Dear Michelle,
This letter is to thank you for publishing the article entitled Mold Assessments: Value Added or Waste of Money? By Scott Walden on January 3, 2022.
Mr. Walden’s main point, that mold assessments and sampling prior to remediation take up resources that could be dedicated to the actual mold removal and cleanup, is certainly true. His corollary, that there are many cases where such assessments by an independent third-party appear to be redundant when a competent mold remediation contractor is involved, is also true.
It was interesting to see that the author recognized that the push for more and more mold assessments was coming from the insurance industry. However, he did not back that recognition up one step and speak to some of the issues that are leading insurance companies to that position. One of the biggest driving factors is the desire for the work to be done in conformance with both the industry standard of care and regulatory requirements.
For example, in the State of Florida, where Scott is licensed, the regulations make it clear that any “physical testing” is automatically part of an assessment process. The relevant section from the state regulations [specifically 468.8411(3)] is quoted below:
“Mold assessment” means a process performed by a mold assessor that includes the physical sampling and detailed evaluation of data obtained from a building history and inspection to formulate an initial hypothesis about the origin, identity, location, and extent of amplification of mold growth of greater than 10 square feet.
The author also mentions NORMI and some of their industry “best practices.” I also respect the efforts that the National Organization for Remediators and Mold Inspectors has expended to professionalize the mold remediation industry. Following those best practices, which recommends having a third-party assessment prior to mold remediation activities, offers a number of specific advantages, particularly for the mold remediation contractor. Briefly, those advantages include protecting the remediator from potential liability. If an improper diagnosis or protocol is provided by an assessor, the assessor is responsible for the outcome. The remediator is only responsible for following the protocol correctly.
A second critical advantage to having an independent assessor is that it avoids the inherent potential conflict of interest of one organization doing the “diagnosis and treatment”. While such combinations of activities are typical in the medical community, it is generally avoided in areas of environmental contamination such as asbestos and lead. Even if this is only the perception of a client, it should be avoided. That is why in some states, like New York, the assessment by an independent third-party is required by statute.
In my experience, the customer’s perception of conflict of interest when the same company does the assessment and remediation oftentimes does not develop until after the work is completed and some disagreement regarding quality or pricing occurs. At that point, it is too late to go backwards to have an independent assessment and scope of work completed.
A third consideration is fairly basic. In a general sense, if a remediator is allowing money to determine how to do his work, he is then allowing the client to run the project rather than following best practices. While there is always some negotiation between what needs to be done and what can be afforded, the remediation contractor can easily put himself in position where their insurance protection can be denied if they are outside the scope of state regulations or industry best practices if all recommendations are reduced down to a monetary basis.
Finally, it would be a lot easier to make the argument that an independent assessment is not necessary on simple, straightforward, mold remediation projects if the industry actually settled on a clear definition of the term “clean” following the mold remediation activities. Without an objective standard to measure the performance of restoration contractors, that key aspect of the project needs to be set as part of the assessment process. Having the remediation contractor set the standard for how their own work is evaluated is fraught with both short-term and long-term difficulties. If nothing else, this should be reason enough for utilizing independent assessors for most mold projects.
Sincerely,
Michael A. Pinto
Certified Safety Professional (CSP), Certified Mold Professional (CMP), Registered Third-Party Evaluator (RTPE)
CEO, Wonder Makers Environmental
