Our company conducts crawl space waterproofing, cleaning, and duct repair on a weekly basis, and we obviously encounter a lot of mold in the process.

There are good and bad things about overlaying additional mold remediation requirements on contractors.  I will list some of those below, as well as provide my overall opinion.

Anyone doing residential mold remediation or cleanup should already be an RBC or HIC contractor class B or higher.  That means they have already proven their qualifications in conducting residential repair, demo, cleaning, rebuilding etc.  Mold is pretty much always part of this process.  Any part of a home that is 50 years old and being remodeled likely has mold and fungus to some extent.

The questions is where do you draw the line, and turn something into a mold remediation project, not general home improvement?  I don't think that question has been close to answered by any governing body and especially not the general assembly.  There is a large difference between someone who has old insulation and duct-work, and needs their crawl space cleaned up, to someone who has a chronic autoimmune issues that are being severely impacted by mold in the home obviously.

Requiring every home cleanup or deferred maintenance project to be a "mold remediation" project, just because mold cleaning is mentioned violates the spirit of the Virginia Existing Building Code, by putting an undue burden on homeowners to turn a basic crawl space or remodeling project into a "mold remediation" project.  This is why the residential mold and asbestos rules were eased in 2012.

We also want to protect people that need comprehensive "mold remediation".  My proposal would be to differentiate between "mold cleaning" and "mold remediation".  The idea that an RBC or HIC can't use the word mold is asinine and insulting.  The proper remedy would be some type of disclosure that requires contractors doing mold cleaning to disclose to homeowners that it is not a comprehensive "mold remediation" project if it isn't.  Homeowners are smart enough to know the difference.

Certified mold remediators can also market their expertise to the public, informing them of the difference between certified mold remediators, and contractors who clean surfaces of mold, such as a crawl space encapsulation contractor.  Everything doesn't need to be regulated into a box with the idea that citizens can't determine the difference, or companies can't use the free market to convey differences.  But creating mold regulations that handcuff home improvement and building contractors into strict mold protocols violates a slew of laws already on the books, mainly the Virginia Existing Building Code.

Final Answer:  Find a way to differentiate between basic mold cleaning as part of general renovations, or maintenance, and mold remediation.  The idea that some contractors do a bad job isn't a very good argument for creating more legislation and licensing.  People who do a bad job will still do a bad job.  Let the free market work that out.