IICRC S520 Mold Remediation Standard: Separating Fact from Fiction (Part 2)

March 11, 2004
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Last month, we began examining the IICRC S520 Mold Remediation Standard and Reference Guide.

I have excerpted several sections from the Standard that further define what it is and for whom it is written (those sections will be in italics). I did not list the references (Section 2), but as you will see upon reading the document, it contains several industry accepted and authoritative documents, such as ACGIH's "Bioaerosols: Assessment and Control," and OSHA 29CFR 1910, General Industry Standard.

1. Scope, Purpose, Application
1.1 Scope

This Standard describes the procedures to be followed and the precautions to be taken when performing mold remediation in residential, institutional and commercial buildings and on personal property contents of those structures.

The Standard explains mold remediation techniques, the principles of which may apply to other microbial remediation projects or services. This Standard assumes that the determination and correction of the underlying cause of mold contamination is the responsibility of the property owner and not the remediator, although the property owner may contract with the remediator or other professionals to perform these services.

1.2 Purpose
It is the purpose of this Standard to define criteria and methodology to be used by the remediator for inspecting and investigating abnormal moisture and mold contamination, and for establishing remediation and safety plans and procedures.

Because of the unique circumstances encountered in mold remediation projects, it is impractical to prescribe procedures that apply to every situation. In certain 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.

Among other things, S520 does not address Histoplasma capsulatum, Cryptococcus neoformans, hanta virus, animal-derived pathogens or other highly infectious agents, including those from bird and bat droppings. Refer to the Center for Disease Control (CDC) and/or the National Institute for Occupational Safety and Health (NIOSH) for appropriate decontamination procedures for these contaminants. See, for example, "Histoplasmosis, Protecting Workers At Risk," NIOSH and NCID, U.S. Department of Health and Human Services, 1997.

1.3 Application
This Standard was written for use by those involved in the mold remediation industry, primarily for mold remediation companies and workers, and secondarily, for others who investigate mold complaints, write remediation specifications, protocols, and/or procedures and manage remediation projects; e.g., property restorers, indoor environmental professionals (IEPs), environmental consultants, industrial hygienists, building engineers, insurance company representatives, property owners/managers and other interested parties.

In order for this industry - indeed, any industry - to communicate effectively, we must understand the exact meanings of the words we use. It is with this in mind that the IICRC Standards Committee had intense and prolonged discussions, followed by research and legal review, regarding terminology.

In particular, existing guidelines for mold remediation attempt to establish "levels" of visible mold (<10 ft2; >10, <50 ft2; >50, <100 ft2 and >10 ft2), which trigger remediation activities or confirm remediation results. The problem that "levels" of mold contamination pose is that they ignore the reality of hidden mold or settled (but non-visible) spores that might have an impact on the health of workers or occupants.

This is the reason for the "philosophical shift" that S520 represents, which was referenced in the part one of this series. As you will see in the following definitions, the IICRC has chosen to use "Conditions 1-3" in describing the fungal ecology or contamination of an environment. Those conditions must be determined the remediation contractor, sometimes with the assistance of a qualified and competent Indoor Environmental Professional - another industry term that required careful definition.

It would be a mistake to skip over the definitions in Section 3 of S520, because they impact the interpretation of everything that follows in both the Standard and the Reference Guide.

3. Definitions
Actual growth: molds that have colonized a substrate, formed fungal mycelia, growth structures and spores; are active or dormant; visible or hidden.
Assessment: a process performed by an Indoor Environmental Professional (IEP) that includes the evaluation of data obtained from a building history and inspection to formulate an initial hypothesis about the origin, identity, location and extent of amplification of mold contamination. If necessary, a sampling plan is developed, and samples are collected and sent to a qualified laboratory for analysis. The subsequent data is interpreted by the IEP. The IEP or other qualified individual may then develop a remediation plan.
Condition: for the purpose of this Standard, Conditions 1, 2, and 3 are defined for indoor environments relative to mold.
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. [...normal fungal ecology (i.e. types and concentrations of molds typically found in non-water damaged, environmentally well-maintained structures, and reflective of the ecological and climatic elements of the geographical region in which the building is located)]
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 growth that is active or dormant, visible or hidden.
Contaminated (contamination): the presence of indoor mold growth and/or mold spores, whose identity, location and quantity are not reflective of a normal fungal ecology for similar indoor environments, and which may produce adverse health effects, cause damage to materials and/or adversely affect the operation or function of building systems.
Due diligence: proper care, attention or persistence in doing a thing; such a measure of prudence, activity, or assiduity, as is properly to be expected from, and ordinarily exercised by, a reasonable person under the particular facts and circumstances.
Indoor Environmental Professional (IEP): an individual that is qualified by knowledge, skill, education, training and/or experience to perform an assessment of the fungal ecology of property, systems and contents at a job site, create a sampling strategy, sample the indoor environment, interpret laboratory data and determine Condition 1, 2 and 3 status for the purpose of establishing a scope of work and verifying the return of the fungal ecology to a Condition 1 status.
Materially interested parties: an individual or entity substantially and directly affected by the mold remediation project.
Mold: a common term for filamentous fungi, often seen as a superficial or "wooly" growth of long chains of fungi cells formed on damp organic materials. Toxigenic molds may produce a potentially harmful substance called a mycotoxin. Mold growth can degrade materials and present potential health risks to humans.
Post-remediation evaluation: an inspection performed by a remediator after a remediation project, which may include visual and/or olfactory methodologies to confirm that the remediation process has been completed.
Post-remediation verification: an inspection and assessment performed by an IEP after a remediation project, which may include visual, olfactory and/or sampling methodologies to verify that the building, system or contents have been returned to a Condition 1 status.
Preliminary determination: a conclusion drawn from the collection, analysis and summary of information obtained during an initial inspection and evaluation to identify areas of moisture intrusion and actual or potential mold growth.
Standard of care: practices that are common to reasonably prudent members of the trade who are recognized in the industry as qualified and competent.


