IICRC chair resigns

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Here's what I found. No resignatons.

It's very long








Reposted by Admin of S520 Issues by Elisa Larkin,

Admin Note: Posting #1
Personal Statement regarding the IICRC S520 Appeal:

The appeal filed was not based on technical information contained within the IICRC S520 Mold Remediation Standards, but instead on the procedures utilized during the process.

The standard itself is a good document. There is a lot of great information in there that should be followed during the remediation process. Several leading industry members spent thousands of hours drafting this version of the document and it would be a shame to lose the information contained in the document on procedural technicalities.

I would ask that we remember with every great endeavor comes challenges; mistakes are often made. However, it is in how these challenges are handled that speaks of the integrity of the industry. Each and every one of us is accountable to and for each other. It is our duty as professionals within this industry to hold each other accountable for our actions. Only when we all take on this responsibility can we begin to make a change in the public’s perception of our industry.

I ask that each one of you take the time to review, your own policies, procedures and standards that you have set for your own companies and ask yourself, “Am I doing the right thing because it’s the right thing to do, or because I am afraid someone is watching?” Know that someone is always out there watching us.

I would urge everyone to take a look at how you perform your projects (be it consulting or remediation) and compare them to the standard. Is your own standard of practices close to what the S520 recommends? Mine are.

Now is the time to make a difference in our industry. Now is the time to voice your opinions and work together to create an industry that we can all be proud to be a member of. If each one of us would become part of the solution we can change the image of our industry. It is not enough to point out the problem, it only keeps us in the problem thus preventing us from moving toward the solution.

I was compelled to take responsibility for the industry that I serve. That is why I filed the appeal. It is the personal duty I feel in bettering not only my own practices, but the practices of our industry as a whole that moved me to make this decision.

It is time we “Stand for Something, Otherwise We Fall For everything”.



Elisa Larkin, CRMI, WRT
ERS Services
elires@yahoo.com
617-839-7836

I find that it is not the circumstances in which we are placed, but the spirit in which we face them, that constitutes our comfort.
-Elizabeth T. King



elires



Admin Note: Posting #2

posted: 02 Dec 2006 03:35 pm Post subject: The Appeal

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IICRC
2715 E. Mill Plain Blvd.
Vancouver, WA 98661

November 21, 2006

RE: Formal Complaint and Appeal to the IICRC S520 Standard and Reference Guide for Professional Mold Remediation

I am writing to register a complaint regarding violations of IICRC policies and procedures in the promulgation of the IICRC S520 Standard and Reference Guide for Professional Mold Remediation. During the past two years I served as a committee member and chapter (sub-committee) chairperson for IICRC’s S520 standards. On October 28, 2006 I submitted my resignation from the S520 committee in protest over IICRC’s failure to adhere to its policies and procedures throughout the S520’s development. I am requesting that the IICRC investigate the violations of policy and procedures as described below and take immediate action to correct said violations.

Violation # 1:
Policy 3.4 Records states:
“Records shall be prepared and maintained to provide evidence of compliance with this policy. With regard to American National Standards developed by the Secretariat, such records shall be available for audit as directed by the ANSI Executive Standards Council (ExSC).”
Objection: Records were not maintained in a consistent manner and in some cases not kept at all. An example of this is would be what transpired during the editing process. During the editing of the Inspection and Preliminary Determination Chapter, the minutes and changes made during the first meeting were ‘lost,’ and the changes were left up to those who could remember what work had been done during the first meeting. Although accidents do happen and data is sometimes lost, there was no back up copy and further changes were then made based on what subcommittee members could remember. This is not a very reliable way to make changes within a standard. Inadequate record keeping has been reported by numerous subcommittees. Members of certain subcommittees have claimed that language not included in their final draft before editing was evident in the final standard published for peer and public review, yet the Editing Committee members claim not to have written the added language.

Section affected: The Inspection and Preliminary Determination Chapter and quite possibly the entire document.

