IICRC S520 Mold Remediation Standard: Separating Fact from Fiction (Part 1)
For almost four years now, the Institute of Inspection, Cleaning and Restoration Certification has been collecting information, reviewing scientific literature, debating technique and writing its long-awaited S520 Standard and Reference Guide for Mold Remediation.
The industry has for years demanded a document that is more comprehensive and definitive than the present New York City or Environmental Protection Agency Guidelines for Mold Remediation; producing a quality document with far-ranging implications, however, takes research, time and diligent work on the part of many volunteers.
Having served on the standard writing committee since 1991, and having attended literally dozens of committee meetings in all parts of the United States, I decided to attempt to address a number of the questions raised by industry supporters and critics alike in order to inform readers of the facts that transcend the fiction. The first segment of this three-part article begins with excerpts from the S520 disclaimer, followed by some brief comments (the excerpts are italicized and set apart to help avoid confusion).
This Standard and Reference Guide (S520) is intended to provide information about the remediation of mold-damaged structures and contents and to assist individuals and entities working in the mold remediation industry in establishing and maintaining their professional competence. Users of this document must keep abreast of the rapid developments in the field of mold remediation, implement changes in technology and procedures as appropriate and follow applicable federal, state, provincial and local laws and regulations. All mold remediation projects are unique and in certain circumstances, common sense, experience and professional judgment may justify a deviation from this Standard and Reference Guide...
In publishing this document, the IICRC is not undertaking to render scientific, professional, medical, legal or other advice or services for or on behalf of any person or entity or to perform any duty owed by any person or entity to someone else. Any and all use of or reliance upon this Standard and Reference Guide is at the user's own discretion and risk. Anyone using this document should rely on his or her own independent judgment or, as appropriate, seek the advice of a competent professional in determining the exercise of reasonable care in any given situation...
As with all IICRC standards, there seems to be an abiding fear on the part of the industry that standards will paint a conscientious, experienced remediator into a corner that prevents him or her from exercising professional judgment in extenuating circumstances. As you can see from the above, that simply is not the case. However, as you will read in the preface to S520, carelessness is never acceptable, and professional judgment on the part of the remediator will prevail.
IICRC S520 is divided into two parts: the Standard and the Reference Guide, the latter being an expansion on the concepts articulated in the Standard. The preface to S520 describes why a standard for mold remediation is needed; the document's scope; who wrote it; who it is written for both primarily and secondarily; and the philosophical shift it represents from other industry guidelines written on the subject of mold remediation. This is a fairly extensive quote, so I'll allow it to speak for itself:
Awareness of mold growth in buildings has risen sharply in recent years. Several factors have contributed to this heightened awareness, including: energy conservation measures, changes in building materials, the use of rapid construction techniques, failure of occupants to manage moisture intrusion and humidity properly and an increased reliance on mechanical (HVAC) systems for comfort control. Significant media focus has fueled increased consumer concern...
In 1994 (Second Edition, 1999), the Institute of Inspection, Cleaning and Restoration Certification (IICRC) published the Standard and Reference Guide for Professional Water Damage Restoration (S500), which describes procedures for correcting and preventing excessive moisture in buildings. While the S500 was a significant step forward in the water damage restoration industry and recognized the problem of microbial growth from water damage, it was not intended to provide specific guidance on the subject of mold remediation. The IICRC Standard and Reference Guide for Professional Mold Remediation (S520) attempts to combine essential scientific principles with practical elements of procedure for technicians facing "real-life" mold remediation challenges.
The Standard and Reference Guide is the result of three years of collaborative effort on the part of dedicated volunteers from the public, institutional and private sectors - remediation contractors, microbiologists and other scientists, government and public health professionals, industrial hygienists, representatives of remediation product manufacturers and training schools - professionals from multiple disciplines who are furthering industry knowledge in the science and practice of mold remediation. These diverse members of the IICRC Mold Remediation Standard Committee assembled with one common goal: to create a procedural standard and reference guide for mold remediation in a manner that places a high priority on the safety and health of property owners, occupants, remediation workers and other affected parties. Committee members researched and reviewed available scientific and industry literature and information on the subject of mold growth, amplification, remediation and prevention, and distilled this body of science and practice into this Standard and Reference Guide for use in remediating mold-contaminated environments.
