TE_53_FHMoldIdentificationandRemediationSOP.pdf

DEPARTMENT OF THE ARMY

US ARMY INSTALLATION MANAGEMENT COMMAND

DIRECTORATE OF PUBLIC WORKS

3040 BUTLER ROAD, BUILDING 22422

FORT HUACHUCA, AZ 85613

AMIM-HUP (420-1d2) 12 April 2023

MEMORANDUM FOR RECORD

SUBJECT: Standard Operating Procedure (SOP) for Mold Identification and Remediation

1. REFERENCES:

a. Operations Order (OPORD) 23-007/1800ZFEB23, Enclosure 1

b. U.S. Army Public Health Center Technical Guide 277 (TG-277): Industrial Hygiene Public Health: Army Mold Remediation Guidance, Annex C, February 2019, Enclosure 2

c. U.S. Army Public Health Center Technical Guide 278 (TG-278): Industrial Hygiene Public Health: Mold Assessment Guide, Annex D, October 2018, Enclosure 3

d. AR 11-34, The Army Respiratory Protection Program, 25 July 2013

2. PURPOSE: To establish guidelines for remediating building materials contaminated with mold. It is the intent of the Directorate of Public Works (DPW) that all mold remediation be conducted as safely as possible.

3. JOB SCOPE: If the quantity of surface area affected by the mold contamination is:

a. Less than 10 square feet: Remediation can be completed by trained building occupants. Work must be completed in accordance with this Section 6 of this document.

Remediation support may be requested from DPW in-house or contracted staff under circumstances where the building or barracks manager feels it is required.

b. Greater than 10 square feet: Contact DPW to visually assess the affected area.

DPW will determine the execution method for remediation and repairs.

c. Note: Raymond W. Bliss Army Health Center (RWBAHC) should be consulted prior to any mold remediation work greater than 10 square feet that is located directly within an HVAC system. The Asbestos Control Manager should be consulted if any materials are suspected to be asbestos containing building materials.

4. DEFINITIONS:

AMIM-HUP (420-1d2)

a. Containment: A component or enclosure designed or intended to control the release of mold or mold-containing dust or materials into surrounding areas of the building.

b. Indoor air: Air within the envelope of a building, including air in spaces normally occupied by persons in the building but excluding air in attics and crawl spaces that are vented to the outside of the building.

c. Indoor mold growth: Mold is a fungal growth that forms and spreads on various kinds of damp or decaying organic matter. There are many different mold species that come in many different colors. Indoors, molds need moisture and a carbon source from building materials or building contents to grow.

d. Mildew: Mildew is a surface fungi that can easily be identified as a patch of gray or even white fungus that is lying on the surface of a moist area. Mildew is easily treated with a store bought cleaner and a scrubbing brush. Mold, on the other hand, can be black or green and is often the result of a much larger infestation.

e. Mold: Any living or dormant fungi or related products or parts, including spores, hyphae, and mycotoxins. Mold is a naturally occurring microscopic fungi that can grow on indoor and outdoor surfaces. Mold can live in all environments, climates, and seasons but requires oxygen, moisture, and a nutrient source to grow. The types of molds and their abundance in an area depend on the availability of nutrients like dirt, water, and temperature. Molds grow well on cardboard, ceiling tiles, paper, and wood products. Mildew is a general term used to refer to certain kinds of mold or fungus that typically grow in a flat growth pattern and are found on shower walls, windowsills, and other places with high moisture levels. Black/Toxic Mold is a generic term used to refer to toxigenic molds, or molds that produce mycotoxins. The color of mold is not an indication of how dangerous mold may be. All visible molds should be properly and safely removed from living areas.

f. Mold Prevention: The key to mold control is moisture control. Solve moisture problems before they become mold problems!

(1) Fix leaking pipes and leaks in the building envelope as soon as possible. Ideally, resolve leaks within 48 hours of identification.

(2) Watch for condensation and wet spots. Clean and dry wet or damp materials within 48 hours.

(3) Fix source(s) of moisture problem(s) as soon as possible.

(4) Prevent moisture due to condensation by increasing surface temperature or reducing the moisture level in air (humidity). To increase surface temperature, insulate or increase air circulation. To reduce the moisture level in air, repair leaks, increase ventilation (if outside air is cold and dry), or dehumidify (if outdoor air is warm and humid). Whenever possible, ventilate areas with high humidity using exhaust pipes or mechanical ventilation (showers and dishwashing areas) to the exterior of the building.

Condensation occurs when warm air collides with cold surfaces, or when there is too much humidity in the building.

(5) Keep heating, ventilating, and air-conditioning (HVAC) drip pans clean, flowing properly, and unobstructed.

(6) Vent moisture-generating appliances, such as dryers, to the outside.

(7) Maintain relative humidity below 60%, ideally 30-50%, if possible.

(8) Maintain a positive pressure on the building envelope.

(9) Perform regular building HVAC inspections and maintenance as scheduled.

(10) Do not let foundations stay wet. Provide adequate drainage and slope the ground away from the foundation.

(11) Clean and repair gutters regularly.

(12) Allow for adequate natural ventilation in crawlspaces under structures. Inspect crawl spaces for stagnant water.

(13) Avoid lawn sprinkler systems from spraying directly onto building exterior surfaces.

g. Mold remediation: The removal, cleaning, sanitizing, demolition, or other treatment, including preventive activities, of mold or mold-contaminated matter that was not purposely grown at a location. Preventive activities include those intended to prevent future mold contamination of a remediated area.

5. ROLES AND RESPONSIBILITIES:

a. DPW – Unaccompanied Housing (UH):

(1) Evaluate areas suspected to be contaminated by mold growth. Provide recommendations to the building occupants to treat areas less than 10 sqft. Housing will evaluate Unaccompanied Housing (UH), O&M will evaluate all other facilities.

(2) Assist DPW Operations and Maintenance (O&M) or Engineering Division (ENGR) in identifying the underlying causes of water intrusion and mold growth and develop the appropriate response(s) to prevent recurrence.

(3) Assess conditions for occupancy after water restoration or mold remediation activities have been completed.

b. DPW – Operations and Maintenance (O&M) or Engineering Division (ENGR):

(1) Shall identify and fix the source(s) of water leak(s) or intrusion within 48 hours of identification if possible.

