Re: Condition 1, was: Certifications Restraint of Trade

[Guest guest]

Hello Steve and Carl,

All three definitions should be better defined and examples given. The concept is OK, but there is too much room for the issues Steve outlined. In my experience, a properly remediated area is cleaner than Condition 1, because it has been aggressively cleaned. I use Condition 1, more often than not, to decide where the remediation cleaning is not needed. The hyper-sensitive occupant issue may be beyond the normal "fungal" remediation standard or perhaps it requires a separate section to address these concerns and remediation methods, as they are very real.

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

-----Original Message-----From: iequality [mailto:iequality ]On Behalf Of AirwaysEnv@...Sent: Monday, August 28, 2006 4:49 PMTo: iequality Subject: Condition 1, was: Certifications Restraint of Trade

Carl,I have never liked the Condition 1 "definition". It isn't a definition at all. It describes a concept -- that there is such a thing as normal levels of fungi indoors. That's all. What is the definition of "normal fungal ecology" for a 100 year old brick foundation basement in upstate New York? Now that would be a specific definition.The "definition" may seem clear until you try to apply it to a specific indoor environment. Then it becomes a professional judgment call. If it isn't Condition 2 or Condition 3, it must be Condition 1.It is an illusion that Condition 1 has a definition. All it describes is the concept that there are normal types and levels of mold in indoor environments. Giving it a name or number doesn't allow you to determine whether the condition exists or not.The danger in the subjective interpretation of Condition 1 is that it will inevitably lead some to conclude that cleaning contamination levels "down to normal background" is the objective of a remediation procedure. This will mean that all of the contamination that can be lumped into a given practitioner's definition of "normal" will be acceptable to leave behind in the remediated environment. It does not take into account the fact that there are lots of different microbial contaminants that can remain after testing to determine "Condition 1". These remaining contaminants are the ones occupants may have been, or may become, sensitized to. The subjective definition can be an excuse to stop cleaning before the sensitizing agents have been thoroughly removed.I think the S520 Condition 1 term is just "professional judgment" by a different name and does not constitute a consensus opinion about anything (which is what the Standard is supposed to be). My view is that the term "Condition 1" is word play and not practically useful in the field and that we are only fooling ourselves if we consider it to be an actual definition of anything but a general concept.The "definition" of Condition 1 is the major issue I have with the S520 document which is mostly written for use by contractors, not IEPs.Steve TemesIn a message dated 8/28/2006 5:04:50 PM Eastern Standard Time, grimeshabitats writes:

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 GrimesHealthy Habitats LLC

[Guest guest]

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

How about "ubiquitously hale fungal ecology"?

[Guest guest]

Brad, , Steve and those off-line,

Thank you for your considered responses. This helps me to understand

the issues. These posts are not in any official capacity with the

S520 committee so if you are an IICRC peer reviewer or ANSI public

reviewer, please be sure to officially submit your comments.

Carl Grimes

Healthy Habitats LLC

[Guest guest]

Brad,

You wrote: In my experience, a properly remediated area is cleaner than Condition 1, because it has been aggressively cleaned. I use Condition 1, more often than not, to decide where the remediation cleaning is not needed.

Me too. How about we use "Condition 1" for initial assessment purposes and "cleaner than Condition 1" as a clearance criterion?

I'm not exactly sure what this means but it adds a needed safety factor.

Steve Temes

Hello Steve and Carl,

All three definitions should be better defined and examples given. The concept is OK, but there is too much room for the issues Steve outlined. In my experience, a properly remediated area is cleaner than Condition 1, because it has been aggressively cleaned. I use Condition 1, more often than not, to decide where the remediation cleaning is not needed. The hyper-sensitive occupant issue may be beyond the normal "fungal" remediation standard or perhaps it requires a separate section to address these concerns and remediation methods, as they are very real.

Bradley Harr MS, CMC, CHMM

Sr. Environmental Scientist

Summit Environmental, Inc.

bdharr@...

Condition 1, was: Certifications Restraint of Trade

Carl,

I have never liked the Condition 1 "definition". It isn't a definition at all. It describes a concept -- that there is such a thing as normal levels of fungi indoors. That's all. What is the definition of "normal fungal ecology" for a 100 year old brick foundation basement in upstate New York? Now that would be a specific definition.

The "definition" may seem clear until you try to apply it to a specific indoor environment. Then it becomes a professional judgment call. If it isn't Condition 2 or Condition 3, it must be Condition 1.

It is an illusion that Condition 1 has a definition. All it describes is the concept that there are normal types and levels of mold in indoor environments. Giving it a name or number doesn't allow you to determine whether the condition exists or not.

The danger in the subjective interpretation of Condition 1 is that it will inevitably lead some to conclude that cleaning contamination levels "down to normal background" is the objective of a remediation procedure. This will mean that all of the contamination that can be lumped into a given practitioner's definition of "normal" will be acceptable to leave behind in the remediated environment. It does not take into account the fact that there are lots of different microbial contaminants that can remain after testing to determine "Condition 1". These remaining contaminants are the ones occupants may have been, or may become, sensitized to. The subjective definition can be an excuse to stop cleaning before the sensitizing agents have been thoroughly removed.

I think the S520 Condition 1 term is just "professional judgment" by a different name and does not constitute a consensus opinion about anything (which is what the Standard is supposed to be). My view is that the term "Condition 1" is word play and not practically useful in the field and that we are only fooling ourselves if we consider it to be an actual definition of anything but a general concept.

The "definition" of Condition 1 is the major issue I have with the S520 document which is mostly written for use by contractors, not IEPs.

Steve Temes

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