Mould Inspections, Investigations and Sampling.

Mar 10 / Ryszard Jankowski MISSE MRPSA
Full disclosure, we’re NOT doctors but at TRA UK and DampAndMould.Academy we’ve been dealing with mouldy buildings and contents and training industry professionals since the early 2000s.

Our certifications and certified school status through the US based (but global) IICRC and a working knowledge of ANSI/IICRC S500 and S520 have kept us at the cutting edge of standards of care and understanding and mitigating the health and workplace hazards posed by mould exposure. 

The US is way ahead of the UK. Some states even require licensing for aspects of mould inspection/remediation or set standards or guidance that these parties must follow when involved in mould:
Arkansas, Florida, Kentucky, Louisiana, Maine, New Hampshire, New York, Oklahoma, Texas, Virginia and Washington DC

Not to mention the England and Wales .gov guidance sends you to directly to the US EPA... 
The sceptic’s case: 
We’re going to tackle this topic by directly addressing the critics’ arguments head-on. Any self-proclaimed ‘mould expert’ should be able to confidently address these critiques and how they approach the underlying challenges. 

There’s a lot to be learned from ‘steel-manning’ the case of sceptics and listening to critics… The best critics will tell you where your blindspots are and understanding their arguments allows you to better defend your methodology. Also, if you understand these as a consumer, you can avoid those selling you meaningless tests and sampling - which we often encounter. More on that later.

Caoimhín P Connell does a great job outlining the sceptic's case (as it stood in 2015) in a 2 hour talk posted to youtube in chunks. If you have a couple of hours the first chunk is the embedded video below. He’s entertaining, doesn’t pull any punches and does land some. That said, a knowledgeable, well trained remedial specialist or surveyor should be able to walk you through the crucial details of each critique in turn.

(Side note: If, like me you need to know how to say Caoimhín in order to read it, it's Irish and pronounced "Quiven", the anglicised version is 'Kevin'.)
Above is Caoimhín's slide of the main takeaways from his talk. These are the claims he thinks they need to understand.

  1. There is no such thing as ‘toxic mould’
  2. None of the ‘testing’ being performed is valid
  3. The ‘certificates' issue is a USA-specific point, we can mostly ignore that for a UK audience.
  4. Sampling is virtually never performed duriing a legitimate mould inspection
  5. What he considers sufficient knowledge, training and experience

CLAIM 1: “There is no such thing as Toxic Mould”:
Caoimhín claims toxicity ALONE is not enough of a problem to cause a health issue due to toxic exposure; mould debris does contain toxins but exposure to them in such small quantities will never be extreme enough to cause a toxicity event in humans. He goes into detail of toxic dose limits. No dispute here - UK regs and guidance aren’t concerned with toxicity, per se.

Where this is outdated for our purposes is that the modern concern is over the vulnerability of certain individuals and groups to mould exposure that affects them and not others. Moulds have allergenic and pathogenic qualities that are not a simple case of dangerously high toxin exposure. We don't consider peanuts as generally 'toxic' and yet some individuals can have a fatal response to exposure to even a trace of peanut in their vicinity. 

We really don’t need to prove the hazards to sceptics any more. Being around mould is bad for us all and CAN cause illnesses (some are pathogenic) like asthma or aspergillosis - but exposure is worse for some individuals and groups. That’s the scientific consensus AND law of the land in the UK. A business ignorant of these issues risks being found negligent in the courts:
  • Multiple references in COSHH associated documentation & guidance

This doesn’t mean there isn’t a discussion to be had about the severity of the hazards and who may be at risk… because there’s an inevitable tendency for companies to use fear and hype to sell products and services you may not need, or at the very least exaggerate the benefits of what they’re selling. They say ‘sex sells’, but fear and anxiety over health certainly do too!

Caoimhín is dead right that the terms ‘Toxic Mould’ and ‘Toxic Black Mould’ are media inventions, see the discussion of three industries section below for more on that.

What we can say with certainty is the UK govt guidance says living with ANY active mould growth is indicative of an unhealthy indoor environment and needs addressing. That’s easier if you can SEE mould growing.

Active mould growth can be remediated safely, affected areas can be decontaminated and if you address conditions for growth, mould won’t return.

CLAIM 2: “None of the 'testing' being performed is valid”:
Let's start with the easy part. We do not recommend sampling for mould in any room where there is visible active mould growth. We know a room with more than trace growth will have raised levels of mould debris in the dust. We can predict what the costly sampling will find.

There are cases where we would take samples, but mostly these are baseline assessments that let us validate a remedial process with post remedial sampling confirming predetermined improvements have been achieved. Maybe a client wants to identify a particular species for some reason. There are special cases but, broadly, if there is visible significant mould growth then there is little practical utility to sampling.

The last exception is not all moulds growth IS actually obvious on visual inspection, so sometimes we would perform sampling if we’re not sure. It’s rare but it does happen.

Most of our domestic clients have health concerns that their doctors or nutritionists have linked to mould exposure and they can’t FIND the mould exposure in their lives. They address their diet and STILL have lab results showing mycotoxins in their system or allergic response markers That’s where the sampling that we do most commonly comes in to play. 

