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Difference Between Recommendations and Protocols
Jason Yost • Mar 12, 2024
The Difference Between Recommendations and Protocols for Remediation
As a peer in the indoor environmental (remediation and assessment) industry, I perform various reviews of individuals and businesses on a regular basis. I’ve performed these duties since 2018, across the Southeast and Midwest United States (U.S.). And I cannot tell you how often I read reports or listen to assessors, hygienists, and other types of inspectors misuse the term “protocol”. Ladies and gentlemen, this is important, so I want to touch on (1) what each is and (2) why having an assessor who knows the difference matters to you.
Differences Between Recommendations and Protocols
Recommendations. A recommendation is something that one person presents another as worthy or acceptance of trial; a suggestion that highlights something as acceptable or attractive. The basis of the recommendation does not have to reference any specific standard of care, regulation, or guideline, nor does it have to speak to any known, specific indoor environmental stressor (or its causal factor(s)); rather, a recommendation may be made based on things like (1) a perceived indoor environmental stressor and/or causal factor(s) (rather than a verified one), (2) a bias by the contractor or assessor making the recommendation (e.g., a contractor who doesn’t install ERVs might try to recommend a dehumidifier as a fresh air intake without getting to know the specifics of the occupants’ needs or the limitations of the device), (3) a limited understanding of the available technology and processes of remediation, and/or (4) general guidelines (i.e., the copy and paste method of report writing) written without reference to superseding standards and regulations.
An example of this is when a mold assessor writes a report saying things like the following:
For verification purposes, this assessment included air and/or surface mold spore sampling to prove the existence of mold growth in the residence. The sample results confirmed mold spore contamination. There should be no occupancy throughout the sanitization/remediation process.
Once the mold sanitization/remediation has been completed a thorough post remediation verification (PRV) shall be performed by a licensed mold assessor such as [redacted]. This PRV should be conducted after the mold sanitization/remediation, but before the rebuild, in order to verify that all mold amplification has been removed.
Notice how this assessor (1) mentions “air and/or surface mold spore sampling” without providing any description of the type of sampling performed or where the sampling was performed, (2) states the “sample results confirmed mold spore contamination” without providing any specification on the interpretation models used or the disclosure of the types of mold spore populations observed abnormal at the time of their assessment, (3) provides no cause for the “mold spore contamination”, and (4) recommends “mold sanitization/remediation” without providing any specifics as to what that might look like. What do you think the homeowner paid this assessor for this? $1,500.00
Folks, there are some cheaper and some more expensive than this performing just as poorly. While some attempt to provide some specification, they are “subjectively vague” as one assessor described his process of reporting to me. This may be the most honest response that I’ve been given by anyone in my 34 years of doing this. Subjective vagueness is a type of vagueness used to refer to concepts and ideas that depend on each one’s subjective to be applicable. And the broad use of subjective vagueness is why you may ask five contractors something and get differing answers to your questions. Frustrating (and infuriating), isn’t it?
Protocols. A protocol is an official procedure or system of governing affairs related to the remediation of mold within a specified building. A protocol is based on (1) a detailed, site assessment, (2) a defined condition to the assessed indoor environment (i.e., evidence and justification for the protocol), (3) scientific research, standards of care, and regulations applicable to the various components of the protocol (e.g., if the assessment found a risk of inhalation hazards to workers, the protocol will seek to enforce regulations and standards of care relative to working in such an environment), and (4) other pertinent resources.
An example of a protocol might include details on what type (if any) air filtration should take place during remediation, including something like:
In keeping with OSHA ventilation principle and the IICRC S520, negative pressure must be maintained throughout the duration of the remediation of the work area. The negative air machine should be used in a fashion that creates negative air pressure in the work area, maintained at -5.0 Pascals (or -0.02 Water Columns [inch]) and at a minimum of 4 Air Changes per Hour (ACH). Pressurization, machine performance, and filter exchanges shall be monitored and recorded throughout the remediation processes, and adjustments made, as necessary, to maintain these engineering controls.
Additional air scrubbers and/or increased ACH may be needed to move air space where the above specifications are not met in micro-climates (e.g., in a corner of a room) with the negative air machine(s) alone. (Alevantis et al., 1996; ACGIH, 1999) If additional air scrubbers are utilized, they shall be regularly monitored and maintained to assure proper performance and cleanliness. The monitoring and maintenance of these devices should be documented.
[Redacted] offers the following guidance: Install Negative Air Machines (NAMs) within the work area(s) as follows:
1) Duct the NAMs through the primary bedroom southwest window.
2) Make-up air should be filtered and brought in through the southwest window located in the kitchen’s southwest window.
3) Ensure the HVAC systems’ NAM(s) usage is in accordance with current standards of care developed by NADCA (see section 3.10 for the HVAC protocol).
Notice how the author bases his recommendations on various regulations and standards of care. (In the report upon which this was extracted, the author has provided much more evidence and justification, even clarification, but it is too much to share in this blog.) This is a sharp contradistinction between protocols and recommendations. The recommendation was a loose fit to the subject building’s needs, while the protocol provided specification for addressing a defined condition within the subject building. The recommendation is subject to bias, while the protocol is subject to governing regulations and standards of care.
Before I go on, what do you think the homeowner paid this assessor for this? $1,500.00 Yeah, the person that paid for this report didn’t save money on the assessment, but they did get a specific answer to (1) what’s causing this or that smell or symptom or etc., (2) is there any of this or that environmental stressor (e.g., mold) in my house/office, (3) what do I/we do about it, etc.
Closing Comments:
Why does this matter to you? Well, there are a lot of reasons, here are just a few: When insurance adjusters, third-party administrators (TPAs), and/or building owners get bad advice or incomplete advice on any insurance claim or property restoration project, several things happen, impacting everyone interested in the claim/project: (1) the duration of the project is made longer by the confusion, conflict, limitations, etc. created by the recommendations in the assessor’s report, (2) the cost of any project, whether an insurance claim or not, goes up, as the risk of falling victim to predatory contract behaviors increase, (3) the risk of secondary damages increase (e.g., where someone gets poor advice on a water-damage, improper procedures may lead to bacterial infections in the building and its occupants), (4) the risk of lawsuits increase, (5) property values may depreciate, and (6) other unwanted outcomes.
This is why it is so important to have an emergency response plan and team in place before a natural disaster, plumbing leak, fire, or other unwanted situation arises. Benjamin Franklin once said, “Necessity never made a good bargain.” And I agree with him. Whether you have one of these plans in place or you’re just beginning to put one together, you need to include a competent indoor environmental consultant on your team of professionals, and you need one who will provide you the specificity that you require to safely and effectively have damages repaired. If you’re putting together your emergency response plan or just starting and want to learn more about how Gulf Coast Center for Indoor Air Quality Services can help you, contact us and let’s discuss how we may best serve you.
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