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| ERMI, Research Data or Commercial Product? | 36 Signatures |
Published by Wei Tang, Ph.D. on Sep 29, 2007
Category: Miscellaneous
Region: United States of America
Target: EPA
Petition text:
EPA shall collaborate with other scientists in related fields, e.g. mycologists, ecologists and environmental consultants, to consider alternative mathematical models based on existing scientific knowledge to replace or improve ERMI and ARMI (simplified version of ERMI) to utilize MSQPCR data for more meaningful indoor environmental quality assessment purposes.
Until further published research and public and peer review has demonstrated that valid conclusions can drawn from the ERMI/ARMI using MSQPCR data, EPA shall require licensed laboratories to provide disclaimers in ERMI/ARMI reports advising of its limitations. This includes, but is not limited to, the following:
(1) When performing an investigation of mold contamination, it is important for qualified professionals to conduct a thorough building inspection and interview occupants regarding building history and health complaints. Sampling is only part of an indoor environmental quality investigation. Water intrusion and dampness in a building is the root cause of microbial growth problems which have the potential to impact the health of occupants. These moisture issues need to be corrected as soon as possible.
(2) MSQPCR does not detect all fungal species or identify the components comprising the mold biomass (spores, hyphal fragments, and/or other fungal structures). Direct microscopic examination is required to detect total spores (viable and non-viable) of all fungal species as well as to identify the presence of other fungal structures.
(3) ERMI does not reflect the total mold count (burden) or overall environmental healthfulness of an indoor environment. It should not be used as the sole decision-making factor for indoor environmental quality investigation or Post-Remediation Verification (PRV).
EPA shall also require licensed laboratories to:
(1) provide the sum and individual quantitative concentrations and the percent composition of each of the 36 species to allow traditional data interpretation methods to be performed.
(2) not accept ERMI/ARMI samples from homeowners without working with a qualified indoor environmental consultant.
[If you have opinions about individual statements or demands, please write them down in the comment section. Thanks.]
Until further published research and public and peer review has demonstrated that valid conclusions can drawn from the ERMI/ARMI using MSQPCR data, EPA shall require licensed laboratories to provide disclaimers in ERMI/ARMI reports advising of its limitations. This includes, but is not limited to, the following:
(1) When performing an investigation of mold contamination, it is important for qualified professionals to conduct a thorough building inspection and interview occupants regarding building history and health complaints. Sampling is only part of an indoor environmental quality investigation. Water intrusion and dampness in a building is the root cause of microbial growth problems which have the potential to impact the health of occupants. These moisture issues need to be corrected as soon as possible.
(2) MSQPCR does not detect all fungal species or identify the components comprising the mold biomass (spores, hyphal fragments, and/or other fungal structures). Direct microscopic examination is required to detect total spores (viable and non-viable) of all fungal species as well as to identify the presence of other fungal structures.
(3) ERMI does not reflect the total mold count (burden) or overall environmental healthfulness of an indoor environment. It should not be used as the sole decision-making factor for indoor environmental quality investigation or Post-Remediation Verification (PRV).
EPA shall also require licensed laboratories to:
(1) provide the sum and individual quantitative concentrations and the percent composition of each of the 36 species to allow traditional data interpretation methods to be performed.
(2) not accept ERMI/ARMI samples from homeowners without working with a qualified indoor environmental consultant.
[If you have opinions about individual statements or demands, please write them down in the comment section. Thanks.]
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