Now that the Missouri River has receded, opportunities abound for repair of both residential and commercial properties that were damaged by the flood. One of the biggest problems with these properties is the mold that has taken over the surfaces that were under water. If you plan to bid on these projects, make sure that you know the risks before submitting your bid.
One of the biggest concerns with mold remediation is employee safety. Surprisingly, OSHA does not have a regulation on mold remediation, but they do offer some guidance. OSHA has published Safety and Health Information Bulletin 03-10-10 entitled A Brief Guide to Mold in the Workplace. As OSHA makes clear in the first paragraph, the guide is not a standard or regulation, but is provided to assist employers in providing a safe and healthful workplace.
The guide initially notes that there are no federal standards or recommendations from OSHA, EPA, or other regulatory entities, that specifically address airborne concentrations of mold or mold spores. Nevertheless, OSHA provides some steps to limit employee exposure to airborne mold or mold spores.
OSHA breaks down its advice by the square footage involved, ranging from less than 10 square feet to over 100 square feet. For projects less than 100 square feet, OSHA does not list any special protective gear, other than disposable respirators, gloves and eye protection. For projects over 100 square feet, OSHA recommends the use of full face respirators with HEPA cartridges and disposable protective clothing. On larger projects, OSHA also recommends isolation of the work area and the use of exhaust fans with HEPA filters to generate negative pressurization.
Ultimately, if OSHA does visit your worksite, and finds your employees without any type of personal protective equipment, OSHA would likely cite you for not providing a safe work environment. Again, there would be no specific reference to a regulation on mold remediation, but OSHA would likely take the position that employees do need some type of personal protective equipment when remediating mold.
If you need some help figuring out your OSHA obligations on mold remediation projects, give me a call.
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