[Editor’s note: This is the first of a three-part series on new American Society for Testing and Materials standards related to mold and asbestos in commercial buildings and to significant changes to the Phase I Environmental Site Assessment and Transaction Screen ESA Standards.]
The ASTM E50.02 Subcommittee on Real Estate Assessment and Management is in the process of writing a standard guide for the evaluation of commercial real estate for the presence of readily observable mold. A proposal to write this standard was approved in April of this year and it is in the early stages of being written. A currently proposed working title for the standard is Transactional Screening of Readily Observable Mold in Commercial Buildings. The standard is unlikely to be ready for publication until May 2004 at the earliest.
Numerous changes in the final standard from the ideas and details mentioned should be anticipated. Even the purpose and objectives of the current draft ideas may change significantly as the process of writing the standard progresses.
Active mold growth in indoor environments is inappropriate and may lead to building materials deterioration, building system failures and building occupant exposure with potentially adverse health effects. Evidence that active mold growth is occurring in buildings is most often sensory, i.e. visual identification or odor perception. The document is being written as a standard guide that presents general concepts that should be used in assessment of mold rather than as a standard practice that presents a more detailed group of actions that must be undertaken in order to meet the standard.
The proposed purpose is to provide a standard that defines good commercial and customary practice for conducting a transactional screening of commercial buildings with respect to the presence of readily observable mold growth. The current concept is to write a standard intended to assess buildings visually and olfactorially, to obtain information from people knowledgeable about the building, to review municipal records, and to determine the potential need for further assessment or other actions beyond the scope of the document being written. As such, it is akin to the ASTM E1527 Phase I Environmental Site Assessment Standard that requires no sampling or testing and recommends a Phase II assessment if appropriate.
The presence of mold in buildings has become a significant issue in recent years and has lead to legal actions in many states, including Massachusetts. Part of the reason this standard is in preparation is to assist lenders and purchasers of commercial property by having a readily available document that defines appropriate inquiry related to commercial real estate transactions. There are attorneys on the ASTM Task Group and their expertise is being relied upon regarding pertinent legal issues.
As background, the proposed title of the standard indicates that the subject of the transactional screening is mold. The word “mold” has no clear scientific meaning and generally refers to visible fungal growth. Fungal colonies most commonly found growing in the indoor environment are often called molds. The term is used in a very general sense of visible fungal growth and is more or less equivalent to a gardener’s use of the term “weed” for a plant growing where it is not wanted. All mold is fungi; however, not all fungi is mold. As such, the term mold will likely be used as a depreciated term and will include suspected fungi and other visual suspect microbial growth.
Such mold growth is nearly always associated with some form of excessive moisture within a building – frequently from building envelope leaks, e.g. roofs, windows; high moisture activities within the building, e.g. swimming pools, spas, kitchens; leaks or water releases within the building, e.g. pipe leaks, fire suppression sprinkler activation, sewer backups; condensation on cold surfaces or other activities that cause excessive moisture or humidity.
Considering the aforementioned concept behind the standard, the proposed assessment will have significant limitations. The proposed standard is not intending to require what Health Canada calls an “extraordinary physical search” for mold in difficult to examine locations such as within wall cavities, above false ceilings, within duct insulation, on the backing of carpet or in other difficult to access locations and hidden spaces. The proposed standard is not intended to evaluate buildings that have significant health or other problems that are known or suspected as being caused by mold. No sampling or testing of suspected mold growth or other sampling or testing is included in this screening assessment.
The presence of mold may be missed even with a proper application of the proposed standard. The proposed standard is not intended to eliminate uncertainty regarding the potential for mold to be present, but to reduce that uncertainty. The proposed standard is not intended to be an exhaustive assessment. It will be an attempt to identify a balance between the competing goals of limiting the costs and time demands inherent in performing an assessment and the reduction of uncertainty about unknown conditions resulting from additional information. Different levels of inquiry may be appropriate for individuals or organizations with a higher or lower level of risk aversion, for buildings with particularly sensitive occupants, for buildings with known or suspected mold or moisture-related issues or for other reasons.
Certain activities are anticipated to be specifically excluded. The proposed standard will likely: exclude relocating materials, furniture, storage containers or finishes in an attempt to view areas; exclude dismantling or operating equipment or appliances and any procedures likely to damage or impair the physical integrity of the property; and require only representative observations of approximately 10 percent of building spaces.
Intended Purpose
What then does the proposed standard accomplish? The intent is to provide a party with interest in a commercial real estate transaction a mechanism to make appropriate inquiry into conditions in the building with respect to the presence of mold or other visually or olefactorilly identifiable suspect microbial growth. It is the opinion of the author and many other members of the ASTM committee that in most cases the presence of mold – and probably many other forms of microbial growth – in a building not already suspected of having a significant mold or moisture problem, will be identified by a systematic visual and olfactory evaluation combined with appropriate questioning of knowledgeable personnel and a review of municipal records. Buildings with known or suspected mold and/or water problems may require assessment that is beyond the scope of the proposed standard.
It is likely that the proposed standard will require a review of municipal health and building department records for indications of complaints, violations or historic problems associated with mold or excessive moisture in a building being assessed. It is likely that it will require asking a list of questions to a knowledgeable person related to potential moisture and mold problems in a building. Questions proposed include inquiry regarding the known current or historic presence of mold or high moisture areas, of building leaks and regarding specific uses, i.e. swimming pools, that would be expected to be areas of high moisture. It is likely that it will require visual observations of a building’s exterior and interior areas. Exterior areas to be observed will likely include the roof for signs of leaks or standing water, walls, swales and drainage areas, cooling towers, etc. This information will be used to guide the consultants in their inspection of interior areas of a building.
While all interior areas of a building would not be required to be observed, generally common areas, major mechanical spaces, basements and 10 percent of representative occupant areas, including residential apartments, would be viewed. Additionally, areas identified as potentially significant with regard to high moisture or mold would be viewed. The consultant will likely be required to provide not only a report of his finding and observations, but an opinion, based upon all information obtained, as to the likelihood of mold being present in hidden areas. The consultant will likely be required to provide a conclusion and recommendation regarding the potential need for further evaluation.
It is anticipated that the standard, when completed, will be used as part of the due diligence process by purchasers of commercial property as well as by lenders and others with a financial interest in such property. The preparation of a report under the proposed standard will likely be required and could be a stand-alone document or included as part of an environmental site assessment or property condition assessment report.
[Anyone interested in participating in the writing of this standard is invited to contact R. Wayne Crandlemere at (617)479-0550 or ASTM in West Conshohocken, Pa., at www.astm.org.]
