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Report to the Chairman, Committee on Health, Education, Labor and 
Pensions, U.S. Senate: 

United States Government Accountability Office: 
GAO: 

September 2008: 

Indoor Mold: 

Better Coordination of Research on Health Effects and More Consistent 
Guidance Would Improve Federal Efforts: 

GAO-08-980: 

GAO Highlights: 

Highlights of GAO-08-980, a report to the Chairman, Committee on 
Health, Education, Labor and Pensions, U.S. Senate. 

Why GAO Did This Study: 

Recent research suggests that indoor mold poses a widespread and, for 
some people, serious health threat. Federal agencies engage in a number 
of activities to address this issue, including conducting or sponsoring 
research. For example, in 2004 the National Academies’ Institute of 
Medicine issued a report requested by the Department of Health and 
Human Services (HHS) summarizing the scientific literature on mold, 
dampness, and human health. In addition, the Federal Interagency 
Committee on Indoor Air Quality supports the Environmental Protection 
Agency’s (EPA) indoor air research program. With respect to the health 
effects of exposure to indoor mold, GAO was asked to report on (1) the 
conclusions of recent reviews of the scientific literature, (2) the 
extent to which federal research addresses data gaps, and (3) the 
guidance agencies are providing to the general public. GAO reviewed 
scientific literature on indoor mold’s health effects, surveyed three 
agencies that conduct or sponsor indoor mold research, and analyzed 
guidance issued by five agencies. 

What GAO Found: 

In general, the Institute of Medicine’s 2004 report, and reviews of the 
scientific literature published from 2005 to 2007 that GAO examined, 
concluded that certain adverse health effects are more clearly 
associated with exposure to indoor mold than others. For example, the 
Institute of Medicine concluded that some respiratory effects, such as 
exacerbation of pre-existing asthma, are associated with exposure to 
indoor mold but that the available evidence was not sufficient to 
determine whether mold and a variety of other health effects, such as 
the development of asthma, cancer, and acute pulmonary hemorrhage in 
infants, are associated. While the reviews GAO examined generally 
agreed with these conclusions, a few judged the evidence for some 
health effects as somewhat stronger. For example, the American Academy 
of Pediatrics concluded in 2006 that a plausible link exists between 
acute pulmonary hemorrhage in infants and exposure to toxins that some 
molds produce. In addition, the 2004 Institute of Medicine report 
identified the need for additional research to address a number of data 
gaps related to the health effects of indoor mold. 

The 65 ongoing federal research activities on the health effects of 
exposure to indoor mold conducted or sponsored by EPA, HHS, and the 
Department of Housing and Urban Development (HUD) address to varying 
extents 15 gaps in scientific data reported by the Institute of 
Medicine. For example, many of the research activities address data 
gaps related to asthma and measurement methods, while other data gaps, 
such as those related to toxins produced by some molds, are being 
minimally addressed. Further, less than half of the ongoing mold-
related research activities are coordinated either within or across 
agencies. This limited coordination is important in light of, among 
other things, the wide range of data gaps identified by the Institute 
of Medicine and limited federal resources. The Federal Interagency 
Committee on Indoor Air Quality could provide a structured mechanism 
for coordinating research activities on mold and other indoor air 
issues by, for example, serving as a forum for reviewing and 
prioritizing agencies’ ongoing and planned research. However, it 
currently does not do so. 

Despite limitations of scientific evidence regarding a number of 
potential health effects of exposure to indoor mold, enough is known 
that federal agencies have issued guidance to the general public about 
health risks associated with exposure to indoor mold and how to 
minimize mold growth and mitigate exposure. For example, guidance 
issued by the Consumer Product Safety Commission, EPA, the Federal 
Emergency Management Agency, HHS, and HUD cites a variety of health 
effects of exposure to indoor mold but in some cases omits less common 
but serious effects. Moreover, while guidance on minimizing indoor mold 
growth is generally consistent, guidance on mitigating exposure to 
indoor mold is sometimes inconsistent about cleanup agents, protective 
clothing and equipment, and sensitive populations. As a result, the 
public may not be sufficiently advised of indoor mold’s potential 
health risks. 

What GAO Recommends: 

GAO recommends that EPA use the interagency committee on indoor air to 
(1) help guide federal research priorities on indoor mold and (2) help 
agencies better ensure that their guidance to the public does not 
conflict, among other things. In commenting on a draft of our report, 
EPA agreed with our recommendations. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-980]. To view the 
survey results, click on GAO-08-984SP. For more information, contact 
John B. Stephenson at (202) 512-3841 or stephensonj@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Many Studies Associate Indoor Mold with Adverse Health Effects but Cite 
the Need for Additional Research: 

Federal Research Activities on the Health Effects of Indoor Mold 
Address Data Gaps to Varying Degrees; Limited Planning and Coordination 
of the Activities May Reduce Their Ability to Close Data Gaps: 

Federal Guidance to the General Public Identifies Various Health 
Effects Associated with Exposure to Indoor Mold, as well as Strategies 
to Limit It, Some of Which Are Inconsistent: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Recent Reviews of the Health Effects of Mold: 

Appendix III: EPA, HHS, and HUD Ongoing Research Activities Addressing 
Data Gaps Identified by the Institute of Medicine: 

Appendix IV: Federal Agency Program Offices Contacted Regarding Their 
Mold-Related Research: 

Appendix V: Selected Publicly Available Federal Guidance Related to 
Mold: 

Appendix VI: GAO Contact and Staff Acknowledgments: 

Table: 

