Drawing the Line between Water Damage Restoration and Mold Remediation

Background of Water and Mold Damage

In recent years, many insurance policies have instituted limits or caps on the amount that will be paid for “mold or microbial damage.” Often, what constitutes microbial damage is defined poorly, if at all, in the policy. Meanwhile, the funds available for water damage restoration are generally not separately capped, and are available up to policy limits.

Since mold would not have grown unless excessive moisture was present, water damage and mold damage almost always overlap. If mold growth is present, it is by definition because materials were wet/damp for an extended period, either from liquid water or from excessive humidity.

In recent months, several restorers and adjusters have asked Indoor Environmental Technologies (IET) for our opinion on where to draw the line between water damage restoration and mold remediation. We are making this article freely available for distribution. All we ask is that IET be credited for its production, by leaving our logo and contact information intact, etc. IET was involved in the creation of the current IICRC S500 and S520 documents within the IICRC and is referenced in its credits. In our reports, we use these documents as the standard for professional water and mold damage restoration and remediation.

Goals of Water Damage Restoration

The purpose of this article is to explain IET’s opinion about where the line should be drawn between “water damage restoration” and “mold remediation” as per the letter and spirit of the IICRC S500 Standard and Reference Guide for Professional Water Damage Restoration, 2006.

The most applicable section is Chapter 13: Structural Restoration, Section 4: Drying Contaminated Structures, Category 2, 3, pages 258 to 264. This section discusses the changes in procedures required to properly restore a contaminated area (such as one where mold growth has occurred) as contrasted with an area where the only issue is one of materials that have become wet with clean water. In such areas, two types of issues must be addressed by the restorer. These issues are intertwined and usually cannot be completely disentangled. IET recommends familiarity with this entire section.

Definition of Water Damage Restoration

Included in “water damage restoration,” in the larger sense of the term, is all work needed to properly restore a structure and its contents items to pre-loss condition after becoming wet.

S500 (Standard – Definitions), P 16:
“Restore/restoration” – To return to a normal, former or pre-damage state.

This includes all procedures from emergency services to reconstruction and final cleaning, as all these are needed to return the property to its pre-damage state.

S500 (Standard – 12.1.27), P 53:
After completing thorough drying and other procedures discussed above, qualified and properly licensed persons should perform authorized and necessary structural repairs, reconstruction or cleaning.

In this broadest sense of the term, mold remediation required by a water damage event should always be considered water damage restoration. However, since insurance policies require a distinction be drawn, in IET’s opinion it is appropriate to draw a line between those materials and items where more than one type of damage is found, and those where microbial contamination is the only issue requiring work.

Where Both “Restoration” and “Remediation” Are Required

S500 P 257, p 4:
Procedures needed to safely and effectively dry a structure, as opposed to those needed to remediate or abate contamination, constitute water damage restoration procedures.

Obviously, there will be some areas and procedures where work will need to be done for both “drying the structure” and “contamination remediation” reasons. In IET’s opinion, any procedures (such as containment or negative pressure) necessary to ”safely and effectively” accomplish any work required for restoration reasons, such as removal of physically or cosmetically damaged materials, is properly classified as water damage restoration, not mold remediation, and should be paid for out of the funds available for water damage restoration. This is because such work would have been required anyway, even if no mold growth had occurred. There is no logical reason why a particular type of coverage (for water damage) should disappear simply because another type of coverage (for mold remediation) also applies.

The most common type of work where this is applicable is the removal and replacement of water-damaged and mold-contaminated drywall and other porous materials. In IET’s opinion, if the material must be replaced for “physical” or cosmetic reasons as a result of water damage, then the work and all auxiliary procedures required to accomplish that work safely and effectively are appropriately classified as “restoration” rather than “remediation,” even if microbial contamination would also require replacement.

There are other industry references as well. According to the Gypsum Association publication Assessing Water Damage to Gypsum Board (GA-231-06) Source: http://www.gypsum.org/pdf/GA-231-06.pdf

Gypsum board exposed to water should be replaced unless all of the following conditions are met. (Emphasis by IET)
• The source of the water or moisture is identified and eliminated.
• The water or moisture to which the gypsum board was exposed was uncontaminated.
• The gypsum board can be dried thoroughly before mold growth begins (typically 24 to 48 hours depending on environmental conditions).
• The gypsum board is structurally sound and there is no evidence of rusting fasteners or physical damage that would diminish the physical properties of the gypsum board or system.