Specific remedial action: Recall the current draft for correction, amend in accordance with ANSI Policy 3.4 and issue an appropriately documented draft.

Violation # 2:
Policy 4.2 Due Process Requirements states:
“Due Process means that persons (organization, company, government agency, individual, etc.) with a direct and material interest may participate by: a) expressing a position and its basis; b) having that position considered; and c) having the right to appeal if adversely affected.”
Objection: Techniques (such as “fogging” activity,) listed in the standard and voted on by the Consensus Body were later changed and/or deleted from the chapter without a vote from the Consensus Body. The adverse effect is that the standard does not accurately reflect the consensus opinion of either the drafting subcommittees or of the Consensus Body and therefore fails to meet the ANSI objective of a consensus-based standard.

Section affected: Tools and Structural Remediation Chapter

Specific remedial action: To uphold the original Consensus Body vote pertaining to these matters.

Violation #3:
Policy 4.2.1 Openness states:
“Notwithstanding the foregoing, the need to maintain lack of dominance and balance, and the need to maintain committees of manageable size, may justify denial of a membership request, or require participation in the standard development process in a less direct manner, such as by participation in the peer review process, commenting on a draft standard, attendance at meetings as a non-voting adviser or observer, or otherwise.”
Objection: The meetings were not open for attendance, except by invitation of the chair or IICRC Technical Advisor. The peer review process also did not follow policy by limiting the number of participants and making the document unattainable to those wishing to participate.

Sections affected: The entire document

Specific remedial action: Any materially interested party should be able to attend meetings, be involved with the peer review process, and express their professional opinions and/or comments.

Violation # 4:
Policy 4.2.2 Balance and Lack of Dominance states:
“The standards development process should have a balance of interests and shall not be dominated by any single interest category, individual or organization. ‘Dominance’ means a position or exercise of dominant authority, leadership, or influence by reason of superior leverage, strength, or representation to the exclusion of fair and equitable consideration of other viewpoints.”
Objection: The IICRC representative stated at the first meeting of the Revision Committee that: “two people from the same company would not be allowed to be Chapter Chairs.” This statement was set forth as the rules for the committee to prevent bias and dominance of the consensus body to protect the credibility of the Standard. This rule has not been enforced, as there are several Committee Chairs who are either employed and/or compensated by other Committee Chairs, thus forming a dominant coalition.

Sections affected: The entire document

Specific Remedial action: Investigate and re-appoint Sub-Committee Chairs in the affected committees.

Violation # 5:
Policy 5.4 Obligations of Membership states:
“All IICRC consensus body standard committee members and associated subordinate body members shall comply with all IICRC rules, regulations, requirements and policies, including the IICRC Anti-Trust Policy, the IICRC Code of Ethics and Conduct, the IICRC Confidentiality/Non-Disclosure/Bias/Policy, the IICRC Conflict of Interest Policy, and the IICRC Email Policy.”
Objection: It has been two (2) years since the committee members have signed and/or revealed conflicts of interest, new affiliations, etc.

Sections affected: The entire document

Specific remedial action: Each committee member should re-sign new documents on a bi-yearly basis, or anytime new affiliations or new positions are obtained. Committee members should then be updated on any and all changes.

Violation # 6:
Policy 5.7 Membership Roster states:
“The Secretariat, with the assistance of the Chair of the SC, shall prepare and maintain an updated membership roster. The roster shall list the title of the SC, the name of the respective consensus body committee, the name and contact information of all members, membership business and organizational affiliations, the capacities in which they serve, the positions held, the classification of each committee member, and the tally of classifications (the total of voting members and subtotals for each interest category).”
Objection: The membership roster was not maintained. Many committee members did not receive pertinent information because the roster was not updated on a regular basis. Further, organizational affiliations were not listed on the roster to assist in clarifying member positions.