Table 1: Potential Adverse Health Effects of Exposure to Indoor Mold 
Cited in Six or More Guidance Documents, by Federal Agency: 

Figures: 

Figure 1: Coordination of Ongoing Federal Mold Research Activities 
within the Agency or among Other Federal Agencies, as of October 1, 
2007: 

Figure 2: Varying Levels of Personal Protection for Cleaning Limited 
Mold Contamination, as Recommended by Selected Federal Guidance: 

Abbreviations: 

CDC: Centers for Disease Control and Prevention: 

DOE: Department of Energy: 

EPA: Environmental Protection Agency: 

ERMI: Environmental Relative Moldiness Index: 

FEMA: Federal Emergency Management Agency: 

HHS: Department of Health and Human Services: 

HUD: Department of Housing and Urban Development: 

NIH: National Institutes of Health: 

NIOSH: National Institute for Occupational Safety and Health: 

OSHA: Occupational Safety and Health Administration: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

September 30, 2008: 

The Honorable Edward M. Kennedy: 
Chairman: 
Committee on Health, Education, Labor and Pensions: 
United States Senate: 

Dear Mr. Chairman: 

Mold is a general term for certain microorganisms that thrive in damp 
conditions and are regularly found in indoor air and on materials and 
surfaces, such as walls.[Footnote 1] While indoor mold was considered 
largely a nuisance as recently as 25 years ago, scientific and medical 
research is now suggesting that mold poses a widespread and, for some 
people, serious health threat.[Footnote 2] The presence of moisture is 
the primary factor leading to mold growth indoors. In the wake of 
Hurricanes Katrina and Rita in 2005 and the extensive flooding of homes 
that followed, the Department of Health and Human Services' (HHS) 
Centers for Disease Control and Prevention (CDC) concluded that 
"excessive exposure to mold-contaminated materials can cause adverse 
health effects in susceptible persons regardless of the type of mold or 
the extent of contamination."[Footnote 3] A variety of health effects 
have been directly linked to exposure to indoor mold, although the 
connection to many of the more severe effects, such as acute lung 
hemorrhaging in infants, remains inconclusive. 

Several components and products of mold may cause disease. Mold grows 
as a mass of microscopic filaments, fragments of which may cause 
adverse health effects. In addition, the spores that mold releases to 
reproduce, along with certain components of mold's cell walls, may also 
cause adverse health effects. Mold products--for example, allergens, 
volatile gases that often create a musty odor, and toxins released by 
certain types of mold under certain conditions--can also cause disease. 
An example of a toxin-producing mold is Stachybotrys chartarum, which 
produces multiple toxins that may suppress the functioning of immune 
cells. 

Mold may affect human health through a number of routes and mechanisms. 
While inhalation is generally the most common route of exposure for 
mold in indoor environments, exposure can also occur through ingestion 
(for example, hand-to-mouth contact) and contact with the skin. The 
roles of these routes of exposure in causing illness are unclear. Once 
exposure occurs, health effects may arise through several potential 
mechanisms, including allergic (or immune-mediated), infectious, and 
toxic. It is not always possible to determine which of these mechanisms 
is associated with a specific health outcome. 

Although federal agencies are engaged in a number of efforts to address 
indoor mold, there are no federal or generally accepted health-based 
standards for safe levels of mold in the air or on surfaces. According 
to EPA officials, the lack of federal regulation of airborne 
concentrations of mold indoors is largely due to the insufficiency of 
data needed to establish a scientifically defensible health-based 
standard. Another factor is the lack of scientific consensus regarding 
how best to measure these concentrations. The presence of mold in homes 
and workplaces has led to numerous lawsuits. For example, highly 
publicized cases involving mold include a Texas homeowner's successful 
multi-million-dollar lawsuit against an insurance company related to 
mold contamination. Moreover, mold contamination at the Walter Reed 
Army Medical Center, where soldiers returning from Iraq are being 
treated, received significant media coverage. 

In 2001, recognizing the need for credible and comprehensive 
information on the health effects of exposure to indoor mold, HHS 
commissioned the National Academies' Institute of Medicine to review 
the available scientific literature on the links among mold, dampness, 
and human health.[Footnote 4] In 2004, the Institute of Medicine issued 
its report, which made a variety of recommendations for research aimed 
at better understanding the health risks of exposure to indoor mold. 
[Footnote 5] Currently, a number of federal agencies conduct mold- 
related research or provide guidance to the public on health effects 
associated with exposure to mold and on ways to mitigate such exposure. 
These federal agencies include the Environmental Protection Agency 
(EPA); the Department of Housing and Urban Development (HUD); the 
Consumer Product Safety Commission; the Federal Emergency Management 
Agency (FEMA); and HHS and a number of its entities, such as CDC and 
the National Institutes of Health (NIH). In 1983, a congressional 
committee directed the establishment of the Federal Interagency 
Committee on Indoor Air Quality to coordinate federal indoor air 
quality research. The research on indoor mold is a small component of 
indoor air research activities, and it is conducted or sponsored by a 
number of different entities within and across agencies. EPA serves 
both as the executive secretary of the interagency committee and as a 
co-chair; other federal departments and agencies participate as co- 
chairs and members. 

