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Thread: Bogus Mould legislation
06-06-2008, 10:44 AM #1
Bogus Mould legislation
Good morning, Gents!
I’ve had a couple of comments on a post I made and comments I made on a professional list of my peers, wherein I criticized “certified” members of the American Indoor Air Quality Council (AIAQC).
I realize that some of you are members of the AIAQC as either CIEs or CMRs or other designations the AIAQC issues. And it is not likely that those so certified will like what I had to say. However, to be fair, and so that it doesn’t seem like I’m shooting folks in the back, I thought I would provide an explanation of my position here.
The post came on the heels of State of Maryland legislation called HB 1309. The bill constitutes institutionalized failure on the part of the Industrial Hygiene profession. The Bill pertains to mould its "assessment" and its “remediation.”
The purpose of the bill may laudable enough and I don't question the intent of the sponsors, but the Bill contains language and a concept that promotes public misconception to the exclusion of sound science, and the current body of knowledge. The proposed legislation reflects junk science and, without foundation, elevates and promotes that junk science to the level of legitimacy by specifying unfounded practices and giving unwarranted credibility to practitioners with no apparent legitimate specialized knowledge in the area of indoor moulds and the proximal advancement of publications parading as “standards.”
The language of the proposed bill promotes junk science by promoting unfounded “assessments” and fails to recognize legitimate national consensus in lieu of pseudo-science by poorly trained professionals. For example, the language of the Bill implicitly identifies “the American Indoor Air Quality Council” as a nationally recognized accreditation body.
Neither I nor my firm (FACTs) has an association with the AIAQC, or any work pending in Maryland. However, it has been our experience that being a member of the AIAQC (or any other of the other popular guilds) does not indicate proficiency in the area of indoor moulds and/or indoor air quality. Indeed, it has been our experience when we have reviewed the work from consultants claiming to be members of the AIAQC (and other similar groups) their work product tends towards junk science and practices that are outside of acceptable, normal standard industry practices. Usually, the entire project and conclusions revolve around useless "samples" and "tests."
It has been our experience that when we have reviewed the work of consultants claiming membership with the AIAQC, the work by the consultant has been grossly substandard, and based primarily on popular myths and misconception. This is not to impugn all members of the AIAQC and neither is it to impugn the otherwise good character of the consultant – at no time did we observe any fraudulent or deceptive practices, merely gross technical incompetence and reliance on myth to the exclusion of good science. I have no doubt that the consultants with the AIAQC are decent, honest and honorable people – my argument is that the ones I have encountered don’t seem to know much about sampling theory, indoor air quality or indoor moulds. I am sure there are members of the AIAQC that are proficient, or technically competent – however, all the ones I have encountered and whose work I have reviewed are not competent in indoor air quality or mould issues.
Even the AIAQC’s web site contains the following statement:
“On January 1, 2006, a major event changed the scope of the Council’s activities. As part of a unification agreement with the Indoor Air Quality Association (IAQA) and the Indoor Environmental Standards Organization (IESO), the Council no longer offers membership services, but instead focuses exclusively on certification programs.”
This is troubling and I am one of many, who do not recognize the IESO “standards” to be scientifically valid, or to carry any probative value in legitimate discussions amongst bone fide indoor environmental quality experts. Based on the information available to me, (conversations directly with the IESO staff), the IESO “standards” were developed a couple of years ago by a particular laboratory in an effort to promote sales. The IESO “standards” (such as IESO 2210) are, in my opinion, mostly myth-based procedures devoid of any actual scientific merit, and lacking any credibility. For example, my copy of the referenced “standard” makes a central point of using outdoor airborne mould levels as comparison to sample indoor levels. However, this is an example of argumentum ad populum in the light of state-of-knowledge; essentially IESO makes the case that “since everyone else seems to be doing it, it must be correct.” However, it has long been known, that there is no correlation whatsoever between indoor and outdoor spore concentrations in the circumstances under discussion, and investigators who practice indoor/outdoor comparisons as commonly seen are usually home inspectors, “certified mould investigators,” and other generalists who lack any particular scientific training, who lack a knowledge of sampling theory and who lack any knowledge in aerobiology. If the IESO or the AIAQC would like to offer some defense for its "standards," I would like to invite them to so do, here. It's not my intention to "beat them up" just put the publications and practices into perspective.
