- THE MAGAZINE
Q: How does the S520 define clean? I read an article where the author stated that the S520 defines the target for remediation success as a "return to a normal fungal ecology," and that there is not a clear definition of what is clean. The author stated that, "...because of this lack of clear definition, having IEPs perform post-remediation verification leaves the remediator at risk because the IEPs will not define their clearance criteria."A: The S520 Standard and Reference Guide for Professional Mold Remediation is currently being revised, and should be available sometime in late 2006. The current edition of IICRC S520 states that, "the primary goal is to safely restore Condition 2 or Condition 3 structures, contents or systems to Condition 1." The Conditions are defined as follows:
Condition 1 (normal fungal ecology): an indoor environment that may have settled spores, fungal fragments or traces of actual growth whose identity, location and quantity are reflective of a normal fungal ecology for a similar indoor environment.
Condition 2 (settled spores): 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 that which is active or dormant, visible or hidden.
The definition of clean is never clear. It is a subjective decision as to what is acceptable. To some, the fact that an item or component of an item looks and smells good is sufficient to declare that it is clean. We all are aware that carpet and upholstery cleaning leaves a remaining percentage of soil in the fabric, yet we still declare it to be clean.
In the asbestos abatement industry, workers are required to perform services very similar to mold remediation and their goal is to abate or remove asbestos containing materials (ACM) or presumed asbestos containing materials (PACM). Removal and control of friable asbestos requires many of the same techniques used in mold remediation. The quality control measures are the same as those in S520 post-remediation evaluations. The abated area and surfaces need to be free of debris and dust. Notice what is said about post-remediation evaluation in the S520 Standard:
10.13 Post-Remediation Evaluation
It is highly recommended that a post-remediation evaluation be conducted by the remediator to confirm that the remediation process has been completed. This evaluation involves application of the internal quality control procedures of the remediator, and a sensory inspection of the containment area, to ensure that malodors, contaminated materials, and visible dust and debris have been removed.
This visual approach to quality control is not confusing to the asbestos abatement industry and should not be confusing to the mold remediation industry. In the glossary of S520, "cleaning" is defined as, "The traditional activity of removing contaminants, pollutants and undesired substances from an environment or surface to reduce damage or harm to human health or valuable materials. Cleaning is the process of locating, identifying, containing, removing and properly disposing of unwanted substances from an environment or material."
So what is clean according to the S520? It is removing and properly disposing of unwanted contaminants or contaminated materials. The remaining areas are considered "clean" when there are no:
- visible areas of mold growth
There are some restorers who may have complicated the evaluation process by suggesting that they need to perform additional services or testing beyond that stated in IICRC S520. As simplistic as it may sound, using a white towel to wipe a surface to see if it is clean is extremely helpful. In the industry, this process is known as the "white glove" test. To make it even more effective, remediators can alternate the white towel with a black towel. Some dusts won't show on a white towel because the dust is white. This may seem to be extremely low tech, and it is, but it works.
Dust serves as a surrogate for mold spores and fragments. If you remove the dust, you remove the mold. If remediators strictly follow this approach to quality control, then the post-remediation verification will almost always indicate that the remediation was successful. The post-remediation verification then establishes that the structure, contents or systems have been returned to a normal fungal ecology or Condition 1.
Post-remediation verification by an indoor environmental professional (IEP) is, in some respects, similar to the certified asbestos consultant's (CAC) activities after an abatement project is completed. Asbestos fibers are not visible, and therefore, confirmation or verification that the work was performed thoroughly is accomplished by an independent CAC. The difference is that there are specified levels that are acceptable for asbestos and there are no established levels for mold.
Assessing whether a surface or the air in a remediation project is acceptable (post-remediation verification of Condition 1) is dependent upon several factors (e.g., spatial and temporal variability; rank-order distribution; shift of fungal ecology to water-indicator fungi). These factors are variables and as a result cannot be accurately specified ahead of time. To suggest that an IEP should or could tell you ahead of time what the exact sample results from a post-remediation sampling need to be indicates a lack of understanding of what is required to characterize Condition 1 or "normal fungal ecology."
Don't be confused by explanations that arise from failing to understand what IICRC S520 recommends. Seek to find simple answers instead of complicating the issue by trying to add unnecessary parameters to the guidance given. For example, in the same article referenced in my introduction, the subject of IEP independence is characterized in the following sentence: "A true independent third party IEP works for the building owner at the building owner's request." There is no such statement in the S520. The IEP can be hired by either a remediator or property owner. The engagement by one party is no more a dependent relationship than being hired by the other party. The point of independence is not who hires the IEP, but that the IEP is not an employee of the remediator or for that matter the building owner. Keep in mind that IICRC S520 was written with the remediator is mind. In the Standard section at 9.4.3 it states "...the extent or Condition (1-3) to which areas of the structure and contents are mold-contaminated be determined by an independent IEP, with no business affiliation to the remediator, before starting remediation." The issue here is "no business affiliation."
Again, the answer to the question about remediation effectiveness is that, according to IICRC S520, "clean" means "the removal and disposal of unwanted contaminants or contaminated materials." Remediated structures, systems and contents can be considered clean when contamination, unrestorable contaminated materials and debris have been removed, and surfaces are visibly free of dust. The term "visibly" can include direct and indirect observation (e.g., using a white or black towel to wipe a surface to observe for cleanliness). Also, remediated areas should be free of malodors associated with microorganisms. At that point, it is probable that the structure, systems and contents have been returned to Condition 1. Verification that the structure, contents or systems have been returned to Condition 1 can then be performed by an independent IEP.