You asked us to determine (1) what recent reviews of scientific 
literature have concluded about the health effects of exposure to 
indoor mold; (2) the extent to which federal research addresses data 
gaps related to the health effects of exposure to indoor mold; and (3) 
the guidance key federal agencies are providing to the general public 
on the health risks of exposure to mold, minimizing mold growth, and 
mitigating exposure to mold, and the extent to which the guidance is 
consistent. For the first objective, we analyzed the 2000 and 2004 
Institute of Medicine reports, Clearing the Air: Asthma and Indoor Air 
Exposures and Damp Indoor Spaces and Health.[Footnote 6] We also 
analyzed 20 reviews of the scientific literature on the health effects 
of exposure to indoor mold that were published from 2005 to 2007; we 
did not review individual studies. To obtain information on federal 
research related to the health effects of exposure to indoor mold, we 
conducted two surveys of officials at EPA, HHS, and HUD from November 
2007 to May 2008. We focused on these agencies because of their past 
and current research activities on the health effects of mold. We used 
one survey to (1) identify research activities related to the health 
effects of indoor mold ongoing as of October 1, 2007, and (2) determine 
the extent to which these research activities address the 15 data gaps 
identified in the 2000 and 2004 Institute of Medicine reports related 
to the health effects of exposure to indoor mold. We also used this 
survey to identify the extent to which these activities were 
coordinated both within and across agencies. We conducted a second 
survey of these agencies to collect basic information regarding their 
mold-related research activities completed from January 1, 2005, to 
September 30, 2007. Overall, we received information on 107 research 
activities from 37 EPA, HHS, and HUD officials. Summaries of the 
research activities conducted or sponsored by EPA, HHS, and HUD are 
provided in a supplement to this report (see [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-08-984SP]). We also examined the 
extent to which the Federal Interagency Committee on Indoor Air Quality 
has been used to coordinate federal research activities related to the 
health effects of exposure to indoor mold. To evaluate guidance 
documents issued to the public by federal agencies, we focused on the 
five federal agencies primarily responsible for providing information 
to the general public on health risks and minimizing and mitigating 
exposure to contaminants, including mold--the Consumer Product Safety 
Commission, EPA, FEMA, HHS, and HUD. Our review focuses on the health 
effects and guidance to the general public related to indoor mold in 
homes and does not address occupational exposures or technical guidance 
documents targeted to specialized audiences such as medical 
professionals. Appendix I provides a more detailed description of our 
scope and methodology. We conducted this performance audit from January 
2007 to September 2008 in accordance with generally accepted government 
auditing standards. Those standards require that we plan and perform 
the audit to obtain sufficient, appropriate evidence to provide a 
reasonable basis for our findings and conclusions based on our audit 
objectives. We believe that the evidence obtained provides a reasonable 
basis for our findings and conclusions based on our audit objectives. 

Results in Brief: 

In general, the Institute of Medicine's 2004 comprehensive report, as 
well as reviews of the scientific literature published from 2005 to 
2007 that we examined, concluded that certain adverse health effects 
are more clearly associated with exposure to indoor mold than others. 
For example, the Institute of Medicine's report said that certain 
respiratory effects, such as nasal congestion and the exacerbation of 
pre-existing asthma, are associated with exposure to indoor mold but 
that the available evidence was not sufficient to determine whether 
associations exist between mold and a variety of other health effects, 
such as the development of asthma, rheumatologic and other immune 
diseases, cancer, acute pulmonary hemorrhage in infants, and 
reproductive effects. While the more recent scientific reviews we 
examined generally concurred with these conclusions, a few of the 
reviews judged the available evidence for some of these health effects 
to be somewhat stronger. For example, the American Academy of 
Pediatrics concluded in 2006 that a plausible link exists between acute 
pulmonary hemorrhage in infants and exposure to certain toxins that 
some molds produce. Conclusively associating exposure to mold with 
certain health effects is challenging, according to the Institute of 
Medicine's 2004 report, because available studies have been of 
insufficient quality, consistency, or rigor. Two key research issues 
contribute to this difficulty: (1) the lack of standardized, 
quantitative methods of measuring exposure to mold and (2) the 
difficulty in determining which of several disease-causing agents in 
damp indoor environments may be responsible for the adverse health 
effects. In this regard, the 2000 and 2004 Institute of Medicine 
reports and the more recent reviews we examined identified the need for 
additional research to address these and other uncertainties related to 
the connection between exposure to indoor mold and adverse health 
effects. For example, the 2004 Institute of Medicine report concluded 
that there is a need for research to determine the health effects of 
long-term exposure to the toxins that some molds can produce. 

The 65 ongoing federal research activities on the health effects of 
exposure to indoor mold conducted or sponsored by EPA, HHS, and HUD 
address to varying extents 15 gaps in scientific data reported by the 
Institute of Medicine. These gaps relate to the need to better define 
any association between a wide range of specific potential adverse 
health effects and exposure to indoor mold. Of the 65 research 
activities, nearly 60 percent address asthma, and more than half 
address measurement methods--that is, sampling and exposure assessment 
methods for indoor mold. Some other important data gaps are being 
minimally addressed. For example, 5 of the 65 research activities 
examine the effects of human exposure to molds that produce toxins that 
may cause a number of adverse health effects, and only 1 relates to 
acute pulmonary hemorrhage in infants--a rare but life-threatening 
condition that may be caused by exposure to mold. Further, identifying 
and coordinating research priorities, and efforts to achieve them, are 
particularly important given the wide range of research needs 
identified by the Institute of Medicine reports, the number of federal 
entities involved in conducting research on mold, and limited federal 
resources. However, federal officials reported that fewer than half of 
their ongoing research activities have involved coordination either 
with other units in their agencies or other federal agencies. For 
example, of the 36 ongoing research activities related to sampling and 
measurement methods, only 14 are being coordinated to some extent. 
Further, in many cases, research activities were only coordinated 
within the agency conducting or sponsoring the research. Moreover, 
although the Federal Interagency Committee on Indoor Air Quality could 
provide a structured mechanism for coordinating research activities, it 
does not serve this function. That is, instead of selecting specific 
topics and tasks to advance scientific knowledge in the area of indoor 
air quality--such as reviewing and prioritizing agencies' ongoing and 
planned research in particular areas--the agendas for the committee 
meetings are largely driven by the interests of the agencies' 
individual committee representatives. 