This document is 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. The S520 is a voluntary Standard and Reference Guide. Users of this document assume all risks and liability resulting from use of and reliance upon this Standard and Reference Guide. Although attempts have been made to ensure that this Standard and Reference Guide is technically consistent with knowledge about mold remediation at the date of its publication, there is no representation or guarantee that every issue and topic relevant to mold remediation has been thoroughly addressed. Users of this document must keep abreast of the rapid developments in the field of mold remediation, implement changes in technology and procedures as appropriate and follow applicable federal, state, provincial and local laws and regulations. All mold remediation projects are unique and in certain circumstances, common sense, experience and professional judgment may justify deviation from this Standard and Reference Guide. It is the responsibility of the remediator to verify on a case-by-case basis that application of this Standard and Reference Guide is appropriate. When in doubt, apply caution and seek additional professional opinion.
IICRC S520 is presented in a two-part format: the procedural standard and a supplementary reference guide. The Standard is printed first within the document on colored pages, followed by the longer Reference Guide section. The Standard summarizes most of the significant and important procedures and methodologies of a mold remediation project, while the Reference Guide restates, embellishes and further explains those procedures and methodologies, and provides additional background information which supports the Standard...The S520 does not attempt to teach mold remediation procedures, but rather provide the principles and foundation for understanding proper remediation practices. The S520 is not a substitute for the remediation training and certification programs that are necessary to attain competence in the field of mold remediation and properly apply this Standard.
S520 is not intended to establish procedures or criteria for assessing mold contamination in an indoor environment. These issues are most appropriately addressed by professional organizations that represent Indoor Environmental Professionals (IEPs). Since these professional organizations have not agreed upon threshold exposure limits or levels of visible mold growth that constitute a concern for occupant and worker safety, the IICRC Mold Remediation Standard Committee decided not to establish action levels or procedures based upon the quantity or size of the area of visible mold growth. Remediators and other parties to the remediation process often request specific guidance regarding quantities of mold or mold spores that trigger remediation activities or confirm remediation success. Quantifying visible levels of mold growth alone is not feasible as an action level decision criterion, because of the wide range of occupant susceptibility and the inability to precisely measure exposure, along with insufficient science to support conclusions in this area at the time of publication.
Thus, S520 represents a philosophical shift away from setting numerical mold contamination action levels. Instead, it establishes mold contamination definitions, conditions (1, 2, 3) and general guidance, which, when properly applied, can assist remediators and others in determining criteria that trigger remediation activities or confirm remediation success.
S520 is a living document; subject to change as more information regarding mold contamination and remediation becomes available, and as scientific developments occur and advancements are made in remediation technology and practice. The S520 will be reviewed, evaluated and validated through application in the field. Thereafter, it is hoped that the S520 will be revised and improved, and then again reviewed, evaluated and validated through application in the field. This process and further professional and public review will allow our industry to develop a body of mold remediation science and achieve our overall goal of improving the environments in which people live and work.
Certainly, S520 is an ambitious undertaking! Next, I want to use S520 to point out the obvious: words have meanings, and we must be very precise in how we use words in writing standards. I'll begin with the definitions of three key words used throughout the standard, which impact our interpretation of everything in it. Those words are "must, highly recommended" and "recommended."
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 and procedures. It is impractical to prescribe procedures intended to apply to every mold remediation situation. In certain circumstances, deviation from portions of this Standard and Reference Guide 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 requirement, including occupational, public health and other relevant laws, rules or 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.
Words have meanings and consequences when we use them. Therefore, throughout S520, these critical words are used to specify exactly what the standard writers mean in a given set of circumstances. As you read your copy of S520, be sure to note the use of "must," "highly recommended" and "recommended," and refer back to their meanings to clarify what is "required" versus that which is merely "recommended."
Coming in March: "IICRC S520 Mold Remediation Standard: Separating Fact from Fiction (Part 2)," where we will examine in more detail the scope, application, references, principles of mold remediation and more as laid out in the IICRC S520 Standard and Reference Guide for Mold Remediation.