Mold and Worker Safety

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Mold and Worker Safety

• State of the ArtState of the ScienceState of
  the Regulations
• presented byMary Ann Latko, CSP, CIH, QEP

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Why are we finding mold now?

• 1970s/1980s mold contamination identified as
  primary cause of poor IAQ in 5 of investigations
• 19861996 molds primary source of
  contamination 35-50 of the time
• 70-80 in newly constructed buildings and
  residences

Until recently, we did not look for mold
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When is mold a concern?

• When there is sustained growth of mold in a
  building
• When there are complaints from building
  occupants
• When there are reports of adverse health effects

• NOT whenever mold is found
• Mold can grow wherever there is high humidity or
  condensation (moist air, cold surfaces)

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ASSE and standards development

• Representatives on nearly 40 standard development
  committees
• Developing and maintaining almost 100 safety,
  health, and environmental voluntary national
  consensus standards
• Secretariat for 9 ANSI standard development
  committees and canvass projects
• Appointed Secretariat for ANSI Z690Guidelines
  for Mold and Fungi Control and Remediation for
  Worker Protection in Indoor Work Environments

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ASSEs mold initiatives
ASSE/ANSI Z690 Canvass Project
Technical White Paper
Position Statement
Teleconference Call
Steering Committee
Resource Listings (web pages)
Education/ Outreach
PDC Sessions
Legislation Tracking/Response
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State legislationTracking and response

• H2272 (AZ) IAQ in schools
• 1350 (FL) Mold Remediation Registration Act
• S22 (GA) Toxic Mold Study Committee
• S3160 (HI) Advisory Board
• H292 (IN) Mold Exposure Standards and Task
  Force
• H132 (KY) IAQ
• H5422 (MI) Unsafe building sales
• L1106 (NE) Schools

• A639 (NJ) Comprehensive Mold Hazard Remediation
• S2816 (NJ) Mold Hazard Study Commission
• S896 (NY) Toxic Mold Protection Act
• H2554 (OK) Fair Assessment and Remediation Act
• S2731 (TN) Home Inspector License Act
• H281 (UT) Real estate disclosures
• H824 (VA) Virginia Residential Landlord Tenant
  Act
• A660 (WI) Certification of Mold Inspectors

Florida 1350 Hawaii S3160 Indiana H292 New York
S896
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Regulatory Standard vs. Industry Consensus
Standard

• Why isnt EPA or OSHA addressing the issue?

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Why isnt there a (regulatory) standard?

• No established, quantitative, exposure-response
  relationships
• No method measures all components
• Not a single entity over 100,000 types of mold
• Variances in personal sensitivities
• Response is none to fatal
• Does not follow toxicological dose-response

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Why isnt there a (regulatory) standard?

• No known mold biomarkers
• Chemicals in the body which have a particular
  molecular feature that make it possible to
  measure if an individual has been exposed to
  disease causing organisms as well as the progress
  of the disease or treatment
• Traditionally used to prove correlation between
  exposure and symptoms or disease

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Needed information

• Which mold species or genus cause adverse health
  effects
• Threshold level(s) for these health effects
• Form(s) and route(s) of exposure
• Work practices that create the exposure
• Appropriate worker and public protection methods

Need clear, good scientific dataand general
consensus on these points
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Needed information

• Reliable and reproducible sampling methods
• Reliable and reproducible analytical methods at
  or below the identified threshold level(s)

Need clear, good scientific dataand general
consensus on these points
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Regulatory Standard vs. Industry Consensus
Standard

• Why is ASSE addressing the issue?

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Mold and the indoor working environment

• SHE professionals are responding to
  mold-related issues NOW
• Work is being performed in the absence of a
  universally accepted standard from a cognizant
  authority
• Guidelines for execution of such work are
  required
• Protection of workers
• No increase in risk to building occupants

ASSEs primary focus is worker protection
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Standard of care is needed

• Can not wait until we are comfortable with the
  science
• Need guidelines NOW, even if the science is
  still maturing
• Approach not new
• 1980s Hazardous waste site workers
• Framework needs to be established
• Protect workers from potential adverse health
  effects
• Evaluation of preventive or remediation measures

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Standard of care considerations

• Preventive measures
• Visual inspections
• Building design, operation and maintenance
• Assessments
• Key parameters
• Problem indicators
• Sampling and testing
• Reproducible methodologies
• Interpreting results

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Standard of care considerations

• Steps to minimize worker exposure
• Engineering measures
• Personal protective equipment
• Remediation procedures
• Appropriate levels of response
• Prevention of recurrence
• Training and certification
• Certified SHE professionals operating under a
  code of ethics
• Non-SHE professionals performing work

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Z690 Guidelines for Mold and Fungi Control and
Remediation for Worker Protection in Indoor Work
Environments

• A Canvass Method Standard Development Project

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What is the canvass method?

