Recent provisions in the National Defense Authorization Act (NDAA) direct the Department of Defense to establish uniform mold remediation guidelines for military housing and facilities. Importantly, those guidelines must align with recognized third-party industry standards, including the ANSI/IICRC S520 Standard for Professional Mold Remediation.

This requirement marks a major shift from discretionary “best practices” to federally guided standards. Furthermore, with the expected passage of Connecticut Senator Richard Blumenthal’s Military Occupancy Living Defense Act, or MOLD Act, military families worldwide can look forward to significant improvements in their living conditions. This industry-wide change will help ensure cleaner, safer, and healthier indoor environments for families.

Why it matters

Mold is a type of fungus that grows in damp or water-damaged areas of buildings, such as behind walls, under floors, in ceilings, or on materials like drywall, carpet, paper, and wood. Mold needs moisture to grow, which means leaks, flooding, high humidity, or poor ventilation can allow it to spread.

Some molds are considered “zero tolerance” molds because they can produce toxic substances called mycotoxins. These toxins can affect people even in small amounts and have been linked to breathing problems, headaches, fatigue, eye and skin irritation, and other health symptoms, especially in children, older adults, and people with asthma, allergies, or weakened immune systems.

Zero tolerance mold refers to a remediation standard for highly toxic molds, such as Stachybotrys, Chaetomium, Fusarium, Memnoniella, and Trichoderma, requiring complete removal. These molds often indicate significant water issues and don’t belong in clean indoor spaces. So even small amounts warrant full remediation.

A critical issue is that mycotoxins can remain harmful even after the mold is no longer alive or visible. In other words, killing mold with sprays or cleaners does not necessarily remove the health risk.

Exposure also doesn’t come only from visible mold. Mold spores, tiny fragments, and contaminated dust can become airborne during everyday activities like walking through a room, opening doors, running fans, or disturbing damaged materials. Once airborne, these particles can be inhaled or may settle throughout a building.

Because of these risks, mold, especially toxin-producing mold, must be physically removed along with the materials it has contaminated. Painting over mold or wiping it down does not make a building safe.

Professional remediation

Historically, mold complaints in military housing were often addressed with superficial responses: Cleaning visible growth, repainting surfaces, or temporarily relocating occupants without correcting moisture sources. These approaches repeatedly failed because they treated symptoms rather than causes.

The NDAA recognizes that inconsistent and incomplete remediation practices are unacceptable. By requiring standardized guidance tied to third-party industry standards, such as the S520, Congress has effectively confirmed that mold remediation is a specialized professional service, not a custodial task.

For contractors and consultants, this means that simply citing the S520 is no longer enough. Work must be performed, documented, and verified in a way that aligns with the standard’s intent and protects occupant health.

S520 interpretation

S520 provides a strong scientific framework, but it is not a step-by-step checklist. Without proper training and interpretation, it can be misapplied, leading to inadequate containment, incomplete moisture control, or insufficient post-remediation verification (PRV) that a space is safe to reoccupy.

In military housing, where occupants include children, medically vulnerable individuals, and active-duty service members, the margin for error is small. This is where professional practice frameworks become critical.

NORMI practices

At NORMI, the National Organization of Remediators and Microbial Inspectors, our work has always focused on connecting building science, health protection, and real-world execution. As outlined in the book “Mold-Free Construction,” mold problems are rarely caused by mold alone; they result from moisture mismanagement, design decisions, poorly designed HVAC systems, and broader building failures. The same is true in remediation.

Through NORMI Professional Practices and NORMIPro Management, we help translate standards like S520 into repeatable, auditable processes, including:

1. Assessing and identifying the problem—Prognosis without diagnosis is malpractice. Once the true cause is identified, implementing the correct and lasting solutions becomes possible.
2. Operationalizing S520 and other industry standards—NORMI has turned an industry-standard document into practical operating procedures that contractors and housing managers can follow and that inspectors can verify establishes consistency and improves work quality outcomes.
3. Training and qualification—Mold remediation requires trained professionals who understand moisture dynamics, microbial behavior, containment logic, assessment protocols, and post-remediation verification. Credentialing matters.
4. Documentation and accountability—Proper remediation is only as defensible as its documentation. Defined scopes of work, moisture data, photographs, equipment logs, and clearance criteria protect occupants, contractors, and the Department of Defense alike.
5. Independent quality assurance—Third-party technical reviews before and after work reduce failures, prevent recurrence, and lower long-term costs. It also aligns with the NDAA’s emphasis on oversight and reporting.
6. Prevention, not just cleanup—Mold remediation that does not address moisture sources is not remediation; it is a delay, leading to the need for repeated work.

