Mould and Marijuana Grow Operations Bruce Stewart, B.Sc., DOHS, CIH, ROH OBOA Conference October 6, 2010 Pinchin Environmental and Affiliates A leader in engineering, environmental health & safety solutions Multi-disciplinary approach by highly qualified, experienced professionals Established in 1981; 240 employees Part of the Pinchin Group of Companies, a national network of over 30 offices Pinchin Environmental Ltd 2010 1
Mould & IAQ solutions for healthier buildings From investigation to management & remediation: Indoor air quality services, including odours & ventilation Moulds & bacteria testing & management programs Legionella testing, including risk assessments Specialized infection control for health care construction Radon testing & mitigation Canada s largest Hazardous Materials management firm Asbestos, lead, mercury, PCBs, etc. From surveys and assessments to abatement and regulatory compliance HMIS-Online offers customized Hazardous Materials inventory system Pinchin Environmental Ltd 2010 2
State-of-the-art laboratories Reliable, confidential results in our lab or on site NVLAP accreditation for asbestos (2 of only 6 Canadian labs) AIHA accreditation for moulds & bacteria Lead in paint, air & bulk samples Legionella Dedicated Odour Lab Mould in New Construction Mould Growth due to Winter Construction Pinchin Environmental Ltd 2010 3
Dry Ice Abrasive Blasting Mouldy Surfaces Before Cryoblasting Pinchin Environmental Ltd 2010 4
Typical Surfaces after Cryoblasting Example of Municipal Building Standards Order 40 unit residential. History of water penetration, balcony structural failure. Order to assess and remediate structural, envelope, mould concerns. Pinchin Environmental Ltd 2010 5
Marijuana Grow Operations Mould Growth in Buildings Spores + organic surface + moisture + time mould growth Pinchin Environmental Ltd 2010 6
Causes of Mould Growth in Buildings Poor construction practices Building envelope failures Floods Condensation Wet sections of air handling units, ductwork Health Canada 2004 Review of medical literature to 2001: this review indicates that living or working in a building with material mould damage is harmful to health mould growth should be prevented by appropriate control of moisture sources and timely remediation of water damages. Mould growing in buildings should also be removed under safe conditions using established remediation protocols. Pinchin Environmental Ltd 2010 7
Health Canada: Residential Indoor Air Quality Guideline for Moulds (March 2007) After reviewing the most recent scientific evidence regarding moulds and their effects on health, the Minister (of Health) recommends To control humidity and diligently repair any water damage in residences to prevent mould growth; and To clean thoroughly any visible or concealed mould growing in residential buildings. These recommendations apply regardless of the mould species found to be growing in the building. Regulatory Responses to Mould in Buildings Pinchin Environmental Ltd 2010 8
Ontario Ministry of Labour, 2000 Mould growth on the interior surfaces of buildings is a risk factor for health problems. Employers are required by Section 25 (2)(h) to take every precaution reasonable under the circumstances for the protection of worker. The OHSAct places a responsibility on constructors, employers and supervisors to ensure the health and safety of workers. This includes protecting workers from mould in workplace buildings. Public Health, City Bylaw and Building Departments Public Health Unit may place orders re. mould in general use buildings: Health Promotion and Protection Act. Municipal building department may issue orders: Property standard bylaws: Residential Tenancies Act 2006 O. Reg. 517/06. Pinchin Environmental Ltd 2010 9
Standards of Care for Mould Assessment and Abatement Canadian Construction Association Mould Guidelines, 2004 Written to assist contractors in reducing risk of mould Background Legal Insurance Health concerns Design, construction practices to prevent mould growth Assessment of mould Mould remediation guidelines Hazard communication Demolition considerations Choosing a contractor www.cca-acc.com Pinchin Environmental Ltd 2010 10