In IET’s opinion, any water damage situation where drywall is in contact with water for extended periods should be removed and replaced, whether mold growth has occurred or not. Such removal is appropriately considered part of water damage restoration rather than mold remediation, since removal would have been required even if no mold growth occurred. As such, it is appropriate to allocate funds from those available for water damage restoration, conserving the funds available for mold remediation for those types of damage that are specific to mold contamination.

If evidence is needed to prove the drywall installation suffered physical damage rendering it unusable, in addition to any possible microbial growth, partial demolition might be performed to check for “evidence of rusting fasteners,” which according to the Gypsum Association document constitutes evidence of unacceptable damage. It also might be possible to remove a section of the wallboard from a damaged area and submit it to a laboratory for analysis of “physical damage that would diminish the physical properties of the gypsum board.” Physical damage to the gypsum board “system” can also be demonstrated photographically by pictures of delamination, bowing, seam tape loosening, etc.

The “Executive Summary” box at the beginning of the Gypsum Association document reinforces this conclusion by stating:

In general, gypsum board should not be exposed to elevated levels of moisture for extended periods. Examples of elevated levels of moisture include, but are not limited to, exposure to rain, condensation, water leakage, and standing water. Some board exposed to these conditions may not need to be replaced, depending upon the source of the moisture and the condition of the gypsum board being considered for replacement. However, IF THERE IS EVER A DOUBT ABOUT WHETHER TO KEEP OR REPLACE GYPSUM BOARD THAT HAS BEEN EXPOSED TO MOISTURE — REPLACE IT. (Emphasis in original)

Similar principles apply to other types of materials and items, such as carpet and cushion, cabinetry, furniture, books and papers, etc. Materials and items that have undergone both physical/mechanical/cosmetic and microbial damage should be classified as requiring restoration rather than remediation.

Are Containment Procedures and Personal Protective Equipment (PPE) Properly Classified as Restoration or Remediation?

As stated above, in IET’s opinion all work required to properly deal with materials and items physically or cosmetically damaged by water is appropriately classified as restoration. Federal regulations require all work be done in ways that are safe for workers. This includes, where needed, the use of engineering controls such as containment and negative pressure, and the use of personal protective equipment (PPE) such as protective clothing and respiratory protection.

S500 P 257, p 3:
Restorers should inspect the structure for the presence of contaminants and determine, to the extent practical, what type they are, where in the structure they are located, and how deeply they have penetrated into structural materials and assemblies. If contaminants represent a significant safety hazard, to comply with OSHA regulations, restorers shall develop a jobsite-specific safety plan outlining how workers will be protected against hazards.

While OSHA regulations specifically address only those procedures needed to protect workers, it can hardly be logically argued that it is proper to ignore similar procedures where needed to protect the health and safety of building occupants.

If work is needed for restoration reasons, and regulations require that this work be done in a certain way, then all procedures necessary to complete this work accordingly are properly classed as restoration in nature, even if the same safety procedures are also needed for remediation reasons.

Per the first sentence in the quote above, in IET’s opinion any procedures, such as the use of a consultant, necessary to determine the type and extent of contamination are also appropriately classified as restoration, if the restorer is to comply with S500 and with OSHA regulations. In many cases the jobsite-specific safety plan required by OSHA regulations cannot be properly developed or implemented without such consultation.

“Remediation Only” Work

Any work necessary solely for remediation purposes, where the only issue found is mold contamination, is appropriately classified as mold remediation and should be paid for out of the funds available for this category of work. Examples of types of work where this is clearly the case might include mold containment and remediation in areas of the structure where water did not penetrate and the only damage found is microbial in nature. This would also apply to work needed to deal with release and spread of contaminants (such as mold spores) from an area of water damage and mold growth.

On most jobs there will be areas and situations that fall into a grey area in which the proper classification is not obvious, and a judgment call must be made by appropriate personnel.

Please contact IET with questions about these issues. We are happy to provide a brief opinion at no charge. However, if research, report writing, etc. is needed, we will charge appropriate fees.

• IICRC S500-06 Standard and Reference Guide for Professional Water Damage Restoration
• IICRC S520-08 Standard and Reference Guide for Professional Mold Remediation
• Assessing Water Damage to Gypsum Board (GA-231-06)

One comment

  1. Brian says:

    Excellent article

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