MHA Mold Policy Protocol

Public Housing Program Approved Plans

This Mold Policy and Protocol (MPP) is designed to aid Marin Housing Authority (MHA), in identifying, controlling and managing issues of moisture and fungal (mold) growth in their properties.

This MPP is developed to provide guidance to MHA on monitoring the building to minimize future moisture and water intrusion issues, and be better prepared to properly address fungal (mold) growth if discovered. 

This MPP consists of:

1. Identification of Responsible Parties (Chapter 2)
2. Background Information on Mold and Fungi (Chapter 3)
3. MPP Responsibilities (Chapter 4)
4. Notification and Recordkeeping Requirements (Chapter 5)
5. Inspection Requirements and Response to Reports of Water or Mold (Chapter 6)
6. Hazard Training Requirements (Chapter 7)
7. Required Work Procedures for Employees (Chapter 8)
8. Required Work Procedures for the Remediation Contractor (Chapter 9) 

3.1 Molds and Fungi

Fungi, including molds, are naturally occurring organisms belonging to the kingdom Eumycota, one of five kingdoms of biological classification. The kingdom Eumycota is large group of organisms, containing over 100,000 described species. Molds/fungi are found in virtually every environment, and can be detected year round, both indoors and outdoors. There are few places on earth that are completely free of fungi, molds and their spores. Molds/fungi are part of the natural and built environment.

Molds/fungi play an important role in nature by breaking down organic matter such as toppled trees, fallen leaves, and other organic matter. Molds/fungi are important for production of certain foods and medicines, like cheese and penicillin. Mold growth, however, is not desirable indoors and it should be avoided if possible. Furthermore, the presence of mold growth on the inside of a building is a symptom of a broader moisture or water intrusion issue. 

3.2 Mold Growth Indoors

Molds/fungi reproduce predominately by spores. These spores are very small and float through the indoor and outdoor air. These spores are present or deposited on most surfaces indoors and out. Molds/fungi can grow on virtually any substance as long as moisture or water, oxygen, and an organic food source are present. Molds/fungi grow favorably on wood, paper, carpet, insulation, and even food, but they do not grow on inorganic materials such as metal, glass, plastic, concrete, and plaster. While mold/fungi do not grow on inorganic materials, they can grow on and are supported by everyday dust and dirt that settles or accumulates on surface throughout our homes and work-place including metal, glass and concrete. Any substance or building material that contains organic constituents is a potential food source. This includes paper faced gypsum board, wood, carpet, and even dust on windows and walls.

While it is impossible to eliminate all molds/fungi and their spores from our environment, controlling moisture becomes a key factor for limiting or preventing mold growth indoors. All molds/fungi share the characteristic of being adaptable and have the ability to grow without sunlight; mold/fungi needs only a viable spore, a food source, moisture, and the appropriate temperature range (typically between 40°F and 100°F) to proliferate.

Mold/fungal problems are widely considered moisture problems. Water intrusion, chronic moisture and/or excessively high relative humidity can provide environments suitable for mold growth. Since mold spores are ubiquitous and most building materials are suitable organic food sources or have sufficient deposits of dust to support mold growth, it is important to control moisture within the building. While most moisture problems can be obvious, others can be very difficult to diagnose and some moisture problems are not associated with leaks at all. Hidden or concealed moisture may only become evident after long periods or after the water has traveled a distance from its origin. It is critical to identify and eliminate the underlying leak and moisture sources to fully resolve a mold issue. It is important to remember that as occupants of an environment, we contribute water to that environment with everyday activities such as cooking, bathing and simply breathing.

It is equally important as occupants to understand that we have the ability and responsibility to control some moisture conditions that can lead to mold growth. By providing ventilation either by opening windows or turning on and using the installed exhaust provisions, a considerable amount of the moisture MHA - MPP PJ13398/4-7-11/pjk -3-1- MHA - MPP PJ13398/4-7-11/pjk -3-2- available for condensation can be removed from the environment and thus preventing or limiting the conditions that allow for mold to grow to occur and persist.

3.3 Health Effects

Most typical indoor air exposures to mold do not present a risk of adverse health effects. Molds can cause adverse effects by producing allergens (substances that can cause allergic reactions). Potential health concerns are important reasons to prevent mold growth.