(2) Shall arrange and manage contract services for water removal and restorative drying of affected structure in accordance with Section 6.

(3) Shall notify Raymond W. Bliss Army Health Center (RWBAHC) immediately when an area of suspected mold growth is discovered in excess of 10 square feet and is located within HVAC equipment. The Asbestos Control Manager shall be notified if any contaminated materials are suspected to contain asbestos.

(4) Shall ensure labor hours, materials, and equipment utilized are recorded for all completed Demand Maintenance Orders (DMOs).

(5) Shall ensure service technicians complete the IMCOM Dampness and Mold

Visual Assessment (VSA) worksheet when required, as identified in OPORD 23-007, Appendix 1 of Annex E, located at Appendix A of this SOP. Once completed the VSA worksheet will be converted to an Adobe PDF file format and uploaded to the corresponding Army Maintenance Application (ArMA) work request ticket submitted by the customer as supporting documentation for work completed.

(6) Shall ensure service technicians complete the IMCOM Post Remediation

Verification (PRMV) worksheet when required, as identified in OPORD 23-007, Annex B, located at Appendix B of this SOP. When completed the PRMV will be converted to Adobe PDF file format and uploaded to the corresponding ArMA work request ticket submitted by the customer as supporting documentation for work completed.

c. Contractor (if contracted):

(1) Shall evaluate and document the extent of damage (e.g., water or mold) in the structure, systems and building contents using appropriate monitoring and detection equipment.

(2) Shall designate a project leader, representing the contractor, to work with O&M or ENGR personnel during the entire project.

(3) Shall provide O&M or ENGR representative a written action plan. Depending on the response activity, the action plan will include a timeline and goals for drying and the implementation of mold remediation techniques which meet or exceed guidance provided in Section 6.

(4) The contractor must notify O&M or ENGR if situations arise that may require a deviation from the original action plan.

(5) Shall record and document all activities and services performed in response to the problem. For water restoration, records would include complete moisture readings.

(6) Shall complete the project in a manner which complies with all federal, state, and local government regulations and procedures.

6. PROCEDURE FOR MOLD REMEDIATION FOR UH AND OTHER FACILITIES

a. CAUSES

(1) Mold growth within an occupied building is indicative of a water problem. The cause of the water problem must be investigated and resolved to prevent remediating the same site multiple times. Likewise, when water is introduced into the indoor environment the affected area must be dried as soon as possible (within 24-48 hours) to avoid the promotion of mold growth.

(2) Once the source of the water problem is identified and eliminated, several methods for remediating visible mold growth are possible. Each situation will dictate which method is most appropriate. The chart below outlines the decision making process for investigating potential mold issues within a facility.

Figure 1: Investigation Decision Logic Plan Flow Chart (Appendix A to TG278)

b. METHODS

(1) Method 1: Wet vacuum – steam cleaning may be an alternative for carpets and upholstery.

(2) Method 2: Damp wipe the area with a water/bleach solution and scrub as necessary; this is the method recommended by the CDC. Bleach works very well in killing the mold. Never mix bleach and ammonia; toxic fumes may be produced.

Detergent must be approved by O&M or ENGR. NOTE: Plain water will not kill mold.

Water and most detergents aren’t much better.

(3) Method 3: High Efficiency Particulate Air (HEPA) vacuum on thoroughly dry surfaces. Dispose of HEPA contents in a well-sealed plastic bag.

(4) Method 4: Discard contaminated material in a sealed plastic bag. HEPA vacuum area after material has been removed and then dispose of HEPA contents in a well-sealed plastic bag.

(5) Guidelines for Remediating Building Materials with Mold Growth Caused by

Water (Cleanup Methods (*) indicates which method number above should be utilized.)

Material or Furnishing Affected

Cleanup Method (*)

Personal Protective Equipment Containment

SMALL – Total Surface Area Affected LESS THAN 10 square feet (ft2) Books and papers 3

Recommended

N-95 respirator, gloves, and goggles

None Required

Carpet and backing 1, 3

Concrete or cinder block 1, 3 Hard surface, porous flooring (linoleum, ceramic tile, vinyl)

1, 2, 3

Non-porous, hard surfaces (plastics, metals)

1, 2, 3

Upholstered furniture & drapes 1, 3

Wallboard (drywall and gypsum board) 3

Wood surfaces 1, 2, 3

MEDIUM – Total Surface Area Affected Between 10 and 100 (ft2)

Limited or Full

Use professional judgement, consider potential for remediator exposure and size of contaminated area

Limited potential for remediator exposure and size of contaminated area

Carpet and backing 1, 3, 4 Concrete or cinder block 1, 3 Hard surface, porous flooring (linoleum, ceramic tile, vinyl)

1, 2, 3

Non-porous, hard surfaces (plastics, metals)

1, 2, 3

Upholstered furniture & drapes 1, 3, 4

Wallboard (drywall and gypsum board) 3, 4

Wood surfaces 1, 2, 3 LARGE – Total Surface Area Affected GREATER THAN 100 (ft2)

OR Potential for Increased Occupant OR Remediator Exposure during Remediation estimated to be Significant

Full potential for remediator exposure and size of contaminated area

Full potential for remediator exposure and size of contaminated area

Carpet and backing 1, 3, 4 Concrete or cinder block 1, 3 Hard surface, porous flooring (linoleum, ceramic tile, vinyl)

1, 2, 3, 4

Non-porous, hard surfaces (plastics, metals)

1, 2, 3

Upholstered furniture & drapes 1, 2, 4

Wallboard (drywall and gypsum board) 3, 4

Wood surfaces 1, 2, 3, 4

c. PERSONAL PROTECTIVE EQUIPMENT (PPE)

(1) Employees engaging in the abatement of mold shall have the following PPE available for their use: Safety glasses/goggles, N95 Respirator, Disposable Coveralls, Gloves.

(2) If an employee has questions concerning the appropriate PPE, they should contact their supervisor. Personnel shall be properly trained to perform the remediation task.

d. WORK AREA CONTAINMENT

(1) Containment of a work area for in-house work less than 10 sq. ft. will not likely be needed, but there are some precautions that will be required prior to performing actual remediation work. For all mold remediation projects, general isolation will be required. The following are best management practices:

(a) Close all doors and restrict general access to the workplace while actual remediation is being performed. Place a sign on the door or provide some type of barrier that warns personnel within the area.

