FALL 2001     Inside: • Mould Standards — A Moving Target? • Appeal Board Decision States Environmental Issues Reduce Assessment and Property Taxes • wasteweb.ca • Staff in the News • Staff Updates & News • 2001 Training Course Schedule MOULD STANDARDS — A MOVING TARGET? By Jim Bagley, M.C.I.O.B. Background Since 1995 there have been a series of publications produced by various expert bodies that have addressed the issue of mould evaluation and remediation. In the absence of prescriptive regulations and standards (of which there are few, if any, in Canada) these various publications have influenced the risk management decisions and responses of public health professionals, property managers, remediation contractors and consultants. Keeping abreast of changes in expert opinion is a key to ensuring that due diligence requirements are being met. Pre 2001 Standards Gypsum board contamination Health Canada was one of the first authorities in North America to produce comprehensive guidelines (Fungal Contamination in Public Buildings: A Guide to Recognition and Management, Federal-Provincial Advisory Committee on Environmental and Occupational Health, Ottawa, Ontario, 1995). This document still remains one of the most useful primers and includes an investigation algorithm which is as relevant today as it was six years ago. The New York City Health Department published guidelines on the assessment and remediation of Stachybotrys in 1993, which were updated in April 2000 to include contamination by all fungal species (New York Department of Health, Guidelines on Assessment and Remediation of Fungi in Indoor Environments, April 2000). This document was adopted by a number of parties, primarily because it used simple risk assessment criteria based on the quantity of visible fungal growth. This document never purported; however, to have any mandate, and the views expressed were those of a small select group of individuals. New Consensus Standards Two documents have been published in 2001 that have the weight of established professional and governmental organisations behind them. The American Industrial Hygiene Association (AIHA) had not published a major document on mould contamination since 1996. Their publication Report of Microbial Growth Task Force, AIHA Press, May 2001 sets out to augment existing standards and reaffirms the following key points from other documents: All fungal growth in occupied buildings, regardless of species, should be remediated as soon as possible and the moisture source rectified. Density and extent of mould growth should determine the degree of remediation and containment procedures. Remediation should comprise removal of contaminated semi-porous materials, cleaning of surfaces and removing remaining dusts. The use of bleach or other biocides is questionable in most instances. Atopic individuals and infants should be removed from affected areas during remediation work. The US Environmental Protection Agency (EPA) had been silent on the issue of mould for some time. This organisation, representing the US Federal Government, produces standards and guidelines on environmental issues that are consistently adopted throughout North America and the rest of the world. In March 2001 the EPA published Mold Remediation in Schools and Commercial Buildings. Stachybotrys under microscope The EPA states that this guide is "designed primarily for building managers", and "should serve as a reference for mold and moisture remediators". Compliance with current EPA recommendations, particularly when there are other somewhat contradictory and conflicting materials also currently available, is likely to be accepted as a clear demonstration of due diligence. The EPA has adopted the New York City Health Department principle of selecting remediation guidelines on the basis of the size of the affected area. They acknowledge that there is a lack of any conclusive research on specific methods appropriate at a certain number of square feet, but recognise that some simple criteria are required to enable remediators to select appropriate techniques. The EPA document, unlike previous guides, details remediation techniques for various materials. This document stresses the need for containment of contaminated areas and negative pressure during remediation to protect occupants and remediators from exposure to mould. The resources list provided by the EPA is extensive, and provides contact details for a wide range of other bodies that provide specialist information on aspects of mould remediation and health not addressed in previous material. The EPA document is available online at: www.epa.gov/iaq/molds/index.html, or can be obtained from any PHH Environmental office. Hidden mould SOME KEY QUESTIONS ANSWERED The following are some of the questions most frequently asked by property managers, remediators and building occupants. Answers given are based wherever possible on the AIHA and EPA 2001 guidelines. What Regulator Will Require Me to Respond to Mould Contamination? Despite the paucity of explicit Federal and Provincial Regulations on this issue a wide range of regulators including Workers Compensation Boards and Medical Health Officers have invoked their powers to make property owners and employers act on mould contamination when brought to their attention. What degree and type of containment is required for mould remediation? Any area of contamination in excess of 10 square feet should be contained using polyethylene barriers. The containment area should be kept under negative pressure using exhaust fans. For containment in excess of 100 square feet the containment should include a decontamination chamber to allow safe uncontaminated access and egress. Are biocides needed to remediate mould-contaminated materials? The use of biocides such as chlorine bleach is not recommended as routine practice during mould contamination. The effectiveness of bleach in reducing allergenic and toxigenic materials in remediation work has not been demonstrated. (In limited cases such as contamination by sewage pre-remediation, biocidal treatment may be useful to reduce concentrations of viable bacteria and viruses.) Should building occupants remain in the vicinity of remediation activities? The use of effective containment during remediation work will greatly reduce the potential for exposure of building occupants to fungal spores and metabolites. If possible remediation activities should be scheduled during off-hours when building occupants are less likely to be effected. The remediation plan should consider and accommodate individuals with asthma, allergies, compromised immune systems and other health-related concerns. Is sampling necessary? If visible mould growth is present, sampling is not necessary to plan a remediation strategy. Where litigation is involved (or likely to be) or the sources of mould contamination are unclear sampling may be required as part of the initial site evaluation. Sampling may also be useful in order to determine if an area has been adequately cleaned or remediated. Controlled removal What constitutes a successful remediation? The moisture problem has been fixed or eliminated. All contaminated material has been removed and all dust cleaned up. Mouldy odours should no longer be present. Species and concentration of moulds in the building should be similar to those found outside. People should be able to re-occupy the space without health complaints or physical symptoms. What about Mould and the General Public? Mould is at least as ubiquitous in the home as in the workplace and public buildings, if not more so. Some housing (particularly specialist or low cost tenanted housing) can be both home and workplace at the same time. Responding to mould contamination can be very costly, often more so than fixing the water problem that caused the damage. Advice on mould abatement and prevention is available to homeowners through a number of excellent publications produced by the Canada Mortgage and Housing Corporation (CMHC). Links to the CMHC and other mould resources can be found on PHH Environmental's website. For more information contact Jim Bagley on 250-499-0090 or on jbagley@phhenv.com