Most species of fungi and mold are generally considered harmless to healthy humans at concentrations typically found in buildings and outdoors. The CDC states that some people are sensitive to molds. For these people, molds can cause nasal stuffiness, throat irritation, coughing or wheezing, eye irritation, or in some cases, skin irritation. CDC advises that people with mold allergies, immune-compromised people, and people with chronic lung illnesses, such as obstructive lung disease may have more severe reactions. There are many species of fungi and mold known to cause allergies in humans, and some species are known to cause disease. In addition, fungi and molds may cause structural damage to certain building components. People differ in their sensitivity to fungi and molds and even with a medical examination it may not be possible to correlate observed health effects to the presence of mold/fungal growth or elevated spore concentrations.

Currently, there are no federal standards or recommendations, (e.g., OSHA, NIOSH, EPA) for airborne concentrations of mold or mold spores. Scientific research on the relationship between mold exposures and health effects is ongoing.

This section lists the responsibilities of the MHA and its Executive Leadership, Environmental Coordinator, On-Site Facility Coordinator, and employees who perform maintenance or fungal remediation activities.

4.1 Executive Leadership

The Executive Leadership has overall responsibility to implement the MPP. The Executive Leadership must:

1. Appoint key personnel with the authority and the resources to carry out the responsibilities of this MPP.
2. Appoint an Environmental Coordinator who has been properly trained to implement the MPP.
3. Periodically review the MPP with the Environmental Coordinator and update as appropriate.
4. Address other issues as they arise. 

4.2 Environmental Coordinator (EC)

The Environmental Coordinator (EC) is responsible to implement and enforce this MPP. The Environmental Coordinator must:

1. Have the authority, the skills and training to implement the MPP.
2. Understand the requirements of the MPP.
3. Ensure that when Uniform Physical Conditions Standards (UPCS) inspections take place, that issues of water intrusion, moisture and mold growth are included and that records of such inspections are kept in accordance with this MPP.
4. Ensure that any reports of suspected mold, water leaks and excessive moisture are responded to in a timely manner by appropriately trained personnel. Ensure that records of such reports and responses are kept in accordance with this MPP.
5. Require tenants to promptly notify the Building Owner or On-Site Facility Coordinators or any other MHA personnel of any suspected mold, water leaks or excessive moisture inside their Units. Ensure that records of such notices and reports are kept in accordance with this MPP.
6. Ensure that any reports of suspected mold, water leaks or excessive moisture are promptly investigated and appropriate action taken. Ensure that records of such investigations and responses are kept in accordance with this MPP.
7. Be able to respond to questions from facility personnel, tenants, contractors, and others.
8. Consult with Environmental Consultant, Remediation Contractor, or other necessary Consultants as appropriate. MHA - MPP PJ13398/4-7-11/pjk -4-1-
9. Ensure that accurate records are kept of (a) any notices to tenants, employers whose employees conduct maintenance or housekeeping activities, and contractors, (b) inspections, (c) tenant complaints, (d) reports of water intrusion, excess moisture, mold, or suspected mold, and (e) responses to such notices and reports.
10. Ensure that the Property Managers follow procedures in the MPP during regular or emergency maintenance and remediation activities where mold may be disturbed.
11. Ensure compliance with any applicable federal, state and local regulations, particularly regarding issues of asbestos containing materials and lead based paint.
12. Update the MPP and notices as conditions change.

4.3 Property Managers (PM)

The Property Managers (PM) are responsible to implement and enforce this MPP. The Property Manager must:

1. Have the authority, the skills and training to implement the MPP.
2. Understand the requirements of the MPP.
3. Appoint an On-Site Coordinators who has been properly trained.
4. Identify qualified employees to assist the On-Site Coordinators in carrying out this MPP.
5. Coordinate with the On-Site Coordinators to conduct periodic inspection to be included with UPCS.
6. Ensure that any reports of suspected mold, water leaks or excessive moisture are promptly investigated and appropriate action taken. Ensure that records of such investigations and responses are kept in accordance with this MPP.
7. Be able to respond to questions from facility personnel, tenants, contractors, and others.
8. Consult with Environmental Consultant, Remediation Contractor, or other necessary Consultants as appropriate.
9. Ensure that accurate records are kept of (a) any notices to tenants, employers whose employees conduct maintenance or housekeeping activities, and contractors, (b) inspections, (c) tenant complaints, (d) reports of water intrusion, excess moisture, mold, or suspected mold, and (e) responses to such notices and reports.
10. Ensure that the On-Site Coordinators follows procedures in the MPP during regular or emergency maintenance and remediation activities where mold may be disturbed.
11. Ensure compliance with any applicable federal, state and local regulations, particularly regarding issues of asbestos containing materials and lead based paint.
12. Update the MPP and notices as conditions change.

