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*	- U.S. Environmental Protection Agency	13-P-0356

i	\ Office of Inspector General	August 22,2013
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At a Glance
Why We Did This Review
An Office of Inspector General
hotline complaint alleged that
firms were using the
U.S. Environmental Protection
Agency-developed
Environmental Relative
Moldiness Index tool to
evaluate homes for indoor mold
even though the EPA had not
validated the tool for public use.
The EPA developed ERMI as a
way to objectively describe the
mold burden present in a
home. The index is based on a
national sample of indoor mold
values. These mold values
were determined using an
EPA-patented technology
called mold specific quantitative
polymerase chain reaction.
MSQPCR is a way to identify
and quantify indoor mold
species. As of January 2013,
the EPA had 10 active licenses
of the MSQPCR technology.
We sought to determine
whether MSQPCR and ERMI
had been properly peer
reviewed and validated for
public use.
This report addresses the
following EPA Goal or
Cross-Cutting Strategy:
• Advancing science,
research, and technological
innovation.
For further information, contact
our Office of Congressional and
Public Affairs at (202) 566-2391.
The full report is at:
www.epa.aov/oia/reports/2013/
20130822-13-P-0356.pdf
Public May Be Making Indoor Mold Cleanup Decisions
Based on EPA Tool Developed Only for Research Applications
What We Found
We substantiated the allegation that firms were using the mold index tool
although the EPA had not validated the tool for public use. The EPA readily
acknowledged that it had not validated or peer reviewed MSQPCR or ERMI for
public use. The agency said it considers MSQPCR and ERMI to be research
tools not intended for public use. Although the EPA has licensed MSQPCR to
companies for introduction into the marketplace under the Federal Technology
Transfer Act of 1986, neither federal law nor the EPA's procedures address the
level of validation needed before or after transferring federally developed
technologies to the private sector. In addition, there are no EPA regulatory
requirements for developing or validating indoor mold test methods or assessing
indoor mold levels.
Licensees were marketing MSQPCR to the public as part of the ERMI tool. In our
view, one current and one past licensee's advertising could mislead the public
into thinking that these research tools are EPA-approved methods for evaluating
indoor mold. The license agreements stipulate that the licensee should not state
or imply in any medium that the EPA endorses MSQPCR. In addition, information
that appeared on an EPA webpage suggested that the EPA validated and
endorsed MSQPCR for public use. Consequently, there is a risk that the public
may make inappropriate decisions regarding indoor mold on the belief that
MSQPCR and ERMI results were based on research tools fully validated and
endorsed by the EPA for public use. Public awareness of indoor mold has risen
over the past several years, and trade industry and other publications have
raised concerns about the legitimacy of some firms offering remediation services.
Because of the numerous questions the EPA received from the public regarding
the ERMI tool, the EPA drafted a fact sheet on indoor mold, MSQPCR, and
ERMI. Informing the public about the ERMI tool and monitoring compliance with
license agreements would improve assurance that the public is not misled about
the ERMI tool and understands its limitations. However, the EPA has not finalized
or published this fact sheet.
Recommendations and Planned Corrective Actions
We recommend that the EPA periodically review licensee advertising of the
MSQPCR tool to determine whether licensees have violated the terms of the
license agreement and take appropriate actions as necessary. We also
recommend that the EPA remove or clarify potentially misleading statements on
its webpage, and finalize a fact sheet on indoor mold, MSQPCR and ERMI to
inform the public that MSQPCR and ERMI have not been peer reviewed or
validated for public use. The agency generally agreed with our report and
provided corrective actions and estimated completion dates that meet the intent
of our recommendations. Also, the agency has removed a webpage containing
potentially misleading statements; thus, we are closing this recommendation.

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