Despite the limitations of current scientific evidence in establishing 
clear associations and causal linkages between a number of adverse 
health effects and exposure to indoor mold, enough is known that 
federal agencies have issued guidance to the general public about 
health risks associated with exposure to indoor mold, how to minimize 
mold growth, and how to mitigate exposure. For example, a majority of 
the 32 guidance documents we reviewed issued by the Consumer Product 
Safety Commission, EPA, FEMA, HHS, and HUD describe some common adverse 
health effects, such as asthma attacks and upper respiratory tract 
symptoms. However, the guidance documents inconsistently identify some 
other health effects that may be less common. For example, only 6 of 
the 32 documents warn that exposure to mold can lead to 
hypersensitivity pneumonitis, a relatively rare but potentially serious 
allergic reaction. In addition, most of the guidance documents offer 
consistent strategies for minimizing the growth of indoor mold--for 
example, keeping areas dry and promptly addressing moisture sources, 
such as leaks or spills. Finally, a majority of the documents also 
address mitigating exposure to indoor mold, including directions for 
cleaning up mold and protective clothing and equipment to wear while 
doing so. However, the guidance is somewhat inconsistent about which 
cleaning agents to use--for example, some documents recommend using 
bleach, a biocide that is toxic to humans, if the mold growth is due to 
floodwater; some recommend bleach regardless of the cause of the mold; 
and others recommend using detergent. Finally, most of the documents 
warn that certain populations may be more sensitive to mold than 
others, but only two provide specific recommendations about the varying 
levels of protective clothing and equipment (such as gloves, 
respirators, and eye and skin protection) that such populations should 
use under various circumstances. As a result of some of these omissions 
and inconsistencies, the public may be at risk of unnecessary exposure 
to indoor mold. 

To better ensure that federal research on the health effects of 
exposure to indoor mold is effectively addressing research needs and 
efficiently using scarce federal resources, we are recommending that 
EPA use the Federal Interagency Committee on Indoor Air Quality to both 
(1) help guide federal research priorities on the health effects of 
indoor mold and coordinate information sharing on this topic and (2) 
help agencies better ensure that their guidance to the public provides 
sufficient information on health effects of exposure to indoor mold, 
and how to minimize it, and does not conflict among agencies. We 
provided a draft of this report to the Consumer Product Safety 
Commission, EPA, FEMA, HHS, and HUD for the agencies' review and 
comment. EPA generally agreed with our recommendations regarding its 
use of the Federal Interagency Committee on Indoor Air Quality. With 
the exception of FEMA, the agencies also provided technical comments 
that we incorporated into the report, as appropriate. 

Background: 

Moisture is the primary factor leading to indoor mold growth. To grow 
indoors, mold also needs temperatures above freezing levels--from 32 to 
130 degrees Fahrenheit--and organic matter. The nutrients upon which 
mold feeds are provided by house dust and many surface and construction 
materials, such as wallpapers, textiles, wood, paints, and glues. 
Because the appropriate temperature and necessary nutrients are common 
in homes, mold growth can rapidly occur indoors when excessive moisture 
or water accumulates as a result of, for example, floods and other 
natural disasters; building design or construction flaws; and poor 
building maintenance practices, such as not repairing leaking plumbing. 
Moist conditions indoors may also foster the growth of other organisms 
capable of causing adverse health effects, including bacteria, 
cockroaches, and dust mites. 

Mold growth may be particularly severe following natural disasters such 
as hurricanes and flooding. The extent of the flooding after Hurricanes 
Katrina and Rita in 2005 led to conditions supporting widespread mold 
growth. Unlike other hurricane-impacted areas, where residents could 
access their buildings relatively quickly after the flood event, many 
residents in New Orleans were unable to access buildings for several 
weeks because of prolonged flood inundation. According to a CDC survey, 
an estimated 46 percent of homes in New Orleans and surrounding areas 
had visible mold growth. Widespread indoor mold contamination can cause 
adverse health effects in returning residents and make it more 
difficult to rehabilitate houses for reoccupation. For example, in 2006 
the Army Corps of Engineers noted that because of mold problems caused 
by the extensive flooding, many residences that did not require 
demolition would nonetheless need to be gutted--stripping the walls 
down to the studs--before they could be renovated.[Footnote 7] 

The Institute of Medicine has identified four possible levels of 
connection between indoor mold and adverse health effects: sufficient 
evidence of a causal relationship, sufficient evidence of an 
association, limited or suggestive evidence of an association, and 
inadequate or insufficient evidence to determine whether an association 
exists. According to HHS, establishing a causal relationship with 
adequate certainty requires several types of evidence, including (1) 
epidemiologic associations, (2) experimental exposure in animals or 
humans that leads to the symptoms and signs of the disease in question, 
and (3) reduction in exposure that leads to reduction in the symptoms 
and signs of the disease. HHS officials said that more data are needed 
to establish a causative association between exposure to mold and some 
illnesses because the vast majority of the studies conducted to date 
have been only epidemiologic. 

