GAO calls for collaboration on indoor mold guidance.

[Nick Gromicko]

GAO calls for collaboration on indoor mold guidance Federal agencies, health care experts, state leaders and homeowners don’t have a consensus on handling hazards associated with indoor mold, according to the U.S. Government Accountability Office. The confusion often spills into lawsuits by homeowners claiming mold-related damages. Read on to see how the GAO wants to get everyone on the same page.

In a 65-page report, the U.S. Government Accountability Office (GAO) is sounding a rallying cry for various federal agencies to come to an agreement on the health risks associated with indoor mold, and the proper ways for homeowners and property managers to mitigate mold problems.

The GAO’s report found that despite dozens of studies by various federal agencies and health experts, none have reached a definite conclusion on the effects of exposure to indoor mold, nor is there a consensus on the best methods for mitigation. The result, the GAO said, is countless lawsuits and harm to residents’ health.

To reduce unnecessary exposure, the GAO is asking the Environmental Protection Agency (EPA), Department of Housing and Urban Development (HUD), Health and Human Services and other groups to collaborate on guidance for indoor mold studies and reports.

For its study, the GAO reviewed a 2004 report by the Institute of Medicine as well as scientific literature from the past three years. Additionally, the GAO noted that the EPA, HHS and HUD had sponsored or conducted as many as 65 federal research activities related to indoor mold exposure and discovered several data gaps. Some of the gaps concerned measurement methods and asthma, according to the GAO.

“Further, less than half of the ongoing mold-related research activities are coordinated either within or across agencies,” the GAO report stated. “This limited coordination is important in light of, among other things, the wide range of data gaps identified by the Institute of Medicine and limited federal resources.”

Information plentiful, but consistent guidance scarce

There is plenty of information available to the general public about the dangers of indoor mold exposure, the GAO found, from agencies like the EPA, HUD, the Federal Emergency Management Agency and the Consumer Product Safety Commission.

Most of the guidance is “generally consistent” on how to minimize indoor mold growth, but there are inconsistencies on the ways to mitigate the problem. The result of these discrepancies is the possibility that the public is insufficiently advised on the potential health risks of indoor mold exposure.

The GAO’s report pointed out that despite efforts by multiple federal agencies to address the indoor mold issue, no generally-accepted standards that address safe mold levels have been accepted across the board.

“According to EPA officials, the lack of federal regulation of airborne concentrations of mold indoors is largely due to the insufficiency of data needed to establish a scientifically defensible health-based standard,” said the GAO. “Another factor is the lack of scientific consensus regarding how best to measure these concentrations.”

And real estate agents should take note, mold has been the center of many lawsuits, especially those from homebuyers who find their dwellings are contaminated. Litigation involving mold typically involves claims of property damage or personal injury, the GAO noted. Courts use varying standards to determine whether “expert witness” testimony in mold lawsuits is admissible.

Courts, states tackle mold laws and litigation differently

The GAO explained that some courts admit this testimony only when it agrees with a generally-accepted consensus of the relevant scientific community. Other state and federal court judges instead choose to independently evaluate reliability of evidence by weighing factors that include the scientific community, among other factors.

Some states have taken action to establish mold exposure limits. California enacted the Toxic Mold Protection Act in 2001, requiring the state’s Department of Health Services to set acceptable indoor mold exposure limits, the GAO noted. And in 2003, Texas passed a law that requires mold remediation contractors to certify to homeowners that a mold contamination was remediated according to protocol or under a mold management plan. Additionally, property sellers in Texas have to provide buyers with copies of mold remediation certificates that have been issued for the home in the preceding five years.

The GAO also pointed out that some states bar lawsuits against real estate agents who act on behalf of sellers or buyers who truthfully disclosed known defects, while other states have laws ordering landlords to disclose to their tenants information about health hazards associated with indoor mold exposure.

Discrepancies in the studies reviewed by the GAO were apparent in the reports on health effects associated with mold exposure. The general conclusion the GAO found in the 2004 Institute of Medicine report as well as the other scientific literature from 2005 and 2007 was that particular health effects may be more clearly associated with indoor mold exposure than others, such as asthma.

“Of the 65 (ongoing federal) research activities, nearly 60 percent address asthma, and more than half address measurement methods — that is, sampling and exposure assessments for indoor mold. Some other important data gaps are being minimally addressed. For example, 5 of the 65 research activities examine the effects of human exposure to molds that produce toxins that may cause of number of adverse health effects, and only one relates to acute pulmonary hemorrhage in infants — a rare but life-threatening condition that may be caused by exposure to mold,” the GAO report said.

GAO: Coordination crucial for indoor mold guidance

Federal agencies have worked together on indoor mold contamination issues, but they’ve yet to reach a consensus on how to address it. The EPA serves as the executive secretary of the Federal Interagency Committee on Indoor Air Quality, the GAO stated, and it addresses federal research activities related to indoor air quality on an “informal basis.” But federal groups aren’t using the committee as a forum to coordinate their efforts on indoor mold, according to the GAO. This poses a significant problem, the agency said.

“Overall, despite useful information provided in the federal guidance we reviewed, some omissions and inconsistencies could cause some individuals to be exposes to indoor mold unnecessarily,” the GAO stated. The lack of knowledge of indoor mold in general can also lead to uncertainty by homeowners or homebuyers on the proper ways to remove mold from a property.


