Developing Procedures for Contamination Situations
Q: Our company primarily does carpet cleaning. Occasionally we handle very small water losses. Sometimes, while on a carpet cleaning job, I've discovered that the property had a previous water loss that was not professionally dried, or that may have been contaminated with sewage or mold.
We would normally turn these jobs down, but what do we do when we find out about them after we have begun work? Is there anything in any of the standards that addresses this problem?
A: Every company should develop procedures for dealing appropriately with a contaminated building. These procedures should be developed by company management and perhaps in consultation with the company's attorney. Apparently, your company has already developed at least an informal policy of turning down mold or contaminated water losses.
Property owners do not always disclose actual or potential contamination prior to starting work. In many cases, the customer may be unaware of the presence of the contamination. Your attorney may be able to add language to your work authorization that gives you some protection in this situation.
Technicians can also contribute to minimizing these kinds of problems by taking appropriate steps on each job site to determine if there are indicators that the structure may be contaminated. For instance, before each carpet cleaning job starts, the customer should be asked about any unusual odors, stains or moisture problems. The answers to these questions will help to determine whether or not there are possible conditions that might complicate the cleaning process. A secondary benefit to asking these questions is that you can offer to solve these problems in the cleaning process either as part of the process or at an additional charge.
Any information received from the customer should be documented on the work order or in the customer file. Even a response that "there are no unusual conditions" should be noted. If it is later discovered that contaminants were present when you cleaned the carpet, the note will show that you made appropriate attempts to determine whether contaminants were present, but were not provided with accurate information by the client. Your records will help demonstrate that you behaved as a reasonable and prudent person would.
Prior to cleaning the carpet, you probably perform a visual inspection for urine and other stains, general condition and type, traffic areas, filtration soiling, as well as other relevant factors. The conditions you find during this inspection affect your decisions about the cleaning procedures that you will use. While performing this routine pre-cleaning inspection, technicians should also be looking for indicators of possible contamination, including obvious odors, water staining (rings), wet areas and any other conditions that point to the possibility of a present or past moisture problem. If such conditions are found, further inquiry of your client might be appropriate. Adding these activities to the inspection that you are already performing should take little, if any, additional time.
For your routine carpet cleaning work I recommend that your technicians be familiar with and follow the Institute of Inspection, Cleaning and Restoration Certification (IICRC) S100 Standard and Reference Guide for Professional On-location Cleaning of Installed Textile Floor Covering Materials. Since you occasionally perform water damage restoration services, technicians should also be familiar with and follow the IICRC S500 Standard and Reference Guide for Professional Water Damage Restoration. These documents cover the procedures that should be used as part of your routine work practices.
If improperly done, both carpet cleaning and routine water-damage restoration services can result in microbial (bacteria and mold) amplification, possibly creating a contaminated environment. The S500 is broken into sections covering sanitary and unsanitary water losses. The sanitary water damage section applies to your routine business; having your technicians familiarize themselves with the section dealing with unsanitary water allows them to recognize situations where your company's policy might be to decline the job.
Since improperly performed carpet cleaning can result in mold growth, technicians need to be familiar with industry documents addressing the mold issue. One of the first guidelines dealing with mold was the New York City Department of Health Guidelines on Assessment and Remediation of Fungi in Indoor Environments. More recently, the Environmental Protection Agency published a document titled "Mold Remediation in Schools and Commercial Buildings," and OSHA has released "A Brief Guide to Mold in the Workplace" as a safety and health information bulletin.
All three of these documents were prepared as general guidance documents to assist decision makers dealing with these issues. They indicate that workers must be properly trained before they are permitted to perform even small isolated areas of mold clean up. The OSHA bulletin has clarified the question of when OSHA can issue citations for mold by stating, "Citations can only be based on standards, regulations, and the General Duty Clause," which requires that employers provide work environments free of recognized hazards or those likely to result in death or serious harm.
Finally, the IICRC recently completed its final review of the S520 Standard and Reference Guide for Professional Mold Remediation. The S520 has been developed by a diverse group of industry experts as a standard of care for mold remediation. It should be in print by the time you read this column. Even if your company doesn't perform mold remediation, it is still highly recommended that workers be familiar with those parts of the document that deal with mold awareness as well as safety and health considerations. You'll want to pay particular attention to the "Inspection and Preliminary Determination"; "Limitations, Complexities, Complications and Conflicts"; and the "Administrative Procedures and Insurance" sections of the S520 Standard and Reference Guide.