Air Date: 11-8-2019|Episode 564
This week we welcome live in the studio at the “World Headquarters”, one of “The Next Generation of IEQ Pros” Shari Solomon, Esq. Shari is an upcoming professional from the DC area, we’ll be discussing infection control, lead paint, mold, IEQ regulations and more.
Shari L. Solomon, Esq. is president of CleanHealth Environmental, LLC. CleanHealth provides comprehensive industrial hygiene, infection control and OSHA training services, offering valuable risk management and compliance solutions. Ms. Solomon possesses more than 19 years of environmental consulting and federal regulatory experience. An attorney by trade, combined with her experience in the industrial hygiene field, Shari holds a unique expertise and understanding of liability prevention techniques. Prior to launching CleanHealth, Shari held the position as Director of Training with a full-service Industrial Hygiene firm and was charged with the development and oversight of all training programs nationwide. Ms. Solomon is a U.S. EPA Accredited Trainer for the Renovation, Repair and Painting Rule (RRP) and has spent many years providing indoor air quality services including litigation support, operation and maintenance program development, and indoor air quality assessments.
On the regulatory side, she served as a Legislative Analyst with the National Multi Housing Council/National Apartment Association Joint Legislative Staff. While there she developed an expertise on indoor air quality issues and authored the first industry white paper on mold as well as an operations and maintenance program for mold/moisture control in apartment properties that has steadily become the industry standard of care.
Ms. Solomon holds a Bachelor of Arts degree from the University of Florida and a Juris Doctorate from The Catholic University of America.
Z-Man’s Blog:
A woman’s place, is in command.
Shari L. Solomon, Esq. is president and founder of CleanHealth Environmental, LLC. CleanHealth provides comprehensive infection control, industrial hygiene, and OSHA training services, offering valuable risk management and compliance solutions. Ms. Solomon possesses more than 17 years of environmental consulting and federal regulatory experience. An attorney by trade, combined with her experience in the industrial hygiene field with a focus on healthcare, Shari holds a unique expertise and understanding of liability prevention techniques, offering clients practical and valuable risk management solutions.
Prior to launching CleanHealth, Shari held the position as Director of Training and was charged with the development and oversight of all training programs nationwide. Shari also conducted indoor air quality and infection control services including litigation support, operation and maintenance program development, infection control evaluations, and indoor air quality assessments.
Nuggets mined from today’s episode:
Shari took an indirect path from studying law to environmental and infection control. In law school she focused on environmental regulatory law and then worked doing legislative analysis for the National Apartment Association/National Multi Housing Council where she identified environmental issues for apartment owners and managers. Association members in CA being sued for toxic mold piqued her interest and she began researching, learning about mold and IAQ. She decided to begin practicing as an Industrial Hygienist. Her first IH healthcare project was legionella.
The Residential Lead-based Paint Hazard Reduction Act was signed into law by Bill Clinton in 1992. The Lead RRP regulation from that law and took 18 years to implement.
She began focusing on healthcare 12 years ago. At first working on occupation exposures in the radiology department and chemical exposures of cleaning staff. Cleaning and disinfection emerged as an issue of interest, along with lead, mold and asbestos.
Infection Control Risk Assessment (ICRA)- key risk assessments that must be conducted by a healthcare facility when conducting minor maintenance tasks (e.g. replacing one ceiling tile) up through and including major construction. ICRAs are driven by risk exposures to patients who are closest to work areas. Classified from 1-4, with 1 being lowest and 4 highest. Focus is on dust minimization. There is no federal or state mandate for ICRA training. Available training programs are based upon best practices and industry standards of care. Hospitals want their contractors and staff to have this training. Shari trains: hospital staff, general contractors and their subcontractors. 80% of attendees like the hands-on component of the course. Course materials based upon “professional plagiarism” of APIC The Association for Professionals in Infection Control and Epidemiology (APIC)and CDC https://apic.org/apic-releases-manual-for-construction-and-renovation-projects-in-healthcare-facilities/
https://www.cdc.gov/infectioncontrol/pdf/guidelines/environmental-guidelines-P.pdf
Guidelines for Environmental Infection Control in Health-Care Facilities
https://www.cdc.gov/mmwr/preview/mmwrhtml/rr5210a1.htm
On ICRA projects, Shari uses particle counters to set baseline prior to the project starting. During the project she’ll take readings adjacent to the work area (i.e., perimeter of the barriers.) It’s important to be aware that secondary sources often effect particle counts and elevated readings only denote that additional investigation of the area is warranted. CDC recommends not doing micro sampling on healthcare construction projects.