The Department of Defense and the NDAA provisions affecting military housing mark an important moment for the mold and remediation industry. Standards-based remediation is no longer optional or situational. It is becoming the expected baseline in high-accountability environments.

For occupants, this shift means better protection, clearer expectations, and safer living conditions. For qualified professionals, and especially mold assessors and remediators licensed by a state government, it is an opportunity to elevate outcomes, reduce repeat failures, and demonstrate that mold remediation—done correctly—protects both buildings and the people who live in them.

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Until now, many inspectors have had to stop short, recognizing moisture issues, visible growth, or building conditions that support microbial amplification, but lacking the credentials, protocols, or authority to assess and report on mold accurately. That gap is precisely what the��NORMI Certified Microbial Assessor (NCMA)��training is designed to fill.

With NORMI’s (National Organization of Remediators and Microbial Inspectors’) newly signed agreement with��InterNACHI (International Association of Certified Home Inspectors), the world’s largest home inspector trade association, we are creating a clear, professional pathway for home inspectors to expand their scope of practice, increase their income, and better serve their clients—without abandoning the building science foundation they already know.

Why home inspectors are a perfect fit for mold assessment

Home inspectors already understand the��building as a system. They know how air moves, how moisture migrates, where failures occur, and why construction defects lead to problems inside the structure. Mold assessment is not a leap—it is a logical extension.

In fact, most mold problems are��not��mysterious biological events. They are the predictable outcome of:

• Improper drainage or grading
• Roof or plumbing leaks
• HVAC imbalances
• High indoor humidity
• Poor ventilation
• Building envelope failures

These are conditions home inspectors identify every day.

As someone who personally worked as a home inspector for several years and as the author of MoldFreeConstruction.com, I understand the mindset, workflow, and limitations inspectors face. The NCMA training was built specifically to bridge that gap—turning observational knowledge into��actionable microbial assessment expertise.

What is the NCMA?

�ճ��������Ѵ���is a trademarked professional certification developed by NORMI that trains individuals to perform��non-invasive mold and microbial assessment����using science-based protocols, proper documentation, and defensible reporting methods. Under the direction of the Center for Indoor Air Quality and Human Health, protocols have been established to guide professionals down a path that allows them to evaluate the problem and offer solutions.

The training focuses on:

• Moisture dynamics and microbial amplification
• Visual and olfactory assessment techniques
• Sampling strategies and limitations
• Chain of custody and laboratory coordination
• Interpreting results responsibly
• Writing clear, professional assessment reports
• Understanding the difference between assessment and remediation
• Avoiding conflicts of interest and scope creep

Importantly, the NCMA program doe����not��attempt to turn inspectors into remediators or medical experts. Instead, it equips them to��identify, document, and asses����microbial conditions—then refer appropriately. What NORMI has always taught is simple: Prognosis without diagnosis is malpractice. Until a professional understands the problem, he cannot offer a solution. This training educates the NCMA on both.

Answering a demand that already exists

The demand for mold information isn’t coming—it’s already here.

Home inspection clients are more educated, more health-conscious, and more concerned about indoor environments than ever before. Buyers, sellers, landlords, and property managers routinely ask inspectors about mold, moisture, and indoor air quality.

By adding the NCMA credential, inspectors can:

• Respond confidently to client concerns.
• Offer a standalone mold assessment service.
• Increase inspection ticket value.
• Create new revenue streams.
• Differentiate themselves in competitive markets.

Many inspectors report that mold assessments generate��significantly more income per job��than standard inspections, often with less time on site and fewer physical demands.

Professional growth without reinventing the wheel

One of the biggest advantages of the NCMA program is that it��builds on what inspectors already know.

There is no need to relearn construction fundamentals. Instead, the training reframes existing knowledge through the lens of microbial risk and moisture science. Inspectors learn how to connect the dots between building conditions and indoor environmental outcomes.

This makes the transition simple, straightforward, and realistic—especially for seasoned inspectors looking to expand without starting over.

A win for inspectors and the industry

The partnership between NORMI and InterNACHI represents more than a training agreement. It reflects a broader industry shift toward��health-focused building evaluations.

As expectations rise, professionals who can competently address mold and microbial concerns will lead the market. The NCMA provides a structured, ethical, and science-based way to meet that need—while maintaining professional boundaries and credibility.

The future of inspection is health-informed

Homes are no longer evaluated solely on structure and systems. Indoor environmental quality has become part of the conversation—and rightly so.

By empowering home inspectors to become��NORMI Certified Microbial Assessors, we are not changing who they are. We are expanding what they can do.

For inspectors ready to take the next step, the NCMA is not a departure from home inspection—it’s the next evolution.

NCMA meets state licensure requirements

NORMI is approved training for states that require licensing, and this course is approved by all states except Texas and New York, which have unique requirements. For more information on training, please see or call 877.251.2296.