(b) If possible, perform work during hours of minimal building occupancy, such as nights or weekends.

(c) HVAC systems in the immediate area of the work shall be shut down and/or the

HVAC returns shall be blanked off where applicable.

(d) Windows in the workplace should be closed and any portable fans shall be turned off—if temperatures in the working space permit.

e. DISPOSAL

(1) Once mold contaminated materials have been removed and sealed in plastic bags, waste can be disposed of as regular trash.

(2) No special labeling or disposal requirements are necessary.

7. TRAINING MATERIALS

The below training materials were provided by Fort Riley. Although the contact information with them is not correct for Fort Huachuca they provide great resources.

a. Housing Inspection Tutorial https://www.youtube.com/watch?v=tCtu7XMLKvA

b. Inspection Briefing https://www.youtube.com/watch?v=WQxTpuNbtpo

c. Mold and Mildew Information https://www.youtube.com/watch?v=K4rbNpH8Op0

8. The DPW Point of Contact for this SOP is Mr. Dale Benth, Housing Division Chief at

(520) 533-3669 or email dale.o.benth.civ@army.mil. The Garrison Point of Contact is Stephen Fairbanks, Garrison Safety Manager, at (520) 533-3697 or email stephen.p.fairbanks.civ@army.mil.

Encls JEFFREY S. BANNER Director, Public Works https://www.youtube.com/watch?v=tCtu7XMLKvA https://www.youtube.com/watch?v=WQxTpuNbtpo https://www.youtube.com/watch?v=K4rbNpH8Op0 if Select

Check if exterior wall*

Select the Select the

Check if exterior wall*

Check if exterior wall*

UNCLASSIFIED

APPENDIX A: Appendix 01 (Dampness and Mold Visual Assessment (VSA) Worksheet) to Annex E to OPORD 23-007 ampness and Mold Visual Assessment (U)

UNCLASSIFIEDE-AP1-1

UNCLASSIFIED

APPENDIX B: Annex B (Post Mold Verification Letter) to OPORD 23-007 (U)

UNCLASSIFIED

B-1

Post Remediation Verification Letter

Property location

Installation

Property Address

Instructions

• Areas reported and identified as mold have been treated (remediated): Either Box A or B below must be filled out. The mold remediation team member must fill out Box A.

• Areas reported that do not contain mold: The mold remediation team member must fill out Box C.

Mold damage has been treated: (If Box A and B are filled out, Box C does not need to be filled out.)

Box A: To be filled out by the certified mold remediation team member (can be remediated in a single visit).

I certify that:

• I treated the areas that were reported and identified as having mold. Treatment can include removing, cleaning, sanitizing, and preventing mold.

• I gave a copy of my report to the tenant and recorded it for maintenance records.

Mold remediation team member signature Date

Garrison Commander or delegated authority signature Date

Annex B (Post Mold Verification Letter) to OPERATIONS ORDER 23-007 (U)

UNCLASSIFIED

B-2

Box B: To be filled out by the certified mold remediation team member (will require rescheduling for more extensive remediation services).

I certify that:

• The reported areas with mold at this property have been treated (remediated).

• With reasonable certainty, the underlying causes of the mold reported have been treated.

• I gave a copy of my report to the tenant and recorded it for maintenance records.

No mold damage was found (If Box C is filled out, Box A and B do not need to be filled out.)

Box C: To be filled out by the mold remediation team member

I certify that:

• I inspected this property.

• I did not find signs (evidence) of any mold.

• I gave a copy of my report to the tenant and recorded it for maintenance records.

Copy ___of___ Copies HQ Installation Management Command (IMCOM)

Fort Sam Houston, TX

161800ZFEB23

OPERATIONS ORDER (OPORD) 23-007: IMCOM Fiscal Year (FY) 23 Operation Counter Mold (U)

Refs: (a) (U) Headquarters Department of the Army (HQDA) Execution Order

(EXORD) 030-23: Improving COMPO 01 Army Readiness Facilities, 07 Oct 22

(b) (U) HQDA EXORD 273-20: Ten Year Facility Investment Planning, 20 Nov

(c) (U) Secretary of the Army-Chief of Staff of the Army (SECARMY-CSA) Memorandum: Facility Investment Priorities for the US Army, 16 Sep 20

(d) (U) Army Regulation (AR) 210-20, (Real Property Master Planning for Army Installations), 16 May 05

(e) (U) AR 600-20 (Army Command Policy), 24 Jul 20

(f) (U) IMCOM Warning Order (WARNO) 01 to OPORD 23-007: IMCOM FY23 Operation Counter Mold, 16 Nov 22

(g) (U) Army Barracks Management Program (ABMP) Handbook V2, 12 Jan 21

(h) (U) U.S. Army Public Health Center Technical Guide (TG) 277, (Industrial Hygiene Public Health: Army Mold Remediation Guidance), Feb 19

(I) (U) U.S. Army Public Health Center Technical Guide (TG) 278, (Industrial Hygiene Public Health: Mold Assessment Guide), Oct 18

(U) Time Zone Used Throughout the OPORD: Zulu.

1. (U) SITUATION. Army leaders across COMPO 01 formations continue to inspect Army maintained barracks, housing, and facilities for mold, unhealthy, and unsafe, living conditions. Data collected from recent inspections provides the Army valuable information to understand the level of mold contamination in our facilities. We have not made significant progress in developing experts needed to prevent and remediate mold, or developing tactics, techniques, procedures to inform occupants of actions to counter and remove mold contamination. Starting with the publication of this OPORD, IMCOM will develop a more comprehensive, enduring, and offensive plan to counter mold in all our facilities prior to summer 2023, when mold presents the highest risk to our formations and facilities.

1.A. (U) Definitions.

1.A.1. (U) Mold is a naturally occurring microscopic fungi that can grow on indoor and outdoor surfaces. Mold can live in all environments, climates, and seasons but requires oxygen, moisture, and a nutrient source to grow. The types of molds and their abundance in an area depend on the availability of nutrients like dirt, water, and temperature. Molds grow well on cardboard, ceiling tiles, paper, and wood products.

OPERATIONS ORDER (OPORD) 23-007: IMCOM FY23 Operation Counter Mold (U)

1.A.2. (U) Mildew is a general term used to refer to certain kinds of mold or fungus that typically grow in a flat growth pattern and found on shower walls, windowsills, and other places with high moisture levels.

