Safe mold abatement requires basic protective measures that are well known and practiced in the environmental hazard remediation business. Basic enclosure, proper cleaning and decontamination methods, and proper use of personal protective equipment can result in safe, effective and economical hazard abatement.  

These well known procedures are practiced on a daily basis by hundreds of Virginia asbestos and lead licensed workers and supervisors. The existing knowledge of these personnel and contracting firms allows them to currently perform safe mold hazard abatement.  This existing knowledge (and training received) should be considered when developing the training and licensing requirements for the mold licensee categories. Those personnel that hold comparable asbestos licenses should be allowed to obtain their mold licenses with minimal or no additional training. Those persons wishing to enter the trades should be trained to standards that are the minimum necessary for the work.

It is our belief that existing training firms in the Commonwealth (currently performing asbestos and lead training) are more than capable to develop training courses that are adequate for the trades. Upgrade training (asbestos to mold) can be minimal, half or one day courses and first-time mold remediator or inspector course material could easily be covered in two or three day courses. Update courses should not be necessary on a frequency of any more than every five years. I have personally been involved in the asbestos abatement industry for more than thirty years. Since 1988 I have warmed the seats of approximately thirty-five asbestos update and first time classes. I am aware that current members of the ALHI Board have probably been through twice as many classes. While the EPA reqires these classes, the technology of the abatement business does not change at a frequency necessary for this much re-training. 

Please consider the cost of training and travel costs (to training) in your reqirements.  Finally, please consider that this remediation work is performed by laborers that are working in containments, in protective suits and respirators.  There are industry factions that want to restrict access to the trade and make you believe this work to be extremely technical.  This work is not complicated.  Please do not make it more complicated and costly than it should be.