4.4 On-Site Coordinators

The On-Site Coordinators must:

1. Obtain and keep a copy of the MPP in the building office.
2. Understand the procedures and responsibilities in this MPP.
3. Coordinate with the Property Manager and employees on periodic inspections of the building for suspected mold, water leaks or excessive moisture. This can be included with other regularly scheduled inspections such as UPCS.
4. Immediately notify the Environmental Coordinator or Property Manager of any reports or observations of suspected mold, water leaks or excessive moisture. Assist the Environmental Coordinator in responding to such reports or observations.
5. Provide notice to and allow only those employees and/or outside contractors who agree to follow the procedures in this MPP to perform work. Keep records of such notice and agreements by these contractors to comply with the MPP.
6. Keep records of (a) training for employees who conduct maintenance or small scale remediation activities, (b) inspections, (c) reports of suspected mold and excessive moisture, and (d) responses to such reports. All records are to be retained in accordance with Section Five.

4.5 Maintenance Staff

Employees responsible for inspection of reported mold growth, moisture issues and water leaks or are responsible for performing remediation limited to small scale work must comply with procedures in Section 8. These employees must be provided suitable awareness training and additional training associated with inspection and remediation of small scale mold growth. 

4.6 Remediation Contractor and Other Outside Contractors

The Remediation Contractor must comply with the procedures in Section 9. The Remediation Contractor must promptly notify the On-Site Coordinators of any newly discovered conditions or mold.

5.1 Notification Procedures

5.1.1 Tenants

The MHA is responsible for providing notices and information to tenants regarding mold. In addition, MHA must require the tenant to promptly notify the Property Managers or On-Site Coordinators of any suspected mold, excessive moisture or water leaks. The notice must be provided prior to entering into a new lease with new tenants, annually thereafter, and updated as conditions warrant.

5.1.2 Employees

who may Contact or Disturb Mold Growth. The On-Site Coordinators must review any proposed work to determine if that work could potentially disturb mold growth and provide notice and direction to the employee. This work may include employees who conduct maintenance, housekeeping, or other activities that may contact or disturb mold growth. Employees must be notified and work must be conducted in compliance with the procedures in Sections 8. 

5.1.3 Outside Contractors

The On-Site Coordinators must review any proposed work to be performed in the building to determine if that work could potentially disturb mold growth. Contractors must be notified and work must be conducted in compliance with the procedures in Sections 8 and 9. 

5.2 Recordkeeping Requirements

The Environmental Coordinator must assure that the following records are kept as stated below. 

6.1 Periodic Inspection Procedures

The Property Manager and On-Site Coordinators must periodically inspect or coordinate inspections of the building to assess the potential for water leaks and mold growth. This inspection may be performed by a suitably trained employee or with or by the Environmental Consultant.

If there is evidence of water intrusion, excess moisture, mold, suspected mold, water damage, physical damage, change in condition, or delamination, the Environmental Coordinator, Property Managers and On-Site Coordinators must take prompt action to assess the condition and meet with, as appropriate, the Environmental Consultant, Remediation Contractor, or other Consultants to take appropriate corrective action.

The periodic inspection must include the following:

• Examination of the exterior building envelope for any evidence of cracks or deterioration that may allow for water intrusion.
• Examination of the interior for evidence of any recent water intrusion or moisture such as staining, blistering, efflorescence, delamination, or warping of building materials.
• Evidence of any visible moisture or standing water.
• Evidence of any mold such as visible mold or musty odors.

6.1.1 Recording the Inspection

The On-Site Coordinators are responsible for ensuring that the periodic Inspection Form is completed. Any signs of damage as listed in item 6.1 above must be noted. 

6.1.2 Reports by Employees, Tenants, or Contractors

Between periodic inspections, employees, tenants, or contactors may report suspected mold, excessive moisture or water intrusion. The On-Site Coordinators are responsible to investigate each such report. The On-Site Coordinators must use the Incident/Report Log to record the inspection.

If any area of suspected mold, water intrusion or excessive moisture is confirmed, the On-Site Coordinators must notify the Environmental Coordinator and an Incident Report should be completed. 

8.1 Notice to the Employee

The Environmental Coordinator, the Property Managers or On-Site Coordinators must provide a copy of this Section. In response to a report of mold growth or water intrusion or when conducting any periodic inspection an Incident/Report Log or inspection form must be completed. 

8.2 Before Work Can Begin

Before allowing work to proceed, the Environmental Coordinator, Property Managers or On-Site Coordinators must review the Work Authorization and assign an appropriately trained employee for the proposed work activity. 