Sections affected: The entire document

Specific remedial action: Maintain a current roster by submitting requests for updates/changes on a regular basis and ensure that organizational affiliations are listed.

Violation # 7:
Policy 6.3 Open Meetings states:
“Meetings of the consensus body and all subordinate bodies shall be open to all members (voting and non-voting) and others having a direct and material interest.”
Objection: Meetings were/are held by invitation only.

Sections affected: The entire document

Specific remedial action: Post meeting times and dates in appropriate places, with an open invitation for those with material interest to attend.

Violation # 8:
Policy 6.6 Minutes states:
“The minutes shall reflect all interim votes, letter ballot votes, actions of the consensus body standard committee, evidence of consensus of the respective committee, and necessary or appropriate information demonstrating compliance with the normative policies and administrative procedures required for accreditation of the Secretariat as established by ANSI or the Secretariat, if applicable.” Policy 6.6 also states: “The minutes shall be distributed to the members of the respective committee and approved by the committee at the beginning of its next meeting, or in the alternative, approved by electronic interim voting ballot.”
Objection: Minutes were not maintained in a consistent manner, were at times not recorded, and were often not submitted to the committees for approval. On several occasions, minutes were created based upon the “memory” of what was said after the meeting had already taken place.

Sections affected: The entire document

Specific remedial action: Minutes from previous meeting should be provided (as an email document, paper copy, or both), examined for accuracy, and voted on prior to the commencement of current meeting. Adequate time should also be allowed to review minutes.

Violation # 9:
Policy 6.8 Meeting Format states:
“Unless otherwise restricted in this Policy, members of the SC, a consensus body standard committee, or other subordinate body, may participate in a meeting of such committee by means of conference telephone, video conferencing, web conferencing, or similar communications equipment, whereby all persons participating in the meeting can hear each other, and participation in a meeting in such manner shall constitute presence in person at such meeting.”
Objection: Members who were not physically present at the meetings were not permitted to vote.

Sections affected: The entire document

Specific remedial action: Every effort should be made to include all committee members’ involvement in meetings by way of telephone/web conferencing, face to face meetings, and/or a combination of all of the above. Instructions should be given to members not able to attend face to face meetings.

Violation # 10:
Policy 8.2.6 Disposition of Views and Objections states:
“An effort to resolve all expressed objections shall be made. Each objector shall be advised in writing (including electronic communications) of the disposition of the objection and the reasons therefore. Voting members who have unresolved negative votes or objections shall be informed in writing (including electronic communications) that an appeals process exists within procedures used by the Secretariat.” Policy 8.2.6 also states: “In addition, except in the case of Audited Designators, each negative vote and objection submitted by a voting member of the consensus body which is not resolved must be reported to the ANSI BSR. Unresolved objections and any substantive change made in a proposed standard shall be reported to the consensus body standards committee in order to afford all voting members of the consensus body an opportunity to respond, reaffirm, or change their vote.”

Objection: During the January 2006 Las Vegas meeting on the “Inspections and Preliminary Determination Chapter” there was one dissenting vote. This voter was not allowed to express their professional reasoning behind the vote, nor were they informed verbally or in writing about the appeals process. At other meetings, committee members were also at times told to “shut up” when they disagreed with the consensus.

Sections affected: The Inspection and Preliminary Determination Chapter and perhaps the entire document.

Specific remedial action: Follow through should be addressed with regard to the appeals process, etc. Votes should always be recorded and if required, sent to ANSI.

