Mould and Marijuana Grow Operations · Dry Ice Abrasive Blasting ... Marijuana Grow Operations...

© Pinchin Environmental Ltd 2010 1

Mould and Marijuana Grow Mould and Marijuana Grow OperationsOperations

Bruce Stewart, B.Sc., DOHS, CIH, ROH

OBOA Conference

October 6, 2010

Pinchin Environmental and AffiliatesPinchin 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


Mould & IAQ solutions Mould & IAQ solutions for healthier buildingsfor healthier buildings

From investigation to management & remediation:management & remediation:

• Indoor air quality services, including odours & ventilation

• Moulds & bacteria testing & management programs

• Legionella testing, including risk tassessments

• Specialized infection control for health care construction

• Radon testing & mitigation

Canada’s largest Hazardous Canada’s largest Hazardous Materials management firmMaterials management firm

• Asbestos, lead, mercury, PCBs, etc.

• From surveys and assessments to abatement and regulatory compliance

• HMIS-Online offers customized Hazardous Materials inventory system


StateState--ofof--thethe--art art laboratories laboratories

Reliable, confidentialresults in our lab or on siteresults 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 in New Construction –– Mould Mould Growth due to Winter ConstructionGrowth due to Winter Construction


Dry Ice Abrasive BlastingDry Ice Abrasive Blasting

Mouldy Surfaces Before CryoblastingMouldy Surfaces Before Cryoblasting


Typical Surfaces after CryoblastingTypical Surfaces after Cryoblasting

Example of Example of Municipal Building Municipal Building Standards OrderStandards Order

• 40 unit residential40 unit residential.

• History of water penetration, balcony structural failure.

• Order to assess and remediate structuralremediate structural, envelope, mould concerns.


Marijuana Grow OperationsMarijuana Grow Operations

Mould Growth iMould Growth in Buildingsn BuildingsSpores + organic surface + moisture + time → mould growth


Causes of Mould Growth in Causes of Mould Growth in BuildingsBuildings

• Poor construction practices

B ildi l f il• Building envelope failures

• Floods

• Condensation

• Wet sections of air handling units, ductwork

Health Canada 2004 Health Canada 2004 Review of medical literature to 2001:

“…this review indicates that living or ki i b ildi ith t i lworking 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 y ggrowing in buildings should also be removed under safe conditions using established remediation protocols.”


Health Canada: Residential Indoor Air Health Canada: Residential Indoor Air Quality Guideline for Moulds (March 2007)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 buildingsmould growing in residential buildings.

These recommendations apply regardless of the mould species found to be growing in the building.”

Regulatory Responses to Regulatory Responses to Mould in BuildingsMould in Buildings


Ontario Ministry of Labour, 2000Ontario 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 Public Health, City Bylaw and Building DepartmentsBuilding 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:• Property standard bylaws:

• Residential Tenancies Act 2006 O. Reg. 517/06.


Standards of Care for Mould Standards of Care for Mould Assessment and AbatementAssessment and Abatement

Canadian Construction Association Canadian Construction Association Mould Guidelines, 2004Mould Guidelines, 2004

• Written to assist contractors in reducing risk of mould• Backgroundg• 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


EACO MouldEACO MouldAbatement GuidelinesAbatement Guidelines

• Environmental Abatement Council of Ontario: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• Consistent with CCA Guide 82 mould remediation procedures.

• Developed in consultation with Ontario Ministry of Labour.

Flood Flood RemediationRemediation

• Mould growth occurs rapidly after wetting. After 48 hours must be suspected on susceptible48 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.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.


Risk Risk AssessmentAssessment

• 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 committeesIn 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 Sensitive OccupantsOccupants

• Particularly susceptible occupants or settingsParticularly 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• During remediation, susceptible individuals should be re-located from the immediate area, and possibly from adjacent areas.


Remediation Remediation PlanPlan

• 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”.p

Remediation Remediation ProceduresProcedures

• Detailed procedures given for multiple levels ofDetailed procedures given for multiple levels of work, depending on extent of mould growth • Work area isolation

• Worker protection (PPE and hygiene precautions)

• Waste packaging

• Cleaningg

• Professional oversight, quality assurance measures recommended for remediation of medium and large scale contamination.


