Remediation
The OSHA rules behind water-damage and mold work
In plain English
There are few laws written specifically for water-damage restoration or mold remediation, but general workplace safety law still applies. The S500 bases its safety chapter on U.S. federal OSHA rules — 29 CFR 1910 (general industry) and 29 CFR 1926 (construction) — and says restoration firms must follow the applicable parts of both. States must at least match federal OSHA and can be stricter. The S500's summary is no substitute for reading the regulations themselves.
Those rules reach most of what happens on a job: site safety surveys, hazard assessments, emergency and fire plans, PPE and respirators, asbestos, lead paint, silica dust, heat, bloodborne pathogens, confined spaces, hazard communication, lockout/tagout and electrical safety, fall protection, noise and scaffolds. Over all of it sits OSHA's General Duty Clause: an employer must keep the workplace free of recognized hazards likely to cause death or serious harm, and must follow OSHA's standards. Since no OSHA standard is written for water-damage restoration, the S500 says restorers must apply the clause's general principles of preventing exposure and keep up with what is known about the hazards of water-damaged buildings. Employers must make sure anyone working in water-damaged or contaminated areas, or where contaminated contents are handled, has the right training, instruction and PPE, and must provide a safe workplace whether or not OSHA has addressed a particular hazard.
Every job site needs an emergency action and fire prevention plan (29 CFR 1926.35 and 1910.38): communication and alarms, the nearest hospital and fire station, posted emergency numbers, posted shutdown, evacuation and rescue procedures, posted escape routes, less-flammable materials, and a written program for employers with more than 10 employees.
Under 29 CFR 1910.132, employers must assess and document the hazards and provide PPE against chemical, physical and biological ones — including allergenic, toxic and disease-causing microorganisms. Exposure can come through breathing, the eyes, nose and mouth, swallowing, and the skin, and employers must provide skin and respiratory protection to anyone entering a containment where microbial remediation is under way. PPE protects workers from breathing or touching microorganisms, their by-products and the chemicals used on the job, and is chosen for the expected exposure, the type of contamination, the tasks and the chemicals involved — with an IEP or other expert consulted when in doubt. It can include a respirator, eye protection, disposable coveralls with hood and booties, and foot, hand, head and hearing protection.
Respirators are required whenever engineering and work-practice controls can't keep the air clean, and may be needed while those controls are being set up. Under 29 CFR 1910.134, an employer whose workers wear them needs a written respiratory protection program: NIOSH-approved respirators, medical evaluation, fit testing, training before use, a program administrator, and cleaning and maintenance. Visitors to the work area should follow the PPE rules too.
Options run from NIOSH-approved N-95 filtering facepieces to full-face air-purifying respirators (APRs) and powered air-purifying respirators (PAPRs) with P-100 (HEPA) filters, up to self-contained breathing apparatus (SCBA). P-100 filters stop spores, spore fragments, bacteria and dust; organic-vapor cartridges are needed for microbial VOCs and some chemicals used on sewage and remediation jobs. An APR pulls air through the filter as you breathe; a PAPR blows it through. Neither may be used where oxygen is low or the air is immediately dangerous to life or health (IDLH).
Warning signs are assessed in the first safety survey and again as conditions change, and OSHA requires them for exits, biological hazards and other cautions.
Lead: OSHA's lead rules are 29 CFR 1926.62 and 1910.1025, and they cover emergency cleanup, demolition and repair that could disturb lead paint or other lead-containing materials. Even if the owner has a lead survey, the restorer is responsible for identifying and controlling lead exposure during demolition in any building built before 1978 (and some later industrial ones), and must follow EPA's Renovation, Repair and Painting (RRP) rule and other applicable laws.
Heat: hot air, radiant heat, high humidity, hot surfaces and hard work — especially in attics and crawlspaces or in protective suits — can cause anything from heat rash and dehydration to heat exhaustion and heatstroke. Heatstroke, often with hot, dry skin and sudden collapse, is a medical emergency: get help immediately. The contractor's PPE and respiratory plans must cover preventing heat illness and responding to it; PAPRs can help keep workers cooler. OSHA's Technical Manual covers this in detail.
Confined spaces: OSHA's rules are 29 CFR 1910.146 and 1926.21, with further guidance in ANSI Z117.1. A confined space is one a worker can enter, with limited ways in and out, that isn't designed for continuous occupancy — think crawlspaces and some attics. Where one exists, the entry program must decide whether it is a permit-required space, identify the hazards, monitor the air, train workers on the safety equipment, define the entry team's duties and set training requirements. A space becomes permit-required if, among other things, it has or could have a hazardous atmosphere or contains material that could engulf someone.
The S520 mold standard leaves this ground to the regulators: it says it was not written to cover work safety and health, and that remediators must follow the safety rules where they work, such as OSHA in the U.S.
Equipment, instruments and tools must meet the safety and inspection requirements of the law, and restorers should follow the manufacturer's safety guidelines, operating instructions and maintenance programs.
Key points
- OSHA 29 CFR 1910 and 1926 both apply; Texas follows federal OSHA for private employers.
- General Duty Clause: no recognized serious hazards — even without a restoration-specific OSHA rule.
- Written hazard assessment, emergency action and fire plan on every job.
- Respirators need a written program: NIOSH approval, medical evaluation, fit testing, training.
- N-95 up to PAPR with P-100 filters; organic-vapor cartridges for MVOCs; never in IDLH air.
- Pre-1978 building: the restorer must control lead and follow EPA's RRP rule.
- Heatstroke is an emergency; crawlspaces may be permit-required confined spaces.
Official text
This topic is covered in our own words because the standard behind it is copyrighted; we cite it below rather than reproduce it.
Citations
- IICRC S500, ANSI/IICRC S500 Standard for Professional Water Damage Restoration — Sec. 6, equipment, instruments and tools, p. 29. Best practice
- IICRC S500, ANSI/IICRC S500 Standard for Professional Water Damage Restoration — Secs. 8.1–8.2, worker safety and health, OSHA General Duty Clause, pp. 31–32. Best practice
- IICRC S500, ANSI/IICRC S500 Standard for Professional Water Damage Restoration — Secs. 8.3–8.5, emergency action and fire prevention plans, PPE, respirator use and written respiratory protection plan, respirator types, warning signs, pp. 32–33. Best practice
- IICRC S500, ANSI/IICRC S500 Standard for Professional Water Damage Restoration — Secs. 8.8–8.10, lead, heat disorders, confined space entry, p. 35. Best practice
- IICRC S520, ANSI/IICRC S520 Standard for Professional Mold Remediation — Sec. 5, safety and health, p. 33. Best practice
