|
|
Discovered Mold -- Now What?
William Yobe (June 28, 2002)
Home
|
Estimating & Project Management | Supply
Chain | Mitigation |
Loss Recovery Guide with Standards
| p1mX-CAT
IndexesSM
Click Here for
Questions & Comments
--on--
Discovered Mold -- Now What?
Introduction
For the past year, I have been crisscrossing the U.S. presenting seminars on loss-mitigation, as well as attending seminars on water and mold. And I constantly hear restoration vendors that handle water losses (structural drying) state: "we are in the water loss (drying) business -- not the mold business." Of which I respond with a quote from Brian Spiegel, of Spiegle Certified Restoration: "If you're in the water damage restoration business, you're in the mold business whether you realize it or not." Spiegle's quote is based on odds. Odds are, if you perform restorative drying -- you will eventually discover mold during the loss site evaluation or drying process.
When trying to understand molds, we need to understand that microorganisms are always present within the built environment. They are just not visible to the naked eye. However, when moisture or water intrudes due to building defects, leaks or flooding, an environment is created that is correct for microorganisms to become visible (mold). Moreover, when mold is discovered, vendors need to develop a formal set of procedures, so they can remedy the situation -- not intensify it.
When reviewing how mold formation should be handled when discovered during a loss site evaluation or during loss-mitigation, restoration vendors should put on their risk management hat. The objective of a risk manager is to manage the risk. When reviewing this article, or when applying the principles within, vendors need to be mindful of the situation. Moreover, vendors need to relate present safety and health regulations, and apply relating (construction, asbestos, lead, etc.) standards and guidelines to the situation as a risk manager would.
The intention of this article "Discovered Mold -- Now What?" -- Section 10.1 Mold Containment (loss-mitigation) is not to be a substitute for mold certification (inspection, remediation, supervision, etc.) as developed by professional indoor air quality organizations. Moreover, the encouragement of restoration vendors that handle water losses (structural drying) to seek certification for mold procedures, while providing a means of mold containment using existing guidelines. Furthermore, the guidelines contained within Section 10.1 are under peer review and will be updated periodically.
Although referenced within this article, the American Indoor Air Quality Council, Code of Federal Regulations, Environmental Protection Agency, Institute of Inspection Cleaning and Restoration Certification or New York City Department of Health do not endorse the comments or suggested recommendations within this article.
Restoration vendors, technicians, adjusters, claims manager, facility managers, Government officials, industrial hygienists, consumers, etc. are encouraged to make comments and suggestions on the contents of this article, and forward them to the editor (see disclaimer page) (please reference section numbers with correspondence)
10.1) Mold Containment (loss-mitigation)
(a) Although the contents of this article are formatted using sections and subsections similar to Loss Recovery Guide with Standards (LRGS), as well as references the LRGS, the contents of this article shall not be considered a part of the LRGS during peer review.
(b) Since each loss poses different post-conditions, requiring different protocols (i.e. special thoughts, treatments, applications, approaches, etc.), the publisher, authors, or sources herein, disclaim any liability, be it injury to property, life, or financial record, of the recommendations contained within.
(c) Since the discovery of mold formation during a loss site evaluation or loss-mitigation process would fall within non-conformance, restoration vendors should formulate a non-conformance and corrective action protocol within the companys quality control and assurance (QC&A) program, as described in the Loss Recovery Guide with Standards Section 5.9) Non-Conformance and Corrective Actions: "Procedures describing the requirements and assignment of responsibility, for the control of non-conformance and corrective actions during the loss-mitigation or restoration process should be developed." An example of a corrective actions process format for mold formation is shown in Illustration 10-1:

Illustration 10-1
(d) The information compiled within this article could be time sensitive requiring revisions and updates periodically. Furthermore, the information contained within this article is not intended to offer legal advice or be a substitute for legal advice.
