topic for another day's discussion. [bEGIN SOAPBOX]and yes, TRULY QUALIFIED consultants should be coordinating the overall effort by defining the required scope of work, overseeing the activities of the remediation contractor, and providing verification. to be clear, by "truly qualified" I'm talking about someone with the appropriate education, training and experience needed to understand this complex field of study. e.g., an undergrad in political science, philosophy, or underwater basketweaving just doesn't cut the mustard when we're dealing with the health of children in our schools or in their homes. and as you probably know, it is ILLEGAL in three states for the same firm to perform the

assessment work (consultant's job) and the remediation work (contractor's job) on the same project. because of the underlying conflict of interest, this just makes sense! those who continue to sell themselves as a turn-key operation (including assessment, remediation AND post-remediation verification) are, IMO, the bane of this industry. [END SOAPBOX]with my regards, Wane<><><><><><><><><><><> Wane A. Baker, P.E., CIH Division Manager, Indoor Air Quality MICHAELS ENGINEERING"Real Professionals. Real Solutions" Phone , ext. 484 Cell Fax mailto:wabmichaelsengineering On the web at: http://www.michaelsengineering.com "To love what

you do and feel that it matters - how could anything be more fun?" - Graham >> I agree that IICRC 520 is written for mold remediator, and we do have to work with all professionals to make it a feasible "standard". Those four (or maybe more) factors shall determine how the remediation job will be performed. > > (1) Conditions/Density:> The only way to determine the 3 conditions (normal fungal ecology, settled spores, actual mold growth) and the mold population density (NOT IICRC S520 terms: high, medium, low, etc.) is to examine the samples under a microscope. The consultants/contractors can not do it without using a microscope plus years of training. The labs have to make the call on those. > > > (2) Extent:> The assessment of the

extent (size/area) of mold growth is done by consulants' building inspection. The labs or the contractors can not do that. There is big difference between a 1-2 square inch (that's all the lab can see) and a 10 square foot of "actual mold growth". > > (3) Individual health conditions> The consultants will have to determine the probable cause (only when necessary and capable) for the compliants and the necessary final acceptable condition according to the occupants' health conditions. A "normal fungal ecology" might be fine for many people, but not for some sensitized individuals. > > (4) Cost> The buliding owner, manager, insurance company, etc. will determine how much cost will be spent on the remediation. > > IMHO, the consultants should have most of the saying in determining the remediation scope. We just need to have the common language "defined" so the contractors can

follow the scope better, or if there is anything discovered during the remediaiton, contractors can communicate with consultants more efficiently. > > Wei Tang> QLAB> Wei Tang, Ph.D.Lab Director QLAB5

DriveCherry Hill, NJ 08003www.QLABusa.com

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------------------------------------------------------------------------------------------------------------ and as you probably know, it is ILLEGAL in three states for the same firm to perform the assessment work (consultant' s job) and the remediation work (contractor' s job) on the same project. because of the underlying conflict of interest, this just makes sense! those who continue to sell themselves as a turn-key operation (including assessment, remediation AND post-remediation verification) are, IMO, the bane of this industry. ------------------------------------------------------------------------------------------------------------ Wane, I agree with you as far as post remediation verification goes but do you really think that ALL mold jobs require a seperate consultant to do an assesment? Do my clients with mold in their crawlspace need to call a

consultant to tell them that they have mold because its 75% rh in July in NC and their AC ducts have condensation? Surely the whole "remediator cant asses" situation cant be a blanket statement? And to say that if I give an "assesment" Im unethical because Im only a CMR but Im ethical if I only do remediation is, quite frankly, insulting. Im either an ethical person or Im not. And you can only tell that but the quality of the work I do and service I provide, not what I do. Using that standard would mean that Im not qualified to run the research lab that I do because I dont have a PhD. Or a Ms. Or even a BSc. I have a GIBiol... And yet the people who hired me to run their lab are more than satisfied with the results Im producing, the progress Im making and the value Im adding to their product. Its my experience that counts. And I will readily agree that you and many others here are way more experienced than I am and I will bow to your superior

knowledge. But Im perfectly qualified to figure out a lot of things moldy. And if I cant, then I'll call in someone who can. The team approach is just fine by me. As long as the job gets done properly and the client is satisfied. Stuart McCallum

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