Mold Safety Concerns
By Mark Drozdov and Carey Vermeulen with Amanda Hosey
Working in the remediation field, we often hear client concerns about mold and its associated health risks, hypersensitivities, and finance-crippling lawsuits, but, despite this, some in the industry continue to underestimate the hazardous effects of mold on workers and occupants. But mold, just like the other contaminants of concern, is dangerous to our health, and failure to prioritize mold safety puts our people, clients, and company in harm’s way.
The bodily effects of mold exposure are many but are primarily respiratory related—from sinuses down into the lungs. There is also the potential for mold to affect one’s immune system long term, making a person not only more susceptible to mold, but also to other respiratory-related illnesses. These reactions occur both in immunocompromised people as well as healthy individuals with no prior allergic reactions. This is why it is so important not to overexpose workers in occupational settings.
This article aims to provide restoration companies an overview of the risks related to mold remediation work and how to keep workers safe while protecting the company from associated liability. This is part of a larger series (Look for more articles from this series in past and upcoming issues.) on PALMS, which is an acronym used to discuss these contaminants of concern:
- Asbestos (March/April 2021)
- Silica (July/August 2021).
Hypersensitivity and workers
For years, clients who reported hypersensitive reactions to mold were met with suspicion and derision from many restoration and insurance companies alike. However, scientific studies like those from the Institute of Medicine have found sufficient evidence to link indoor mold exposure with upper respiratory tract symptoms—coughing, wheezing, shortness of breath, stuffy nose, itchy eyes and skin, fever, etc.—in otherwise healthy people, in addition to the immunocompromised. These findings have compelled most of the industry to accept the existence of hypersensitivities.
It is important to remember that those same sensitivities in clients can occur in front-line workers—and hypersensitivity can develop over time from overexposure to mold. Many remediators working in the field prior to the rise of safety equipment use were exposed to high concentrations of mold over the years and have since developed their own hypersensitivity to the substance. Those in the industry who still do not take the proper precautions (PPE, pressure differentials, containment, etc.) are opening themselves up to the same problems, and the adverse effects of exposure might not be evident until much later.
Many have questioned whether hypersensitivity or the potential for hypersensitivity should preclude someone from working in the industry altogether, but avoiding the work is unnecessary—and unrealistic on a larger scale. If we avoided all hazardous materials, restoration and many other industries would cease to exist.
There are many hazardous materials that workers can interact with safely. The other contaminants of concern on the P.A.L.M.S. list all pose dangers to workers, and potentially more so than mold, but technicians are able to work with them without harm. The key is exposure prevention. If workers understand the materials they work with, whether mold, asbestos, PCBs, silica, or other contaminants; know how to prevent exposure through containments, negative air, engineering controls, administrative controls, and personal protective equipment (PPE); follow best practices; and get licensed, they will be protected.
Despite the interaction with dangerous materials, hazard pay is illegal in settings with mold or other contaminants because it offsets the exposure prevention responsibility by shifting focus from prevention to reaction. The responsibility to prevent exposure is both a moral and legal one that depends on proper controls.
Personal protective equipment
Remediators should always wear proper PPE for every potential exposure. This means skin coverage, respiratory protection (with a HEPA-filtered P100 and organic vapor cartridge), and eye protection. Per the United States Occupational Safety and Health Administration (OSHA), the level and type of PPE for each project should be determined by performing a risk/hazard assessment.
While we recommend workers wear full-face respirators whenever possible because it gives a slightly higher protection factor and covers the eyes, many workers prefer half-face respirators because they wear glasses, have respiratory issues, etc. Added eye protection in these cases is essential, and skin should be protected using disposable coveralls, booties, and sometimes a double layer of nitrile gloves. A hood is highly recommended, and in some cases, work gloves are, too. Any openings—at the wrist and ankles and around the hood and respirator—should be sealed with tape.
Regulations and training
Mold remediation work is not regulated at the federal level in the United States, but more and more states (15 currently) are implementing their own regulations on the industry. Likewise, in Canada, mold remediation, except for in health care facilities and government buildings, is not regulated at the federal level, and a push for providence-level regulations is underway. (Quebec currently has regulations in place.) With the continued growth of weather-related water-infiltration events, like major hurricanes and flooding, regulations will, no doubt, grow in response to needed large-scale remediation recovery work.
OSHA and the U.S. Environmental Protection Agency (EPA) have issued numerous guidance documents on safe work practices with mold, especially in schools and other institutional and health care settings, that address proper management of mold growth and limiting worker exposure, but these are recommended practices, not laws. Importantly, however, the General Duty Clause of the OSH Act of 1970 requires “due diligence,” and similar requirements for due diligence exist in Canada under the guidance of the Canadian Centre for Occupational Health and Safety.
Due diligence places the onus on employers to ensure workers are not exposed to hazardous conditions that could cause serious harm on the job site, as well as to comply with the safety and health standards set forth in the Act. This means that, while there may be no direct laws regulating the work in an area, it is still the responsibility of the employer to protect employees or face penalties ($13,653 per serious violation and up to $132,598 per violation in the case of willful or repeated offenses per OSHA). Due diligence requires a site risk/hazard assessment and the development of an exposure control plan that lays out the appropriate equipment and PPE needed, among other requirements, but it is unfortunately not uncommon for workers to go forward with a project without performing an acceptable risk assessment.