Photos courtesy of Indoor Air Management
The next section excerpted partially from S520 is the "Principles" section. As with definitions, the Principles of Mold Remediation and their subsections pervade the entire document, and they are critical to reaching an understanding of what must be done and why. It includes:

4. Principles of Mold Remediation,
There are five general principles used in the remediation of mold-contaminated structures and materials. Applying these principles may require a multi-disciplinary approach involving professionals from several fields of expertise. The five principles of mold remediation are defined in sections 4.1 to 4.5 herein.

4.1 Safety and Health
When it has been determined that an indoor environment is contaminated with mold, remediation workers must be protected from exposure hazards. Engineering controls are the primary means for preventing exposure. Appropriate respiratory protection and/or other personal protective equipment (PPE) must be used to protect workers when engineering controls are insufficient as indicated in 29 CFR 1910.134(a)(1). It is highly recommended that a reasonable effort be made to inform occupants of and protect them from similar exposure as a result of investigation and remediation activities.

4.2 Project Documentation
It is highly recommended that environmental conditions and work processes associated with mold remediation be documented.

4.2.1 Assessment
When a preliminary determination indicates that mold contamination (as defined in S520) exists or is likely to exist, it is highly recommended that an assessment (as defined in S520) be performed prior to starting remediation. It is highly recommended that an independent IEP with no business affiliation to the remediator be used for this purpose. In circumstances where an entire building or system is fully involved as a result of Condition 3 mold contamination or when the scope of work can be determined without sampling or independent IEP inspection and assessment, engagement of an IEP for assessment may not be necessary. Furthermore, some loss mitigation services may be initiated before or during assessment of conditions and/or performance of remediation processes. Notwithstanding the foregoing, if health issues are discovered or apparent that seem to be related to the actual or suspected mold contamination, it is highly recommended that an IEP or other appropriate professional be engaged by the property owner.

4.2.2 Pre-Remediation Documentation
It is highly recommended that the extent and Condition (1, 2 or 3) to which areas of the structure, systems and contents are potentially mold-contaminated be determined and documented.

4.2.3 Documentation During Remediation
It is highly recommended that the conditions and work processes be documented on an on-going basis during remediation work.

4.2.4 Post-Remediation Documentation
It is highly recommended that the return of the remediated portion of the structure and salvable contents to Condition 1 status be documented before the structure is rebuilt or the contents reused.

4.3 Contaminant Control
It is highly recommended that the spread of mold contamination be controlled as close as possible to its source. Methods of controlling the spread of contamination are further defined herein. Initial moisture mitigation services may be performed to control amplification, while ensuring that mold contamination does not spread from more-contaminated to less-or non-contaminated areas.

4.4 Contaminant Removal
Physically removing mold contamination is the primary means of remediation. It is highly recommended that mold contamination be physically removed from the structure, systems and contents to return them to Condition 1 status. Attempts to kill or encapsulate mold generally are not adequate to solve the contamination problem.

4.5 Contamination Prevention
To prevent recontamination or future contamination, the moisture problem that contributed to the mold growth must be identified and corrected or controlled. It is highly recommended that affected salvable materials be dried to acceptable moisture content following the current IICRC Standard and Reference Guide for Professional Water Damage Restoration (S500).

Note that this covers excerpts from only four of the 15 sections in the Mold Remediation Standard. I encourage all readers to get a copy of this valuable industry document and read it from cover to cover.

In the next articles in this series, I will discuss the S520 Reference Guide and how it will influence mold remediation for years to come. Stay tuned.

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