The GAO recommended that the EPA, utilize the Federal Interagency Committee on Indoor Air Quality to achieve two goals:

• Articulate and guide research priorities on indoor mold in the relevant federal agencies, coordinate information-sharing on research and provide this information to the public;
• And assist agencies with reviewing their existing indoor mold guidance for the public to ensure it sufficient alerts the public about potential health hazards associated with exposure to indoor mold, along with education on how to minimize mold in households.

“The reviews should take into account the best available information and ensure that the guidance does not conflict among agencies,” the GAO noted.

HUD and the Consumer Product Safety Commission generally supported the GAO’s recommendations for the EPA, the agency said.

[Joe Farsetta]

"According to EPA officials, the lack of federal regulation of airborne concentrations of mold indoors is largely due to the insufficiency of data needed to establish a scientifically defensible health-based standard,” said the GAO. “Another factor is the lack of scientific consensus regarding how best to measure these concentrations.”

And there you have it...

[Nick Gromicko]

http://www.iac2.org/sop.php

[Joe Farsetta]

Our standard is good, but it fails to address the following fact which stymies any resolution to the basic promlem, which is:

lack of scientific consensus regarding how best to measure these concentrations

"concensus" being the key factor

[Nick Gromicko]

"Consensus is the absence of leadership" Margaret Thatcher

http://www.iac2.org/sop.php

[James E. Braun, CMI]

Originally Posted by gromicko

"Consensus is the absence of leadership" Margaret Thatcher

Agree

[Gary L. Farnsworth, CMI]

Any court of law will not see a "Proper Mold Inspection" without tearing out sheet rock walls every three feet to sample and analyze the back sides of the sheet rock, tear out every six feet of duct work, sample every 6 feet of attic insulation, look behind every baseboard, tear out carpet and tile to look at the sub-floor, and test every suspected area of the home for mold. I am in the middle of a lawsuit on mold, and the "proper" test took a company 16 days and cost $2,800. Take my advice Nick, and get out of the mold testing/certification business. There is just too much of a chance to get sued, and for thousands of dollars.

[Nick Gromicko]

That's **** backwards.

The only inspectors who ever got sued over mold testing got sued because they DIDN'T do it or recommend it....not because the DID offer it or do it.

All business is a trade of legal safety for profit. Every home inspection assumes some risk with the profit it generates. Wanna lower your risk and increase your profit? I know you do . Here is how:

1. Get IAC2 mold certified. Courses are online at www.nachi.org/education.htm

2. Recommend mold testing.

3. Offer mold testing.

[James E. Braun, CMI]

Originally Posted by gfarnsworth

Any court of law will not see a "Proper Mold Inspection" without tearing out sheet rock walls every three feet to sample and analyze the back sides of the sheet rock, tear out every six feet of duct work, sample every 6 feet of attic insulation, look behind every baseboard, tear out carpet and tile to look at the sub-floor, and test every suspected area of the home for mold. I am in the middle of a lawsuit on mold, and the "proper" test took a company 16 days and cost $2,800. Take my advice Nick, and get out of the mold testing/certification business. There is just too much of a chance to get sued, and for thousands of dollars.

Interesting, I mold inspector doing destructive testing. I hope they used containment with negative air. What type of procedure did they follow? IICRC 502S is the most commonly used in my area for remediation, I wonder what would be used for destructive testing? I would think using borescopes and inner wall air samples would be suffice. According to:
American Conference of Governmental Industrial Hygienists (ACGIH) states in its Bioaerosols: Assessment and Control (1999 version) that indoor growth of fungus is inappropriate and should be removed.
So taking a sample on a piece of inside drywall would not be necessary. I think if I was the mold inspector being sued I would get me a better lawyer.

[Michael Larson]

Does Mould Make You Sick? Doctors Seek Answers

Bennett believes that moulds could potentially cause illness in certain susceptible people via volatile organic compounds -- gassy versions of chemicals produced as the organisms metabolize food.

She has been unable to show this in the lab so far. But she told a joint meeting of the American Society for Microbiology and the Infectious Diseases Society of America.
She has tested various moulds on the laboratory roundworm C. elegans. "Sometimes the worm swims away and sometimes the worm does nothing and sometimes the worm eats the fungus," Bennett said.

"I am actually looking for something that has never been discovered by methods that have never been worked out."

Yet hundreds of lawsuits have been filed -- and some won -- by people claiming mould in their homes or workplaces has made them ill.

[Gary L. Farnsworth, CMI]

That is why inspectors should not be doing mold testing of any kind. There are no government, state, local testing procedures, or testing results that are limited. Example, there are EPA standards on radon of 4.0 or greater. What will a judge go by in a mold case? 4, 40,000? What is the standard? What is safe? If you are IAC2 mold certified, and say that you have 120,000 spores in your home, is that safe for an average person, or is it way over for a sensitive person? Too many variables in testing. Too much liability. Does not matter if you recommend testing, or state that you do not perform environmental testing of any kind? No. You still can get sued for any reason. I am. Welcome to Kansas, Nick.

[Nick Gromicko]

???

No radon level is safe either. Radon risk is linear, no-threshold. As inspectors we don't determine if the results mean the client is safe or not. We simply pass on the results.

[Joe Farsetta]

Nick,

Your comment is technically correct.

However, unlike mold, there IS a maximum safe level for radon which has been established by the EPA.

Even the new RMI does not actually establish an acceptable STANDARD for mold levels in the home.

Before deciding how to test, perhaps the Feds should come up with a LEVEL. To date the CDC cannot and will not do this.

[James E. Braun, CMI]

Nor should they, the EPA needs to do it.

[Joe Farsetta]

Agreed, James. Agreed.

Once someone sets a true standard level, folks like you and I can stop the debating and concentrate on conformance.