EACO Mould Abatement Guidelines Environmental Abatement Council of Ontario: contractors, insurance professionals, environmental consultants, Ministry of Labour, suppliers. Guidelines for small, medium and large scale abatement, published in 2004. Updated version to be published in 2009. Consistent with CCA Guide 82 mould remediation procedures. Developed in consultation with Ontario Ministry of Labour. Flood Remediation Mould growth occurs rapidly after wetting. After 48 hours, must be suspected on susceptible materials. Some materials may be difficult to dry effectively (ceiling tiles, fibrous glass insulation, cellulose insulation). Proactive removal should be considered. Where the water source contains human pathogens (i.e., sewage), abatement practices have to be enhanced. Remove all porous materials, carefully disinfect, test for E. coli. Pinchin Environmental Ltd 2010 11
Risk Assessment All species of mould growth pose a health risk to occupants and must be abated. Mould within wall and ceiling cavities degrades air quality in occupied space. Must investigate for and remediate hidden mould growth. Risks must be communicated to occupants: In workplaces, joint health and safety committees must be informed of inspection, invited to see testing, and receive any report. Standards recommend disclosure to all occupants. Consider need for evacuation. Sensitive Occupants Particularly susceptible occupants or settings (infants, elderly, immuno-compromised, strong allergies, residents in health care facilities, etc.) require additional care: May be a need to immediately relocate reacting or susceptible individuals. During remediation, susceptible individuals should be re-located from the immediate area, and possibly from adjacent areas. Pinchin Environmental Ltd 2010 12
Remediation Plan Underlying causes of mould growth (excess moisture) must be identified and remedied prior to completion of cleanup. Building materials supporting fungal growth must be remediated as soon as possible. Remediation Procedures Detailed procedures given for multiple levels of work, depending on extent of mould growth Work area isolation Worker protection (PPE and hygiene precautions) Waste packaging Cleaning Professional oversight, quality assurance measures recommended for remediation of medium and large scale contamination. Pinchin Environmental Ltd 2010 13
Basis of CCA/EACO Mould Remediation Guidelines Extent of Mould-Affected Material General Areas: <1 m 2 (<10 sf) General Areas: 1-10 m 2 (10-100 sf) General Areas: >10 m 2 (>100 sf) HVAC Contamination: <3 m 2 HVAC Contamination: >3 m 2 Method Level I (Small) Level II (Intermediate) Level III (Large) HVAC, Small HVAC, Large Mould Abatement Pinchin Environmental Ltd 2010 14
Marijuana Grow Operations Hazards of Indoor Marijuana Grow Operations (MGO) Initial Response Hazards Responder safety due to criminal activities Booby traps Combustion products Persistent Hazards Structural (alteration or deterioration) Electrical Chemical (pesticides, fertilizers, solvents) Microbiological Pinchin Environmental Ltd 2010 15
Fertilizers/Pesticides Regulatory Responsibilities Municipal Clerk responsible to assess for safety when grow houses or meth labs identified (Bill 128). May require clearance testing. Performance on this varies from town to town. If power has been cut, (Ontario) Electrical Safety Authority requires environmental clearance by a CIH, ROH or P.Eng. with masters degree in occupational hygiene before re-instatement. Pinchin Environmental Ltd 2010 16
Liabilities of Former MGOs Landlord to tenant Vendor to purchaser Real estate agent to purchaser Municipality to property owner Pinchin Environmental Ltd 2010 17
Provincial Advisory Group (on Properties Impacted by Illicit Drug Operations) Established in 2009, to provide advice to Ontario municipalities, public bodies and associated stakeholders, regarding hazards from illicit drug operations. Office of the Fire Marshall (chair) Ministry of Community Safety and Correctional Services Police; RCMO, OPP, local Fire departments, municipal building officials and Ontario Building Officials i Association Insurance industry Real estate Environmental consultants Legal Provincial Advisory Group Planned outputs: Recommendations for changes to legislation Advisories to fire, police, municipalities, etc. Recommended protocols for notification, OH&S precautions, assessment and remediation Pinchin Environmental Ltd 2010 18
DRAFT PAG MGO Environmental Assessment & Remediation Protocol (EARP) Draft, January 2010 Advice given from municipality to homeowner or managers to satisfy municipal order Assessment Remediation Acceptance PAG MGO EARP General Points 1. Protocol addresses environmental hazards only. Be mindful of booby traps, electrical or structural hazards. 2. Protocol (as written) is non-mandatory. Check with local authorities for specific requirements. 3. Permits may be required: Building permits, MOL, Notice of Project, etc. 4. Homeowner strongly advised to retain professional environmental contractor for larger scale remediation. Pinchin Environmental Ltd 2010 19