The federal government has responded to the uncertainty surrounding the 
health effects of exposure to indoor mold by, among other things, 
sponsoring reviews of the available scientific evidence. Committees of 
the National Academies' Institute of Medicine have produced two reports 
in the past several years that relate to the health effects of exposure 
to indoor mold. For a 2000 report requested by EPA, Clearing the Air: 
Asthma and Indoor Air Exposures, the Institute of Medicine assembled a 
multidisciplinary committee to examine the relevant research pertaining 
to asthma and the indoor environment, including, among many other 
issues, the possible impact of indoor mold on asthma prevalence. For 
its 2004 report requested by the CDC, Damp Indoor Spaces and Health, 
another Institute of Medicine committee reviewed the scientific 
literature to determine the connections among damp indoor spaces, 
microorganisms such as mold, and a variety of human health effects. 
This committee used a uniform set of categories to summarize its 
conclusions regarding the evidence of association between various 
health outcomes and exposure to indoor dampness or the presence of mold 
or other agents in damp indoor environments. While research in this 
field continues to evolve, both reports made recommendations for 
additional research related to mold and other areas that remain 
relevant--that is, the data gaps have not been resolved. 

In addition to sponsoring reviews of the available scientific evidence, 
federal agencies have the opportunity to share information on various 
aspects of indoor air quality, including mold, through the Federal 
Interagency Committee on Indoor Air Quality. Title IV of the Superfund 
Amendments and Reauthorization Act of 1986 directed EPA, among other 
things, to disseminate the results of its indoor air quality research 
program and establish an advisory committee consisting of other federal 
agencies.[Footnote 8] EPA serves as the executive secretary of the 
Federal Interagency Committee on Indoor Air Quality, which fulfills 
this advisory role. The committee is co-chaired by EPA, the Department 
of Energy (DOE), the Consumer Product Safety Commission, the National 
Institute for Occupational Safety and Health (NIOSH), and the 
Occupational Safety and Health Administration (OSHA). Other federal 
departments and agencies participate in the committee as members. In 
1991, we recommended that the Administrator, EPA, work with other 
members of the committee to clearly define in a charter the roles and 
responsibilities of the agencies participating in the committee in 
order to strengthen interagency coordination of indoor air research. 
[Footnote 9] However, EPA has not implemented this recommendation. 

Although federal agencies are engaged in a number of efforts to address 
indoor mold, there are no federal or generally accepted health-based 
standards for safe levels of mold, its components, or its products in 
the air or on surfaces. In fact, neither EPA nor OSHA has established 
health-based standards for airborne concentrations of mold or mold 
spores indoors. Similarly, NIOSH has not set recommended exposure 
limits for indoor mold or mold spores. Further, according to EPA 
officials, the lack of federal regulation of airborne concentrations of 
mold indoors is largely attributable to the insufficiency of data 
needed to establish a scientifically defensible health-based standard. 
EPA officials also emphasized that the agency lacks the authority to 
establish airborne concentration limits for mold indoors. Legislation 
to require EPA to take action with respect to indoor mold has been 
introduced in Congress in the past but was not enacted. For example, 
the proposed United States Toxic Mold Safety and Prevention Act, most 
recently introduced in Congress in 2005, would have directed EPA to 
promulgate standards for preventing, detecting, and remediating indoor 
mold growth, among other things. 

The presence of mold in homes and workplaces has led to numerous 
lawsuits alleging personal injury or property damage. To obtain a 
judgment that mold has caused personal injury, an individual must 
persuade the court that the type of mold at issue is capable of causing 
the individual's condition and that the mold actually caused the 
condition in the specific case. Litigants generally use expert witness 
testimony in an attempt to prove or disprove these points in court. 
Courts use different standards to judge whether such testimony is 
admissible. In some states, courts will admit such testimony only if it 
is in accord with generally accepted consensus of the relevant 
scientific community. In other states and in the federal courts, judges 
independently evaluate the reliability of the evidence by weighing 
several factors, only one of which focuses on the views of the relevant 
scientific community. Many state courts use a mixture of these two 
methods. 

Insurance companies are frequently defendants in mold litigation, and 
in response to the rise in cases early in the decade, many began 
changing their policies to specifically exclude mold-related injuries 
and property damage from coverage. For example, many insurance policies 
now contain language stating that the insurance company "will not pay 
for loss or damage caused by or resulting from ... rust, corrosion, 
fungus, decay," and other conditions. As of 2006, the insurance 
regulatory agencies in 40 states had approved mold-related exclusions. 

Partly in response to a significant increase in mold litigation in the 
early part of this decade, states began enacting legislation to address 
various aspects of the mold problem. For example, in 2001 California 
enacted the Toxic Mold Protection Act, which requires the state's 
Department of Health Services to establish permissible mold exposure 
limits for indoor air.[Footnote 10] In addition, in 2003, Texas passed 
legislation requiring a mold remediation contractor to certify to a 
homeowner that the mold contamination identified for the project had 
been remediated as outlined in the mold management plan or remediation 
protocol. Further, the Texas law requires owners selling property to 
provide buyers with copies of each mold remediation certificate issued 
for the properties the 5 preceding years. Examples of other state 
legislative responses to mold issues include laws: 

* requiring landlords to disclose to tenants information about the 
health hazards associated with exposure to indoor mold; 

* prohibiting litigation against a real estate agent acting on behalf 
of a buyer or seller who has truthfully disclosed any known material 
defects; 

* establishing licensing requirements for individuals involved with 
mold assessment and remediation; and: 

* creating a group to study the effects of toxic mold.[Footnote 11] 

Many Studies Associate Indoor Mold with Adverse Health Effects but Cite 
the Need for Additional Research: 

While the 2004 Institute of Medicine report, and reviews of the 
scientific literature published subsequently, have found evidence 
associating indoor mold with certain adverse health effects, the 
evidence supporting an association between mold and other health 
effects remains less certain. Two factors, in particular, pose 
challenges for those attempting to determine the health effects of 
exposure to indoor mold: valid quantitative methods of measuring 
exposure are lacking, and a wide variety of other potential disease- 
causing agents are likely to be present in damp indoor environments, 
along with mold. According to the Institute of Medicine and recent 
reviews of the scientific literature, further research is required to 
advance the understanding of the relationships between dampness, indoor 
mold, and human health. 

