MOLD: Problem? or NOT?

I've been a microbiologist since 1979 so I’ve seen plenty of furor over fungi! Sometimes, to a homeowner or Realtor, it may feel like the most dangerous thing about mold is the inspection. Unfortunately that is sometimes the case. Almost 30% of our company’s business is redoing mold inspections for a homeowner after a home sale has fallen through, or is about to, due to a false positive, incomplete or otherwise unusable mold inspection report procured by the buyer. The majority of these homes had no real mold problem at all. The problem in most of these cases was that the reports did not distinguish between the simple presence of mold spores in the home and actual mold growth in the home.

Since mold spores are everywhere, it is perfectly normal and expected that there will be some mold spores in every home. Mold spores are not the problem; mold growth is the problem. However, two common sampling methods used by most mold inspectors can erroneously identify a problem where none exists. One of these is viable swab sampling, where a swab is rubbed across a surface, inserted into a vial of growth media, and sent to a lab. Any viable spore will grow in the media even if it wasn’t growing in the home. The most popular sampling method used by inspectors is air sampling, which has its place in a comprehensive inspection, but not as a stand alone method, which unfortunately is too often the case. The problem with air samples is that the lab report will tag a sample as a problem if the number of spores in an indoor sample is greater than the number in the outdoor sample. Unfortunately, the number of spores outdoors will fluctuate tremendously depending on the season, the weather and even the time of day. For example; an indoor sample taken on Monday has a spore count of 500 and the outdoor sample has a spore count of 1000. Great, no problem indicated on the lab report. Take the same two samples on Tuesday after it’s rained. The indoor sample is still 500, but now the outdoor sample is only 200. The lab report from Tuesday’s sampling tags this as a problem. Another problem with air sample only inspections is that even if a mold growth problem actually exists, air samples alone do not pinpoint the source or extent of the fungal growth, which is the information a homeowner or homebuyer actually needs.

A good mold inspection uses a combination of methods to accurately determine if there is mold growing in the home and will include ALL of the following:

The report is just as important as the inspection. Some inspectors simply hand over the lab report which provides the analytical data and typically states only whether an “elevated mold condition” exists or not. A good report should include not only the laboratory results, but professional conclusions based on those results. And finally, no mold inspection report is complete without specific recommendations as to what to do about any problems that were identified.

 

New Florida Mold Regulations

Laws regulating mold inspectors and mold remediators went into effect on July 1st 2010. The rules require that inspectors and remediators be licensed by the state, carry $1 million dollars in professional Errors and Emissions (E&O) insurance in addition to $1 million dollars in liability insurance and comply with the regulation’s standards of practice.

While mold remediation contractors may also be licensed as mold assessors if they meet the education, experience and testing requirements, the new law makes it illegal for remediation contractors to conduct their own mold inspections on buildings that they are also remediating. Remediation contractors also can no longer conduct their own post remediation clearance inspections.

It is no longer legal for anyone to claim the titles “Certified Mold Assessor or Remediator”, “Registered Mold Assessor or Remediator”, “Licensed Mold Assessor or Remediator”, “Mold Assessor or Remediator”, “Professional Mold Assessor or Remediator” or any combination thereof unless they are state licensed.

While the law went into effect on July 1st, the Florida Department of Professional Regulation (DPR) did not start accepting applications for licensure until July 1st. Therefore the DPR will not be enforcing the licensure requirement of the law until July 1st 2011. The remainder of the law however is enforceable now.

 

Imported Chinese Drywall

During a domestic drywall shortage from approximately 2004 to 2007, an estimated 320 million square feet of drywall was imported from China. Some of this imported drywall has been off-gassing volatile sulfur compounds which can produce a rotten egg odor and which is corrosive to bare copper. So components like A/C coils, refrigeration lines, plumbing lines and electronics have been failing at a higher than normal rate in homes containing this drywall. This is the most common symptom of the problem, and the only one to date that has been scientifically linked to the drywall.

Drywall is made from gypsum, which can be naturally mined or synthetic. The synthetic gypsum is made from a byproduct of power plant air scrubbers. The first theory was that the Chinese drywall was contaminated by fly ash, another power plant byproduct. But it turns out that the problem drywall was actually made from naturally mined gypsum which has been traced back to mines in the Shandong Province of China.

So far no one is sure what is causing this off-gassing. The U.S. EPA, Florida Department of Health (FDOH) and drywall manufacturers have all done comparison testing on a very limited number of samples of Chinese and domestic drywall. They found that when subjected to elevated heat and relative humidity in an environmental chamber the Chinese drywall produced two volatile sulfur gases which the domestic drywall did not; hydrogen sulfide (H2S) and carbon disulfide (CS2). They also found that the Chinese drywall contained several other compounds that were not present in the domestic samples. These are iron disulfide, strontium sulfide and some organic compounds.

None of these tests has determined what the actual component is that is causing the off-gassing. There’s speculation that it might be coming from the iron disulfide or strontium disulfide, or that fumigation materials may be reacting with the organic compounds….no one knows right now.