10.1.1) Basis of the Property Restoration Industry
(a) When dealing with emergency services (loss-mitigation), restoration, construction, or mold containment, vendors should understand the basis of the industries they serve:
(b) It does not matter which paraphrases we choose, they both relate to the mold business and the water loss (drying) business. Meaning, when mold is discovered during the evaluation or drying process, steps must be taken to protect the health of workers and occupants within the structure, as well as preserve the structure from further damages
10.1.2) It Begins with Knowledge
(a) Based on the paraphrases in Section 10.1.1 (a): What is a restoration vendor that lacks mold certification or experience to do when they discover mold during a loss site evaluation or drying process?, if you are in the water damage restoration business -- you should get mold certification. Furthermore, restoration vendors need a formal protocol on what should or should not be done when mold is discovered.
(b) So where does a vendor begin when developing a formal mold containment protocol system? It begins with knowledge:
(c) Although there are presently no federal or state regulations for the loss-mitigation, restoration or mold remediation industries, restoration vendors should formulate an internal educational / certification growth program. Where all aspects of the companys operation have a formal educational process that grows with the company, and includes all aspects of the companys operation, as well as regulation and technical changes as shown in Illustration 10-2
- |
In-House(1) |
Regulations(2) |
IICRC/ASCR(3) |
NIDR (CR)(4) |
WLI (WLS)(5) |
QC&A(6) |
IAQ(7) |
Personal(8) |
|
Technician |
X |
X |
X |
- |
- |
X |
- |
- |
|
Estimator |
X |
X |
X |
- |
- |
X |
X |
X |
|
Project Manager |
X |
X |
X |
X |
X |
X |
X |
X |
|
Fire/Water Manager |
X |
X |
X |
X |
X |
X |
X |
X |
|
QC&A Manager |
X |
X |
X |
X |
X |
X |
X |
X |
| Administrative |
X |
X |
X |
- |
- |
X |
- |
X |
Illustration 10-2 See Footnotes below:
Illustration 10-2 (footnotes):
(1) Restoration vendors should develop an in-house training program on the use, storage, maintenance and safety practices of all company owned or rented equipment, on all testing procedures, on all supplies (i.e. chemicals), as well as on the companys quality control & assurance (QC&A) program.
(2) Restoration vendors should have their technicians and managers trained and certified on Code of Federal Regulations (CFR) safety and health programs and certified with the Federal Insecticide, Fungicide and Rodentcide Act. when required by law.
(3) All company personnel should receive ASCR (CRT) or IICRC (SRT, ASCT, WLT) certification.
(4) Project managers, fire/water managers and the companys QC&A manager should receive Certified Restorer (CR) certification through the the ASCR's National Institute of Disaster Restoration (NIDR).
(5) Project managers, fire/water managers and the companys QC&A manager should receive Water Loss Specialists (WLS) certification through the ASCR's Water Loss Institute (WLI).
(6) The company should formulate a quality control and assurance program. And all company personnel should be trained on the companys QC&A program. A QC&A manager should be designated and management should be educated on QC&A procedures.
(7) All company personnel should be educated on IAQ awareness, while project managers, fire/water management and the companys QC&A manager should receive mold certification from the American Indoor Air Quality Council (AmIAQ Council) or the Indoor Air Quality Association (IAQA).
(8) It should be the practice of the companys upper management to promote the personal management advancement (i.e. Dale Carnegie) of its employees.
10.1.3) The Built Environment
(a) Whether estimating, evaluating, or drying losses that involve water -- we need a complete understanding of the built environment. An understanding of how structures are built. How they breathe, what affect water has on a structure, as well as what affect the structure has on water flow and humidity.
(b) The training of technicians and management on the built environment should include the characteristics of building components (i.e. gypsum board, plaster, framing, flooring, roofing, facades, insulation, vapor barriers, etc.). What affect water and moisture have on these components, what affect forced drying has on these components, as well as what affect these components have on air movement within a structure (i.e. natural and forced).
(c) Technicians and management need a full and complete understanding of psychrometrics principles. However, unless technicians and managers can relate psychrometrics to the built environment, a structure will not thoroughly dry due to hidden and trapped moisture, or a structure will not dry within a time frame that prevents or greatly reduces mold formation.
