Conflict of Interest, Bias, and Mold
Challenging the Wall Street Journal

17 Jan 2007 in Regulatory Science, Litigation

On January 9, Wall Street Journal reporter David Armstrong published a long Page One article alleging that a position paper on the health effects of mold published by the American College of Occupational and Environmental Medicine suffered from bias and conflict of interest.

Today, ACOEM president Tee Guidotti responded to some of Armstrong's allegations.

Armstrong's original article is temporarily available to non-subscribers. In it he says that the ACOEM's 2002 position paper was "written by people who regularly are paid experts for the defense side in mold litigation;" that the paper did not reveal this fact; and that the conclusions of the paper are inconsistent with those reached by a 2004 Institute of Medicine report.

The ACOEM position paper has been a popular weapon used by defendants in tort litigation because it is perceived as an authoritative expert consensus characterization of the science. Armstrong quoted one scientist and one physician who are critical of both the science in the position paper and the process by which it was produced. Both represent plaintiffs in mold cases.

The Armstrong article appears to have generated controversy among some ACOEM members. Neutral Source has obtained an email sent by its president, Tee Guidotti of George Washington University, challenging both the scientific and procedural criticisms in Armstrong's article. The text of this email is below (with a redundant addendum omitted).

A critical element of Armstrong's article is the claim that the 2004 IOM review reached substantively different conclusions about the health risks posed by indoor mold. According to Armstrong, the IOM report is supportive of plaintiffs' claims:

Plaintiffs attribute ills ranging from asthma to cognitive problems to inhalation of mold. The Institute of Medicine, a largely federally funded nonprofit, reviewed the research in 2004 and said "studies have demonstrated adverse effects -- including immunotoxic, neurologic, respiratory and dermal responses -- after exposure to specific toxins, bacteria, molds or their products."

But Armstrong quotes the IOM out of context:

In vitro and in vivo studies have demonstrated adverse effects—including immunotoxic, neurologic, respiratory, and dermal responses—after exposure to specific toxins, bacteria, molds, or their products. Such studies have established that exposure to microbial toxins can occur via inhalation and dermal exposure and through ingestion of contaminated food. Animal studies provide information on the potency of many toxins isolated from environmental samples and substrates from damp buildings, but the doses of such toxins required to cause adverse health effects in humans have not been determined. In vitro and in vivo research on Stachybotrys chartarum suggests that effects in humans may be biologically plausible, although this observation requires validation from more extensive research before conclusions can be drawn (emphasis added to sentence quoted by Armstrong, p. 7).

"May be biologically plausible" is almost the weakest scientific statement that could be made. (The weakest is biologically implausible.)

Missing entirely from Armstrong's article are the IOM committee's scientific conclusions with respect to indoor mold:

Sufficient evidence of a causal relationship does not exist with respect to any health outcome examined
Sufficient evidence of an association exists with respect to upper respiratory tract symptoms, wheeze, asthma symptoms in sensitized asthmatic persons, cough, and hypersensitivity pneumonitis in susceptible persons
Limited or suggestive evidence of an association exists with respect to lower respiratory illness in otherwise-healthy children
Inadequate or insufficient evidence exists to determine whether there is an association with respect to dyspnea, skin symptoms, airflow obstruction in otherwise-healthy persons, asthma development, mucous membrane irritation syndrome, gastrointestinal tract problems, chronic obstructive pulmonary disease, fatigue, inhalation fevers, neuropsychiatric symptoms, lower respiratory illness in otherwise-healthy adults, cancer, rheumatologic and other immune diseases, reproductive effects, and acute idiopathic pulmonary hemorrhage in infants

See Table ES-2 ("Summary of Findings Regarding the Association Between Health Outcomes and the Presence of Mold or Other Agents in Damp Indoor Environments").

A causal relationship, nor just an association, is minimally essential for prevailing in a tort case. Several of the health outcomes portrayed by Armstrong as caused by mold belong in the lowest of these four categories -- that is, they have the least possible scientific support.