Our inspections to date have found, not surprisingly, that there is a direct correlation between the amount of copper corrosion and the amount of Chinese drywall in the home. Rarely have we found homes where all of the drywall was imported. Normally there is a combination of domestic and imported drywall. This is because drywall is a commodity. Builders order it not by brand, but rather based on the specifications required for the different applications present in every home (i.e.; ceilings, walls, high impact, mold resistant, etc.) When a warehouse receives the order they simply send whatever brands they have that meet those specifications. We have seen as many as five different manufacturers’ products in a single home.

There are no Federal or State regulatory guidelines for conducting these inspections. So it’s important to have one done by someone who understands the science and can provide a comprehensive inspection.

The procedure we use is based on the analytical data collected from the studies conducted to date by the Florida Department of Health, EPA, and the drywall manufacturers. It uses all of the currently available indicators to determine the presence of Chinese drywall.

We are closely following the EPA, CPSC, CDC, FDOH and industry research, and will be amending this procedure as new facts come out.

 

New EPA Lead-based Paint RRP Rule

The new U.S. Environmental Protection Agency (EPA) Lead-Based Paint Renovation, Repair and Painting Program Rule went into effect April 22, 2010. This rule requires all renovation, repair and painting work including electrical, plumbing, painting, carpentry and even hurricane window installation, to be conducted by firms that have been trained and certified by EPA. Workers must use lead-safe practices including containment of the work area, wearing of personal protective equipment such as respirators, and proper clean-up techniques such as HEPA filters to clean the air and HEPA vacuuming of surfaces after work is completed. Clearance testing is also recommended. Exceptions to this rule are homes built after 1978, housing for the elderly and disabled (unless children under 6 live with them), zero bedroom dwellings, projects disturbing less than 6 square feet of painted interior surfaces or 20 square feet of exterior surfaces, and homes or components that have been found to be lead-free by an EPA certified Lead-Based Paint Inspector or Risk Assessor. A list of local EPA certified inspectors, risk assessors and renovation contractors can be obtained from the National Lead Information Center at (800) 424-LEAD.
 
Property managers, their employees, maintenance workers and contractors, which includes anyone receiving compensation for repair, renovation or painting work,  must provide the occupant (homeowner, tenant, etc.) with EPA’s pamphlet Renovate Right within sixty days prior to starting the work. Written confirmation of receipt of the pamphlet must be obtained from the occupant. In addition, the pamphlet and signs describing the nature, locations and dates of work to be performed must be posted at the job site. The pamphlet explains the law and the ways the contractor or property management company must perform the work to prevent contamination of the home with construction dust and debris which could potentially contain lead. Techniques which create dust such as dry sanding, scraping and certain uses of heat guns are prohibited.

The reason EPA and HUD continue to promulgate new lead-based paint regulations is because there are still significant numbers of children with elevated blood lead levels in the US. Elevated blood lead levels can affect a child’s brain and nervous system development resulting in lower IQ, learning disabilities and behavioral problems. In adults elevated blood lead levels can result in numerous health problems including hypertension and kidney disease.

Most people think that lead poisoning is caused by ingesting paint chips. While this does occur, the main route of lead poisoning in both children and adults is ingestion and inhalation of lead particles contained in household dust.  Lead-based paint which is present in the home, especially on high wear or friction surfaces such as doors, windows, stairs and flooring, releases invisible lead particles into the air which then settle into the household dust. In addition, lead-based paint on exterior surfaces of the home can contaminate the soil around the home which is then tracked inside on shoes. Renovation and repair activities which disturb painted surfaces are a major contributor to the lead content of household dust. The dust is then inhaled or ingested by hand to mouth contact. That is the reason the EPA has issued this new regulation which strictly controls these activities and that is also the reason that the potential maximum fine for non-compliance with the rule is a hefty $32,500 per violation, per day.

Lead based paint is present in a significant number of homes built prior to 1978 when EPA banned its use in residential properties. The older the home is the higher the probability of lead-based paint being present. The following table is based on the latest HUD data and shows the probability of a home containing lead-based paint based on the age of the home.

While most people think of public housing or other low income dwellings when they think of lead-based paint, the opposite is true. Lead-based paint was an expensive and durable paint. Most of the lead-based paint that our company has identified in South Florida is on older, high end homes, such as those in Palm Beach, Rio Vista, Key Biscayne, Star Island, etc.

There is an alternative to the costly requirements of this rule. As stated above in paragraph 1, any home or component that is inspected by an EPA Certified Lead-Based Paint Inspector or Risk Assessor which is found to be lead-free, is exempt from this rule and can be repaired, renovated or painted by non-certified contractors or management company employees. This can significantly decrease the cost of repair, renovation and painting projects. Unlike other home inspections, once a lead-based paint inspection states that there is no lead present, the report is good forever so it can also be used for all future RRP activities.

Another advantage to having an EPA certified lead-based paint inspection prior to the renovation or repair is that the report can also be used later to meet the requirements of the Title X Lead-Based Paint Disclosure Rule, when the home is sold or leased. Under Title X, a seller or landlord or their representative must provide the buyer or tenant with another EPA pamphlet, Protect Your family From Lead in Your Home, prior to ratification of a contract or lease. The buyer then has 10 days to have a lead inspection, or they must sign a release refusing one. Having a clean lead-based paint report on hand avoids this delay and uncertainty and can add value to the home.