Basis of CCA/EACO Mould Basis of CCA/EACO Mould Remediation GuidelinesRemediation Guidelines

Extent of MouldExtent of Mould--Affected Affected MaterialMaterial

MethodMethodMaterialMaterial

General Areas: <1 m2 (<10 sf) Level I (Small)

General Areas: 1-10 m2 (10-100 sf) Level II (Intermediate)

General Areas: >10 m2 (>100 sf) Level III (Large)

HVAC Contamination: <3 m2 HVAC, Small

HVAC Contamination: >3 m2 HVAC, Large

Mould AbatementMould Abatement


Marijuana Marijuana GrowGrowGrow Grow

OperationsOperations

Hazards of Indoor Hazards of Indoor Marijuana Grow Marijuana Grow

Operations (MGO)Operations (MGO)

• Initial Response Hazardsp• Responder safety due to criminal activities• Booby traps• Combustion products

• Persistent Hazards• Structural (alteration or deterioration)• Structural (alteration or deterioration)• Electrical• Chemical (pesticides, fertilizers, solvents)• Microbiological


Fertilizers/PesticidesFertilizers/Pesticides

Regulatory Regulatory ResponsibilitiesResponsibilities

• 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 p , ( ) yAuthority requires environmental clearance by a CIH, ROH or P.Eng. with masters degree in occupational hygiene before re-instatement.


Liabilities of Former MGOsLiabilities of Former MGOs

• Landlord to tenant

• Vendor to purchaser

• Real estate agent to purchaser

• Municipality to property owner


Provincial Advisory Group (on Properties Provincial Advisory Group (on Properties Impacted by Illicit Drug Operations)Impacted by Illicit Drug Operations)

• Established in 2009, to provide advice to Ontario municipalities, public bodies and associated stakeholders regarding hazards from illicit drugstakeholders, 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

O t i B ildi Offi i l A i tiOntario Building Officials Association• Insurance industry• Real estate• Environmental consultants• Legal

Provincial Advisory GroupProvincial Advisory Group

• Planned outputs:R d ti f h t l i l ti• Recommendations for changes to legislation

• Advisories to fire, police, municipalities, etc.

• Recommended protocols for notification, OH&S precautions, assessment and remediation


DRAFT PAG MGO Environmental DRAFT PAG MGO Environmental Assessment & Remediation Protocol Assessment & Remediation Protocol

(EARP)(EARP)

• Draft, January 2010

• Advice given from municipality to homeowner or managers to satisfy municipal order

• Assessment → Remediation → Acceptance

PAG MGO EARP General PointsPAG 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 etcMOL, Notice of Project, etc.

4. Homeowner strongly advised to retain professional environmental contractor for larger scale remediation.


Assessment Assessment –– Qualified Qualified AssessorAssessor

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 Assessment –– HistoryHistory

1. Property secured by police? Ask for copies of police/fire/municipalof police/fire/municipal reports/orders.

2. Use of building for grow operation – where, when, extent?


Assessment Assessment –– HistoryHistory

3. Age of building, prescreening for asbestos or lead paintasbestos or lead paint.

4. Building description, area, configuration, crawlspaces, attics.

5. Heat and power?

Assessment Assessment ––Walkthrough InspectionWalkthrough Inspection

1. No mould air samples unless absolutely certain no mould growth.y g

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.


Assessment Assessment –– Destructive Destructive Inspection for Mould RequiredInspection for Mould Required

1. Remove base trim throughout, peel back carpet.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 )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 Assessment –– Other Other Environmental ConcernsEnvironmental Concerns

1 Note any pesticides fertilizers1. 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 lead-based paint.


Assessment Assessment –– Sampling and Sampling and AnalysisAnalysis

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 Abatement RecommendationsRecommendations

1. Abatement plan, prepared by competent professionalprofessional.

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 waste6. 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.


PostPost--Abatement Assessment Abatement Assessment ––InspectionInspection

1. Should be performed by investigator who previously inspected the propertypreviously 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.

PostPost--Abatement Abatement Assessment Assessment ––Air SamplingAir Sampling

1. Spore trap mould air samples from all levels of the structure, including attics, basement, crawlspaces, , g , , p ,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).


Final Reporting RequirementsFinal Reporting Requirements

• Report to document investigation, remediation successful completionremediation, successful completion.

• Include all analytical reports, inspection reports.

• Comply with reporting requirements of ESA, municipality.

Questions?Questions?

Bruce Stewart, B.Sc., DOHS, CIH, ROH

Pinchin Environmental LtdPinchin Environmental Ltd.

(905) 363-1388

[email protected]

www.pinchin.com

Mould and Marijuana Grow Operations · Dry Ice Abrasive Blasting ... Marijuana Grow Operations...

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