Whenever science is relevant to decision-making -- whether in legal disputes such as this or in the context of regulation -- scientists will find themselves on one side or another of a financial, political or policy contest. When one side discerns that it has the weaker scientific case, it is tempted to raise tangential issues, such as who paid for research rather than its quality, or failing that, outright bias. A common theme in press accounts such as Armstrong's is that scientists corruptly "take sides" and ally themselves with defendants or regulated parties. Analogous alliances with plaintiffs or regulatory agencies is rarely considered evidence of corruption, and Armstrong's article is no exception.

Some scientists surely are motivated more by ideology or policy advocacy than by science. But it's much more likely that ideologues and advocates who happen to be working one side of a specific issue opportunistically search out scientists who happen to agree with them based on the conclusions they've drawn from their scientific work. That is, the common bias accusation has cause and effect backward. It's after they've staked out a scientific position when scientists are recruited to serve as experts. Scientists may be uncertain where research will lead, but after it's published everyone knows where it led.

Even if the scientists who wrote the ACOEM position paper had absolutely no prior knowledge of mold toxicity, authoring the report was bound to make them them invaluable assets to whichever side in civil litigation found their new expertise most valuable. In this case, it happened to be the defense because the scientific consensus didn't support the "toxic mold" theory. In other cases, scientists will congregate on the side of plaintiffs because that's where the science leads them. Indeed, if the science turned out to support the "toxic mold" theory, the ACOEM authors would now be in high demand as plaintiffs' experts. Where scientists of equal caliber are prevalent on both sides, chances are there is no scientific consensus. A scientific consensus may be right or wrong, but rarely if ever is it the product of a conspiracy.

Claims alleging conflict of interest and bias also have a confused picture of incentives in the expert witness market. As a rule, to maximize their value as expert witnesses the ACOEM authors should have reached plaintiff-friendly conclusions. That would increase, possibly dramatically, the number of suits filed alleging personal injury, and hence the number of opportunities to serve as a paid expert witness. On the contrary, reaching defendant-friendly conclusions dampens the supply of lawsuits and thus limits their opportunities to profit as expert witnesses for the defense. A highly defendant-friendly scientific consensus (which is how Armstrong characterizes the ACOEM position paper) could drive these suits out of court entirely, and that would terminate their opportunities to profit as defense experts.

Whichever side careful scientists aid in these battles, and regardless of the scientific merits, they will be criticized by whichever side is harmed by the revelation of their expertise. Careful scientists should be vigilant in responding when their scientific views are misrepresented, though this seems to happen rarely. Scientists also should protect themselves from being manipulated by their clients. This happens when they are tempted or encouraged to proffer expertise where they don't have any, or to deliver policy views and advice couched in the language of science so as to increase its apparent respectability. (Members of the IOM committee on mold succumbed to this temptation. Much of their report consists of policy recommendations, about which committee members were not always expert or well-informed, nor did they represent diverse perspectives.)

By comparison, reporters do not seem to encounter similar tensions. The prestige of a Page One story appears to be lasting regardless of its technical merits or accuracy. The profession punishes fraud in the rare cases in which it is detected, but not error.

On 9 January 2006, the Wall Street Journal ran a front-page story on the ACOEM Statement on Adverse Human Health Effects Associated with Molds in the Indoor Environment. The College would like to address points raised in the three or four postings to the List in response.

What is lost in the WSJ article is the technical accuracy of the statement. The contentious issue at hand is not damp spaces or the association of mold and mold spores with allergic, infectious, or irritating conditions. It is whether the metabolic products of mold known as mycotoxins, absorbed through biological particle inhalation in indoor air, is responsible for systemic human disease under conditions encountered in normal life, an unproven theory called "toxic mold" in the vernacular. The weight of evidence to date, despite years of investigation, does not support that it is and seems unlikely to shift with new findings.

