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Did You Fail a Mold Clearance or

Did the Mold Consultant Fail You?

by Larry D. Robertson, MAC, MRC, CIEC, CIAQP

Robertson Environmental Consulting Group, LLC 2484 N FM 39 Jewett, TX 75846

ldr@tisd.net So, your building just failed a mold clearance and your now even further delayed on the re-entry into the space? What do you do? If you’re like many building, property, or facility managers in Texas you’ve suddenly found yourself at the whim of a MAC, a licensed mold assessor consultant saying, you’re now going to have to pay more to resolve the problem. Left with no available alternatives and the desires to “get you’re building back”, you simply say, “Yes, do what has to be done”. Regretfully you pay the bill but inside you may be happy because the “nightmare” is over. But the reality is… the reason that the project-failed clearance may not necessarily be related to the quality of the remedial services performed. Certainly, if a remedial company does a poor job, then failure is warranted. However, whether a remedial company actually did a poor job is quite easy to determine. A simple visual inspection to determine if all of the water damaged and/or mold containing materials have been removed from the impact area is the first step. Any mold remediation company that leaves water damaged and/or mold containing materials in a mold remediation work zone should expect to fail. As a result, most remediation companies explicitly know and strive not to leave these materials behind. After all, not only is their reputation at stake, but more times than not, failing a clearance means that they will have to incur all of the costs to re-remediate the area. Obviously, this is something they want to avoid! Step two in the evaluation of clearance involves a simple visual inspection to determine if all of the surfaces in the impact area have been wiped free of any settled dust or debris. Again, a mold remediation company that leaves dust and debris on surfaces in the work zone expects to fail clearance. Again, with obvious consequences, they typically make certain the area is “shining” before they leave. The reality is that most mold remediation projects fail clearance when the 3rd step or “testing” is performed. This is where the current mold regulations in Texas begin to breakdown relative to the protection of the consumer (you) in our state. Texas regulations require that a “mold remediation protocol” site at least one nationally recognized analytical method be used with each remediated area to determine whether mold contamination identified for the project has been remediated, as well as, the specific criteria to be used for evaluating analytical results to determine whether the remediation project “passes clearance”. This may sound “appropriate” in terms of legislative authority and language, but what has resulted as a consequence has been the development of a myriad of “individual mold clearance criteria” from consultants all over the state. No uniformity exists and it represents the “wild west” of the mold industry. MAC’s have

the legislative authority to pick whatever analytical means they want to use and whatever result will achieve clearance even if it is not based on standard industry practice or sound science. Despite published industry references on “mold clearance” and “post remedial verification”, MAC’s in Texas often just make up their own clearance criteria! As a result these criteria are often unrelated to the overall concept and goal of what mold remediation is suppose to be all about, which is to simply return mold concentrations to typical and normal background levels. To the contrary, a MAC can dictate that the presence of “1 spore of any particular fungus is enough to fail a clearance in any given project”. Perhaps in a special environment such as a burn patient ward, surgical room, or other medically sensitive environment, such stringent levels of mold control/clearance might be warranted, but this is certainly not the case for common mold remediation practices in typical offices, buildings and homes. Applying that level of mold clearance for common indoor environments is not a standard industry practice and/or supported by any specific science. From my observations, this sort of “clearance absurdity” is practiced routinely, every day throughout our state. The more “stringent” the criteria, the more likely that a remedial project will fail and the more likely the MAC will get to charge for additional services. Remedial companies are all to aware of these shenanigans and are often made to suffer unnecessary financial and reputation penalties as a result of unrealistic clearance criteria. The problem is, they won’t /can’t do anything about it. Mold assessment and remediation practices in Texas occupy a relatively small niche of individuals and companies. Many have integrated business relationships. The moment a remediation company challenges the overseeing consultant’s practice, that relationship has the great potential of going sour. If that were to occur, the consultant would most likely remove that company from its list of recommended businesses and the remedial company would loose future business. Knowing that, remedial companies essentially elects the lesser of two evils in favor of continued business opportunities with the consultant. Clearly, not all MAC’s in Texas generate “absurd clearance criteria”; however, it’s been my experience that a great many of them do. As a result, it is highly likely that a great many of the mold clearance failures experienced by building owners, property managers, and maintenance engineers are more likely related to unrealistic clearance criteria generated by the MAC rather than the failure of the remediation process. To complicate this absurdity with even more audacity, imagine that the laboratory data being utilized by the MAC is not reliable and they knew it? What did I say? Yes, you need to be aware of this too! You need to know that the analytical method most utilized by MAC’s to evaluate “air samples for clearance” involve what is termed a “spore trap”. These include devices such as Air-O-Cells, Cyclex, Allergenco cassettes, as well as a variety of other methods. Problems with the reliability and the precision of spore trap analysis from accredited and proficient laboratories dates back to a paper presented at the 2007 Indoor Air Quality Association Conference. Since that time, research citing the poor precision of spore trap analyses has also been published in a Mycologia, the worlds premiere peer-review research journal for fungi (mold), presented at 3 additional national and international indoor air quality conferences, as well as, publish in the only IAQ