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Mold Remediation for Health-Sensitive Individuals

In the world of indoor air quality and mold remediation, few organizations have had as much of an impact as NORMI — the National Organization of Remediators and Microbial Inspectors. Since its founding in 2004, NORMI has provided science-based training and certifications for professionals working in mold removal and indoor environmental quality. Now, it’s taking things even further with groundbreaking initiatives that aim to transform the way mold remediation is done — especially for individuals with mold sensitivities and related health conditions.

A Visionary in the Remediation Industry

Being a visionary means seeing future needs and creating solutions before they become mainstream. NORMI has done just that. With over 32 certifications developed to meet the requirements of states like Texas; Louisiana; Florida; New York; Washington, D.C.; and Portland, Oregon, NORMI has trained thousands of professionals across the U.S., Canada, Europe, and South America. Other states, including California and Illinois, have begun recommending contractors be certified by reputable organizations like NORMI.

As an approved training provider for the U.S. Environmental Protection Agency (EPA) and various state agencies, NORMI stands out as a trusted authority in the field.

Introducing the NORMI Medical Advisory Board

One of NORMI’s most important recent achievements is the formation of its Medical Advisory Board in the remediation industry. Chaired by Dr. Andrew Heyman, a leading expert in environmental health, this board is helping to bridge the gap between medical science and remediation practices.

The aim? To ensure that mold remediation methods not only remove visible mold but also address the hidden contaminants that can make people sick—especially those who are already sensitized to mold, bacteria, or other environmental toxins.��

Why Mold Remediation Needs to Evolve

Water-damaged buildings are more common than most people realize. And when water damages buildings—whether from leaks, flooding, or humidity—mold and bacteria can grow. These microbes release harmful byproducts such as mycotoxins, beta-glucans, and actinobacteria, which can become airborne and spread far beyond the area that initially got wet.

For people with mold sensitivities, chronic inflammatory response syndrome (CIRS), asthma, or weakened immune systems, even low levels of these contaminants can trigger serious health issues.

Traditional remediation methods often focus only on the visibly damaged areas, ignoring contamination that has spread through the air or into other parts of the building. That’s where NORMI comes in—offering new approaches based on the latest science and supported by medical professionals.

Backed by the Latest Science

The National Institute of Environmental Health Sciences (NIEHS) recently updated its information on mold (April 23), confirming that exposure to mold affects human health in numerous ways. According to NIEHS, “These organisms can affect human health in a variety of ways, depending on the type of mold, amount and duration of exposure, and the person exposed.”

This makes it more critical than ever to ensure that remediation professionals understand how to identify, assess, and treat environments in a way that supports the health of the people who live or work in them.

The NORMI Level Four Protocol

To meet this challenge, NORMI created the Level Four Protocol — a detailed, step-by-step process specifically designed for people who are medically sensitized to mold and other biotoxins. This protocol has been officially reviewed and endorsed by the NORMI Medical Advisory Board.

Unlike standard mold removal practices, the Level Four Protocol looks at the entire environment, not just one room or surface. It aligns with the respected IICRC S-520 standard for mold remediation but goes further to address the unique needs of those with mold-related illnesses.

Through this protocol, certified NORMI professionals can perform a thorough assessment and implement a whole-home decontamination plan that truly supports healing. These professionals earn the designation of NCRSI — NORMI Certified Remediator for Sensitized Individuals — and follow procedures that have been validated as medically sound. Click for the class schedule.

A National Network with a Mission

NORMI is now launching its . This network connects trained, certified professionals across the country who are ready to offer comprehensive, medically informed mold remediation services.

However, this network extends beyond simply cleaning homes. One of its groundbreaking goals is data collection. When professionals follow NORMI’s Level Four Protocol, they’ll collect critical environmental data before and after remediation. This data shared securely and confidentially through a centralized system will help medical researchers better understand how environmental decontamination leads to improved health outcomes.

The hope is that, over time, this research will provide even more evidence linking comprehensive mold remediation with better patient recovery — something that could have lasting impacts on both the health and remediation industries.

Join the Next Generation of Mold Remediation Experts

NORMI is extending an open invitation to remediation and environmental professionals who want to become part of this cutting-edge movement. By joining the NORMIPro Management National Service Provider Network, contractors and consultants can position themselves at the forefront of the industry — offering services that are not only technically sound but also medically validated.

Professionals interested in evaluating the program may find more information . If you or someone you know struggles with mold-related illness, or if you’re a contractor ready to take your skills to the next level, NORMI offers the tools, training, and support to make a meaningful difference — one home and one life at a time.

The post A Paradigm Shift in the Industry appeared first on Cleanfax.

But they all had one thing in common: none of them holistically addressed indoor air quality. And they all could have.