Proper remediation training is key to ensuring due diligence is followed. It is more important than simply making sure workers know how to do their jobs; training also teaches them how to protect their own health and safety, as well as that of their families and others they could expose secondhand. The ANSI/IICRC S520 Standard for Professional Mold Remediation provides guidelines for workers to properly decontaminate themselves when leaving a containment area to prevent just that. If workers are not aware of the practices laid out in the Standard and the required due diligence, they will open themselves up to exposure, and the company opens itself up to legal, moral, and potentially criminal liabilities due to health-related issues.
[infobox title=’A Note on Containment’]Outside of small amounts of mold or where it is limited to the surface and can, therefore, be remediated with source removal, containment should be built. Once we have moderate or significant levels of mold present and must remove building materials, containment with pressure differentials is necessary to contain dust and spores in a localized area. This prevents cross contamination of unaffected areas.
If you spread the hazards to otherwise clean areas, you are creating additional work for yourself to rectify the situation—or worse, if left unaddressed, creating liabilities for your company. In states and jurisdictions with mold regulations in place, it is illegal not to build containment.[/infobox]
Pre-sampling and PRV
Sampling costs money, but it is an expenditure that protects workers, occupants, and companies, both before and after a remediation project.
One of the most important aspects of remediation is to initially locate the mold. Condition 3 contamination (“Conditions” are defined in the ANSI/IICRC S520.) identification is easy to find, as it consists of visible mold and/or active growth, but in situations with Condition 2 mold, where an area is contaminated with settled spores spread there by airflow, people, etc., it can typically only be identified by sampling.
Clients might be apt to say, “The mold is there on that wall. I just want it removed,” but discovering any other contaminated parts of the building is critical to the work. As a contractor, it is important to identify Condition 2 areas via pre-sampling to
avoid taking blame for their contamination, and the only way to do that is to find them ahead of time. Entering a project without establishing background levels leaves you open to liabilities if Condition 2 contamination is later found.
We sometimes hear people in the industry say sampling is unnecessary because there is no established threshold limit to which we can compare samples, as exist for PCBs, asbestos, lead, or silica. While it is true there are no recognized limits for mold contamination, comparing post-remediation samples against pre-work samples taken in unaffected areas provides proof of success (or failure) on a project; alternatively, juxtaposing post-remediation sampling with samples taken from outside also offers a means for judging success. The air inside the building should have the same types of mold as outside, only at much lower concentrations.
Sampling is key to post-remediation verification (PRV), which serves as a risk assessment for reoccupancy. There are other verification processes beyond sampling that are important, like visual and olfactory inspection, but surface and air sampling are highly important for gauging remediation success. It is important to note that PRV by a third-party, independent of the contractor, is required in areas where mold remediation is regulated.
An indoor environmental professional (as defined by the ANSI/IICRC S520), which may be refered to as a certified mold accessor or industrial hygienist depending on jurisdiction, certifies a project’s completion by ensuring: all visible mold is removed, areas are dust free, no dirty water is left behind, and everything is clean overall with nothing of concern left behind for occupants.
Focusing on safety
Recognition of mold hazards and early remediation date back thousands of years. The Bible chapter Leviticus refers to “defiling mold” and provides methods of remediation, including inspection and removal of contaminated areas and ultimate demolition of the entire structure if the mold could not be removed or contained.
If people living more than two millennia ago recognized the inherent dangers mold exposure poses, then perhaps it is well beyond time all remediation professionals do as well. We must ensure anyone interacting with mold contamination is properly trained and equipped to protect themselves and those around them, that we use all the tools in our box—including proper work practices, containment, and sampling—to guarantee success, and that we lean on post-remediation verification to prove that success to insurance adjusters, clients, regulators, and ourselves.
Ultimately, adhering to safety guidelines for mold remediation can only serve our companies. They benefit us by protecting our most important resources, our workers and clients, while also protecting our businesses from lawsuits and a destroyed reputation.
ANSI/IICRC S520 Standard and IICRC R520 Reference Guide for Professional Mold Remediation
OSHA Safety and Health Topics: Mold
EPA Mold Guide
CDC Mold Guide
“General Duty Clause,” OSH Act of 1970
NYS Department of Labor Mold Program
NYC Health Mold Guide
“Damp Indoor Spaces and Health,” Institute of Medicine
NIEHS Disaster Recovery: Mold Remediation
Mark Drozdov is known for his diverse work in environmental, health, and safety (EHS) projects worldwide including HazMat remediation; industrial hygiene; hazard/risk assessment; and compliance training, certification, and audits. He contributes to the AIHA/RIA/IICRC Crisis-Response Joint Task Force, IICRC Board of Directors, ISO infection control and EHS standards, and AIHA government relations. Drozdov’s PALMS program is the go-to method for dealing with contaminants of concern. Email him at [email protected].
Carey Vermeulen is the owner of Indoor Air Management Canada. He is known as one of the IICRC’s busiest instructors, averaging more than 70 classes yearly, has served on the IICRC Board of directors for 23 years, including three as president, and was elected chair of the executive committee for 2022. Vermeulen helped develop the ANSI/IICRC S500, S520, S100, and S300 (for which he was chair) standards. He is an industry speaker, technical author, and consultant to the restoration, cleaning, and insurance industries.
Amanda Hosey is the managing editor of Cleanfax. She has worked as an editor and writer for more than a decade, including seven years with Cleanfax. Reach her at [email protected].
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February 21, 2023