Violation # 11:
Policy 11.2 Statement from Patent Holder states:
“Prior to approval of such a proposed IICRC standard, the IICRC shall receive from the identified party or patent holder (in a form approved by the IICRC) either: assurance in the form of a general disclaimer to the effect that such party does not hold and does not currently intend holding any invention the use of which would be required for compliance with the proposed IICRC standard or assurance that:
a) A license will be made available without compensation to the applicants desiring to utilize the license for the purpose of implementing the standard; or
b) A license will be made available to applicants under reasonable terms and conditions that are demonstrably free of any unfair discrimination.”
Objection: The term “Indoor Environmental Professional” and the abbreviation “IEP” have been widely debated and discussed within the committee. During drafting of the 1st edition, the IICRC applied for, and received trademarks on the terms “Indoor Environmental Professional” and its abbreviation “IEP” as a designation. This could be in violation of ANSI Policies in regard to “commercialization.”

Section affected: The entire document

Specific remedial action: Change the language to reflect a non-patented, widely acceptable term similar to the term used by OSHA in the Asbestos laws such as: ‘competent person’ or a suitable alternative.

Violation # 12:
Policy 13 Peer Review states:
“Proposals for new standards, or reaffirmation, revision or withdrawal of existing standards, shall be submitted for peer review and comment. The Chair of the SC and the Chairs of any applicable consensus body standard committee shall coordinate peer review.”
Objection: The number of reviewer’s was restricted in both number and application. This limits the ability to gain industry wide acceptance for the standard, if those who have a professional interest are not allowed to take part in the peer review process of the document.

Sections affected: The entire document.

Specific remedial action: Having an open peer review process that allows any materially interested party within the industry to review and comment on the standard.

Violation # 13:
Policy 14 Public Review states:
“Proposals for new American National Standards (ANS), or reaffirmation, revision or withdrawal of existing ANS shall be transmitted to ANSI using the BSR-8 form, or its equivalent, for listing in Standards Action in order to provide an opportunity for formal public comment.” Public Review further states: “However, any substantive change subsequently made in a proposed standard requires submittal for approval by letter ballot, and listing of the change in Standards Action.”

Objection: Although the standard was transmitted to ANSI for listing in Standards Action for public review, again the number of reviewer’s was restricted. Many people tried to gain access to the standard and were not allowed access, i.e. emails went unanswered, the system was down, and/or there were complications with printing. These issues were made known to the IICRC designated representative and were not corrected. As a direct result, public reviews were limited in number due to the public not being able to access the document. Also, a letter ballot was not conducted following the substantive changes made to the standard during editing. Many chairs had the daunting task of having two or even three versions of the section they worked on and the comments were to revert back to previous versions. This added confusion and a re-examination of the comments if they accepted the comment to revert back to the previous version. Further adverse affects included a public review of a proposed standard that had not received consensus.

Sections affected: The entire document

Specific remedial action: An open public review process separate from the peer review process allowing any number of reviewers to comment on the standard being proposed. Specific remedial action: Voting should also be conducted using a letter ballot and a new public review period should be conducted allowing the maximum number of participants.

Violation # 14:
Policy 15 Legal Review states:
“Proposals for new standards, or reaffirmation, revision or withdrawal of existing standards, shall be submitted for legal review. Legal review shall be coordinated by the Chair of the SC and the Chairs of any applicable consensus body standard committee.”
Objection: There is confusion among committee members as to when or how the legal review of the document was conducted. Conflicting evidence has the legal review process taking place at two separate points within the document’s creation.

Section affected: The entire document

Specific remedial action: Legal Review should be conducted, then a letter ballot voting process be conducted followed by a peer review process, after comments are received and reviewed, the standard should then be voted on and sent out for public review.

In closing, please review each of these IICRC Policy and Procedure violations, and act accordingly. While this document has the potential to become an esteemed industry Standard, it is imperative that the violations listed herein be acted upon immediately to salvage the hard work that has been put forth thus far. A level of trust and transparency must be maintained if the document is to be trusted, respected, and utilized by both the industry and the public as a whole.

Thank you,

Elisa Larkin

Elisa Larkin, CRMI, WRT

CC: Anne Caldas

SGK has been definately defeated as far a novels go?

I just wokeup and now this??

More than I like somedays?

There will be no change in the commandments ? It has been etched in stone?