1.A.3. (U) Black/Toxic Mold is a generic term used to refer to toxigenic molds, or molds that produce mycotoxins. This term typically refers to the species stachybotrys chartarum, which can be identified in water damaged buildings.

1.A.4. (U) Typical, conditions that lead to mold growth in buildings are chronic water intrusion, lack of adequate ventilation and moisture control, or isolated floods caused by the weather or a water pipe bursting.

1.A.5. (U) The color of mold is not an indication of how dangerous it may be. All visible molds should be removed from living areas. When mold growth is present, the inspection, removal and cleaning of contaminated materials must be handled with proper precautions. Air sampling for mold should never be part of a routine assessment, due to it not being a good indicator of the presence or absence of mold in a building. Remediation strategies generally can be made based on a visual inspection, or surface sample. Air sampling methods for some molds are prone to false negative results and therefore cannot be used to definitively rule out contamination.

2. (U) MISSION. NLT 01 Apr 23, IMCOM executes offensive counter mold operations within Army maintained barracks, housing, and facilities to improve the Quality of Life (QoL) for Army Soldiers, Families, and Civilians, and inform resource decisions made by Army Senior Leaders (ASL).

3. (U) EXECUTION.

3.A. (U) Intent.

3.A.1. (U) Purpose: The purpose of this operation is to proactively eliminate threats to life, health, and safety from mold and improve the QOL for people in Army facilities.

This will allow IMCOM, Army Materiel Command (AMC), and the Army to reinforce the Army’s commitment to quality facilities and investment in our Army Soldiers, Families, and Civilians.

3.A.2. (U) Key Tasks:

3.A.2.A. (U) Define and distinguish mildew, mold, and hazardous mold.

3.A.2.B. (U) Inform and educate residents, public works experts, and Garrison leaders how to identify and prevent mold and appropriately mitigate any threats.

3.A.2.C. (U) Develop and share command-wide prevention and mitigation techniques, procedures, and policies.

3.A.2.D. (U) Execute preventative efforts across all at-risk facilities.

3.A.2.E. (U) Rapidly mitigate and remediate identified mold threats.

3.A.2.F. (U) Conduct an end of season After Action Review (AAR) to learn and improve operations for the next FY.

3.A.3. (U) End State:

3.A.3.A. (U) Eliminate threats to life, health, and safely from mold in Army facilities.

3.A.3.B. (U) Improve confidence of housing and barracks residents in Army’s commitment to quality housing.

3.A.3.C. (U) All policies, procedures, and methods utilized to inform, mitigate, and prevent mold are synchronized and incorporated into IMCOM's everyday business activities for FY24 and beyond.

3.B. (U) Concept of Operations. This operation will be executed in three phases:

3.B.1. (U) Phase I: Set Conditions (Near-Term). Phase I begins on publication of this order. The purpose of this phase is to set conditions that enable decisive actions to be conducted to improve QoL for Army Soldiers, Families, and Civilians. During this phase, standard operating procedures (SOPs) and other supporting products will be developed to best inform and educate Army barracks, housing, and facility occupants of mold and unhealthy, unsafe, living conditions. This phase ends when counter mold information products are published to PAO’s counter mold SharePoint repository located at: https://armyeitaas.sharepoint-mil.us/sites/IMCOM-HQ- PAO/SitePages/Counter-Mold.aspx, and initiate Army-wide distribution.

3.B.2. (U) Phase II: Execute Operations (Mid-Term). Phase II begins 01 Mar 23. The purpose of this phase is to inform and educate targeted populations on what mold is, what to do when mold is found, occupant actions to be taken, and who and how to contact Garrison staff for assistance. During this phase, steps will be taken to improve prevention operations, reporting, mitigation, and response procedures across all echelons. Phase II will continue to be executed across multiple FYs until this order is rescinded or a FRAGO is issued modifying the Concept of Operations.

3.B.3. (U) Phase III: Assess and Institutionalize (Long-Term). Phase III begins 01 Oct

23. The purpose of this phase is to establish and publish a battle rhythm to normalize counter mold operations. During this phase, annual mold assessments will be planned and conducted, standardized prevention operations, reporting, mitigation, and response procedures will be reviewed. Existing contracts capable of supporting IMCOM’s counter mold operations will be reviewed and leveraged and where necessary, regional, or enterprise-wide contract vehicles will be created. Phase III will continue to be executed across multiple FYs until this order is rescinded or a FRAGO is issued modifying the Concept of Operations.

3.C. (U) Tasks to Staff.

3.C.1. (U) HQ IMCOM G-Staff. (G3)

3.C.1.A. (U) Phase I: Set Conditions (Near-Term).

3.C.1.A.1. (U) Synchronize existing Battle Rhythm events to provide updates to the Command Group (Line of Effort 2 Decision Board, Commander’s Update Brief, All Things Housing, Housing Review, Facility Investment Plan, G4 updates, etc.).

3.C.1.B. (U) Phase II: Execute Operations (Mid-Term).

3.C.1.B.1. (U) Monitor existing reporting forums (Decision Boards, All Things Housing etc.) and provide recommendations to the G3/5/7 as needed.

3.C.1.B.2. (U) Support G4 counter mold reporting and battle tracking in the Army- General Funds Enterprise Business System (GFEBS), Enterprise Military Housing (eMH), Army Maintenance Application (ARMA) systems of record.

3.C.1.B.3. (U) ICW G4, G7, Safety, and the Command Surgeon, support the development of enterprise level mold awareness and prevention training.

3.C.2. (U) HQ IMCOM G-Staff. (G4)

3.C.2.A. (U) Phase I: Set Conditions (Near-Term).

3.C.2.A.1. (U) G4 Public Works.

3.C.2.A.1.A. (U) Incorporate mold related instructions into the Public Works section of the IMCOM FY23 Technical Cost Handbook Revision 1.0, Public Works Support Services (PWSS), and Army GFEBS eTraining (GeT) references.

3.C.2.A.1.B. (U) Manage IMCOM’s ArMA facilities maintenance work request tool.