While Mold Is Associated with Certain Adverse Health Effects, Evidence 
for Others Is Less Certain: 

The 2004 Institute of Medicine report, Damp Indoor Spaces and Health, 
found sufficient evidence of an association between exposure to indoor 
mold and certain adverse health effects--that is, an association 
between the agent and the outcome has been observed in studies in which 
chance, bias, and confounding factors can be ruled out with reasonable 
confidence. These health effects include: 

* upper respiratory tract symptoms, including nasal congestion, 
sneezing, runny or itchy nose, and throat irritation; 

* exacerbation of pre-existing asthma; 

* wheeze; 

* cough; 

* hypersensitivity pneumonitis in susceptible persons; and: 

* fungal colonization or opportunistic infections in immune-compromised 
persons. 

Of these health effects, the upper respiratory tract symptoms 
associated with allergic rhinitis are the most common, according to the 
American Academy of Pediatrics.[Footnote 12] In addition, the 
association between indoor mold and exacerbation of asthma symptoms is 
a particularly significant public health concern because asthma is the 
most common chronic illness among children in the United States and one 
of the most common chronic illnesses overall, according to the 
Institute of Medicine's 2000 report, Clearing the Air: Asthma and 
Indoor Air Exposures. Importantly, mold can affect certain populations 
disproportionately. For example, the 2004 Institute of Medicine report 
found sufficient evidence of an association between exposure to the 
mold genus Aspergillus and serious respiratory infections in people 
with severely compromised immune systems (such as chemotherapy patients 
and organ transplant recipients). This report also found sufficient 
evidence of an association between exposure to indoor mold and 
hypersensitivity pneumonitis--a relatively rare but potentially serious 
allergic reaction--in susceptible persons. In addition to these more 
established health effects, this report also found limited or 
suggestive evidence of an association between indoor mold and lower 
respiratory illness (for example, bronchitis and pneumonia) in 
otherwise healthy children. 

Most of the 20 reviews of the scientific literature published from 2005 
to 2007 that we examined generally agreed with the conclusions of the 
2004 Institute of Medicine report.[Footnote 13] However, two of the 
reviews characterized the relationship between exposure to indoor mold 
and certain of the above health effects more strongly. The American 
Academy of Pediatrics stated in its 2006 report that epidemiologic 
studies consistently support causal relationships between exposure to 
mold and upper respiratory tract symptoms and exacerbation of pre- 
existing asthma. The American Academy of Pediatrics also said that 
epidemiologic studies support a causal relationship between exposure to 
mold and hypersensitivity pneumonitis in susceptible persons.[Footnote 
14] Moreover, a 2007 meta-analysis[Footnote 15] sponsored by EPA and 
DOE found that building dampness and mold are associated with increases 
of 30 percent to 50 percent in a variety of health outcomes, such as 
upper respiratory tract symptoms, wheeze, and cough. The authors 
concluded that these associations strongly suggest these adverse health 
effects are caused by dampness-related exposures.[Footnote 16] 

According to the 2004 Institute of Medicine report, the evidence of an 
association between exposure to indoor mold and a variety of other 
health effects, however, is inadequate or insufficient--that is, the 
available studies are of insufficient quality, consistency, or 
statistical power to permit a conclusion regarding the presence of an 
association. The health effects for which there is inadequate or 
insufficient evidence of an association with indoor mold include: 

* acute idiopathic pulmonary hemorrhage in infants; 

* airflow obstruction in otherwise-healthy persons; 

* cancer; 

* chronic obstructive pulmonary disease; 

* development of asthma; 

* fatigue; 

* gastrointestinal tract problems; 

* inhalation fevers not related to occupational exposures; 

* lower respiratory illness in otherwise-healthy adults; 

* mucous membrane irritation syndrome; 

* neuropsychiatric symptoms; 

* reproductive effects; 

* rheumatologic and other immune diseases; 

* shortness of breath; and: 

* skin symptoms. 

Most of the recent reviews of the literature we examined generally 
concurred with these Institute of Medicine conclusions as well, 
although a few found a somewhat stronger relationship between indoor 
mold and certain of the health effects listed above. For example, a 
2007 review concluded that dampness and exposure to indoor mold can 
exacerbate or may cause shortness of breath, among other health 
effects.[Footnote 17] In addition, other reviews differed in their 
conclusions regarding the link between exposure to indoor mold and 
acute idiopathic pulmonary hemorrhage in infants, the sudden onset of 
pulmonary hemorrhage in a previously healthy infant. This condition was 
reported among a group of infants from the same part of Cleveland, 
Ohio, in the 1990s and attributed by some researchers to exposure to 
indoor mold. Five of the reviews we examined contained conclusions 
about acute idiopathic pulmonary hemorrhage in infants and children. 
Two concluded that mold has not been proven to cause this condition. 
[Footnote 18] However, a third review--the American Academy of 
Pediatrics 2006 report--said that although a causal relationship has 
not been firmly established, a variety of studies have provided some 
evidence that such a relationship is plausible. The fourth review said 
that the association between acute idiopathic pulmonary hemorrhage in 
infants and children and mold is strong enough to justify removing them 
from moldy environments or cleaning up these spaces,[Footnote 19] and 
the fifth review reiterated this recommendation.[Footnote 20] 