10.1.4) Mold Levels
(a) When we discover mold during our loss site evaluation or loss-mitigation process, we need a thorough understanding of the five-mold levels developed by the New York City-Department of Health (NYC-DOH) and the three-mold levels developed by the Environmental Protection Agency (EPA):
(b)
NYC-DOH · Five-Mold Levels:
(c) EPA · Three-Mold Levels:
10.1.5) Our Senses
(a) When entering the structure, or a room within, do we stop and smell the roses per se, or do we rush through without taking the time to notice potential (mildew) odors? The EPA states, "You may suspect hidden mold if a building smells moldy, but you cannot see the source, or if you know there has been water damage and building occupants are reporting health problems."
10.1.6) Evaluation
(a) Before we proceed with our loss-mitigation (drying) services, we should perform a thorough inspection of the loss site, which begins when we approach the structure. What type of facade does the structure have? Is the roof new, or old and in need of repairs? Are the gutters and downspouts structurally sound, or are they sagging and separated? Does the topography of the land divert waters from the structure, or does the topography of the land favor the structure?
(b) When we evaluate the origin room and adjoining rooms, do we visually inspect all walls, ceiling, and floor spaces for visible mold? Do we move contents (furnishings) to inspect for hidden mold, behind and underneath? According to the NYC-DOH guidelines, "A visual inspection is the most important initial step in identifying a possible contamination problem. The extent of any water damage and mold growth should be visually assessed." If an exterior wall is wet, do we relate pre-existing conditions and/or recent repairs to the conditions of the exterior facade, gutters, downspouts, roof, etc.?
(c) The visual inspection of a water loss site should include, but not be limited to the following areas:
(d) In addition to a visual inspection of surface areas, hidden areas that may contain
mold formation should be a concern, predominantly when forced air is used to dry hidden
areas (walls, cabinets, etc.). Air-movers (turbo fans) can produce up to two feet
per second of air, and when used to dry hidden areas, they could contaminate the entire
structure if mold formation goes unnoticed.
The inspection of hidden areas is best performed with
the aid of a boro-scope.
Boro-scopes
will not detect mold spores that could be present within hidden cavities, while the
use of a boro-scope could aid visual inspections when searching for visible mold
formation. (Could = possible, maybe, all venues should be evaluated.)
Furthermore, access holes, when
needed for air movement within hidden areas can be used for boro-scope inspections.
10.1.7) Questions and Answers
(a) As restoration vendors and technicians, we need to ask specific questions during our loss site evaluation. Moreover, listen to the answers and relate them to the processes. Answers to questions of the following nature could provide awareness to possible pre-existing mold formation, which would help prevent the spread of mold contamination:
10.1.8) Safety and Health
(a) The American IAQ Council had an article titled "We Dont Do Asbestos or Lead Work" by Dale Becker of the Asbestos Institute in its April/May 2002 newsletter, which states; "It is wrong for any remediation contractor to think that there are no regulations for the microbial or water damage restoration business. We do have a lot of good published guidelines in addition to many different regulations that are applicable to the work in question." This article references EPA and OSHA regulations which are printed in the Code of Federal Regulations (CFR) and available online at http://www.access.gpo.gov/nara/cfr/:
(b) Although the aforementioned government regulations relate to asbestos and lead, prudent restoration vendors will review CFR standards, and relate the specifics to mold, loss-mitigation and restoration and incorporate them into their daily operations.
(c) Restoration technicians could encounter areas know as confined spaces during a loss site evaluation or loss-mitigation. Confined or enclosed space means any space having a limited means of egress, which is subject to the accumulation of toxic (mold, black water, asbestos, lead, etc.) or flammable contaminants or has an oxygen deficient atmosphere, per 29 CFR 1910.146.
(d) When dealing with water losses, moreover when mold is discovered in the indoor environment, restoration vendors will want a complete understanding of OSHA regulations. In addition, the EPA states within its guidelines, "The remediation managers highest priority must be to protect the health and safety of the building occupants and remediators."