8.3 Inspection

The trained employee should conduct an initial assessment of the incident and all information regarding the incident recorded in the log form. This assessment should at least include the following:

• Identification and control of the source of the water leak or moisture.
• Determination of the source of the leaked water, clean or contaminated (category I, category II or category III). 
• If water source is contaminated with sewage, chemical, or biological pollutants then additional precautions will be necessary.
• Determination of the extent of the water impact to the surrounding area and all the affected and potentially affected materials.
• Document the presence of moisture with a moisture meter.
• Consider water or moisture may be trapped inside wall cavities, under floor coverings and below cabinets. 
• Determination of how long impacted materials have been wet.
• If < 48 hours, the potential of encountering mold growth is low.
• If > 48 hours, the potential for encountering mold growth is increased.
• Determination of the presence of visible mold growth or the potential for hidden mold growth and the quantification of the amount of visible mold growth or estimated the amount of potential hidden mold growth.
• Determine if contents or furnishings are impacted.
• Were the contents or furnishings directly impacted by the water or moisture and do they have visible mold growth.
• Were the contents contaminated by settled spores from nearby mold growth.
• Determination for the need of outside assistance. 
• Can the affected areas be dried within 48 hours using in-house resources?
• Is sewage, chemical, or biological contamination involved?
• Is the amount of mold growth or potential hidden mold growth greater than 10 square feet?
• Determination of other or regulated hazards.
• Will asbestos containing materials be contacted or disturbed?
• Will lead based or lead containing paints be contacted or disturbed?

8.4 Work Procedures for Employees Performing Small Scale Mold Remediation or In House Drying

When it has been determined that the work can be performed in house, the work should be done by the trained employee under the direct oversight of the Environmental Coordinator, the Property Managers or On-Site Coordinators with input from the Environmental Consultant. The work should be performed using work practices and equipment that minimize the disturbance of affected materials and dispersion of mold spores. Measures should also be taken to protect the health and safety of individuals performing remediation activities as well as the surrounding area. Generally, work performed by the employee will be limited to small scale remediation in localized areas of less than 10 square feet of mold growth. Employees performing the work must consider that additional mold growth may be hidden or concealed within wall cavities or behind other finishes and that mold should be included in the area estimate. At a minimum, the work should be performed in accordance the following guidelines addressing mold/water intrusion remediation:

• Environmental Protection Agency “Mold Remediation in Schools and Commercial Buildings” (EPA 402-K-01-001, March 2001)
• New York City Department of Health “Guidelines on Assessment and Remediation of Fungi in Indoor Environments” (2008)
• Institute of Inspection, Cleaning and Restoration Contractors IICRC S500 “Standard and Reference Guide for Professional Water Damage Restoration” (2006)
• Institute of Inspection, Cleaning and Restoration Contractors IICRC S520 “Standard and Reference Guide for Fungal Remediation” (2008). 

8.5 Required Set-up Procedures

The following procedures will be minimum requirements to be performed during mold-related work:

• Clear all unauthorized personnel / building occupants from the immediate work area.
• Set up containment provision as required for the Level of Work Performed (small scale).
• Post signs or warnings to prevent entry by personnel not working on the project and not wearing the appropriate protective clothing and respirators. If you are working in an occupied area, consider a plastic drape between the work area and the occupied area(s).
• Shut off and lock out HVAC, electrical, mechanical, and/or life safety systems that may be impacted by the work.
• Put on protective personal equipment as required.
• Verify that asbestos containing materials and/or lead based paints will not be disturbed unless properly accredited or certified. 

8.6 Small Scale Mold Remediation and In House Drying

The Environmental Coordinator, the Property Managers, On-Site Coordinators, or trained employee will determine the appropriate means to dry an impacted area. Consider the use of fans versus de-humidifiers and whether limited destruction is necessary to dry hidden or concealed areas. The use of fans when drying impacted materials with visible mold growth is discouraged without secondary containment due to the risk of cross contamination.

The Environmental Coordinator, Property Managers, On-Site Coordinators, or trained employee will determine if mold impacted materials can be adequately cleaned or removal is necessary. Generally, nonporous (i.e., concrete, metal, glass) materials can be cleaned while porous materials (gypsum board, particle board, carpet) should be removed. When semi-porous materials (wood and plaster) are impacted professional judgment will be necessary to determine if the material can be adequately cleaned or if removal is necessary. All areas of visible mold growth (obvious and concealed) need to be addressed during remediation.

Mold remediation will require the use of specialized cleaning equipment such as HEPA filtered vacuums and air filtering devices. Cleaning of non-porous surfaces can generally be performed with a simple water and detergent solution. 

8.7 Tenant Relocation

The Environmental Coordinator, Property Managers and Environmental Consultant will determine whether tenant relocation during mold remediation is required. All areas of visible mold growth need to be addressed during remediation.

