MOLD ASSESSMENTS
INDOOR AIR QUALITY
INDUSTRIAL HYGIENE
Since the work on the very first mold remediation standard (the IICRC S520, First Edition), there have been controversies over who is on the committee (putting the IICRC standard together) and the content within (and left out of) the standard. I recall that during the first mold remediation standard, many occupational safety and health (OSH) professionals opposed some of the OSH language being proposed as “not reflecting” OSH standards and laws at that time. Despite the debates, the first through the third editions of the mold remediation standard got published with a chapter on “Safety and Health”. Were they perfect? No. But was it a step toward maturation for the mold remediation industry? Yes.
You see, prior to the publication of the IICRC S520, there was no written standard for mold remediation. Contractors either drew from the asbestos remediation standards various procedures (e.g., containment and air filtration) or they just tore things out and rebuilt the building. So, while the first edition was not perfect, it was a good first step toward maturation.
However, since that first step, the IICRC committee debates have led the IICRC to remove the “Safety and Health” chapter from its 2024 (Fourth Edition) standard. While some were arguing for an inclusion of risk assessment language, others thought that went too far, requiring the mold remediation standard to become “a safety and health standard”; “Something we didn’t want the standard to be,” one IICRC representative told me. So, rather than taking the next step toward maturation, the IICRC decided to remove the “Safety and Health” chapter altogether.
Why Is This Important?
As someone who has an education in occupational safety and health and has worked for over 33 years (in some capacity) in an occupational safety and health/industrial hygienist role, it has been my experience that occupational safety and health is an area the disaster restoration industry is desperately needing guidance on, not just in the form of a chapter in the S520, but in the means of business planning and the application and monitoring of the business plan(s). I have, firsthand, seen how such OSH ignorance leads to dangerous conditions, illnesses, and injuries in the mold remediation (in fact, the entire disaster restoration) industry; I have consulted companies and corporations on how to handle some of these issues; I have performed accident and incident investigations for businesses; and I have worked with OSHA and other agencies in post incident/accident investigations, volunteer business organization programs, and citation investigations and consultations. The liabilities have exceeded the mold remediation workers; they have included injuries to building owners and occupants, sub-contractors, and neighboring buildings and individuals.
It's as simple as this: If a remediation technician doesn’t care about his or her health and safety, how do you expect them to care for your own? Your family’s? Your customers’? Your employees’? Etc.
By failing to incorporate safety and health into the mold remediation standard, the IICRC has become complicit (those who would willfully violate public and worker safety and health laws) by abstention; a step that could take the industry backward rather than toward maturation.
The More Things Change, The More They Stay The Same
So, while the IICRC continues to provide revisions to the mold remediation standard, the condition of the mold remediation industry stagnates, leaving customers frustrated and potentially harmed, and worker incident/illness rates higher than the reported numbers (as many mold remediation companies are untrained in the required reporting laws governing their industry).
What Can Be Done?
I, recently, became aware that the IICRC developed a committee to develop a Field Guide (not a standard; perhaps in a future blog I can discuss the differences) for safety and health for disaster restoration professionals. Willing to volunteer my time and talents, I signed up to be on this committee. By the time I was approved, the committee was several chapters into writing the document and there were many issues with the developed content. Sufficient for this blog: I resigned the position disappointed in what was being done, by who was doing it. In my resignation letter, I cited several things wrong with the committee and document before going on to suggest ways the IICRC could correct these issues. These cited issues included but were not necessarily limited to the following:
I must warn the IICRC that the path that it is on is a dangerous one; perhaps not for the IICRC, itself, but for those who look to the IICRC for guidance in their industry. . .. I pray that the IICRC (1) strongly considers replacing the current committee leader with a competent person, (2) time is taken to develop a quality committee of safety and health professionals, (3) time is taken to develop a document that focuses on the truth in subject matter, and (4) issues a challenge to the disaster restoration industry to mature (as OSHA and other occupational safety and health regulatory bodies and industry-based agencies and organizations have done) - if not for the integrity of the IICRC and the document, for the safety and health of those who are employed in the disaster restoration industry as well as those they serve.
So, Does This Mean The IICRC Mold Remediation Standard Lost Its Relevancy?
To a point, yes. Federal, state, local, and provincial occupational safety and health laws dictate the responsibilities of employers and employees working in the disaster restoration industry. As the IICRC publishes revisions to its standards that do not reflect those requirements, their standards become less relevant to (1) those who understand these legal responsibilities and (2) care about their own, their employees’, and their customers’ safety and health.
In Closing:
There will always be those who are callous to the safety and health of others; predators who seek to profit from the needs of others. We – those who either work as mold remediators and those who hire mold remediators (i.e., You and me) – must demand better, by asking the right questions of those we intend to hire, demanding a level of quality service – guaranteed in the contracts we sign with them –, and holding them accountable to themselves and others. Sound like a big task; one you, the customer, shouldn’t have to undertake? I agree. But it is, unjustly, where the mold remediation industry has left us.
The good news is that there are occupational safety and health consultants, like the Gulf Coast Center for Indoor Air Quality Services, who work with the public (and anyone else interested) to ensure proper measures are taken to protect the health and safety of mold remediators and other building occupants. If you have any questions regarding this blog or would like to discuss a need that you have with one of our industrial hygienists, contact us for a free, no-obligation review of your needs.
E-mail: myiaq@gulfcoastiaq.com
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