I find it interesting that my learned colleagues with ABIH certifications as industrial hygienists feel that Virginia does not need regulations to protect citizens of the Commonwealth, including mold remediation workers, from recogized health risks and unscrupulous consultants and contractors. Granted fungi, including those categorized as moulds (molds) have been part of the natural environments for many millenia; however, modern man-made buildings and the penchant for society to spend more than 8 hours in any given day create health concerns and property damage not encountered on a routine basis until the 1950's.

The federal Institute of Medicine, the American Industrial Hygiene Association, the American Conference of Government Industrial Hygienists, the New York City Department of Health and Mental Hygiene, the Virginia Department of Health, OSHA, and the CDC (to list a few) have published reports on health concerns related toexposure to moulds in the indoor environment and standards of care for those involved in mould assessment and remediation. IF the presence of mould, and the associated causal factors, were not a concern, why publish the documents?

As seven other states have determined, there is a need for regulations that set a baseline for knowledge related to mould in the indoor environment and a baseline for standards of care and work practices. Investment bankers, insurance companies, propertymenagement firms, and home owners have lost millions of dollars in this state because of ineffective remediation of water damage and subsequent mould growth. Only tort lawyers prosper where there is no regulation.

I do agree that the current regulation need to be revised for clarity and that those with licenses from other states or certifications from the ABIH or ACAC should be accepted by DPOR, with instruction in state regulations. In my opinion, the current mechanism of training is inept and the cost for training unjustified for the quality of current instruction (in many cases), but can be rectified.