9.1 Notice to Remediation Contractor

The Environmental Coordinator, Property Managers or On-Site Coordinators must provide a copy of this Section to the Remediation Contractor. 

9.2 Work Procedures

All work done by the Mold Remediation Contractor should be performed under the direct oversight of the Environmental Consultant and using work practices that minimize the disturbance of affected materials and dispersion of mold spores. Measures should also be taken to protect the health and safety of individuals performing remediation activities as well as the surrounding areas. At a minimum, the work should be performed in accordance the following guidelines addressing mold/water intrusion remediation: 

• Environmental Protection Agency “Mold Remediation in Schools and Commercial Buildings” (EPA 402-K-01-001, March 2001)
• New York City Department of Health “Guidelines on Assessment and Remediation of Fungi in Indoor Environments” (2008)
• Institute of Inspection, Cleaning and Restoration Contractors IICRC S500 “Standard and Reference Guide for Professional Water Damage Restoration” (2006)
• Institute of Inspection, Cleaning and Restoration Contractors IICRC S520 “Standard and Reference Guide for Fungal Remediation” (2008) 

9.3 Submittals

Each contractor must certify that it has properly trained its employees and also submit to the Environmental Coordinator, Property Manager or On-Site Coordinator:

• Copies of its Contractor's License and Contractor's Insurance Certificate. 

9.4 Required Set-up Procedures

The following procedures will be minimum requirements to be performed during mold-related work: 

• Confirm the presence or absence of asbestos containing materials or lead containing paints in the work area.
• Clear all unauthorized personnel / building occupants from the work area.
• Performing set-up operations as required for the Level of Work Performed.
• Post signs to prevent entry by personnel not working on the project and not wearing protective clothing and respirators. If you are working in an occupied area, establish a black or opaque drape between the work area and the occupied area(s).
• Shut off and lock out HVAC, electrical, mechanical, and/or life safety systems that may be impacted by the work.
• Put on protective personal equipment as required.
• Remove or clean the impacted materials as prescribed by the Environmental Consultant. 

9.5 Tenant Relocation

The Environmental Coordinator, the Property Manager and Environmental Consultant will determine whether tenant relocation during mold remediation and decontamination is required. All areas of visible mold growth need to be addressed during remediation and decontamination.

10.1 Visual Inspection (All Work Levels)

At the completion of mold remediation, a visual inspection will be performed. For small scale work this inspection may be performed by the Environmental Coordinator, Property Manager, On Site Coordinator and/or the Environmental Consultant. For medium and large scale work this inspection should be performed by the Environmental Consultant. A final visual inspection should be conducted after all the work area has been thoroughly cleaned and all equipment and waste has been removed from the area.

For areas involving remediation work of 10 square feet of mold or less, remediation will be deemed complete following an acceptable visual inspection, with the area being free of visible mold growth and reasonably free of dust and debris and all materials are indicating dry. 

10.2 Air Sampling

Air sampling will be required for all remediation work involving more than 10 square feet of mold (medium and large scale work). Air sampling will only be performed after the area has passed visual inspection by the Environmental Consultant. The Environmental Consultant will then collect air samples. Air samples must be collected from the contained area and outdoors and from adjacent areas where makeup air provided. Generally, non viable spore trap samples will be used for post-decontamination air sampling.

At the discretion of the Environmental Consultant or when contents or furnishings have been impacted, surface lift samples may be collected to verify that cleaning was adequately performed.

Remediation will be deemed complete when the concentration of airborne mold spores levels and the relative distribution within each work area sample is approximately the same as or below that observed outdoors and/or when the surface lift samples yield results indicating a background level of fungal spores (trace or minor). 

10.3 Re-occupancy/Post Restoration

After remediation has been deemed complete, the Environmental Consultant will promptly inform the Environmental Coordinator, the Property Managers and/or the On-Site Coordinators that the area can be restored and contents replaced. The Environmental Consultant shall also provide the Environmental Coordinator, the Property Manager and/or the On-Site Coordinator with a clearance letter.

• Appendix A: Copies of training certificates for Environmental Coordinator and On-Site Facility Coordinators and other employees
• Appendix B: Periodic Building Inspection Reports
• Appendix C: Inspection/Incident/Report Log – These forms must be used for periodic inspections, to report the presence of mold, suspected mold, water intrusion, and excessive moisture
• Appendix D: Reference Documents – US EPA Mold Remediation in Schools and Commercial Building and NYC DHMH Guidelines on Assessment and Remediation of Fungi in Indoor Environments