That realization changed the trajectory of my life. I committed myself to fixing the problems to which I had unknowingly contributed. But even as I advanced in building science and began to improve indoor environments, something crucial was still missing.

No connection existed between the work we were doing to improve the built environment and the doctors treating people affected by it. I could fix buildings—but I couldn’t fix people. No matter how much we improved air quality, no clear pathway emerged to communicate those changes with medical professionals, let alone coordinate care or validate outcomes. I knew we needed a way to bridge that gap, to bring physicians into the remediation process and give them tools they could trust.

And now—for the first time in our industry’s history—that connection has been made.

A first-of-its-kind partnership

In a landmark move, Dr. Andrew Heyman, MD, a nationally recognized expert on Chronic Inflammatory Response Syndrome (CIRS) and functional medicine, has joined forces with the leadership at NORMI (the National Organization of Remediators and Microbial Inspectors) to launch the NORMI Medical Advisory Board. This collaboration has resulted in the creation of the Level 4 Protocol—a medically informed assessment and remediation process designed specifically for environmentally sensitized, immune-compromised, and chemically sensitive individuals, and tied tightly to training and the trademarked NCRSI (NORMI Certified Remediation for Sensitized Individuals) course.

This marks a monumental step forward in our field. For the first time, remediation professionals can now work together with medical practitioners to address the real-world health consequences of indoor environmental contamination.

Science, testing, and standardization

Thanks to emerging technology, we now have the tools to support this connection. Advanced testing for microbial contaminants—far beyond basic spore traps or visual assessments—has become both accessible and affordable. Air and surface testing for mycotoxins, endotoxins, and actinomycetes can give physicians the actionable data they need to connect environmental exposures with patient symptoms.

This scientific validation gives remediation professionals an unprecedented opportunity to work under a doctor’s direction, perform targeted remediation, and provide proof that the work directly addresses the patient’s needs.

No longer do doctors need to send their patients back into contaminated environments, hoping for the best. With the right collaboration and protocols in place, they can now confidently prescribe environmental remediation as part of a holistic health plan.

The partnership’s effect on the industry

This partnership elevates the entire profession. It validates the importance of our work—not just in terms of structural integrity or aesthetics, but in real human health outcomes. It empowers restoration professionals with medically backed procedures, standardizes protocols across projects, and establishes a framework for collaboration with physicians.

In other words: it sets a new bar.

New education and training programs will be developed focusing on the health impacts for workers and customers. As a result of these new training efforts, new and updated information will be given to NORMI members to help them locate scientific and medical studies, along with other research, and give them content that is understandable, useful, and improve their bottom line. Professionals who want to be part of this next chapter must be prepared to integrate their knowledge of the built environment with insights from the medical community. That’s where NORMI’s training and certification programs are leading the charge.

The opportunity ahead

This isn’t just a win for patients, it’s a huge opportunity for our entire industry. It opens doors in hospitals, dormitories, cruise ships, athletic facilities, and more. As I’ve often said: the only people who need the sanitization protocols we teach are people who breathe.

This collaboration between NORMI and the medical community is more than an advancement. It’s a revolution, a new framework, a new language for communication between two critical industries, and most importantly, a new way to ensure that our work improves not just buildings but lives.

This isn’t just a new chapter—it’s a whole new book. And we’re just getting started.

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We have seen the ongoing health effects that resulted from the Sept. 11 disaster as those effects have persisted for many years and cost billions of dollars. Since Hurricane Katrina, we’ve learned even more about the long-lasting results of improperly handling materials contaminated with CAT 3 water (category 3 “black water” polluted with toxins and pathogens). CAT 3 water carries many contaminants that negatively affect the air and the water and could affect your health. Both residents and volunteers are seldom trained in proper methods that should be used to clean up the area, and so they often resort to whatever is convenient or easy at the time.

Being unprepared, and with emotions heightened, mistakes are made that may later result in negative impacts to their health and well-being. NORMI, through our not-for-profit , is distributing this information now wanting it to get out AHEAD of the next disaster in order that, just like stocking up on food and other essentials, residents can prepare to protect health and safety. This should become part of the staging plan. The three important documents are:

1. Tips for Disaster Area��Residents—The first step to recover from a disaster is to stay healthy, differentiating between the tasks you can safely do yourself—without putting your health at undue risk—from the ones you need to delegate to a trained professional or other skilled laborer. Things like identifying those most at risk from exposure (such as infants, the elderly, or immune-compromised) should have evacuated but certainly not be involved in the clean-up efforts.�� Using the right personal protection equipment (PPE) and creating a “safe, clean” place to spend the night is critical to preserving the safety and health of residents after a natural disaster.
2. Tips for Disaster Area��Volunteers—Though it is wonderful, and needful, to have so many volunteers coming from great distances to help in the recovery efforts, those who are untrained or unskilled can often become a burden on the sparse resources that remain after a disaster. When they get injured or ill, they take away some of the resources required by the local residents to sustain themselves.�� Trainings from Occupational Safety and Health Administration (OSHA); Institute of Inspection Cleaning and Restoration Certification (IICRC); and NORMI, National Organization of Remediators and Microbial Inspectors, can go a long way toward helping a worker understand the value and use of PPE while handling contaminated materials and learn the proper methods for cleaning up possessions covered with mold and other invisible microbials.
3. NORMI Professional Guidance for DIY Projects—Because resources become limited following a disaster, many residents must resort to self-help or do-it-yourself (DIY) efforts. To avoid waiting for insurance clearance, or because they don’t have the money to pay a professional, residents jump right in and start the clean-up process often with no formal training on how the work should be done.�� The simple, but common, mistakes that are often made should be avoided and this document will help the resident put together a plan of action that will have better results.

These three documents can be downloaded from or from the bottom of�� where you’ll find “Resources for the Do-It-Yourselfer.” Because you are preparing for the next hurricane season, make this a part of your staging plan, and make sure those who work on your property are properly trained and prepared to handle the disaster. It’s the best thing you can do for yourself and your family.

For more information, also check out and

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Bleach is a powerful oxidizer and can, in many instances, sanitize nonporous surfaces of certain microbial contaminants. Still, when faced with a semi-porous wall covered in mold, straight bleach is NOT the product to use. Even the U.S. Environmental Protection Agency (EPA) now recognizes this is not the solution.¹

In July 2004, prior to Hurricane Katrina in 2005, the State of Louisiana put in place the nation’s first mold remediation licensing law.�� When Katrina devasted New Orleans, it also destroyed the residential pesticide industry, so following Katrina, in October 2005 and as part of the state’s emergency declaration, the then Commissioner of the Louisiana Department of Agriculture and Forestry, Bob Odom, declared mold a “pest” (LAC 7:XXIII.125).�� Because the chemistries used to kill mold are registered as pesticides, this declaration resulted in requiring all licensed mold remediators, who clean and fog chemistries, to become a licensed pesticide applicator with the state of Louisiana. Sodium Hypochlorite is an EPA Registered Disinfectant, not registered as a pesticide.

Bleach alone won’t do the trick

Eyebrows raise in disbelief every time I say the phrase “bleach doesn’t kill mold.” Some look at me as if I’m speaking another language, and they are right. But I am telling the truth. Jug bleach (the only active ingredient is sodium hypochlorite) is very effective in removing the discoloration but may leave the microflora that will enable the mold to return to precisely the same spot when conditions are right. So, how do I know this?

Several years ago, we helped develop a process by which shingle and tile roofing systems could be cleaned of the mold and mildew that discolors and shortens its life. Look at any real estate guide or website that lists homes for sale, and you’ll see house after house with mold streaks running down from top to bottom of the roofing system. The mold on the roof is ugly, but that is not our biggest concern. There are two other concerns that are good reasons to address this roof mold problem. Mold destroys the shingle, and it also makes the air conditioning system less efficient.

Mold destroys shingles

First, shingles are made primarily of organic materials. A shingle’s asphalt or fiberglass content is only a small percentage of the entire composite. This organic material is ripe fruit for the mold to eat. As we know, mold needs to have a nutrient of some sort, and organic materials are especially appealing.

The petroleum-based asphalt is protected from the UV light of the day’s sun by a “ballast” or granules that are “glued” to the surface of the shingle. When the mold begins to grow, it “pops” the granules off of the shingle, exposing the asphalt to the UV, thus shortening the shingle’s life. When shingles begin to curl, that’s a good sign that the shingle is drying out and its life is ending.

Cleaning the roof off using an effective biocide can lengthen the life of the shingle by allowing the granules to remain tightly adhered to the surface.

Mold can cause inefficiencies in air conditioning

Secondly, a black roof absorbs more heat than a lighter roof. Interestingly enough, in Florida, most homeowners choose a lighter roofing color for that very reason, and yet, after a few years, they all turn the same color—black.

We commissioned a study in conjunction with the University of South Florida (USF) and found a substantial difference in attic temperatures once the roof was cleaned and the original lighter color restored. We saw a temperature difference of 30 degrees or more.

So, by simply cleaning your roof back to the lighter color, you could make a significant difference in the attic temperature, especially if the air handler were in that hot attic. A lighter roof would allow your air conditioning system to function more efficiently. In most cases, the attic is the insulating space just above the air-conditioned space, so reducing those temperatures substantially lowers the air conditioning bill.

What can be done to combat mold?