Some of the health effects for which the evidence remains unclear (for 
example, fatigue and acute idiopathic pulmonary hemorrhage in infants) 
have been attributed to reactions to toxins, or "mycotoxins," that can 
be produced by certain types of mold that grow indoors. The reviews we 
examined were largely consistent in their interpretations of the 
evidence for the role of mycotoxins in relation to adverse health 
effects. The Institute of Medicine reported in 2004 that (1) exposure 
to mycotoxins can occur via inhalation, contact with the skin, and 
ingestion of contaminated food and (2) research on Stachybotrys 
chartarum (a species of indoor mold that can produce mycotoxins) 
suggests that effects in humans may be biologically plausible. However, 
the report also noted that the effects of chronic inhalation of 
mycotoxins require further study and that additional research must 
confirm the observations on Stachybotrys chartarum before a more 
definitive conclusion can be drawn. Among the more recent reviews we 
examined that specifically addressed mycotoxins, five reached a similar 
conclusion--that is, that the current evidence is inconclusive or 
limited.[Footnote 21] However, one review suggested that it is likely 
that mycotoxins play some role in building-related disease, including 
exacerbation of pre-existing asthma.[Footnote 22] On the other hand, 
another recent review cast doubt on the health effects of mycotoxins in 
one set of circumstances--specifically, the review concluded that it 
was improbable for mycotoxins to cause negative health effects through 
a toxic mechanism when individuals inhale mycotoxins in nonoccupational 
settings (such as homes). This review, however, explicitly stated this 
conclusion did not address adverse health effects of mycotoxins that 
may be caused by immune-mediated mechanisms or stem from exposure in 
occupational settings or by ingestion.[Footnote 23] 

Two Key Factors Pose Challenges for Determining the Health Effects of 
Exposure to Indoor Mold: 

According to the 2004 Institute of Medicine report, two key issues 
largely contribute to the scientific data gaps regarding the 
relationship between mold and adverse health effects: (1) valid 
quantitative methods of measuring exposure are lacking, and (2) a wide 
variety of potential disease-causing agents are likely to be present in 
damp indoor environments, which makes it difficult to link health 
effects with specific agents. Without standardized, quantitative 
methods to measure exposure, it is difficult to compare exposure levels 
across studies or between individuals with and without symptoms of 
adverse health effects. This makes it challenging to draw valid and 
consistent conclusions on the health effects of indoor mold. 

No single or standardized method to measure the magnitude of exposure 
to mold has been developed. Consequently, researchers use a variety of 
methods to assess exposure, each of which has advantages and 
disadvantages. For example, most studies use an indirect method to 
assess exposure--occupant questionnaires about the presence of dampness 
or mold in a building--according to the 2004 Institute of Medicine 
report. Other exposure assessment methods include personal monitoring, 
which involves measuring agent concentrations with monitors carried by 
individuals, and quantifying biologic response markers in bodily 
fluids. Another method of exposure assessment is to collect 
environmental samples of indoor air, dust, or building materials such 
as wallboard and quantitatively analyze the presence of mold (or its 
components or products) in the samples. In addition to the various 
methods that can be used to collect and analyze samples, environmental 
sampling for mold is complicated by the fact that concentrations of 
mold (particularly in the air) can vary over time and across an indoor 
environment. Moreover, many newly developed sampling methods are not 
commercially available or well-validated. 

The second issue contributing to limitations in the understanding of 
the relationship between mold and a number of adverse health effects is 
the variety of potential disease-causing agents--including many species 
of mold and other biological agents, such as bacteria or dust mites-- 
that are likely to be present in damp indoor environments. The number 
of such agents makes it difficult to know which ones are specifically 
responsible for the adverse health effects attributed to these 
environments. For example, of the approximately 1 million species of 
mold, there are about 200 species of mold to which humans are routinely 
exposed, although not all of these are commonly identified in indoor 
environments, and not all types pose the same hazards to human health. 
The mold genus Alternaria, for instance, which has been found in moldy 
building materials, has been linked to severe asthma. Furthermore, 
several different components or products of mold, such as mycotoxins, 
may function as disease-causing agents in indoor environments. The 
release of these mold components or products varies with environmental 
and other factors, and the individual roles they may play in adverse 
health effects are not fully understood. People are also exposed to 
mold in outdoor environments, where the concentrations, while they vary 
considerably, are usually higher than those found indoors. While the 
specific species of mold that grow indoors may differ from those found 
outdoors, the potential for outdoor exposure further complicates 
efforts to determine the relationship between adverse health effects 
and indoor exposure to mold. 

In addition to mold, damp indoor areas can support other biological 
agents that may result in adverse health effects, including bacteria, 
dust mites, cockroaches, and rodents. Dust mites, for example, are 
known to cause the development of asthma. Damp conditions may also lead 
to potentially harmful chemical emissions from building materials and 
furnishings. For example, excessive indoor humidity may increase the 
release of formaldehyde, a probable human carcinogen, from building 
materials such as particle board. Exposure to formaldehyde has been 
linked to some of the same health effects that have been attributed to 
indoor mold, such as wheezing, coughing, and exacerbation of asthma 
symptoms, as well as more severe effects. 

