As the Manager of an environmental consulting firm with over 30 years experience in environmental health and safety including indoor environment and mold issues, I support the issuance of the momld regulations and offer the following comments.

1. We support the requirement that there be a 6 month apprenticeship type experience prior to application for licensure as a mold inspector because of the much needed field experience.

2. We strongly support the conflict of interest language that specifies that mold inspectors and mold remediation workers/ supervisors cannot be one in the same.   This is division of labor is routine  in the environmental industry for other remediation projects (asbestos, lead, etc)  and is an important third party verification that the project was done professionally and is complete.  It provides protection for the building owner and building occupants. 

3.  Because of the level of expertise needed to become a mold inspector and the limited amount of changing research in the mold area, we do not believe an annual refresher is needed for mold inspectors.  DPOR has recognized this in drafting the mold supervisor language and we  would ask that the 24 month language for refresher classes be designated for the  mold inspectors as well.