Business opportunity exists for restoration and IEPs to help organize healthcare construction projects and reduce Healthcare Associated Infection (HAI) risks. There’s a growing market as the healthcare industry moves away from big hospitals and build new smaller specialized facilities.
According to the CDC, there are 75,000 HAIs related deaths in the US annually. Environmental services staff are not housekeepers, they are an integral part of the healthcare team. Surface contamination leads to infection. Environmental services staff need adequate time to clean and disinfect rooms after patient discharge. There is 120% increase in infection rates for the new patient in rooms where the previous patient had an HAI.
While bleach is regularly used for hospital cleaning, Shari isn’t a bleach advocate and recommends her clients move away from it. She prefers hydrogen peroxide-based disinfecting products.
Washington, DC has mold licensing for professional mold remediators and inspectors. Working in DC area involves 3 separate jurisdictions (DC, VA and MD). Maryland passed mold laws which were never funded. Tenant activism (based upon a lack of tenant recourse) was the impetus for the DC mold regulations. After the law was passed it was passed off for regulation and enforcement to the DC-DOEE. In DC, a license is necessary to inspect or remediate a visual area of mold of 10 square feet or greater. Visual means visible, visible doesn’t mean accessible. Under the DC regulation, mold assessors and mold remediators may perform both functions on the same project so long as they provide the client with full disclosure; a group is trying to amend the law to disallow licensed professionals from performing both functions on the same project. When a tenant complains the landlord has 7 days to inspect. If visible mold of 10 square feet or more is found a licensed assessor must be hired to inspect, and prepare a remediation protocol. Assessors have 5 days to notify authorities; notification is done via computer online. Once identified, landlords only have 30 days to remediate. An emergency exemption exists if mold will continue to grow without intervention; 99% of all projects fall into this category. DC requires verification that the moisture problem has been fixed. A licensed remediator must conduct the remediation if over 10 sq. ft. of visible growth in an affected area. The assessor must perform PRV on project. While the law requires analytical assessment, mold sampling isn’t specified. Ethics parameters exist for assessors and remediators. The DC-DOEE regulates compliance, provides compliance assistance and enforcement. She always advises clients to make good faith compliance efforts.
Opined that the MD mold law of 2008 which handed off regulation and enforcement to the MD Home Improvement Commission, put the wrong agency in charge resulting in a lack of implementation.
Shari is active in the Environmental Information Association (EIA) which she described as an education and networking group.https://eia-usa.org/about.php
There is a lack of RRP (Lead Renovator, Repair, Painting) compliance in DC like in many other parts of the USA. https://www.epa.gov/lead/lead-renovation-repair-and-painting-program
Lead is a high priority for the EPA, there have been some significant enforcement actions.
Climate change will increase mold issues, pathogens and be good for the industry.
She has met many young women and minorities who are focused on public health, environmental policies, climate change because it’s affecting their futures.
Emerging issues, since she started the business 5 years ago in healthcare. Healthcare continues to be a growing market. A hospital bedrail gets touched 150-200 times per day, on average. Using ATP found windowsills in patient rooms to be bio-burden reservoirs. Cleaning products and methods, continuous disinfection, deep cleaning upon discharge, UV light, HPV (hydrogen peroxide vapor), lower intensity UV light in patient rooms, building oxidation capability into systems are all areas of ongoing industry interest and study.
Refers to CDC guidelines for high touch surfaces in patient rooms. Educate hospital patients and staff on the importance of cleaning the hospital beds. Beds need to be properly cleaned and disinfected after patient discharge. https://www.cdc.gov/HAI/toolkits/Environ-Cleaning-Eval-Toolkit-10-6-2010.pdf
https://www.cdc.gov/hai/pdfs/toolkits/Environmental-Cleaning-Checklist-10-6-2010.pdf
Association for the Healthcare Environment. https://www.ahe.org/
https://www.ahe.org/ahe-practice-guidance-health-care-environmental-cleaning-2nd-edition
Career advice: study environmental science, industrial hygiene, occupational health and safety, earn an MPH.
Final comment; While training is inadequate, the healthcare industry is moving in the right direction. There is more accountability due to Medicare payouts and insurance costs of HAIs.
Z-Man signing off
Trivia question:
How many organisms are on the World Health Organizations’ list of bacterial threats?
Answer
Twelve.