10.1.9) Containment
(a) If we discover mold formation during a loss site evaluation or during the drying process, the IICRC Reference Guide for Professional Water Damage Restoration S500 states; "When visible microbial growth has occurred in a structure, mold remediation practices must be properly employed to address the situation, and containment procedures may be necessary to prevent spreading spores to uncontaminated areas."
(b) The containment of mold formation begins with an understanding of mold levels, the severity or risks associated within each level and an understanding of the containment procedures recommended within the NYC-DOH guidelines and the EPA guidelines. Then applying prudent judgment that would remedy the situation to protect the health of workers and the occupants within the structure, as well as preserve the structure from further damages.
(c) One would think that a full understanding of the NYC-DOH mold levels and recommended mold remediation processes contained within the "Guidelines on Assessment and Remediation of Fungi in Indoor Environments" developed by the NYC-DOH, and the mold levels and recommended mold remediation processes contained within the "Mold Remediation in Schools and Commercial Buildings" developed by the U.S. Environmental Protection Agency (EPA) would provide restoration vendors with a complete understanding of containment and levels of risk associated with various levels of mold formation. However, we see confusion within the industry, mainly with restoration vendors that perform loss-mitigation (drying) after water losses due to the varying mold levels and recommendations.
(d) When confronted with a discrepancy between two guidelines, we reference the Loss Recovery Guide with Standards (LRGS): Section 1.2 "In the event of a discrepancy between a building, electrical, mechanical or health standard or guideline, and the standards and guidelines referenced within the Loss Recovery Guide with Standards (LRGS), the more restrictive standard or guideline provision shall supersede the lesser provision. While adopted building codes shall supersede standards and guidelines." This is similar to a recommendation developed by the National Fire Protection Association (NFPA).
(e) To lessen the confusion, or maybe create more confusion, Table 10-A, titled: "Loss-Mitigation Mold Containment" in Section 10.12 has been developed.
(f) The objective of Table 10-A in Section 10.1.12 of this article is to view the recommended guidelines developed by the NYC-DOH and the EPA, combine the more restrictive recommendations into a set of recommendations that would lessen a restoration vendors overall risk exposure, as well as the insurer who underwrites the vendors liability risk rider(s).
(g) The EPA says, "The purpose of containment during remediation activities is to limit release of mold into the air and surroundings, in order to minimize the exposure of remediators and building occupants to mold. Mold and moldy debris should not be allowed to spread to areas in the building beyond the contaminated site."
(g.1) When reviewing the EPA recommendation in Section 10.1.19 (g) and relating it to the containment of mold during a loss site evaluation or the loss-mitigation processes, restoration vendors should apply containment measures that would prevent or greatly limit the release of mold spores into the interior environment.
(g.2) Mold containment barriers should be placed beyond the mold formation, using method(s) that does not disturb the mold formation due to the possible explosive nature of some mold spores, which could release mold spores within the interior environment.
(h) Restoration vendors not trained or certified in mold remediation should refrain from removing mold at any level (NYC-DOH: Level I, II, III, IV, V -- EPA: Level Small, Medium, Large), even when requested by the occupant, building owner or adjuster.
10.1.10) Communication
(a) When mold is discovered during a loss site evaluation or during the loss-mitigation process, restoration vendors should openly communicate their finding with occupants, property owner(s) and claims adjusters based on the penal codes (civil laws) within the state that has jurisdiction over the loss.
(b) In addition to a state's penal codes, vendors should abide by all state hazardous communications laws, or laws directly relating to mold. For example:
(b.1) When mold is discovered, or when conditions are correct for possible mold formation (i.e. 24-48 hours after a water loss, non-loss-mitigation, improper loss-mitigation, etc.), restoration vendors should reference the following sections within the Loss Recovery Guide with Standards (LRGS):
(c) When mold is discovered -- restoration vendors should apply the recommended communication requirements within the NYC-DOH guidelines and EPA guideline. Although the communication requirements within the NYC-DOH guidelines and EPA guidelines are for the remediation of mold, restoration vendors should apply the specifics within these guidelines as they relate to mold containment:
(d) With the NYC-DOH only addressing large scale mold remediation communication and the EPA stating small remediation efforts will usually not require a formal communication process as stated in Section 10.1.10 (c). Restoration vendors should communicate the containment of all mold levels with building occupants, property owners, and insurer using professional judgment based on, but not limited to the recommendations in Section 10.1.10 (b.1).