Assessment Qualified Assessor 1. Assessment to be performed by investigator with appropriate science or engineering degree, qualified by experience and training, and minimum 2 years experience in mould assessment. 2. CIH, ROH, or P.Eng. with masters degree in occupational hygiene, required by ESA. Assessment History 1. Property secured by police? Ask for copies of police/fire/municipal reports/orders. 2. Use of building for grow operation where, when, extent? Pinchin Environmental Ltd 2010 20
Assessment History 3. Age of building, prescreening for asbestos or lead paint. 4. Building description, area, configuration, crawlspaces, attics. 5. Heat and power? Assessment Walkthrough Inspection 1. No mould air samples unless absolutely certain no mould growth. 2. Inspect the attic, common location for condensation mould growth from venting. 3. Inspect all flooring. Consider lifting floor finishes, particularly at exterior walls and in grow op areas. 4. Inspect all finishes looking for water damage. Check current moisture levels. 5. Check for pesticides, fertilizers, including in drains and traps. Pinchin Environmental Ltd 2010 21
Assessment Destructive Inspection for Mould Required 1. Remove base trim throughout, peel back carpet. 2. Cut inspection openings: 1. Each exterior wall of all rooms, all levels, potential condensation damage. 2. At a few randomly selected interior walls. 3. Around all moisture-prone areas (bathrooms, kitchens, laundry areas, etc.) 4. All walls in and surrounding reported grow operations. 5. Two locations in basement ceilings. 3. Be mindful of risk of asbestos in plaster, drywall joint compound, flooring products. Assessment Other Environmental Concerns 1. Note any pesticides, fertilizers at site. Look for areas of potential spillage. 2. Check for asbestos materials that could be disturbed during inspection or remediation. 3. Check for fluorescent and HID lamps, mercury sources. 4. Consider age of structure for risk of leadbased paint. Pinchin Environmental Ltd 2010 22
Assessment Sampling and Analysis 1. Limited number of samples to test for mould. 2. Asbestos samples follow Ministry of Labour prescribed sampling strategy. 3. If pesticides found at a site with septic tank, test tank for pesticides. Wipe testing of building surfaces not recommended. 4. Analysis should be in ISO 17025 accredited laboratories (CALA, NVLAP and/or AIHA programs). Abatement Recommendations 1. Abatement plan, prepared by competent professional. 2. Mould cleaning shall follow methods recommended by Environmental Abatement Council of Ontario. 3. Abatement of attic mould growth consider options. 4. Asbestos disturbance must follow O. Reg. 278/05. 5. Lead paint, follow Ministry of Labour guideline. 6. Mercury, dispose of as hazardous waste. 7. Pesticide or chemical staining, detergent cleaned, encapsulate if necessary. Remove porous materials with persistent staining. 8. Clean HVAC systems including ductwork. Pinchin Environmental Ltd 2010 23
Post-Abatement Assessment Inspection 1. Should be performed by investigator who previously inspected the property 1. The required scope of work has been completed. 2. All accessible surfaces free of dust and debris. 3. Surfaces are sufficiently dry to prevent mould growth. 4. HVAC and ductwork are clean. Post-Abatement Assessment Air Sampling 1. Spore trap mould air samples from all levels of the structure, including attics, basement, crawlspaces, attached garage(s). Compare indoor to outdoor, consider water-damage indicator moulds. One per floor in open concept floor plans. Two (minimum) per floor on multi-room floors. One in each of attics, garages, crawlspaces. Three outdoor reference samples. Field blanks 2. Asbestos air sampling, if required (Type 3 removal). Pinchin Environmental Ltd 2010 24
Final Reporting Requirements Report to document investigation, remediation, successful completion. Include all analytical reports, inspection reports. Comply with reporting requirements of ESA, municipality. Questions? Bruce Stewart, B.Sc., DOHS, CIH, ROH Pinchin Environmental Ltd Pinchin Environmental Ltd. (905) 363-1388 bstewart@pinchin.com www.pinchin.com Pinchin Environmental Ltd 2010 25