By comparison, bone fide national consensus standards organizations would include ASHRAE, ANSI and ASTM International and others. These organizations publish technically exhaustive standards that are consensus criteria developed by hundreds of professionals across the globe over the course of many years and that often carry weight of law.
The promulgation of true standards is an arduous process involving literally hundreds of experts. For example, the ASTM International D22 Indoor Air Quality Committee has been engaged in the promulgation of an indoor mould assessment standard for over three years. The process involves the vetting of the language and the science by a broad spectrum of scientists, medical personnel, engineers, public policy experts, and even untrained, self-appointed “victim advocates” before the standard will see the light of day. Ultimately, an entire ASTM standard could be held up on the opposition of just one expert, until consensus is achieved or the objection is shown to be unsupported by sound science. By contrast, based on my information, the IESO was formed in 2002, and the “standard” was instantly published without review by any other organization or expert anywhere outside the author's small group.
In their defense, the IESO indicates it’s lack of technical merit in its own standards. My copy of the IESO 2210, explicitly states, in its own language, that the standard is not technically exhaustive, and should only be used to determine if an appropriate specialist (e.g. an Industrial Hygienist) is required for further investigation. Indeed, the IESO 2210 clearly states:
7.0 Applicability and Limitations
7.3 The results and recommendations made by the inspector relative to this standard are not a warranty, surety, or guarantee of any nature or kind.
I realize that the AIAQC and other groups were created to fill a vacuum - and I applaud the work of Charlie and others who have attempted to appropriately fill that gap. It is not my intention to denigrate their hard work or commitment, only call into question the value of the final product.
For those of you who have not yet seen it, here is a wonderful example of the level of credibility seen in national consensus “Certified Mould Inspectors:” (the following PDF has been linked directly from the internet – if, I have violated copyrights in some way, please let me know and I will remove the link and page immediately, and apologize to the copyright holder.) The author of the following ad identifies himself as a CIE and CMR.
Recently on the industrial hygiene board where I participate, we have seen discussions on the merits of the advancement of good science, and obstacles thereto; and in recent months we have seen (narrowly defeated) challenges to the scientific merit of Industrial Hygiene as a profession. It was my position that if Industrial Hygienists don’t take a stand and 1) promote and practice good and valid science; and 2) defend good science and defeat junk-science, the line between the professional Industrial Hygienist and the “certified whatzit” will become increasingly blurred. (By the way, in the last two years, I have been involved in litigation involving six ABIH certified industrial hygienists, two of whom also sported PhDs - in each case, the CIH's lost their arguments since sound science didn't support their practices, or conclusions; so industrial hygienists need to be careful and not fall into the "certification" trap ourselves.)
The proposed Maryland Bill moves to aggressively blur the distinction between peddlers of pseudo-science and legitimate scientifically based practitioners of industrial hygiene as much as possible and, in my opinion, will do nothing to protect the citizens of Maryland, and will only serve to open the door to encroaching junk-science and the promulgation of myths.
A negative comment I received from one of my peers was that my initial post was short on specifics regarding my comments on members of the AIAQC exhibiting a gross lack of technical competence in mould related issues and indoor air related issues. So I provided two examples (although I have many more).
Like other consultants most of my work is performed under strict confidentiality and therefore, my reports seldom see the light of day. However, occasionally, some of my work surfaces on the web. For the first example, I used one of my actual reports that appeared on the web in the last few weeks wherein one of my clients published our report in an unsecured area of the web, thereby making the report freely available to the general public. Therefore, the report has entered the public domain and I’ve provided a copy of our critical review here:
The report was a standard “Critical Review” we performed on work by an individual identified by the AIAQC as one of its members. The work by the AIAQC member exhibited the kind of gross technical incompetence that I have come to associate with each member of the AIAQC whose work I have reviewed. I have not seen any AIAQC member perform an adequate or scientifically based “mould inspection.”
