Virginia Regulatory Town Hall
Agency
Department of Professional and Occupational Regulation
 
Board
Virginia Board for Asbestos, Lead, and Home Inspectors
 
chapter
Mold Inspector and Mold Remediator Licensing Regulation [18 VAC 15 ‑ 60]
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10/15/11  8:07 pm
Commenter: Julie Sobelman CIH, CSP, LEED AP

mold regulations
 
I am of the opinion that licensing of mold inspectors is a solution looking for a problem. It is unclear exactly who the licensing requirements are designed to protect and what the cost/benefit is to the Commonwealth of Virginia.
 
Fungi, as a phylogenetic kingdom, include yeasts, molds, and mushrooms – living organisms that have existed for millions of years (5-15 million depending on source literature) - long before mankind.   Having a degree in biology I don’t think I’d be going out on a limb to say that fungi will continue to populate the earth long after mankind. Since Va. licensing has focused on mold, I’ll limit my comments to those.
 
Microbiologists do not know how many species of mold exist. They do know that varying species of mold can be found anywhere in the world – D.C. city streets, the Antarctic, or the Mohave dessert – if you look for it, it can be found.   So, with or without a license, any interested party looking for mold (living or spores) would likely find it.
 
Only a fraction of the molds that exist have been classified. Again, with or without a license, anyone submitting a “sample” to a microbiology laboratory will be relying on the knowledge of the analyst to identify the species. They can only identify what they know – a fraction of what may really exist in the sample. At BEST, the information is inconclusive.
 
There are clear scientific uses and benefits from specific molds – antibiotics such as penicillin, cultured foods (cheeses, sake), natural pest controls, and bio-remediation of oil spills to name a few.   All of these have documented, reproducible, viable outcomes.  By comparison, there are NO agreed upon species or levels of mold that represent a public health hazard.  With or without a license, using the partial information obtained from microbial laboratory analysis, someone is making a judgment on the potential effect of mold in the environment from which it was sampled. This judgment is being made in the absence of standards, and with no regard for clear cause/effect or outcome. Results may or may not be reproducible.
 
With regard to the economics of mold licensing, Has a cost benefit analysis been performed? Are there enough people clamoring for licensing to even pay the cost of operating the program?
Aren’t there enough professionals available to assess conditions that contribute to and prevent mold proliferation in buildings?
 
Mold is not new. The conditions that lead to mold proliferation are not new. Methods for the inspection and remediation of conditions that promote mold proliferation are not new. Health effects from varying species and concentrations of mold are neither conclusive nor reproducible. 
 
Until the Commonwealth can conclusively demonstrate 1)the harm that would result from not licensing mold inspectors and 2) the cost benefit to business AND taxpayers within the Commonwealth, I see absolutely no reason to license mold inspectors.
 
CommentID: 21014