3.C.2.A.1.C. (U) ICW the Command Surgeon and Safety office develop and distribute minimum standards, processes, procedures, training materials, and certification criteria for assessing, mitigating, remediating, and closing mold related Demand Maintenance Orders (DMOs), Preventative Maintenance Orders (PMOs), Project Work Orders (PWOs), and Operational Work Orders (OWOs). Standards, processes, and procedures must be applicable to in-house government, Base Operations contracted, and Overseas Continental United States workforce environments. These will form the baseline standards from which IMCOM, United States Army Garrison (USAG), Directorate of Public Works (DPW) will develop internal Standard Operating Procedures (SOPs).

3.C.2.A.1.D. (U) ICW the Command Surgeon and Safety office develop and distribute virtual online training and instruction for IMCOM DPW Work Reception/Order Clerks and service technicians. At a minimum, this training will outline standards for receiving, creating, processing, assessing, mitigating, remediating, and closing mold related DMOs, PMOs, PWOs, and OWOs.

3.C.2.A.1.E. (U) Collect, analyze, and report mold related maintenance and work order data, generated by Garrison DPWs using the GFEBS, ArMA, and IMCOM Geospatial capabilities. Ensure data and information quality and integrity standards are being properly implemented across all IMCOM DPWs.

3.C.2.A.1.F. (U) Survey all IMCOM DPWs to establish current baseline capabilities and capacities (C&Cs) for addressing mold related mitigation and remediation requirements.

3.C.2.A.1.G. (U) Identify gaps in mold related C&Cs and use the baseline assessment to inform Senior Leaders where mold related risk exists across the Command.

3.C.2.A.1.H. (U) ICW HQ IMCOM G8 Acquisitions Division, develop a Category Intelligence Report (CIR) that best informs the development of future Intergovernmental Support Agreement or contract acquisition strategies for mitigating Garrison DPW C&Cs gaps identified through the baseline survey.

3.C.2.A.2. (U) G4 Housing.

3.C.2.A.2.A. (U) NLT 01 Mar 23, update and maintain the Post Remediation Verification template located in Annex B of this order and document in eMH and GFEBS systems of record.

3.C.2.A.2.B. (U) NLT 01 Oct 23, provide Quality Assurance (QA) inspector's a standardized list and funding for tools.

3.C.2.A.2.C. (U) Update the QA packet, mold definition, reporting, and remediation processes NLT 01 Oct 23.

3.C.2.B. (U) Phase II: Execute Operations (Mid-Term).

3.C.2.B.1. (U) G4 Public Works.

3.C.2.B.1.A. (U) Incorporate enhanced DMO, PMO, PWO, and OWO instructions and guidance into the IMCOM FY24 Commander’s Narrative Funding Guidance and Technical Cost Handbook (TCHB), Garrison DPW Annual Work Planning (AWP) and Preventative Maintenance Planning (PMP)documents.

3.C.2.B.1.B. (U) Align IMCOM’s G4 Facilities Sustainment Analytics-Tool (FSA-T) with expanded mold data collection standards and practices to enhance facilities the FSA-T capabilities for planning and tracking Garrison DPW sustainment requirements and allocations.

3.C.2.B.1.C. (U) Continue partnering with the U.S. Army Corps of Engineers, Engineering Research and Design Center in expanding Army VANTAGE capabilities for automating data collection, reporting and analysis between Army systems of record and Army strategic management systems (SMS).

3.C.2.B.1.D. (U) Continue partnering with HQDA DCS G9, HQDA Program Executive Office-Enterprise Information System, and U.S. Army Financial Management Command in leveraging existing Army systems of record and SMS capabilities in data collection and exchange processes, enhanced mobile utilization, expanded geospatial data layers for decision makers, and communications/management interfaces for customers.

3.C.2.B.1.E. (U) Utilize CIR findings to identify and develop recommended courses of action (COA) for IMCOM Senior Leader decision.

3.C.2.B.1.F. (U) NLT 30 Sep 23, develop and deploy an initial prototype of Facilities Sustainment Common Operating Picture (COP).

3.C.2.C. (U) Phase III: Assess and Institutionalize (Long-Term).

3.C.2.C.1. (U) G4 Public Works.

3.C.2.C.1.A. (U) NLT 31 Mar 24, develop and deploy a statistical assessment methodology for establishing DMO, PMO, PWO, and OWO data quality, using the criteria and standards for Real Property and Financial audit Readiness testing and measurement. Use the results of the statistical assessment to establish a Command baseline for data quality and compliance.

3.C.2.C.1.B. (U) NLT Sep FY24, develop and deploy automated PW data collection and analysis to include enhanced Geospatial data layering capabilities enabling leaders at echelon, to utilize visual representations of garrisons for identifying and developing facilities maintenance and sustainment intervention strategies, master planning, AWP and PMP prioritization and execution.

3.C.2.C.1.C. (U) NLT 30 Sep 24, analyze, plan, and monitor the implementation of Commander approved CIR COAs, and report CIR COA results through the Facilities Sustainment COP.

3.C.2.C.1.D. (U) NLT 30 Sep 23, introduce the Facilities Sustainment COP for initial use in routine Garrison DPW planning and operations across all Base Operations environments.

3.C.2.C.1.E. (U) Conduct a command counter mold AAR to capture counter mold operation lessons learned. Date and format to be published.

3.C.3. (U) HQ IMCOM G-Staff. (G8)

3.C.3.A. (U) Phase I: Set Conditions (Near-Term).

3.C.3.A.1. (U) Support G4 in conducting an initial assessment of current in-house or contracted capabilities at garrison level that can be leveraged to support counter mold efforts.

3.C.3.A.2. (U) Provide guidance on tracking mold related costs.

3.C.3.B. (U) Phase II: Execute Operations (Mid-Term).

3.C.3.B.1. (U) Support G4 in identifying current garrison contract capability gaps or shortfalls that may need new or expanded contract capabilities to include estimated scope changes and cost IOT support counter mold operations.

3.C.3.B.2. (U) Develop funding strategies to resource counter mold operation requirements.

3.C.3.B.3. (U) Monitor and report mold related costs.

3.C.3.C. (U) Phase III: Assess and Institutionalize (Long-Term).

3.C.3.C.1. (U) Support G4 in developing and executing IMCOM Directorate (ID) and garrison acquisition strategies (Job Order Contracts, regional contracts, enterprise vehicles, etc.) to support gaps or shortfalls identified for future counter mold efforts.