The importance of understanding these problems makes it relatively easy to sell the customer of the value of having their roof cleaned. However, what product or products to use could make a substantial difference in the longevity of the cleaning process and the effect of the cleaning process on the roofing system.

Of course, any type of high-pressure wash could destroy the shingle by removing the granules, so a low-pressure wash is desirable, making the chemical solution you use more important. We used a combination of surfactants, detergents, and sodium hypochlorite (yes, bleach) to lightly spray on the roof then rinse it off with no more pressure than a garden hose. It worked great.

The only problems were that the landscaping had to be protected from the toxicity of the mixture, and the mold would return in less than two years. Even walking around on the roof every few years could damage the roofing system, so we looked for a better alternative.

Anecdotally, and at about the same time, my wife wondered why she had to clean the same spot of mold on the bathroom tile month after month. Now she knows why. The mold has never been killed—it simply goes clear and then returns. Jug bleach will not kill the mold, but a suitable biocide or anti-microbial solution will.

To underscore the validity of my claim, I suggest the Forest Products Journal article, referenced below, which commissioned a study by Oregon State University a couple of years ago.² The “implications” of their testing showed exactly what we have been training for years. The stain disappears, but the microflora remains, and under the right conditions, the mold will begin to grow.

Our NORMI sanitization protocol recommends using green technologies like natural enzyme cleaners to remove surface mold. Many EPA-registered products also use sodium hypochlorite as one of their ingredients to reduce staining, but it has been approved to effectively reduce fungal growth.

When you use the right kind of antimicrobial, the mold will be destroyed, and the underlying bio-slime will be annihilated. I wish we knew about these technologies when we were cleaning roofing systems twenty years ago. Instead of spending so much time protecting the landscaping, we could have done an additional job or two, and our warranty work would have been reduced.

References:

¹ U.S. Environmental Protection Agency. (Updated 2023, October) Should I use bleach to clean up mold?

² Taylor, A.M., Freitag, C.M., Morrell, J.J. (2004, April) Ability of bleach and other biocide treatments to remove and prevent mold growth on Douglas-fir lumber. Forest Products Journal Vol. 54, No. 4, 45-49.

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In 2008, the Obama Administration directed the EPA to consolidate the state’s lead licensing under the one federal agency. So, on April 22, 2008, EPA issued a rule requiring the use of lead-safe practices and other actions aimed at preventing lead poisoning which included a very specific one day training program, examination for certification and registration with the EPA to confirm those working in pre-1978 housing we protecting the public from the harmful effects of lead-based paint.

Let’s take a look at why you, as a restoration contractor, should be registered and utilize lead-safe practices whenever you disturb surfaces in homes older than 1978.

1)Children chew on painted surfaces—Who among us hasn’t seen their infant child gnaw on their crib rails, low windowsills, or painted pet gates? Children put things in their mouths and when those are painted with lead-based paints, even multiple layers below the surface, small fragments of lead may be ingested and cause damage to the developing brain of the child.

According to the National Library of Medicine, “approximately 590,000 US children aged 1 through 5 had elevated blood lead levels…and 4.3 million children resided in homes with lead paint in 2019.” It’s a big problem.

2) Lead-based Paint becomes airborne—this is seldom considered when discussing paint because this action is unseen by the naked eye. In older homes where double-hung windows are being moved up and down on a regular basis, lead becomes airborne. During a renovation or repainting project, scraping and sanding is performed and cause the lead to contaminate the air we breathe and may be inhaled by the home’s occupants. Therefore, any pre-1978 home being remediated, painted, renovated, or remodeled should be evaluated for lead paint.

3) Untrained professionals pay a $37,500 fine—if a non-trained professional begins work on a pre-1978 home and does not check for lead paint, the fine can be massive. The EPA website states, “from October 2015 through September 2016, EPA entered into 123 settlements for alleged violations of one or more of the three lead-based paint rules—the Renovation, Repair and Painting Rule, the Lead Disclosure Rule, and the Lead-based Paint Activities Rule of abatements.”

Sears Home Improvement Products Inc., for instance, agreed to settle alleged RRP Rule violations related to work performed by its contractors, by paying a $400,000 penalty and adopting compliance measures. This is serious business and, for the small contractor, can put him out of business immediately.

Since 2010, the EPA has approved training providers across the country to teach a one-day Lead RRP course. After having this course, the student takes a short exam and receives a certificate evidencing his training. The professional is then required to register with the EPA which complies with the rule.

“Our problem, as an approved EPA provider,” reported Doug Hoffman, Executive Director of NORMI, “is convincing contractors, remediators and modelers that the course is important and required when working on older homes. To help them make the right decision, our one-day onsite course, has been approved by the State of Florida Mold Related Services for continuing education toward their CE requirement for Certified Assessors and Remediators (7 hours). Still, we don’t see much of a demand, so we hope the lack of awareness is the reason.”