ACOEM is not alone in its interpretation of the evidence. For reasons that are unclear, Mr. David Armstrong, the WSJ reporter, chose to imply that the ACOEM statement is at odds with the report of the Institute of Medicine, Damp Indoor Spaces... A careful reading of both will show that the two are compatible, as are both with the recent statements of the American Academy of Asthma, Allergy, and Immunology, and the American Academy of Pediatrics. The reason that the ACOEM statement has attracted so much attention is that it was issued relatively early and was put to use by litigants. The IOM, AAAI [American Academy of Allergy, Asthma, and Immunology] and AAP [American Academy of Pediatrics] statements are now probably cited in testimony as or more often.

The article includes an indirect quote attributed to me that "no disclosure is needed because the paper represents the consensus of its membership and is a statement of the society, not the individual authors." That is a correct description of the policy in force at the time the statement was released but it has to be read in the context of what Mr. Armstrong, unfortunately, chose to place much later in the article: the description of the formal and accountable process by which the statement was prepared and finally approved.

The statement was initiated by the College precisely because the topic is important in environmental medicine. The lead author who was chosen (a retired Assistant Surgeon General) had no conflict of interest at the time. The statement was substantively revised four times, in a process closely managed by the chair of our Council of Scientific Affairs. It then underwent three levels of review (Council, Board committee, full Board) before finally being approved by the elected representative governing body, the Board of Directors of the College.

Two correspondents stated that the membership had no opportunity to comment on the statement. In fact, a notice was published on the front page of the fall 2002 issue of ACOEM Report, a newsletter (now replaced by ACOEM eNews) then distributed to all ACOEM members. A well-attended session on mold, which featured the statement and the rationale behind it, was held at the 2003 American Occupational Health Conference, with lots of opportunity for open discussion.

The WSJ article implies that there is an extensive scientific debate on this topic. The reality is that there are rather few scientists who embrace the theory of "toxic mold." The mainstream of medical opinion does not. We stand behind the conclusions of the statement while remaining open to new evidence in the future.

Tee L. Guidotti, MD, MPH
President
American College of Occupational and Environmental Medicine

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Comments on Conflict of Interest, Bias, and Mold
Challenging the Wall Street Journal

From another opinion on 12 February 2007, 20:30

some things that don't add up to me.. (admittedly a non 'professional')

* MY OWN EXPERIENCE and I am still sick and I have the right to say that and its NOT A LIE

* Research on inhaled mycotoxins (trichothecenes - T-2 toxin) on animals that I have seen show that the inhalational route is often much more toxic (by 5 to 20 or more times) than inhalational or dermal absorbtion. If the research the ACOEM consulted was so conclusive why didn't they mention that the inhalational route IS TOXIC?

* Endotoxins potentiate mycotoxins, apprently. Thats another fact that needs to be mentioned i order for the report to be honest. That they didn't shows that it was biased, I think.

* What about ergot alkaloids in aspergillius. Ergot alkaloids are very powerful and they can also disrupt sleep recent research has shown that lack of sleep damages the ability to learn during that time.

* What about the fact that current definitions of 'toxic' require animals to die. Captive animals getting ill in subtle ways would not register. However, humans who have jobs need to function at high levels and the kinds of subtle damage that are caused by mold can be DEVASTATING on someone's life.

* What about the growing body of evidence that low chronic levels of ochratoxin A - a known neurotoxin - causes permanent changes in neurotransmitters like dopamine and serotonin? So presumably it can cause depression and ADHD, among other diseases. That these changes can cascade into other life changing damage. Lets not be naive, this is important. That it can probably cause parkinsonism? This is important.