3.C.3.C.2. (U) Monitor and report mold related costs.

3.C.3.C.3. (U) Ensure mold related requirements are built into future Program Objective Memorandum submissions.

3.C.4. (U) HQ IMCOM G-Staff. (Safety)

3.C.4.A. (U) Phase I: Set Conditions (Near-Term).

3.C.4.A.1. (U) Assist G4 and the Command Surgeon in developing mold training materials targeted towards Army Soldiers, Families, and Civilians.

3.C.4.A.2. (U) Support enterprise counter mold operations as needed.

3.C.4.A.3. (U) Support G4 and the Command Surgeon in identifying baseline certification requirements IOT conduct mold post remediation inspections.

3.C.4.A.4. (U) Support G4 and the Command Surgeon in identifying and coordinating operational guidance and procedures to be used by Army inspection and remediation personnel.

3.C.4.B. (U) Phase II: Execute Operations (Mid-Term).

3.C.4.B.1. (U) Train Garrison Safety Managers on mold educational materials for the Local Area Hazard Briefing.

3.C.4.C. (U) Phase III: Assess and Institutionalize (Long-Term).

3.C.4.C.1. (U) Coordinate the incorporation of mold training and awareness materials into garrison Local Area Hazard Brief.

3.C.5. (U) HQ IMCOM G-Staff. (PAO)

3.C.5.A. (U) Phase I: Set Conditions (Near-Term).

3.C.5.A.1. (U) Coordinate with IDs, garrisons, and tenant units to obtain existing information products (posters, flyers, social media posts etc.) IOT select the most effective for facilitating a common understanding of mold-related terms and activities across the Army.

3.C.5.A.2. (U) 15 Apr 23, post mold information products to PAO’s counter mold SharePoint repository located at: https://armyeitaas.sharepoint-mil.us/sites/IMCOM-HQ- PAO/SitePages/Counter-Mold.aspx, and initiate Army-wide distribution

3.C.5.A.3. (U) Integrate counter mold related information and educational materials from across the IMCOM staff to develop and implement an overarching strategy to inform and educate the Army about the proper prevention, identification, and mitigation of mold in Army facilities.

3.C.5.B. (U) Phase II: Execute Operations (Mid-Term).

3.C.5.B.1. (U) Coordinate with IDs and garrisons to produce and distribute a video series to inform and educate the Army community about the proper prevention, identification, and mitigation of mold in Army facilities.

3.C.5.B.2. (U) Monitor and assess inform and educate activities and outcomes to adjust in ways that facilitate the most effective communication.

3.C.5.B.3. (U) NLT end of Phase II, plan for transitioning mold information and education into routine institutional practices.

3.C.5.C. (U) Phase III: Assess and Institutionalize (Long-Term).

3.C.5.C.1. (U) Monitor and assess inform and educate activities and outcomes to adjust in ways that facilitate the most effective communication.

3.C.6. (U) HQ IMCOM G-Staff. (Command Surgeon)

3.C.6.A. (U) Phase I: Set Conditions (Near-Term).

3.C.6.A.1. (U) Support G4 and Safety in identifying IMCOM standard certification requirements for mold post remediation inspections.

3.C.6.A.2. (U) Provide liaison coordination with Defense Health Agency, Office of the Surgeon General/Medical Command and U.S. Army Public Health Center ISO counter mold operations.

3.C.6.B. (U) Phase III: Assess and Institutionalize (Long-Term).

3.C.6.B.1. (U) Review annually the effectiveness of the IMCOM counter mold efforts.

3.D. (U) Tasks to Subordinate Units.

3.D.1. (U) Commander, United States Army Environmental Command (USAEC).

3.D.1.A. (U) In coordination with (ICW) G4, fully Integrate environmental hazard assessment protocols into the Command Environmental Performance Assessment System internal and external Inspections.

3.D.1.B. (U) In support of (ISO) G4, be prepared to coordinate external mold subject matter expert (SME) support to execute counter mold operations.

3.D.2. (U) IDs. (All)

3.D.2.A. (U) Communicate key messaging that informs and educates occupants of Army barracks, housing, and facilities IAW Annex A of this order.

3.D.2.B. (U) Key messaging to be delivered throughout all phases of the operation:

3.D.2.B.1. (U) Reframe how we think about mold. Mold is a normal part of our environment, and mold prevention is the responsibility of every member of the Army community.

3.D.2.B.2. (U) Mold exists, and we have the tools to manage it.

3.D.2.B.3. (U) Taking quick action to clean or report mold once it is identified is vital to manage it effectively.

3.D.2.B.4. (U) ArMA, the Army Maintenance Application, is the best way to document/photo suspected mold and report it. Register at:

https://www.armymaintenance.com/arma.

3.D.2.B.5. (U) Mold can grow almost anywhere; learning to identify, report and remediate it correctly is everyone's business.

3.D.2.B.6. (U) If you encounter mold and don’t know what to do, inform your chain of command.

3.D.2.B.7. (U) Effectively countering mold is part of taking care of our people, the Army's number one priority. The health and welfare of our Soldiers, Families, and Civilians are the foundation of Army readiness.

3.D.2.B.8. (U) IMCOM has established and is implementing standards to help Soldiers, Families, and Civilians identify, report, and remediate mold in all Army facilities, including housing and barracks.

3.D.2.B.9. (U) We are taking deliberate actions to assess, address, and remediate mold related issues and refining systems within our ability to reduce mold frequency in Army facilities.

3.D.2.B.10. (U) We are monitoring these actions and standards across the force to capture the lessons learned and best practices that will help us integrate mold prevention behavior into a routine and enduring part of everyday life for members of the Army community.

3.D.2.B.11. (U) Enforcing standards and maintaining focus is leader business. We empower and expect leaders to routinely visit housing, barracks, and other facilities with appropriate notice and consent.

3.D.2.B.12. (U) Mold exists everywhere the U.S. Army operates. Soldiers, Families, Civilians, and members of Army communities are informed and aware of easy, effective, and routine measures to prevent mold in Army housing, barracks, and facilities.

3.D.2.C. (U) Comply with, and support instructions and guidance published in this order.

3.D.2.D. (U) Utilize the PWSS request process for submitting all requests for assistance through the HQ IMCOM G4.