For more information on this course, contact NORMI, National Organization of Remediators and Microbial Inspectors, at 877-251-2296 to voice your interest in this course or email support@normi.org. Classes are taught in Florida, Louisiana, Arizona, and California and for individual companies or entities by demand.

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My sister-in-law was highly allergic to perfumes, specifically women’s perfumes. When a heavily perfumed elderly lady sat down in front of her at church, my sister-in-law had to move to avoid getting a headache. On the other hand, her husband never noticed that the elderly lady sat down.

Often one employee will complain about “sick building syndrome” (SBS), but until there are several people who complain about the same area of the building, the employer won’t acknowledge that it could be a problem. It’s time to take all employee complaints seriously.

One of the reasons why government agencies have yet to set standards for mold contamination levels in indoor air environments is because everyone responds differently to the issue. Why is that true? Here are three reasons:

1. We have different immune systems. Frankly, some of us are healthier than others, and if our immune system is suppressed, we might react to IAQ contaminants when a healthier person might not.
2. We have different levels of sensitivity. Women are typically more sensitive to their environment than men. That sounds biased, but it’s simply a fact. While my sister-in-law could not go into her basement because of the mold, her husband and four boys played ping-pong down there with no apparent reaction. When I talk with women who are experiencing IAQ problems while their husbands are “oblivious,” I tell them that’s the reason we marry each other—because we’re different, not because we’re the same.
3. Some molds are more toxic than others. Mold is ubiquitous, even in indoor environments, so we are seldom in an environment where mold is not present. So, why don’t all of us react? Some folks react to specific molds, while others won’t react at all. Some molds produce elevated levels of mycotoxins, while others do not. A lot of mold can be problematic to some, whereas a little might not. So, in this discussion, the type of mold, the amount of mold, and the environment in which it is growing are all factors influencing a person’s reaction.

As employers, we should take employee complaints about IAQ and mold problems seriously. If we are proactive about dealing with environmental issues we are not personally experiencing, it will validate the concerns of those who might be more sensitive and establish confidence that we are concerned about the health and safety of our fellow workers.

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As a certifying agency, the National Organization of Remediators and Microbial Inspectors (NORMI) too often receives calls from clients concerned about a member misrepresenting either what they’ve been taught or what they should have more closely listened to in a NORMI class. This is the question every trade association faces: What can the organization do when its members don’t follow their training, their professional practices, or the industry standard of care? The answer isn’t easy.

When you do your own thing

Several years ago, we received a call from an attorney suing a remediator who had cleared a mold project with “just a few” Stachybotrys spores in the Air-O-Cell. At the deposition, which had just occurred the previous day, the attorney asked the remediator where he had received his training and certification. The remediator proudly declared, “I learned this from NORMI.” Fortunately, we were able to send the NORMI professional practices and training slides to the attorney as evidence that what the remediator had done was totally against his training. The NORMI professional practices identify Stachybotrys as a zero-tolerance mold.��

According to the attorney, NORMI was off the hook, but the remediator was not. Because he did what he wanted to do instead of what he was trained to do, he was on his own.

The risks of going rogue

If a trade association had a licensing or franchise agreement with professionals who use their logo, the association would have some control over how those professionals market their businesses and services. If a trade association had some ownership in the companies they train, the association would have some control over the quality of work performed or the techniques used. But because none of these relationships exist between the trainer and the trainee, a trade association can only recommend best practices and continue encouraging their members to “do the right thing.”

What we’ve learned, through the years and by experience, is that insurance carriers can defend an insured professional when that professional follows the training. When they don’t follow industry standards or guidelines, they can be on their own, shouldering the burden of any legal expenses and jeopardizing their license or certification. It’s a very unpleasant place to be.��

For these reasons, we suggest every trained professional take the following three steps:

1. Get trained and certified��by an organization recognized in the industry for its integrity and support of the standard of care and professional practices. It isn’t about the money; it’s about the quality of the training. The investment is worth it, and the consequences of getting bad training could cost a professional a lot more than his business.
2. Stay trained and certified. Quality certification agencies want to ensure that the professional is staying up to date with trends, new products, and techniques in that industry. Certifying agencies that require some type of re-certification credits help professionals stay connected to the industry. The mold industry is incredibly dynamic and requires the professional to keep current with license changes, reporting requirements, and government oversight changes. Again, the investment is worth it and could save the professional time and money.
3. Get more training. The cynical professional might think this is just about the money, but a good organization will encourage the professional to get all types, and different kinds, of training. NORMI recommends the Institute of Inspection Cleaning and Restoration Certification’s (IICRC) Water Damage Restoration Technician (WRT) course along with the Applied Structural Drying Technician (ASD) course. Also encouraged are Occupational Safety and Health’s 10-hour training (OSHA10), U.S. Environmental Protection Agency’����Lead Renovation, Repair, and Painting��(EPA Lead RRP) course, and other 91��Ƶ training and programs that will strengthen the professional’s place in the marketplace and help him broaden his offerings to the client. And, with good, reputable certifying agencies, re-certification credits can come from many sources. Again, the goal is to keep getting more training.��

