Any industry, agency, company or individual that is allowed to both identify a need for an action or service, and provide the solution identified—weather by means or by action—will be perceived as a conflict of interest.  Perception by the consuming public is the basis for trust and sustained reputation for any entity (government or private).  Whereas the need for regulating, licensing and oversight of mold inspectors and mold remediators may be worthwhile, allowing any entity to do both is not.

Public perception is what drives a capitalistic society. Even government is susceptible to public (constituent) perception. Public perception drives change, competition, service and ultimately capital gain. But creating a situation that does not allow for “a level playing field” will eventually lead to stagnation in the market, flawed partnerships, poor delivery of service and new litigation.

As a small business owner who has an interest in both the accurate inspection and identification, and proper remediation of mold and related moisture issues in residential and commercial property, I strongly believe that the licensed inspector and remediator should be kept as separate parties.

Similar to how the Commonwealth defines and regulates asbestos licensing categories; certain situations between mold license categories should be considered a conflict of interest and therefore prohibited (reference “VIRGINIA ASBESTOS LICENSING CONSUMER INFORMATION SHEET”, publication 33acis.pdf).

Further, if licensing mold inspectors and/or remediators is enacted by the Commonwealth, is should be a mandatory requirement for all practitioners, be it the primary business or a supplemental service of a company. In addition to a minimum requirement of education and experience, a minimum of continuing professional education hours should be obligatory. Likewise, standards of practice should be drawn up by a body comprised of building professionals, mold and indoor air quality experts, and the consuming public, and made mandatory for the industry to adhere to or face disciplinary action by the Commonwealth, similar to that required of building contractors, home inspectors and other professional and trade practitioners in Virginia.

Examples of how mold inspectors and remediators are qualified and regulated may be explored by looking at how Texas and the Gulf states currently certify and license their practitioners. New problems with mold and the effects of moisture left untreated were discovered in the aftermath of hurricanes Katrina and Rita in 2005.

Thank you for your consideration.