* What about Dr. David Straus's research that shows that a large amount of the fungal toxin load in stachybotrys situations is carried on tiny UNIDENTIFIABLE fungal fragments smaller than conidia. (Similar situations probably exist for other molds as well) That the only kind of sampling device that can claim to accurately measure these toxins in air is a high volume impingement sampler, which uses fluids and centrifugal force to extract material from a high volume of air. (Not unlike lungs..) Was this important and relevant information considered in the suspiciously oh so conservative ACOEM calculations? NO.

* What about the research published in Indoor Air that shows that these TINY fragments can travel throughout the walls of wooden buildings even as larger particles are stopped

* What about the research that shows that tiny amounts of stachybotrys toxins (just a few tiny fragments) can set off an inflammatory cascade in toxically sensitized patients.. (people like me) causing extreme fatigue, headaches, ringing in my ears, and many other issues. People like me react and that change could certainly be measured? It has to have a quantifiable medical effect. But it isn't being studied. In fact, scientists who do study these things basically seem to have bad things happen to them. There is clearly a kind of vendetta, a retaliation going on against them. WHY THE COVER UP?

From another opinion on 12 February 2007, 20:45

They also need to mention that each person has just so much toxic mold tolerance in them (yes, I am sure it varies, so what) in their life. When it gets USED UP they are in a very bad situation because then they get sick when they get exposed to mold and this happens FREQUENTLY. It makes them miserable and it impacts their life quite a bit. For many working people it means they can't work in many workplaces.. (many workplaces couldn't care less about exposing their employees to mold.. people are expendable, I guess) What are you supposed to do when your tolerance for toxic mold is used up for THIS LIFE, reincarnate? Seriously.

Someone needs to say this. We only have one life. We can't all be doctors or high priced paid 'experts' Like Ted.

The ACOEM seems to think this 'isn't important'. It is VERY important. That is probably WHY they are playing this GAME with our LIVES.

SHAME ON THEM.

From Sharon Kramer on 25 February 2007, 10:15

With all due respect, you are in error in your critique of the accuracy of the Wall Street Journal article. The reporter is right. There is a fatal flaw within the calculations being promoted as science by ACOEM in regard to understanding human illness from mycotoxin exposure.

The fatal flaw has to do with an unscientific, non-sequitor finding within ACOEM document. In order to support the statement, "Levels of exposure in the indoor environment, dose-response data in animals, and dose-rate considerations suggest that delivery by the inhalation route of a toxic dose of mycotoxins in the indoor environment is highly unlikely at best, even for the hypothetically most vulnerable subpopulations.", the authors simply applied mathematical calculations to data borrowed from a single rodent study to corrolate that to human exposure. This is not now, nor has it ever been accepted scientific methodology in the understanding of human illness. The study they chose to apply the math to, "Rao CY, Burge HA, Brain JD. The time course of responses to intratracheally instilled toxic Stachybotrys chartarum spores in rats. Mycopathologia. 2000;149:27-34." was not even a study of mycotoxins. It was a study of mold. And, it ends with the sentence, “The consequences of low-level chronic exposure remain to be investigated, as does the relevance of the rodent data to human exposure.” The leap from limited rodent data to absence of human illness is an unethical non-sequitur, never replicated. The premise does not fit the conclusion.

So besides the author of the chapter on mycotoxins for the Damp Indoor Spaces and Health Report, IOM pointing out the fatal flaw, that the method used by the ACOEM authors to establish lack of human illness from mycotoxin exposure indoors, the study the authors chose to base their calculations upon, clearly states that what they did is not useful information in understanding human illness (or lack there of) from mycotoxin exposure within an indoor setting.

It would serve you well in the future to get the full picture before you accuse a respected writer of the Wall Street Journal of fraud in his writings.

You Sir, owe the writer an apology.

____________________

From Douglas R. Haney on 2 April 2007, 19:15

“THE TRUTH ABOUT MOLDS? Fungi (Mycotoxins) Can, and Do Cause Disease!”

Douglas R. Haney (Author: “Toxic Mold Toxic Enemy!”)