So what is a ‘legitimate mould inspection’?
What should a normal ‘legitimate’ mould inspection focus on? In any situation where mould growth is significant or obvious then the inspection or investigation should be focused on WHY it is there at all. The focus should be how to address conditions of growth, identifying vulnerable areas and how best to remediate the existing growth and carry out effective decontamination. 

It doesn’t matter what species is growing. Mould shouldn't be growing at all. The England/Wales housing guidance doesn’t talk about any risks associated with particular species (other than Aspergillosis being a disease caused by Aspergillus spp.) but rather the risks associated with living in a damp and mouldy environment generally.

If you want to know more about what the HSE says regarding Aspergillus in construction and refurbishment follow that link.

CLAIM 3: Certificates aren't valid - Not really valid for the UK market
Perhaps it's worth mentioning, though, that there really are no bonafide 'qualifications' in mould surveying or remediation in the UK. Organisations certify individuals and companies, but that's not the same thing. Anyone claiming to be a 'mould inspector' is free to do so but you should research on what basis they make this claim and engage some critical thinking.

CLAIM 4: "None of the sampling being performed is valid" (statistically relevant)
This is the most out-of-date of Caoimhín’s claims, from our perspective BUT he’s right about one thing. A LOT of sampling conducted is STILL statistically irrelevant or mis-sold and doesn’t help an occupant determine what’s happening in their home.

For example, we are often presented with a client’s recent ‘ERMI score’ results. When we ask, it turns out protocols weren’t followed and the ERMI score isn’t worth the PDF it’s printed on. Not only that… here’s what the EPA says about ERMI sampling:
"The Environmental Relative Moldiness Index (ERMI) is a research tool developed by EPA scientists for estimating mold contamination. Researchers can use the index to estimate the amount of mold and some of the types of mold present. ERMI has been peer reviewed for research purposes but has not been validated for non-research purposes."
BUT modern science to he rescue!

Modern 'index' methods mitigate the problems of ubiquity and baselines or 'benchmarking'. Here’s a recent paper on just that from the UKCMB

What do we mean? Well…

It’s hard to quantify what is ’normal’ in any given property and any one or handful of samples might not represent the overall contamination levels. Mould is everywhere and you can walk into any home and find viable spores and mould debris on ALL surfaces. 

What we mean by benchmarking is determining what ‘normal’ levels of mould debris are in a ‘normal’ environment. The IICRC standards calls that ‘Condition 1: Normal fungal ecology’. It will vary seasonally and geographically. Domestic norms will also vary if you live in an urban setting or a rural or wooded area.

How can you possibly tell if the mould debris in your home is ABNORMAL, if you don’t know what NORMAL is? This is what Caoimhín P Connell is referring to when he says “None of the ‘Testing’ being performed is valid.” We agree to a point… much mould sampling that is sold to people is indeed statistically irrelevant.

Microscopy - looking at mould through microscopes, in our opinion, is all but dead…. unless you have a gargantuan budget, scientists and statisticians at hand. Why? Because mould is ubiquitous. Its everywhere. You can walk in to any property on the planet and find viable mould spores and non-viable debris of thousands of species. You can take that to a lab, have some low paid intern take their best ‘educated guess’ at what they see, maybe even grow cultures, but it gives you no valid analysis for how contaminated the property, as a whole, might be. 

(Yes, by the way, when you have mould analysed using microscopy in a lab, it’s rarely senior or experienced scientists doing this work.)

A Tale of Three Industries

Caoimhín’s last bullet point is about what those that claim to be professionals, or even experts, dealing with mould in the built environment should know. To his mind, the room of insurance and claims professionals he's talking to is full of people with enough knowledge to call themselves 'mould inspectors.' 

In his introduction, Caoimhín identifies two ends of the industry that are, as he puts it, 'diametrically opposed'.

 - The ‘legitimate scientific and medical industry' 
 - The 'fear-based, hype-filled remediation industry’

He’s talking sense. In housing, we can actually identify three groups of stakeholders and every one has their own interests:

  • Landlords and insurance companies who may be liable and paying (or avoiding paying) for work.
  • Mould remediators who are looking for and paid for work.
  • The media because ‘if it bleeds it leads’. Caoimhín identifies this and is right again: The term ‘Toxic Black Mould’ was “created by sensationalist news outlets” (in America decades ago), it sells papers and gets ratings and, these days, clicks. Watch this 10 year old US news trailer and you’ll see what I mean…
DampAndMould.Academy exist independently of these main interests. We have no dog in the fight. We are independent of property and liability concerns, remedial services and media hype. This is deliberate - we want to provide the clearest assessment we can without any incentive to tell you what you, or we, want to hear.

We don’t turn a profit by confirming or denying a problem exists, nor by finding a problem and offering you our services to solve it. We independently assess every situation in the context of industry best practices, the highest standards of care and the latest advancements in the field.

In other words, we have zero conflict of interest. 

So, then, if you are concerned you have a mould problem that might be affecting your health then protect yourelf by doing some research (we recommend our free course, blog posts and YouTube channel) and beware of anyone offering anything for free, even a quote. At least understand that the way they offer it for free is by getting paid work later.

Modern techniques CAN identify elevated mould debris in a property’s dust… but what results mean in context, what to do about it and in what order is all a matter of interpretation of the raw data