(e) The communication of mold containment between restoration vendors and building occupants, property owners, and insurer should be conveyed in writing, while verbal communications should be confirmed in writing.
(f) As part of their companys operation procedures, restoration vendors should have a formal communication process in-place for document control as specified in Section 5.4 Document Control in the Loss Recovery Guide with Standards, which should include mold formation: "Procedures describing the methods of preparing, reviewing, approving, distribution and revisions of documents, which affect quality, should be developed." An example of formal document control procedures is shown in Illustration 10-2:
Document Description |
Preparation |
Review (1) |
Review (2) |
|
Quality Assurance Procedure |
Quality Control Inspector |
Quality Control Manager |
President |
|
Mold Containment |
Project Manager |
Operations Manager |
President |
|
Message Reply * |
Supervisor Technician |
Project Manager |
Operations Manager |
|
Material Request Order (MRO) * |
Supervisor Technician |
Operations Manager |
Procurement Officer |
| * On fast track projects or emergency services, the approval of a "Message Reply" or "MRO" by upper management could delay the overall project. In cases such as this, restoration professionals should pre-formulate what shall or shall not be included within a "Message Reply" or ordered using a "MRO" shall be pre-determined. Along with a formal method of follow up to assure the "Message Reply" or "MRO" is as stated and/or requested. | |||
Illustration 10-2
10.1.11) Conclusion
(a) Restoration vendors that perform loss-mitigation, restoration, or mold containment should follow all applicable safety and health regulations developed for construction, asbestos, lead, etc.
(b) Restoration vendors that work within the residential market (i.e. single family, multi-family) should apply all safety and health regulations developed for construction, asbestos, lead, etc. in commercial or institutional structures within their residential market practices. When trying to understand safety and health regulations in the residential environment, we reference Charlie Wiles, executive director of the American IAQ Council in the AmIAQ Councils April/May 2002 newsletter; "While you may want to argue about whether or not OSHA has jurisdiction over workers in residential mold remediation projects, wed suggest that you not attempt to pursue the argument with the nearest OSHA compliance officer."
(c) Restoration vendors that perform emergency services (water loss drying) should seek mold certification:
(d) Restoration vendors and their technicians should seek water damage certification:
(e) Restoration vendors should join and get involved with a professional restoration contractors association:
10.1.12) Table 10-A
(a) Although the development of Table 10-A represents a blend of the more restrictive containment and safety measure recommended within the NYC-DOH guidelines and the EPA guidelines. When federal or state mandates or regulations supersede the recommendations within Table 10-A, or the recommendations within this article, the mandates or regulations having jurisdiction over the loss-mitigation, restoration or mold remediation project shall take precedence.
(a.1) A mold containment scope of work, when developed by a certified industrial hygienist or professional engineer, or a person certified in mold (inspection, remediation, etc.) by a professional certification organization could take precedence over Table 10-A, or the recommendations contained within this article.
Loss-Mitigation Mold Containment(2) |
||
NYC-DOH |
EPA(1) |
Notes(3) |
|
Level I: < 10 sf |
Small Area: |
a, b, d, e |
|
Level II: 10-30 sf |
Medium
Area: |
c, f, g, h, l |
|
Level III: 30-100 sf |
||
|
Level IV:
>100 |
Large Area: |
c, d, i, l |
|
Level V: HVAC |
References
EPA guide: |
c, d, e, i, l |
|
Level V HVAC |
References
EPA guide: |
j, k, l, m |
Table 10-A
(1) The EPA states that their guidelines are general, further stating: "Their purpose is to provide basic information for remediation managers to first assess the extent of the damage and then to determine whether the remediation should be managed by in-house personnel or outside professionals." Or, in the case of mold containment, managed by a professional restoration manager, or by a certified mold remediation manager.
