OF SAFETY ENGINEERS
1800 East Oakton Street
Des Plaines, Illinois 60018-2187
May 23, 2003
The Honorable James F. Clayborne, Jr.
Environment and Energy Committee
121C Capitol Building
Springfield, IL 62706
RE: Recognizing Appropriate Safety, Health and Environmental Professionals in HJR 12
Dear Chairman Clayborne:
The American Society of Safety Engineers (ASSE) is an international organization located in Des Plaines, Illinois, representing more than 30,000 safety, health and environmental (SH&E) professionals dedicated to workplace safety and health. More than 1400 of those members work and live in Illinois and belong to six chapters in Chicago, the Northeastern Suburban Chicago, Peoria, the Quad Cities, Rockford, and Southwest Suburban Chicago. ASSE's members are committed to seeing that every American worker has the best possible opportunity to return home healthy and safe from their jobs. As the enclosed fact sheet indicates, ASSE is the largest professional occupational safety and health organization and, founded in 1911, has been in existence by far the longest.
On behalf of ASSE's members in Illinois, ASSE respectfully asks that you reconsider or amend HJR 12, the Resolution you sponsored to establish a Joint Task Force on Mold in Indoor Environments to examine mold issues in Illinois and make recommendations to the General Assembly concerning the regulation of mold in indoor environments in Illinois. ASSE's concern is that the Resolution, as written, unnecessarily limits SH&E professionals involved in the task force to Certified Industrial Hygienists (CIHs) and, so, does not reflect the fact that a variety of other SH&E professionals also have the training and experience to provide expertise on mold issues. Not including a wider representation of SH&E professionals limits the capabilities of the task force from the beginning and leaves open the possibility that one SH&E designation may be given economic favor over others in the way Illinois ultimately decides to address the mold issue.
To help address the concern, ASSE suggests that HJR 12 be amended to reference not only CIHs but also "accredited certified safety, health and environmental professionals" as possible members of the task force in the second resolve of the Resolution.
CIHs Not Only SH&E Mold Professionals
That CIHs are qualified as authorities on mold is not in question. ASSE is proud to count CIHs among the variety of SH&E professionals that are its members. In fact, ASSE's Industrial Hygiene Practice Specialty is the fastest growing area of the Society's membership. What is important is that, if Illinois is to obtain the best advice on the issue, it should include the widest possible breadth of knowledge and experience available.
CIHs are not the only SH&E designation capable of addressing mold analysis and remediation issues. As one example, Certified Safety Professionals (CSPs), which are a core group of ASSE members, must pass a stringent and long-established certification examination administered by the independent Board of Certified Safety Professionals that includes demonstrating mastery of industrial hygiene. In addition, there is a long list of other SH&E designations that allow individuals to gain professional capabilities in mold testing and remediation, including but not limited to Certified Hazardous Materials Managers, Certified Health Physicists, Certified Occupational Health Nurses, Certified Professional Chemists, Occupational Health and Safety Technologists, Registered Environmental Assessors, Registered Environmental Health Specialists, Registered Hazardous Substance Professionals, Registered Hazardous Substance Specialists, and Registered Safety Professionals. ASSE is most likely the one organization that represents the widest variety of these different SH&E professionals.
Despite the different designations, however, it is important to note that each of these professional designations are accredited by either the Council on Engineering and Scientific Specialties Board (CESB) or the National Commission on Certifying Agencies (NCCA), the two internationally recognized bodies that provide a level of certainty that professional designations truly measure the professional capabilities they say the do.
Mold Risks Not Fully Established
Although ASSE appreciates your well intentioned desire to protect Illinois citizens from what appears, from anecdotal media accounts, to be a widespread threat to health and safety, ASSE would recommend caution and due deliberation in addressing this issue through legislation at this time. Contrary to what the media and some organizations that may have a self-serving agenda would lead most to believe, not enough is known about the actual threats posed by mold to say that any legislative action is the correct action to take at this time.
Enclosed is a recent article from Professional Safety, ASSE's professional journal, entitled, "Mold 101: An Overview for Safety, Health and Environmental Professionals." In short, the article states that, while the Occupational Safety and Health Administration (OSHA) and the American Conference of Governmental Industrial Hygienists (ACGIH) currently offer guidelines for determining mold risks, much of the information on the health risks of mold is only anecdotal. The article goes on to say
(i)t is hoped that continued studies of the relationship between airborne mold levels and health effects will eventually move the information from a quasi-industry standard to a full-fledged consensus standard and perhaps ultimately, provide the basis for regulatory guidance.
Also enclosed is an article entitled "Molds and Mycotoxins in Indoor Environments" published recently in ASSE's Industrial Hygiene Practice Specialty newsletter. The article reiterates the position that, though progress is being made in determining the health effects of mold, still more needs to be learned.
ASSE is confident more will be known in the near future. ASSE's own Environmental Practice Specialty and Industrial Hygiene Practice Specialty are currently studying the issue and will be making recommendations about how to proceed in addressing mold threats. Until more is known about the science of the issue, ASSE suggests it would not be appropriate to move forward with any legislation, especially one that would require the adoption of permissible exposure limits for mold.
Both our members in Illinois and staff at ASSE's national headquarters in Des Plaines stand ready to help you fulfill your goal of helping Illinois's residents and businesses deal with the possibility of mold risks to health and safety. ASSE appreciates your time and consideration of the Society's concerns.
Mark D. Hansen, PE, CSP
Click here to go back