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This is a continuation of a paper presented by me on September 30 in Vancouver, BC to the Air and Waste Management Association. The first part on regulatory activities was in last month’s issue.

Standards

The S-520 Project
In the year 2001, members of various organizations involved with providing services related to the indoor environment became concerned about the growing need for uniformity in mold remediation and initiated a project to develop an industry consensus standard to dealing with mold contamination in buildings. Although this work has drawn from the various guidelines that currently exist, the objective of the design team was to establish a new paradigm and is best described in the introduction to the Standard:

“This document is the result of a collaborative effort primarily involving industry experts, companies, training schools, industry trade associations, government and educational institutions, institutes and professional societies. The three principal designers of the document include:

• Institute of Inspection, Cleaning and Restoration Certification (IICRC)
• Indoor Air Quality Association (IAQA)
• Indoor Environmental Institute (IEI) Other organizations contributing to the creation of this document include the American Indoor Air Quality Council (AmIAQ), the Association of Specialists in Cleaning and Restoration (ASCR, International), the International Society of Cleaning Technicians (ISCT) and the National Air Duct Cleaners Association (NADCA). The publication of this document was made possible through the boundless contributions of a dedicated group of experts. The IICRC Board of Directors and the Standards Committee members genuinely appreciate the time and effort contributed by these individuals. They exhibit the true volunteer spirit that has been the driving force behind the IICRC since its inception.”

The document is designed to set the standard of care for remediation contractors. The committee and other contributors represent a broad section of individuals from industry, consulting firms, law, academia and science. The prime criteria for selection of contributors were knowledge of the processes and willingness to submit to the ambitious schedule that the group imposed for completion of the document. The core working committee consisted of 33 individuals. An additional 40 persons are listed as contributors and over 250 participated in the initial peer review. This represents the majority of the United States based individuals who are considered “expert” in indoor environmental issues.

The membership of the main committee with one exception was composed entirely of US residents so the document strongly reflects terminology and practices common in the United States. At the same time, the primary sponsoring organization, the IICRC, is owned by trade groups from throughout the world and every effort possible was made to produce a document that can easily be adapted to incorporate national and regional needs.

The publication will actually consist of two documents. The first is the Standard, which defines the “state of the art” and, “… describes the procedures to be followed and the precautions to be taken when assessing moisture intrusion and performing mold remediation in residential, institutional and commercial buildings. The standard defines mold remediation techniques, the principles of which may apply to other microbial remediation projects or services. The second is a reference guide that expands on and explains the concepts introduced in the standard.

In addition to the main committee that discussed and voted on the contents of each section, the group was broken up into a series of sub committees. Each sub-committee was charged with drafting a given chapter of the reference guide (and the corresponding Standard language) and presenting that content to the main committee for discussion and consensus. Issues that did not obtain consensus in the main committee were referred back to the responsible sub-committee for additional research, study and revision. The smaller working groups were tasked with identifying research or source documents relating to the points at issue.

Critical Definitions
The key to the S-520 standard is a series of definitions that guided the deliberations of the committees. The first set of these dealt with the force of the recommendations set forth in the documents. The committee settled on three levels of importance that are explained at the very beginning of the document:

“Important Definitions Throughout this document the terms “must”, “highly recommend(ed)” and “recommend(ed)” are used to compare and contrast the different levels of importance attached to certain practices. It is impractical to issue blanket rules intended to apply to every mold remediation situation. In extenuating circumstances, deviation from portions of this standard may be appropriate. Carelessness is never acceptable and common sense and professional judgment are to be exercised in all cases.

must: when the term must is used in this document, it means that the practice or procedure is mandatory due to natural law or regulatory requirements, including occupational, public health and other relevant regulations, and is therefore a component of the accepted “standard of care” to be followed.

highly recommended: when the term highly recommended is used in this document, it means that the practice or procedure is a component of the accepted “standard of care” to be followed, while not mandatory by regulatory requirement.

recommended: when the term recommended is used in this document, it means that the practice or procedure is advised or suggested.”

The IICRC S520 Standard Committee interprets the “standard of care” to be: practices that are common to reasonably prudent members of the trade who are recognized in the industry as qualified and competent.

Part 3 of the Standard contains additional definitions, a commonly held view of which is necessary to clear understanding and interpretation of the standard and its meaning. Less critical terms are defined in an extensive glossary at the end of the document. The definitions that were the target of the most intensive and prolonged debate were those that dealt with the “condition” on interior spaces. These definitions are key to determining when remediation is required, what level of intensity the remediation project demands and when remediation is satisfactorily completed. It is these definitions that will receive ongoing discussion and be the object of both support and controversy. These definitions addressed the most often raised question in discussions of indoor environmental quality, “How clean is clean enough?”:

“contaminated (contamination): the presence of indoor mold growth and/or mold spores, whose identity, location and amplification are not reflective of a normal fungal ecology for an indoor environment, and which may produce adverse health effects and cause damage to materials, and adversely affect the operation or function of building systems.

Condition: for the purpose of this standard, Conditions 1, 2, and 3 are defined for indoor environments relative to mold. Definitions for each Condition are provided here.

Condition 1 (normal ecology): an indoor environment that may have settled spores, fungal fragments or traces of actual growth whose identity, location and quantity is reflective of a normal fungal ecology for an indoor environment. (ed. – This recognizes that indoor environments are seldom or never “sterile” as a normal condition. Some contamination is normal and possibly desirable.)

Condition 2 (settled spores and trace growth): an indoor environment, which is primarily contaminated with settled spores that were dispersed directly or indirectly from a Condition 3 area, and which may have traces of actual growth.

Condition 3 (actual growth): an indoor environment contaminated with the presence of actual mold growth and associated spores. Actual growth includes growth that is active or dormant, visible or hidden.”

The greatest question posed by the above definitions is, “How do you tell the difference between the three condition levels?” or stated in another way, “Who makes the determination of condition?” The document deals with this burning question in two ways that we will discuss in next month’s column.

Mr. Baker’s field of expertise is the control of contamination in air-conditioning and ventilating systems by mold, mildew and bacteria. He writes and speaks frequently about the efficacy, legal risks, and regulatory issues involved in various control strategies. He serves on ASHRAE Technical Committee TC 2.3, TC 2.4, TC 9.8, and Sampling of Airborne Particulate Concentration in Commercial and Residential Buildings GPC 17P. He also serves as a member of ASTM D22.06 (Indoor Air Quality) and is on the Board of Directors of the Indoor Air Quality Association and the Florida Public Health Foundation. Because HVAC applications encompass new uses from an U.S. EPA regulatory standpoint, Mr. Baker works closely with the EPA and industry groups, including serving as the chair of the IAQ committee of the Consumer Specialty Products Association, to help formulate policy in this area.

Bob Baker is Chairman and CEO of BBJ Environmental Solutions, Inc., a company specializing in providing clean air through environmentally responsible products, such as BBJ MicroBiocide , BBJ Micro Coil Clean , “FreshDuct Odor Eliminator “, and BBJ Mold and Mildew Remover™ as well as the revolutionary new Power Coil Clean™. For additional information, Mr. Baker can be reached at (800) 889-2251 or through the company web site at www.bbjenviro.com.