3.D.2.E. (U) Utilize ArMA as their primary customer relationship management tool located at: https://www.armymaintenance.com/arma.

3.D.2.F. (U) Utilize the GeT platform as the primary end user desk reference and virtual training tool.

3.D.2.G. (U) NLT 15 Mar 23, provide existing mold information and education materials in use to inform communities of mold and forward to IMCOM PAO at usarmy.jbsa.imcom-hq.mbx.public-affairs-office@army.mil.

3.D.2.H. (U) Capture mold related costs in GFEBS under Work Breakdown Structure

(WBS) S.0095945.1.

3.D.2.I. (U) Participate in planning and designing a Facilities Sustainment COP.

3.D.2.J. (U) Utilize IMCOM G4 generated reports and data for all briefings to Installation and IMCOM leaders. Locally generated reports often do not directly align with data reported by HQ IMCOM G4, AMC, or HQDA entities.

3.D.2.K. (U) NLT 15 Oct 23, ensure Garrisons conduct annual property condition/preventative maintenance inspections in Army maintained housing facilities using existing QA checklist and upload documents in eMH.

3.D.2.L. (U) Capture, consolidate, and upload ID and Garrison counter mold operation lessons learned to a SharePoint URL TBP.

3.D.2.M. (U) Participate in deploying and executing approved Critical Information Requirement Courses of Action.

3.D.2.N. (U) NLT 30 Apr 23, ensure garrisons produce a counter mold SOP specific to their installation. At minimum the SOP will include:

3.D.2.N.1. (U) Garrison Commander endorsement letter that specifies the Commander’s intent.

3.D.2.N.2. (U) The definition of mold as defined in this order.

3.D.2.N.3. (U) Mold prevention procedures and awareness training specific to the Garrison.

3.D.2.N.4. (U) Procedures to signing up for and receive competency training and requisite certification(s) specific to IMCOM’s baseline standard for mold assessment and remediation TBP NLT 01 Apr 23.

mailto:usarmy.jbsa.imcom-hq.mbx.public-affairs-office@army.mil

3.D.2.N.5. (U) Installation specific mold inspection and remediation standards consistent with Army guidance referenced in Annex C and Annex D of this order.

3.D.2.N.6. (U) Personal Protection Equipment (PPE) Requirements consistent with Army guidance referenced in Annex C and Annex D of this order.

3.D.2.N.7. (U) Procedures for monitoring and measuring effectiveness of Garrison counter-mold program.

3.D.2.N.8. (U) Garrison points of contact (POC) to assist occupants of Army barracks, housing, or facilities in answering mold related questions.

3.D.2.N.9. (U) Specialized training and instruction requirements specific to that Garrison geographic and climatic location. Garrison Command Teams are responsible for development of training and certification criteria, materials, and practices specific to that Garrison.

3.D.2.N.10. (U) Installation specific Standard Operating Procedures (SOPs) for mold assessments and remediation response procedures will be consistent with the U.S.

Army Public Health Command (USAPHC) standards found in USAPHC Technical Guide 277 (TG 277) Army Mold Remediation, and TG 278 Army Mold Assessment. Found in Annex C, D, and E of this order.

3.D.2.N.10.A. (U) TG 277: Provides the Army’s guidance for remediation of clean water and mold contamination. It will guide you in making a reasonable judgment as to whether the situation can be handled in-house of if additional assistance is required.

3.D.2.N.10.B. (U) TG 278: This mold assessment guide used in conjunction with the TG 277 outlines guidance on mold assessment, evaluation, remediation, and personal protective equipment.

3.D.2.O. (U) Garrisons with privatized housing partners will provide their partner a copy of the legally approved SOP and request they meet or exceed the local SOPs.

Garrison Housing Managers will conduct an annual review of the SOP, partner standards and document in annual compliance report.

3.D.2.P. (U) Ensure Garrison Commanders place all counter mold inspectors on appointment orders.

3.D.2.Q. (U) Ensure Garrison DPW Work Order/Work Reception Desks and Business Operations and Integration Divisions incorporate the instructions and guidance provided in the TCHB and GeT platform for DPW SOPs and routine business practices located at: https://armyeitaas.sharepoint-mil.us/sites/IMCOM-HQ-G4/SitePages/Infrastructure- Sustainment-PW-GFEBS-eTraining-(GeT).aspx.

https://armyeitaas.sharepoint-mil.us/sites/IMCOM-HQ-G4/SitePages/Infrastructure-Sustainment-PW-GFEBS-eTraining-(GeT).aspx https://armyeitaas.sharepoint-mil.us/sites/IMCOM-HQ-G4/SitePages/Infrastructure-Sustainment-PW-GFEBS-eTraining-(GeT).aspx

3.D.2.R. (U) Ensure Garrison DPWs use ArMA as their primary customer relationship management tool. All DMOs must have a corresponding ArMA Work Request ticket.

3.D.2.S. (U) Ensure Garrison DPWs will make all G4 tasks, instructions, and guidance a priority, adhering to all suspense dates and response requirements and work to minimize the frequency and impacts to routine Garrison DPW operations to the greatest extent possible.

3.D.2.T. (U) Ensure garrisons utilize the PWSS request process for submitting all requests for assistance through the HQ IMCOM G4 located at:https://armyeitaas.sharepoint-mil.us/sites/IMCOM-HQ-G4/SitePages/Infrastructure- Sustainment-PWSS-Submit-Request.aspx.

3.D.2.U. Ensure garrisons utilize the GeT platform as the primary end user desk reference and virtual training tool.

3.D.2.V. (U) Ensure Garrison DPW service technicians comply with data collection requirements for all DMOs, PMOs, PWOs, and OWOs. Service technicians’ involvement is critical to the quality and completeness of data collected and reported to IMCOM Senior Leaders.

3.D.2.W. (U) Ensure garrisons conduct IMCOM mold education briefings in stakeholder meetings, initial resident communications, town halls, newcomer briefs, and/or onboarding process NLT 15 Mar 23.

3.D.2.X. (U) Ensure garrisons implement requirements for occupants of Army facilities to provide Garrison DPWs written notice of vacancy more than 7 days and allow access NLT 15 Mar 23.

3.D.2.Y. (U) Ensure garrisons provide existing information and education materials in use to inform communities about mold.

