Regulation is much needed and overdue. However, a fair and reasonable approach that allows for an affordable service to the consumer as well as a reasonable registration process and cost for licensing to the service provider is also needed.

PBI has long taken the position that third party testing and clearance by a licensed and certified Industrial Hygienist is the professional way to assure a project has been properly remediated. This method provides a check and balance system to the company doing the work vs. the company inspecting the work. This does not preclude the company doing the work to perform their own inspection and preliminary clearance testing to assure a quality job. Also, not all projects neccesarily have a need to be cleared by third party. The IICRC S520 provides excellent direction on this matter.

We at PBI participate in the IICRC and RIA training programs. Both of these trade associations have offered excellent training and certification for our industry for years and are flagship organizations with an excellent track record. ACAC is a new organization that was developed in conjunction with new regulations in the State of MD. ACAC's history is a bit muddled.

Certifications such as the AMRT or AMRS in conjunction with water damage certification  WRT from the IICRC for technicians or supervisors performing work on a remediation project. should be required. This ensures safety for both the worker and the client and provides asurance that an acceptable standard of knowledge is imparted by the company providing services.

My opinion is that the regulation provide language for firms to have certification by recognoized trade associations, but not requiring homeowners to obtain third party inspections. Rather. allow the homeowner the option. If the homeowner chooses, then testing and clearance should be provided by a licensed and certified Industrial Hygienist that is independant of the firm providing the remediation services. Regulations can requiure language in remediation firms contracts that explain this requirement and that the consumer must be informed of their right to have third party testing.