My conclusion is, don’t go rogue! There are too many “cowboys” out there already messing up the industry’s reputation. Follow the industry standards and implement them into your business model. Make sure that your employees are supporting your efforts to provide the highest quality service they can under your direct supervision. This will protect you from potential liability and give you an advocate, your insurance carrier, who can and will defend you.��

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For many years, the position in the industry has been pretty simple: “If you see mold, you don’t have to test for it; just remove it.” To date, of the states that require licensing in the mold industry, only Florida requires sampling to be a part of the mold assessment process, and that regulation only applies when there are more than 10 square feet of visible mold. At NORMI (the National Organization of Remediators and Microbial Inspectors), our opinion is that this practice of not testing for mold has led to many unnecessary and expensive remediation projects. There are several good reasons why mold (or suspect mold) should be tested in every case, without exception.

To test … or not to test?

The Environmental Protection Agency (EPA) has a published document we often quote in our classes that takes an unsettling position on the subject. The one-page document begins by stating, “If you see mold, remove it; no need for testing.”��However, in the very next sentence, it says, “If litigation is possible, or there are concerns about health, testing might be necessary.”��As we know, litigation is almost always possible, and our clients’ health is often an issue.

The most alarming statement of all is found in the last paragraph of the EPA document, where it reads: ��“To determine the difference between dirt, mold, or other substances, testing might be necessary.” So, the only way to tell for certain if you are dealing with a mold problem is to test. If that’s true, doesn’t it make sense to know whether you are dealing with a mold problem before starting a multiple-thousand-dollar mold project?

Reasons to test

Here are a few good reasons why a professional assessor, restoration contractor, or mold remediator would want to test suspected mold:

Testing determines whether there is a problem. Testing what appears to be mold can substantiate the reason for implementing a remediation project and help determine whether to remediate or sanitize the surfaces. In our initial CMACMR (Certified Mold Assessor/Certified Mold Remediator) licensing class, we show a video where, in a “TV sting operation,” mascara is put on surfaces, and then professional mold assessors are asked to decide how to solve the problem. Only those who used some device to test, like an ATP luminometer, were able to say, “Not sure what it is, but it isn’t microbial.” Testing allowed them to determine whether there was even a problem, saving their customers thousands of dollars.

Testing proves the job was done correctly. Testing enables the contractor to create a baseline to which he might compare a PRV (post-remediation verification) sample proving the job was done correctly. Because we are dealing with what we cannot see, clean surfaces can only be considered “clean” when there is little or no evidence of microbial contamination, and that can only be done by testing. No matter how good your vision, no one can tell if it’s mold by simply looking, and we encourage clients to run from that kind of assessment.

Testing helps in the progress of the job. Testing can also be utilized by the contractor during the remediation project. We call this “interim testing,” confirming that progress is being made toward the final PRV or clearance. Using particle counters, ATP, and other methods, the professional can detect spikes in the contamination levels, possibly find breeches in containment, and identify other problems that might hinder the progress of the job. Interim testing is an effective way to help the professional stay on track and help his employees do a better job more quickly.

Testing reassures the client. Finally, third-party lab sampling is the only way to objectively prove to a client that the air and surfaces are now free from elevated levels of contamination. This both reassures the client and protects the professional from potential litigation. With proof that the job is correctly finished, the contractor is less likely to have issues with doubtful clients withholding final payment.

Final thoughts

It’s not clear to me why so many professionals have ignored the value of independent testing, but it’s certainly time to change the paradigm.��To mitigate the liability, reduce the unnecessary waste of resources, and objectively confirm a positive outcome of the project, testing is needed and should be, in my opinion, required. And money—or who will pay for it—should not be the obstacle that keeps us from doing our jobs correctly. A good contractor will incorporate the costs somewhere in the project and save himself a lot of grief … and money.

For more information on the initial CMACMR licensing course (FL, LA, DC, TX, and NY) and other IAQ (indoor air quality) mold training opportunities, contact NORMI at 877.251.2296 or visit

CMAT-NORMI Certified Mold Assessment Technician is designed to train remediators and restoration contractors on the techniques used for pre-, interim, and post-sampling to ensure that projects are done correctly. Register with Jillian at The Experience.

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