Mold Aid Fully Supports Regulations, Few Changes To The Proposed Regulations Needed
Mold regulations are desparately needed in VA. A simple licensing and qualification program would assure home and building owners the ability to hire a qualified indoor air quality company. While regulations are important, I'm concerned that complicated regulations may make mold testing and mold remediation unaffordable to the average homeowners. The indoor air quality business is a very serious industry, but it's equally important that services are affordable when they're needed. Most people will own or rent a home with an indoor air quality problem at some point in their lives. Educating consumers and assuring them that they have the means to hire qualified contractors to find and repair moisture and mold issues is a productive step for any state.
My name is John Taylor. I am the owner of Acquired Home Services Inc. a Virginia Corporation. We provided general contracting services, home and building inspections and our Mold Aid division provides mold testing and remediation services. Our Mold Aid division has operated since 2003. We have provided over 8000 mold related services which includes mold testing, general indoor air quality and remediation. We have provided assessments for residence, commercial buildings and many high profile projects in the DC metro area. Our company refers to this industry as a happy industry because we are able to provide diagnosis and fix problems for our clients in a way that 99% of the time leads to happy customers. In over 8000 projects we have had minimal service related complaints and zero legal complaints to date. We follow Approved American National Standards in both mold testing and remediation and we feel our company is one of the most experienced and well trained in the industry. Our company requires all employees who provided Indoor environmental services to be independently certified and trained.
Classes, training and certifications include: Institute of Inspection Cleaning and Restoration Certifications (WRT), (AMRT) Indoor Air Quality Associations: (CIE) and all of our Indoor Environmental Professionals must meet the State standards for home inspection training and pass the National Home Inspectors Exam. We also have minimal certification requirements for our field personnel which includes Certified Mold Professional through I.O.T.
That being said we welcome Virginia's Mold Inspection and Remediation Regulations with a few comments.
1. I have trained many Indoor Environmental Professionals and I would highly recommend that all mold inspectors have experience or also be trained as home and building inspector. I think the IICRC and the Indoor Air Quality Association would agree a huge part of a mold inspection requires full knowledge of building science which can be obtained by accomplishing Virginias current required hours of training for the home inspection certification and passing the National Home Inspectors Exam. The current industry mold training touches on building science but the training has proven in our experience, not to be enough without the proper background.
2. The regulations should address the responsibility, home and building owners have to repair or disclose known problems. In todays foreclosure market about 60% of the vacant homes have substantial mold problems. This mold is called discoloration by the banks and asset managers so they can hire regular contractors to remove the contamination and avoid costly remediations. We have records of many clients who have suffered serious health problems because of this loop hole in the disclosure rules.
3. 18VAC 15-60-790 Conflict Of Interest
The proposed Virginia regulation indicates that providing diagnosis and repair services from the same company or person is a conflict of interest. The proposed regulation then goes on to disallow remediation companies to provide testing services and vice versa. I understand the theory behind this and I also understand the idea of it in I.A.Q.A documents but what we have found in our long proven experience is that it is not practical. For a company to offer a valuable, competent, guaranteed priced service they must be able to evaluate the problem. You wouldn't expect a doctor to operate without proper evaluation, you would not expect a contractor to offer a fix from another companies write up and you can't expect an indoor air quality remediation company to give a fixed price for remediation and offer a warranty to a client who had a write up from a different company. No other industry operates like this and there is a reason for it. It doesn't work.
Here are a general list of problems this conflict regulation would create:
A. If the inspection company is wrong with their diagnosis and the remediation company discovers this during the project what is the fix. Who pays for the mistake? Who is responsible.
B. If the inspection company writes a scope of work and the scope of work has to be expanded is the testing company responsible for the addition charges or will the home or building owner be responsible to pay the change order costs while the project is in process. Remember mold grows behind walls, floors cabinets ect. in many cases the full scope is not fully known.
C. If the inspection company and the remediation company are forced to be two separate entities there will be many legal issues. Each entity can blame the other when problems arise.
D. Creating a regulation where the inspection company cannot be the same company that fixes the problem makes an already slow industry process excessively drawn out for the customer. In most cases the customer is suffering from a health related exposure or is trying to protect their family or workers from exposure to the contamination.
E. Cost: Mold Testing and Remediation services are already costly. We have seen through normal competition the costs of testing and remediation services reduced to about half of what they were 2003. By separating the inspection company and the remediation services, remediation of mold becomes unaffordable to the average home or building owner who will find no insurance relief. Making a service that protects people from their indoor environment unaffordable is unreasonable.
F. If the inspection companies protocol is followed and the clearance fails who is paying for the additional work and testing required to assure a proper clearance. Did the project fail clearance because the remediation company failed to follow protocol or did it fail because the inspection company failed to provide a proper scope of work. Also the inspection company has an incentive to fail remediation with normal fungal ecology to earn more testing dollars. We understand and support third party clearance inspections but you can make a case that there will always be a possibility of a conflict. The reality is Virginia's regulation requiring licensing will quickly weed out any companies that have questionable business practice. It's likely that most of these companies have already gone out of business due to qualified competition.
There are many more reasons I can describe if this board wishes to reach out to me or my company to discuss at some point.
In closing I want to mention AHS Mold Aid is approved to provide franchises in Virginia and we recently sold a franchise in the Commonwealth. Our franchise model is based upon a successful structure that allows for a reliable and proven method of testing and inspection. We offer our franchises across the nation except for in one State: "Texas" where our research shows mold problems are a nightmare to deal with for home and building owners as well as service providers. In Texas regulations force owners to inspect and remediation with two separate entities. This creates all the problems listed in A through F and also has two companies fighting for dollars from one client. This is no good for the consumer or the companies that provide services.
Thank you for allowing my comments today. As stated we welcome regulation in this industry. We feel that anyone that offers indoor air quality services should be trained and certified and the proposed regulations seem to address this well. Over regulating an industry that addresses problems that most home and building owners will have at some point in their lives could harm an industry that run relatively smooth following current national standards.
Kind Regard
John K. Taylor / WRT, AMRT, CIE, G.C., C-HI,
Acquired Home Services Inc.
Corporate Mailing Address
P.O. Box 868 Gainesville VA 20156
Phone: 703-754-3766
Fax: 703-754-1216
Cell: 703-932-6134
E-Mail myhomewarranty@aol.com Website: www.moldaid.com