• Proposed standard drafted by members of the
  designated accredited standards development
  organization
• Canvass list developed
• List of potential canvassees must conform to
  lack of dominance requirements and include
  interested parties and persons materially and
  directly affected
• Canvass initiation announced

No fewer rigors than committee method Over
two-thirds of ANSI standards are developed via
the canvass method
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What is the canvass method?

• Canvass conducted
• Views and objections disposed
• Developer must have prompt considerationof
  written views and objections from canvassees
• Public comment period
• Appeals process initiated (if needed)
• Proposed standard submitted to ANSI for approval

No fewer rigors than committee method Over
two-thirds of ANSI standards are developed via
the canvass method
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Existing canvass method standards

• All UL standards
• ANSI/ISEA 102 Gas Detector Tubes
• ANSI/ISEA 104 Air Sampling Devices
• ANSI/ISEA 105 Hand Protection Selection
  Criteria
• ANSI/ISEA 110 Air Purifying Respiratory
  Protective Escape Devices
• ANSI Z89.1 Industrial Head Protection
• ANSI Z358.1 Emergency Eyewashes and Showers

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Actions to date

• JUL 2003 announcement of ASSEs proposed
  initiation to develop a standard to address
  worker protection issues during mold remediation
  projects published in Standards Action
• No negative comments received
• SEP 2003 ASSE awarded Z690 Secretariat
• JAN 2004 Solicitation for committee applicants
  sent to ASSE members

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Actions to date

• FEB 2004 Initial review of applications
  completed
• MAR 2004 Initial committee member selection and
  structure established
• Drafting to begin immediately
• Upcoming actions
• JUN 2004 Presentation on status of canvass
  project at ASSEs Annual Professional
  Development Conference

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Z690Preliminary draft of scope

• Intent is to provide minimum requirements to be
  followed for the control and remediation of mold
  and fungi in non-industrial and industrial work
  environments
• NOT intended to pertain to residences, vehicles,
  agricultural operations, etc.
• NO intent to establish an exposure limit or
  action level

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Mold and Worker Safety

• Identification, Sampling and Analysis

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To sample or not to sample?That is the question

• Primary approach should be visual inspection and
  identification
• Seeing is believing
• Sampling is rarely necessary as proof of the
  presence of mold
• No health complaints?No pending litigation?
• Remove the mold, remediate the cause
• Dont make this a research project

Learn to live with not knowing species or
concentrations
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To sample or not to sample?That is the question

• Consider need for sampling
• To verify performance of remediation
• To determine exposure
• To confirm presence of mold for litigation or
  insurance claims
• What do you expect to do with the results?

Sample collection is not always necessary or
helpful
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Sampling issues

• Is the sampling reproducible?
• Is the technique documented?
• Would two SHE professionals collect the sample
  in the same way?
• Is the sampling defensible?
• Was the standard of care used the same as that
  generally applied by competent professionals
  practicing in this discipline in the same
  geographic area?
• Is the sampling representative?
• Does the sample provide a measure of actual
  exposure or does it confirm the presence of mold?

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Sample analysis issues

• Selection of proper laboratory
• Staff expertise
• Mycologist, microbiologist
• Experience
• Mold assessments of buildings
• Support provided
• Sampling procedures, equipment, references
• Certification
• American Industrial Hygiene Association
  Environmental Microbiology Laboratory
  Accreditation Program (AIHA EMLAP)
• Level of speciation provided
• Media selection

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Polymerase chain reaction(PCR)

• Advantages
• Reduces human error
• Quick turnaround
• Based on species-specific DNA pattern
• Reported in units of cells/m3
• Can be qualitative (qPCR)
• Disadvantages
• Small number of labs
• Prohibitively expensive
• Relies on available probes
• Available for 24 species
• Need to identify/select species before analysis