(2) When evaluating and applying the "Loss-Mitigation Mold Containment" recommendations in Table 10-A, column three (notes) vendors must understand that, although they represent the more restrictive guidelines between the NYC-DOH and EPA, sound judgment should be used when evaluating and applying these guidelines, which could increase or decrease the recommended disciplines.
(3) Notes · Loss-Mitigation Mold Containment · Table 10-A column three:
(a) Containment of the work area is not necessary.
(b) Seal ventilation ducts/grills in the work area with plastic (polyethylene) sheeting.
(c) Seal ventilation ducts/grills in work area and areas directly adjacent with plastic (polyethylene) sheeting.
(d) Respiratory protection (e.g., N95 disposable respirator), in accordance with the OSHA respiratory protection standard (29 CFR 1910.134), is recommended. Gloves and eye protection should be worn.
(e) Containment can be conducted by building maintenance staff. Persons should receive training on personal protection, and potential health hazards. This training can be performed as part of a program to comply with the requirements of the OSHA Hazard Communication Standard (29 CFR 1910.1200).
(f) The work area should be unoccupied. Vacating people from spaces adjacent to the work area is not necessary but is recommended in the presence of infants (less than 12 months old), persons recovering from recent surgery, immune suppressed people, or people with chronic inflammatory lung diseases (e.g., asthma, hypersensitivity pneumonitis, and severe allergies).
(g) The work area and areas directly adjacent should be covered with a plastic (polyethylene) sheeting (two-layers - 30 square feet or greater) and duct taped to contain mold formation and possible release of mold spores. (see Section 10.1.12 (g.1)
(g.1) The recommendation of plastic (polyethylene) sheeting (two-layers - 30 square feet or greater) in Section 10.1.12 (g) could include 30 square feet or less, while the use of one-layer plastic (polyethylene) sheeting in lieu of two-layers of plastic (polyethylene) sheeting for 30 square feet or greater should be based on the professional judgment of the restoration contractor and/or their technician based on the specifics of the situation (i.e. mold formation, moisture source, etc.).
(h) Personnel trained in the handling of hazardous materials and equipped with respiratory protection, (e.g., N95 disposable respirator), in accordance with the OSHA respiratory protection standard (29 CFR 1910.134), is recommended. Disposable protective clothing covering both head and shoes, gloves and eye protection should be worn.
(i) Personnel trained in the handling of hazardous materials equipped with:
(j) The work area and spaces adjacent to the work area should be unoccupied. Infants (less than 12 months old), persons having undergone recent surgery, immune suppressed people, or people with chronic inflammatory lung diseases (e.g., asthma, hypersensitivity pneumonitis, and severe allergies) should be vacated from all areas maintained under the affected HVAC system.
(k) Containment of the affected area:
(l) The HVAC system should be shut down prior to containment activities.
(m) Personnel trained in the handling of hazardous materials equipped with:
10.1.12) Loss Site Evaluation Check List
(a) Exterior Evaluation
(b) Interior Evaluation
(c) Questions and Answers
(d) Containment Procedures
10.1. 13) Publications Referenced within this Article
Relevant Links:
Time is Critical When Responding to Water Losses ....
http://www.americancraftsman.net/mold.htm
CoOL/ Stanford: pages dealing with fungi (mold,
mildew) ...
http://palimpsest.stanford.edu/bytopic/mold/
Florida State Legislation HB 1659 ....
http://www.leg.state.fl.us/data/session/2003/House/bills/analysis/pdf/h1659.hc.pdf
Klima und Lagerung: Magazinhygiene ...
http://www.uni-muenster.de/Forum-Bestandserhaltung/grundlagen/klima-hygiene.html
Clay County K-12 Library Media Policies & Procedures ....
http://www.clay.k12.fl.us/districtmedia/Procedure%20Manual%2006%20C.pdf#search='mold%20clay%20county%20library%20media%20policies'
© Copyright 2002-2008 p1m.com
[Top of Page]