Thank you for the opportunity to submit comments regarding the NOIRA for mold remediators and mold inspectors.

We have several comments:

1. We believe that the training course for mold inspectors should be 1 - 2 days but that an apprenticeship period be mandated in the regulations (as was done for the asbestos inspector).  As a professional industrial hygienist who has been conducting mold inspections for close to 30 years, there is much more to learn through field experience than there is to learn in a classroom setting.  We would suggest that to become a mold inspector in Virginia,  a 1 - 2 day training course be required along with at least 6 month period with at least 6 projects  documented before being eligible for  licensure. 

2.  We believe mold remediators should be limited to  a 1-2 day course since so many of the mold remediators at the current time are asbestos laborers who already understand proper control methods.  

3.  We would suggest that the continuing education requirement be a 3 year requirement as exists for lead paint licensees.  There are not enough changes in the science of mold  to warrant more frequent refresher classes.

4.  To make it less burdensome on small business in this economy, we ask that individuals who have been performing this work for at least 5 years, be initially grandfathered in as mold inspectors or remediatiors if they can show proof of their experience.