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Interpreting the results

• Currently, there are no standard sampling or
  analytical methods
• Multiple sampling techniques provide a more
  complete picture
• Snapshot vs. time averaged, viable vs.
  nonviable, growing vs. dormant
• Numbers are affected by environmental conditions
  including
• Occupant activities (e.g., cleaning)
• Seasonal, diurnal variations, and weather
• Building system operation mode (e.g., heating,
  cooling)

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Mold and Worker Safety

• Current and Emerging Guidelines for Worker
  Protection

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OSHA

• Promulgating a standard? Not likely!
• No general recognition of a likely, serious
  hazard or significant risk
• No generally accepted actions that can be taken
  to reduce, prevent, or eliminate the risk
• Mold complaints not a high priority
• Unless accompanied by serious/reported health
  effects (e.g., hospitalization)

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OSHA

• Use of General Duty Clause?
• Must have recognized hazard plus threaten death
  or serious physical harm plus feasible/useful
  steps to correct or remove harm plus
  exposure/risk matrix (does-response)
• Allergic reactions do not have these elements
• Has not found any consensus standards it can
  adopt

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OSHA

• Focusing on outreach and information and
  participation in conferences
• In agreement with Evidence-Based Statement
  Adverse Human Health Effects Associated with
  Molds in the Indoor Environment
• American College of Occupational and
  Environmental Medicine

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Health effects issues

• Can be allergic response, infection, or toxic
  response
• Response may be minor, serious, or negative (no
  recordable response)
• Not discrete, not clinically apparent
• Flu-like symptoms
• No biological marker to confirm exposure
• No good predictive tool available at this time
• Even if skin tests are for sensitivity,
  individual may not experience adverse health
  effects

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Known diseases

• Invasive aspergillosis
• Pulmonary aspergilloma
• Allergic bronchopulmonary aspergillosis (ABPA)
• Infections from blastomyces, coccidiodes,
  crytococcus, and histoplasma

Scientific data lagging media and legal hype over
other, implicated illnesses
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Attributed health effects
More reviews than actual studies
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USEPA

• 2001 Mold Remediation in Schools and Commercial
  Buildings
• Change in focus regarding reducing exposure of
  public to indoor mold
• Focus on low-cost options for homeowners without
  using a professional
• Will be publishing mold remediation course on
  website
• Looking to partner with an organization to offer
  CEUs
• Would like to see widely-accepted remediator
  credential

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USEPA research

• Mycotoxins
• Working to determine environmental conditions
  that trigger production
• Looking for mold biomarkers

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NIEHS

• JAN 2004 Sponsored invitation-only national
  technical workshop
• Co-sponsors included NYC DOH
• Focus on defining PPE and training requirements
• Segregates work as
• Maintenance vs. remediation
• General vs. HVAC
• Draft straw man document Preliminary
  Guidelines for the Protection and Training of
  Workers Engaged in Maintenance and Remediation
  Work Associated with Mold
• Revised document due shortly

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ACGIH(American Conference of Governmental
Industrial Hygienists)

• ACGIH has had several lawsuits over conflict of
  interest
• Now has more stringent process for disclosure,
  discussion and management including Board of
  Directors oversight
• Does not publish consensus standards
• Publishes guidelines based solely on health
  factors
• No consideration for technical feasibility or
  economic factors

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ACGIH Bioaerosol Committee

• Sponsored symposium in NOV 2003
• Mold Remediation The National Quest for
  Uniformity
• Presentations and discussions will be used to
  develop best practices document
• Expect publication in 2004

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Health Canada

• 1993 IAQ in office buildings addresses
  interpretation of fungal sampling data
• 1995 Guide for recognition and management of
  fungal growth in commercial buildings
• Remediation guidelines due out later this year

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IICRC(Institute of Inspection, Cleaning, and
Restoration)

• S520 Standard and Reference Guide for
  Professional Mold Remediation
• Published DEC 2003
• Revision process already begun
• Addresses mold remediation, training,
  certification
• Published as peer-reviewed
• Does not conform to ANSI balance/review
  requirements
• Validity for use outside restoration industry
  questionable

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For more information

• visit the ASSE web site
• Position statements
• White papers
• Informational materials
• Updates on all of ASSEs mold-related initiatives
  and projects
• The American Society of Safety Engineers1800 E
  Oakton StDes Plaines, IL 60018USA1
  847.699.2929customerservice_at_asse.orgwww.asse.org