Edition No. 11

Mold Management: A Proactive Overview

The management of mold can often follow the old adage, out of sight, out of mind. Many times if there hasn't been a water incident or a leak, mold management falls way down on the list of priorities. That's where a mold management program is valuable. Not only does it ensure that controls are in place for an incident, but it assigns specific responsibilities to EHS personnel and remediation services to ensure that mold management is always part of a comprehensive EHS program.

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The major focus of the Water Response and Mold Prevention Program (WRMPP) is to minimize property damage and liabilities resulting from a water loss or mold growth condition. Key elements of this program help:

Detect water losses and mold growth early to minimize property damage and liability;
Provide guidance for preventing and responding to moisture/water or mold growth conditions; and
Outline the minimum required procedures for responding to a moisture/water or mold growth condition.

Key Program Areas

The following components are critical in the development of a comprehensive WRMPP:

A written WRMPP document
Assignment of responsible parties for job functions within the WRMPP
Proactive planning and management of projects and subcontractors
A preventive maintenance and inspection program
Established procedures to minimize potential moisture/water intrusions
Proper documentation of a moisture/water condition or mold growth
Guidelines for response to a moisture/water condition
Identification of mold growth and determination of the extent of damage
Guidelines for remediation of mold-containing building materials
Training objectives and goals for company personnel
Communication with interested parties during and following a moisture/water or mold growth condition

Roles and Responsibilities

After a short discussion of building construction and the indoor environment, the WRMPP describes fungi, growth of fungi in building and how to prevent it. Next is a description of the WRMPP's roles and responsibilities. In order for a WRMPP to be successfully implemented, it is important that management define roles and responsibilities for specific tasks and management authority for specific aspects of the WRMPP. The key roles and responsibilities outlined in the program are designed to:

Ensure that safety and health procedures are in place for personnel conducting actions associated with the WRMPP
Deploy an effective WRMPP
Effectively oversee and administer the WRMPP
Retain and maintain all documentation under the WRMPP
Ensure that procedures are current and effective through periodic review and update of the WRMPP
Budget for the WRMPP
Provide assistance in the development and training of all employees
Provide tenants with the Tenant Mold Prevention Letter prior to their signing a lease or renewal and explain the tenants’ responsibilities under the WRMPP
Complete the Tenant Mold Investigation Letter and communicate the results of a mold investigation to all tenant(s) in the investigated rental space(s)
Keep the tenants updated on the status of any water extraction or mold remediation activities being conducted within their building(s)
Minimize the likelihood of water loss associated with construction/renovation activities on the interior or exterior of the building by putting a preventive maintenance (PM) program in place
Protect all porous building materials installed by company employees or subcontractors from precipitous weather exposure (e.g., morning dew, rain, sleet, snow, etc.) prior to and during installation within the building
Ensure that any dampened/wetted building materials are dried thoroughly and inspected for signs of moisture, water damage, and mold growth, prior to installation within the building
Ensure that no mold-contaminated or damp materials (especially porous materials) are installed within the building
Conduct the periodic water loss and mold contaminated building materials inspections required under this program
When a water loss or mold growth condition is discovered, complete and submit to the appropriate person (by job title) under the WRMPP a Water Loss and Mold Contaminated Building Materials Incident Report Form
Confirm the water/moisture or mold growth conditions reported on incident report forms
Determine the level of response required following observation of a moisture/water or mold growth condition
Qualify water extraction, mold remediation, and mold investigation subcontractors
Contract/coordinate emergency water extraction, mold remediation, and site investigation subcontractors
Direct tenant complaints/concerns of a possible moisture/water or mold growth condition(s) to the appropriate person (by job title) under the WRMPP
Conduct or facilitate on-site inspections following tenant complaints/concerns of a possible moisture/water or mold growth condition
Maintaining relative humidity levels below 55% using dehumidification equipment in the event of long periods of downtime, such as facility shutdown and power outages

Additional Program Sections

Section Three describes how mold incidents are communicated while Section Four reviews documentation and record keeping. The following checklists and forms are included in the WRMPP to document: a) inspections for potential water losses and mold-contaminated building materials to be carried out under this program; b) reports of moisture/water or mold growth conditions; and c) water extraction and mold remediation activities. Listed below are the documents included in the program; each describes the form's intended use and how long it should be retained and by whom.

Tenant Mold Prevention Letter
Tenant Mold Investigation Letter
Water Loss and Mold-Contaminated Building Materials Inspection Checklist
Water Loss and Mold-Contaminated Building Materials Incident Report Form
Water Loss and Mold Contaminated Building Materials Incident Report Log
Water Loss and Mold Contaminated Building Materials Follow-up Tracking Form

Section Five, Competencies and Training, explains the competencies and training required for all employees involved in the WRMPP and the subcontractors (mold remediation, water extraction and investigation subcontractors) that may be hired to assist them.

Section Six highlights the other program requirements including: Preventive Maintenance, Programmed Inspections, Long Periods of Downtime, Weather Exposure and Subcontractor Expectations.

Section Seven reviews procedures for responding to water losses and/or mold contamination including management of a tenant complaint or concern, management of an observed moisture or water condition and management of an observed or suspected mold growth condition. It is important that the company define clear objectives for the work being provided by water extraction, mold remediation, and investigation subcontractors required under the response management procedures in Section Seven.

Section Eight is intended to outline basic services and deliverables that these subcontractors are expected to provide. Details are outlined for water extraction subcontractors, remediation subcontractors and IAQ investigation subcontractors.