A January 9, 2007, a front page Wall Street Journal article titled “Court of Opinion: Amid Suits Over Mold, Experts Wear Two Hats” authored by David Armstrong has rekindled a longstanding battle over the American College of Occupational and Environmental Medicine society’s solicitation of a document titled “Adverse Human Health Effects Associated with Molds in the Indoor Environment” authored by a former high-ranked government health official. People who have been suffering from what they say are health issues caused by indoor mold exposures, and several of the medical doctors who treat them are upset, indicating that this document, now used as the ACOEM’s “Position Paper” is “seriously flawed.”

In response to the Wall Street Journal article, on January 13, 2007, Tee L. Guidotti, M.D., MPH, current President of the ACOEM issued the following statement: “What is lost in the WSJ article is the technical accuracy of the statement. The contentious issue at hand is not damp spaces or the association of mold and mold spores with allergic, infectious, or irritating conditions. It is whether the metabolic products of mold known as mycotoxins, absorbed through biological particle inhalation in indoor air, is responsible for systemic human disease under conditions encountered in normal life, an unproven theory called “toxic mold” in the vernacular. The weight of evidence to date, despite years of investigation, does not support that it is and seems unlikely to shift with new findings.”

Unfortunately, Dr. Guidotti fails to comprehend the objective of the WSJ article. It has little to do with scientific findings, and a great deal to do with the perceived impression that the ACOEM is, in effect, using perceivably contrived and distorted facts of “rat study” on “consensus-based acceptance” and not on sound scientific research. The ACOEM official position on molds and health is potentially full of alleged ethics violations, conflicts of interest, and selective manipulation and promotion of flawed research activity on a grand scale! This act threatens to destroy ACOEM’s integrity, and gravely harm many victims of such exposures living and working in unhealthy mold infested and contaminated homes, schools, and office buildings. For the president of the ACOEM to blatantly offer that the science is not there to support current medical knowledge, is to claim absolute ignorance of the facts! The fact is that apparently the medical community has chosen to ignore the facts that hospital environments have been treating and recording for nearly 100 years. In highly “controlled” hospital environments there is enough patient-monitored and recorded epidemiological evidence to support a literal landslide of facts that some medically-important micro fungi species are deadly.aspergillosis, and bronchiopulmonary aspergillosis, etc?aspergillosis, and bronchiopulmonary aspergillosis, etc?aspergillosis, and bronchiopulmonary aspergillosis, etc?

One has to question, where does disease caused by molds normally occur; in a hospital environment? The answer is “no!” People normally go to hospitals because molds have gained enough strength chemically to disrupt and begin decomposing a live cells one or more at a time after initial exposure in a home, school, or office environment. Medical doctors then send people to the hospital as a consequence of diagnosing a disease that has reached a stage to where it needs special disease control protocol… normally. There are millions more people living in an uncontrolled fungal infested and contaminated home, school, office environment than are observed in a hospital allergen-free “controlled” environment. aspergillosis, and bronchiopulmonary aspergillosis, etc?aspergillosis, and bronchiopulmonary aspergillosis, etc?

Doctors also seem to have trouble referencing the words “infestations” and “contaminants,” separately. Simply stated “infestations” represent the growth and binding into colonies or life-forming groups (e.g., live-celled organisms) for the purpose of strength, territorial gain, and species survival. Live-cell species can apply to anything from bees, bacteria, and molds to fish and humans, among the many life-forms existing on earth. “Contaminants” are the chemicals that live, dying, or dead species release as a mechanism for defending their survival, or defeating their enemies after they have died. However, when people who are protecting their own interests, or are hired to protect the interests of others in American enterprise system observe molds, it is fairly easy to understand why they might want to advertise molds as “contaminants” instead of live-celled “infestations.” Bacteria are not recognized as contaminants, and neither are viruses.