industry trade journal, IE Connections. No doubt that the word is out. Certainly after 7 years of circulating this information through the IAQ industry, one would expect the MAC’s in Texas to respond accordingly. Most of them have NOT and continue to provide opinions and assessments based, in part, on data they know, or should know, are unreliable!! Who is suffering??? Ultimately You! Furthermore, I believe that you represent the best possible source to bring about a needed change in the industry. What can you do about it? Several options exist… One is do nothing. Accept the situation for what it is. Consider the premise “one has to choose their battles carefully” ignore it and move on. If this is something that doesn’t impact your life on a routine basis, then you may just want to hold your nose and get through it. Another option would be to specifically confront the consultant before the project begins with regards to the specifics of clearance. Have the MAC provide some industry accepted reference or guidance document to support the specific clearance criteria that are being offered for the project. Furthermore, have the MAC agree that any laboratory data used in developing opinions should be deemed reliable. If that involves some sort of “spore trap” measurement, then that means the data should have some level of “precision” associated with each of the results. Don’t let the MAC “blow smoke” by saying the lab is “licensed, accredited or “proficient”. They should be! You should make certain that a “precision” measurement is provided on the lab report that is “specific to each of the results that are involved with your project”. Simply saying the lab is licensed, accredited or proficient doesn’t insure that will occur! More likely than not, you wouldn’t become “technically involved” with a mold remediation project until the “failed clearance” report has been issued. That’s when the proverbial “stuff hits the fan”. Now your property has the potential of obtaining a permanent “mold stigma”. This is not good. It would have been nice to deal with the clearance specifics before now, but it’s too late. My suggestion would be to repeat the above steps. Ask the MAC to prove up that their clearance criteria are supported by science and standard industry practice. Ask for references. Also, make certain the lab data are valid. If spore trap samples, look for a specific measure of precision with each sample. If they have neither of these, then be prepared to watch you MAC crawfish across the floor in retreat. Turn on some music and enjoy the show! At that point, it would be a great time to re-represent to them the importance of the project compliance with standard industry practice and sound science. Consulting behaviors will change when the consumer actually knows more than the consultant! Obviously, that option requires a “point person” to be involved with “technical specifics” of the project. Some facility managers, owners and engineers like to be involved at that level and would enjoy vetting out those specifics. If so, go for it! Let the REC Group know if you need minor assistance to get started and we’ll be happy to oblige. However, others may not want that level of involvement and seek to hand those technical specifics off to a more experienced source. In that case, the REC Group could be of more direct service. For a nominal charge, the REC Group can essentially serve as an ancillary

consultant to the project, making certain that the mold assessment and clearance are appropriate relative to current industry practice, science, and Texas regulation. Probably after only 1 or 2 episodes of that level of oversight, your standard MAC will get the idea and modify their services to something more consistent with standard industry practice and science. If not, and if taking it to an even higher level might be necessary as a result of damages or the desire to file a formal complaint, the REC could possibly assist in that action too. Bottom line is, the REC Group is not interested in becoming your standard go-to MAC for mold assessment and remedial oversight, albeit we can direct you to reputable companies we know and recommend as providing sound judgment and service. The REC Group seeks to help you in making the mold service business in our state fairer for YOU, the consumer. Hopefully, you won’t ever need such assistance, but in the case that you do, I hope this article has been helpful in the dilemmas that you may face. If REC Group can assist let us know.