3.D.2.Z. (U) Ensure garrisons capture mold related costs in GFEBS under Work Breakdown Structure (WBS) S.0095945.1.

3.D.2.AA. (U) Ensure garrisons complete the Garrison Assessment of Mold Procedures and Capabilities located at: https://forms.osi.apps.mil/r/nphBuXE55w NLT 15 Mar 23.

3.D.2.BB. (U) Ensure all Garrison personnel involved in remediating mold in housing or facilities follow the guidance and procedures in the U.S. Army Public Health Center (APHC) Technical Guide 277 (TG-277): Industrial Hygiene Public Health - Army Mold Remediation Guidance, when conducting mold prevention and remediation actions.

https://armyeitaas.sharepoint-mil.us/sites/IMCOM-HQ-G4/SitePages/Infrastructure-Sustainment-PWSS-Submit-Request.aspx https://armyeitaas.sharepoint-mil.us/sites/IMCOM-HQ-G4/SitePages/Infrastructure-Sustainment-PWSS-Submit-Request.aspx https://forms.osi.apps.mil/r/nphBuXE55w

3.D.2.CC. (U) Ensure all Garrison personnel involved in assessing mold in housing or facilities follow the guidance and procedures in the APHC Technical Guide 278 (TG- 278): Industrial Hygiene Public Health - Mold Assessment Guide when conducting routine mold evaluations and investigations.

3.D.2.DD. (U) Ensure all DPW inspectors, Housing inspectors, DPW work order clerks, and barracks managers who conduct mold prevention, assessment, or remediation activities complete competency training offered through HQ IMCOM G4, DPW School of Public Works NLT 01 May 23. Training will be developed and available virtually NLT 01APR23. Registration information TBP.

3.D.2.EE. (U) Ensure garrisons utilize TG-277 and TG-278 guidance referenced in Annex C and D of this order, competency training, and Garrison staff analysis in the development of the garrison specific counter-mold SOP.

3.D.2.FF. (U) Ensure all Garrison DPWs immediately incorporate IMCOM G4 directed changes to practices, processes, and procedures into local SOPs and routine operational practices.

3.D.2.GG. (U) Ensure all Garrison DPWs make all data corrective actions a priority for immediate resolution. Garrison DPWs are responsible for effectively communicating any condition that would prevent compliance with corrective actions.

3.D.2.HH. (U) Ensure all Garrison DPWs will, wherever possible, utilize IMCOM G4 generated reports and data for all briefings to Garrison and Installation leaders. Locally generated reports often do not directly align with data reported by HQ IMCOM G4, AMC, or HQDA entities.

3.E. (U) Coordinating Instructions.

3.E.1. (U) This order is effective upon publication.

3.E.2. (U) Direct Liaison Authority (DIRLAUTH) is granted to all commands, units, IDs, staff, and staff sections to take necessary actions in support of the execution of this OPORD. At the direction of the Commanding General (CG), participate in or act in support of activities, meetings, and/or workshops required to successfully execute this

OPORD.

3.E.3. (U) All requests for exemptions to the instructions in this OPORD or suspense extensions may be granted by HQ IMCOM G4 on a case-by-case basis.

3.E.4. (U) Acknowledge receipt to the PoCs in paragraph 5 NLT one week after receipt of this OPORD.

4. (U) SUSTAINMENT.

4.A. (U) Funding. TBP

5. (U) COMMAND AND CONTROL. The Office of Primary Responsibility is the HQ IMCOM G4 and all others are the Office of Coordinating Responsibility. HQ IMCOM POCs for this OPORD are:

5.A. (U) G4 Army Barracks. Mr. David D. Gettelman at COMM: (210) 466-0455/DSN:

312-450-0455; e-mail: david.d.gettelman.civ@army.mil.

5.B. (U) G4 Army Owned Housing. Mr. David D. Gettelman at COMM: (210) 466- 0455/DSN: 312-450-0455; e-mail: david.d.gettelman.civ@army.mil.

5.C. (U) G4 Army Facilities. Mr. Ward A. Nichols at COMM: (210) 466-0896/DSN 450-8906; e-mail: ward.a.nichols.civ@army.mil.

5.D. (U) G4 Army Maintenance.com (ArMA). Mr. Douglas V. Enfield at COMM: (210) 466-0612/DSN: 450-0612; e-mail: douglas.v.enfield.civ@army.mil.

5.E. (U) G4 Army Public Works Support Services (PWSS). Ms. Kimberly A. Willard at COMM: (210) 466-0606/DSN: 450-0606; e-mail: kimberly.a.willard.civ@army.mil.

5.F. (U) G4 Environmental. Mr. David P. Giffin at COMM: (210) 466-0448/DSN: 312- 450-0448; e-mail: david.p.giffin.civ@army.mil.

5.G. (U) G8 RM Acquisition. Mr. Doug L. Adams at COMM: (210) 466-0779/DSN:

312-450-0779; e-mail: douglas.l.adams2.civ@army.mil.

5.H. (U) G8 Programs and Budget. Mr. William (Bill) R. Maner at COMM: (210) 466- 00770/DSN: 312-450-0770; e-mail: william.r.maner.civ@army.mil.

5.I. (U) Safety. Mr. Gordon E. Tate at COMM: (210) 466-0366/DSN: 312-450-0366;

e-mail: gordon.e.tate.civ@army.mil.

5.J. (U) Public Affairs. Mrs. Maria E. Gallegos at COMM: (210) 466-0122/DSN: 312- 450-0122; e-mail: maria.e.gallegos6.civ@army.mil.

5.K. (U) Command Surgeon. COL Donald E. Kimbler at COMM: (210) 466- 0936/DSN: 312-450-0936; e-mail: donald.e.kimbler2.mil@army.mil.

mailto:ward.a.nichols.civ@army.mil mailto:douglas.v.enfield.civ@army.mil mailto:kimberly.a.willard.civ@army.mil

February 2019

Industrial Hygiene Public Health

Army Mold Remediation

Guidance

Technical Guide 277

Approved for public release; distribution unlimited.

Enclosure 2: Annex C (USAPHC TG277 Army Mold Remediation Guidance) to

OPORD 23-007(U)

TG 277 Feb 2019

Use of trademarked name(s) does not imply endorsement by the U.S. Army but is intended only to assist in identification of a specific product.

NOTICE

This publication is essential and current. An administrative review has been performed…