Why would it be desirable to classify the Aspergillus, Alternaria, Stachybotrys, and other live-celled, contaminate mycotoxin-excreting molds as simply “contaminates, volatile organic compounds (VOC), airborne particulates?” Let spell it out like this. Molds and mycotoxins, unlike bacteria and viruses, are massively used in producing products that keep Americans working and products selling. Molds and mycotoxins are used in the formulation of thousands of products for their odors, coloring, and taste (i.e., foods, drinks, etc.). Molds and their mycotoxins are used in the manufacture of alcohol, tobacco, and even cleaning and/or bleaching products. Molds and the mycotoxins they excrete are used in everything from medicines to natural supplements. In other words, there is a real beneficial purpose in the American economy for molds and yeasts as opposed to other competing microbes. The problem is that molds compete in nature with almost all other forms of live-celled life, and can remain dormant and live in harmony until it is time to perform their natural decomposing tasks. Sometimes, these harmless-appearing ugly microbes found on blocks of cheese and breads are far more deadly than we as humans, give them credit for. There is a good reason for the classification of “opportunists” that medical doctors refer to in identifying molds and yeasts living within the human body!aspergillosis, and bronchiopulmonary aspergillosis, etc?aspergillosis, and bronchiopulmonary aspergillosis, etc?aspergillosis, and bronchiopulmonary aspergillosis, etc?

Even the infamous 107-yearold Merck Manual commonly used as a medical reference guide states as to Aspergillus (the most abundant micro fungi species on planet Earth, found indoors) and Aspergillosis, a respiratory disease it is specifically recognized as causing: “Opportunistic infections caused by Aspergillus sp and inhaled as mold conidia, leading to hyphal growth and invasion of blood vessels, hemorrhagic necrosis, infarction, and potential dissemination to other sites in susceptible patients… Aspergillus sp are among the most common environmental molds, found frequently in decaying vegetation (compost heaps), on insulating materials (in walls or ceilings around steel girders, in air conditioning or heating events, in operating….” And the list on page 1222 of Chapter 158, Section 13, goes on and on. And according to this same Merck Manual, 17 Edition, 8 of the 11 diseases presented are directly related to inhalation! So, either most medical doctors registered as members of the ACOEM are unable to read, or something is wrong in the philosophies endorsed by the ACOEM as a “college” of medical practitioners.

Another question that begs an answer is why was the primary author of the ACOEM Position Paper, Bryan Harding, PhD (a Principal of Veritox, Inc. (formerly GlobalTox, Inc.) principal author of the ACOEM Position Paper provided with a free membership in the ACOEM in 2002? Prior to 2002, it is my understanding that all registered members of the ACOEM had to be medical doctors, exclusively.

Recalling a recorded statement of Ruth Etzel PhD, M.D., in parting ways with her prestigious position within the Centers for Disease Control as one of its most highly-respected medical researchers in Environmental Medicine, that, “The CDC has sought to bury the connection between mold and disease…” (Ref. Mark Moran, WebMed Medical News Interview. July 26^th 2000. Titled: “Answers Prove Elusive in Mold-Linked Deaths”) is extremely important! Why? Because Dr. Etzel’s statement offers a direct link to one of the primary “defense experts” of VeriTox, Inc., and ACOEM Position Paper author Bryan Hardin, PhD., who it seems was a high-ranking official with NIOSH (with direct working connections with the CDC). Along with Bruce Kelman, PhD, in conjunction with Andrew Saxon, M.D., of the UCLA Medical Center, Dr. Hardin authored the ACOEM’s Position Paper. Dr. Saxon’s connection with government is that he receives grants from federal entities such as the National Institutes of Health, which the CDC falls under. To think that this activity is simply going to be put to rest without critical legal analysis is to be totally oblivious to potential civic and penal ramifications for dealing with such unorthodox activities.