Essentially, as seems to be the standard procedure of the certified mould inspector, the consultant collected some useless indefinable and uniterpretable samples and then made unsupported claims based on the meaningless “results.”
Although the report is available on the internet, in deference to the client, I censored the client’s identity, but left the name of the AIAQC “certified mould consultant” intact. My argument stands – This consultant is precisely what I typically see coming from members of the AIAQC – it’s hype, it’s mythologically based, it lacks science, it lacks precision, it lacks accuracy, it lacks support, it lacks legitimacy, it lacks definition, it lacks credibility, it lacks relevancy and it is what the Good People of Maryland apparently have been handed in the dark under the guise of professionalism.
In the second example, the “CIE, CMR” (“certified” individual), is Mr. Tal Moore, who has produced some remarkable discussions on mould and identified himself as a CIE, CMR. These designations are, I believe, are issued by the AIAQC. Here is a copy of some of Mr. Moore’s very interesting writings regarding indoor mould (I’m not making this stuff up):
Here is another interesting document about Mr. Moore outlining what the courts seem to think about him:
I would call your attention to page four of the April, 2006 document by the Fourth Judicial District, Court of Appeal for State of Florida, wherein Mr. Moore’s “Expert Witness” is also listed as a member of the AIAQC and of whom the court noted:
“Dugay (sic) does not have a college degree or a resume. He testified that 0.5% of his work is testing for mold contamination and he relies on industrial hygienists to do mold testing. Dugay (sic) stated that he spent approximately one hour reviewing the case at the time of the trial. He never visited the Chodorows’ (plaintiff) home or saw pictures or videos of the home. He did not review any test results or documents, nor did he conduct any tests, before forming his opinion.”
DuGuay supported Moore in the placement of allegedly useless equipment and diametrically opposed the opinion of Dr. Ron Huggins, CIH, MPH of whom the courts observed:
“Dr. Huggins has a B.S. in Biology, an M.S. in Environmental Biology, an M.P.H. in Environmental Health/Industrial Hygiene, and a Ph.D. in Industrial Hygiene/Toxicology. He has an extensive background and career in assessing air quality and evaluating damage due to water intrusion and mold.”
Disturbingly, during the testimony, DuGuay was initially seen on equally footing with Dr. Huggins. (Well, after all, DuGuay IS a member of the AIAQC and therefore obviously an expert, right? The State of Maryland seems to think so.) It is my understanding, based on Moore’s representations, that he too, at the time, was a member of the AIAQC. Now it’s possible I’m incorrect and Moore used the designations without authority and was not an AIAQC member; I would like to know if the “CIE” and/or “CMR” designations are used by other than the AIAQC, and I would like to know if this “certified” mould guy was in fact a member of the AIAQC when he wrote this rubbish.
Last weekend, I trawled the web and looked at various sites of members of the AIAQC; I was appalled at the wide reaching lack of technical competence exhibited in the writings. It was rubbish. Although, I’m sure there are several out there somewhere, I failed to find a single web site that identified themselves as members of the AIAQC and also provided sound indoor mould related information devoid of hype and/or myth. What I saw was bunk.
Now, mind you, I’m not entirely complaining about bunk – after all, bunk keeps me in business. If it were not for the bunk peddlers, I would have far too much nonbillable time on my hands for comfort, and my mortgage holder would then become nervous (not to mention my wife).
However, if legitimate scientists are not careful and do not stand up and oppose stuff like the Maryland legislation, we will find ourselves in the position where Dr. Huggins found himself: An environment where bunk competes on equal footing with legitimate science and objective facts; and the bunk peddlers will be indistinguishable in the eyes of the consumer (and possibly the trier of fact) from the legitimate, knowledgeable, scientists. Apparently, that has already happened in Maryland.
Caoimhín P. Connell
Forensic Industrial Hygienist
Forensic Industrial Hygiene
(The opinions expressed here are exclusively my personal opinions and do not necessarily reflect my professional opinion, opinion of my employer, agency, peers, or professional affiliates. The above post is for information only and does not reflect professional advice and is not intended to supercede the professional advice of others.)
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