The "United States Toxic Mold Safety and Protection Act of 2002," also known as the "Melina bill," was introduced by John Conyers Jr., D-Mich. The legislation addresses many issues related to mold, including a requirement to set standards for mold exposure, creation of indoor mold hazard assistance, development of construction standards as they relate to mold, providing tax provisions for mold inspection and remediation, and creation of a national toxic mold hazard insurance program.
"We recognize that the intent of the bill is to address mold as a broad issue. However, we believe the best way to do this is to prevent mold growth in the first place," said AIHA President Gayla J. McCluskey, CIH, CSP, ROH, QEP. "AIHA is pleased that the issue of mold is being addressed. We hope that our input will be considered on the areas of concern for OEHS professionals."
AIHA expressed four basic areas of concern:
- AIHA does not believe it is possible to define or set permissible exposure limits for "toxic mold." With the current science, AIHA believes that it is not possible for any single study to ascertain levels at which exposure to mold or mold byproducts will harm human health.
- The group is primarily concerned about standards for individuals involved with inspection and remediation of mold. AIHA would like to see certified industrial hygienists formally recognized as being pre-qualified to address mold inspection and remediation. Others who work with mold should be required to have sufficient education and training.
- The group also believes that only accredited labs should analyze mold samples. One of the requirements to address the potentially harmful effects of mold contamination is to identify the type of mold and the level of exposure. It is imperative that only laboratories accredited for the appropriate analyses by a nationally recognized accrediting body or authority conduct mold testing.
- The Occupational Safety and Health Administration and the National Institute for Occupational Safety and Health should be among the agencies designated to implement this legislation, according to AIHA. As the bill stands, the Environmental Protection Agency is given complete oversight over the issue. Mold occurs in the occupational environment as well as residences. AIHA is concerned with people who are exposed to potential mold hazards in the workplace as well as those who are involved in mold inspection and remediation.
Additionally, AIHA is concerned about language in the bill that would leave development of standards, guidelines and recommendations to those who develop national building and construction standards. The group does not feel that organizations involved with establishing construction standards have the necessary background and insight into the qualifications necessary for individuals and laboratories involved with mold inspections and remediation.
More information about mold can be found on the AIHA web site (www.aiha.org), where consumer and professional fact sheets, the transcript of a June 2002 mold press conference and other materials can be found.