According to information on the VeriTox, Inc. website (a company with litigation experts known for their defense antics in providing expert testimony for the purpose of dissuading juries from accepting the idea that exposures to indoor molds infestations and contaminants lead to serious human health problems), Bryan Hardin, PhD, FATS, "…was commissioned into the US Public Health Service and began his public health career with the National Institute for Occupational Safety and Health (NIOSH) in 1972, where he served in research, policy, and management roles, culminating as Deputy Director of NIOSH and Assistant Surgeon General in the Public Health Service.” To say that Dr. Hardin does not have intimate connections at high levels of government including the CDC, would be a gross misstatement. To believe that many of the medical doctors most influential in processing the ACOEM position paper do not also have similar political connections, would perhaps also fail a scrutiny test.

Many Americans who are seriously ill have been putting their faith in an American medical system that is failing them, and unfortunately until there is a major change the mindset of the medical community the American Justice system has to step up to the plate and protect the health and safety of all its American citizenry.

Douglas R. Haney, Maridea EnviroHealth Research & Consulting, Inc., Douglas_Haney52@hotmail.com

From Teresa McCormick on 25 May 2008, 17:45

Please see Washington Free Press- "Is it safe to Buy a Home in Washington?" also see initiative petitions for the people in Washington State 1012 and 1013. (http://www.vote.wa.gov/">www.vote.wa.gov then search engine intiatives for the people 2008 numbers 1012 and 1013). This cover-up is a national crime. The Home described was purchased from a Weyerhauser Executive Secretary. Almost at the same time all national home inspection associations announced that they also would not be telling us about the mold in our homes. This was all done without informing the general public. Why the cover up and who is responsible? Weyerhauser who pays over one million annually to tort reform and the US Chamber of Commerce is located just a few miles south of Veritox in Washington State. Is there any wonder?

From Douglas R. Haney, (Formerly of Maridea, now Environmental Health Projects of Northern California) on 25 May 2008, 21:30

Teresa/All: Failure for a home inspector to disclose anything about a home that could cause injury or death is a form of "Fraudulent Concealment," and also "Deceptive Business Practices." If the National Home Inspectors have anounced this publicly, it is a very stupid thing to do. Because you as a new home owner, should you observe that the former owner of a home concealed evidence of "live-celled mold colonization" verified through a certified genetics laboratory specializing in mold and mycotoxins; capable of causing you and your family serious illness and possibly death, this is something to take up with an experienced environmental law firm that specializes in toxic tort litigation as well as your state Attorney General's Office. (42 U.S.C. http://www.law.cornell.edu/uscode/42/7401.html" title="http://www.law.cornell.edu/uscode/42/7401.html" class="external text">§ 7401)

This also leaves open the chance that being in collusion with members of national association in something that could cause serious health and safety issues indoors or outdoors, the National Home Inspectors Association might just be in violation of their Non-Profit Status with the IRS as well as RICO laws. There have been many "ground-breaking" litigation decisions across the United States to firmly establish the serious health ramifications of mold inhalation, esp., relating directly to the for production of VOC, particulates, and mycotoxins implicated in the "direct" causation of cancers, birth defects, genetic (cellular) mutations, bone marrow diseases, immune suppression, and neurological damage.

My personal thought is that if your statement is accurate, and I don't doubt that it is, the National Home Inspectors Association might want to reconsider... and FAST!

The law IS closing in on this type of deception nationally. However, for some, the legal system is awkward and slow, and any Federal judge especially should be deeply ashamed if he or she accepts a "junket" to listen to anyone advocating that molds are NOT harmful AND dangerous! More than 180 have done this already. Is this a "National Coverup?" "If it looks like a duck, quacks like a duck, and waddles like a duck... Ever smell a duck up close? It smells much better than this "cover up; national crime" as you have suggested! And, as long as American products that contain molds and mycotoxins are uncontrolled in our foods, tobacco, medicines, cleaning products, drinks, alcoholic beverages and many others, public and Congressional changes will move very slowly indeed.

Thank you for the information re: Washington State initatives. I will be searching them out and reading them.