Re proposed 18VAC15-60. Mold Inspector and Remediator Regulations
Re: 18VAC15-60-10. Exemptions from licensure requirement.
5. Phase 1 environmental site assessments conducted in accordance . . .etc.
What about ASTM E2418–06 Standard Guide for Readily Observable Mold and Conditions Conducive to Mold in Commercial Buildings: Baseline Survey Process assessments?
Re: 18VAC15-60-20. Definitions.
Baseline Survey Process should be included (see above note).
Re: 18VAC15-60-60. Licensure or training course approval by reciprocity.
A.The board may issue a license to perform mold inspections or mold remediation to any applicant . . . etc.
8. Pre-inspection planning and review of previous inspection records.
Most mold investigations are conducted in response to a water intrusion event, and previous inspection reports are likely not pertinent, if they even exist. Mold is not asbestos—it doesn’t stay in one place.
Re: 18VAC15-60-320. Mold inspector.
1. The sampling of mold shall be conducted using documented methodologies that incorporate adequate quality control procedures;
Mold is not usually or always sampled during an investigation; observation of suspected mold by a trained investigator is sufficient to establish the presence of mold.
3 h. Location and type of all mold identified during inspection;
Locations of suspected mold should be recorded on a site diagram for inclusion in the report of finding, but the type is not usually important.