Additional Research Is Needed to Better Address Uncertainties Related 
to the Connection between Health Effects and Exposure to Indoor Mold: 

The 2000 and 2004 Institute of Medicine reports and other recent 
reviews of the scientific literature have identified numerous areas 
where further research is required to advance the understanding of the 
relationships between dampness, indoor mold, and human health.[Footnote 
24] Specifically, the health effects of the components and products of 
mold require further study. The effects of mycotoxins in particular 
remain poorly understood, partly because most of the toxicologic 
studies on mycotoxins have examined the acute (or short-term) effects 
of high levels of exposure to mycotoxins in small populations of 
animals. To address these limitations, the 2004 Institute of Medicine 
report recommended that studies be conducted to help determine, among 
other things, (1) the effects of chronic (or long-term) exposures to 
mycotoxins via inhalation and (2) the dose of mycotoxins required to 
cause adverse health effects in humans. This report also recommended 
research on a particular species of toxin-producing mold, Stachybotrys 
chartarum, and on the relationship between mold and dampness and acute 
idiopathic pulmonary hemorrhage in infants. In its 2000 report, the 
Institute of Medicine also called for additional research related to 
mold particles as allergens and research to evaluate the association of 
dampness and mold with the development of asthma. As can be expected as 
research progresses over time, some of the more recent reviews we 
examined made additional or more specific research recommendations 
related to mycotoxins and other components and products of mold. A 
number of lawsuits alleging serious health effects as a result of 
exposure to indoor mold have involved exposure to mycotoxins, 
underscoring the need for additional research in this area. 

In addition, research to develop, improve, and standardize methods for 
assessing exposure to mold is a high priority for understanding the 
health effects of mold, according to the Institute of Medicine's 2004 
report. Specifically, the report recommends additional research to 
validate and refine existing exposure assessment methods for mold, 
including procedures for collecting and analyzing environmental 
samples. Such research would facilitate comparison of results within 
and across epidemiological studies and help better define the 
relationships between mold and adverse health effects. In addition, 
improved methods for measuring exposure to specific components of mold 
would help efforts to study the roles of these agents in causing 
adverse health effects. 

The 2004 Institute of Medicine report also identified the need for 
additional research on mold mitigation strategies and measures to 
prevent or reduce dampness, the growth of indoor mold, and exposure to 
mold. These strategies could include remediation activities, building 
renovation, and changes in building operation or maintenance practices. 
For example, research is needed to develop standardized, effective 
cleanup methods to mitigate mold growth after flooding and other 
catastrophic water events. In addition, the 2004 Institute of Medicine 
report recommended research to assess how effectively personal 
protective equipment, such as gloves, safety goggles, and respirators, 
reduces exposure to mold during mitigation activities.[Footnote 25] 
Research in these areas is important to help ensure that (1) mold 
mitigation actually improves unhealthy conditions in indoor 
environments and (2) protective equipment used during remediation 
successfully reduces the amount of mold to which workers and building 
occupants are exposed. 

Federal Research Activities on the Health Effects of Indoor Mold 
Address Data Gaps to Varying Degrees; Limited Planning and Coordination 
of the Activities May Reduce Their Ability to Close Data Gaps: 

Federal research activities address gaps in scientific data on the 
health effects of indoor mold identified by the Institute of Medicine 
to varying degrees, with a large number focusing on two areas in 
particular--asthma and measurement methods. The impact of this research 
portfolio may be reduced, however, by limited planning and 
coordination. 

Federal Research Activities on Mold Largely Address Asthma and 
Measurement Methods: 

EPA, HHS, and HUD officials reported that they were conducting or 
sponsoring 65 mold research activities as of October 1, 2007: HHS 
reported 43 ongoing research activities; and EPA and HUD reported 15 
and 7, respectively. The Institute of Medicine's 2000 and 2004 reports 
identified a number of gaps in the research needed to more clearly 
delineate any association between exposure to indoor mold and a number 
of adverse health effects.[Footnote 26] As shown in appendix III, these 
gaps may be grouped into 15 broad categories.[Footnote 27] Agency 
officials reported that most of the individual federal research 
activities address 2 or more of the 15 data gaps. Collectively, the 
agencies indicated that their research activities address all of the 15 
data gaps to varying extents--the number of research activities 
addressing individual gaps ranged from 1 to 32 (see app. III). 
Moreover, EPA, HHS, and HUD officials reported that 75 percent of their 
mold research activities address at least one of five particular data 
gaps--three of which relate to asthma, and two of which relate to 
sampling and measurement methods. These five data gaps are as follows: 

* Identify environmental factors that either lead to the development of 
asthma or precipitate symptoms in subjects who already have asthma 
using good measures of fungal exposure. 

* Determine the association of dampness problems with asthma 
development and symptoms by researching the causative agents (e.g., 
molds, dust mite allergens) and documenting the relationship between 
dampness and allergen exposure. 

* Advance the understanding of specific bioaerosols (small airborne 
particles) in relation to asthma by studying the epidemiology of 
building-related asthma in problem buildings where there are excess 
chest complaints among occupants in comparison to buildings where there 
are not complaints; or provide exposure-response studies of many 
building environments and populations. 

* Improve sampling and exposure assessment methods for mold and its 
components (for example, by conducting research that will lead to 
standardization of protocols for sample collection, transport, and 
analysis or developing or improving methods of personal airborne 
exposure measurement, DNA-based technology, or assays for bioaerosols, 
etc.) 

* Develop standardized metrics and protocols to assess the nature, 
severity, and extent of dampness and effectiveness of specific measures 
for dampness reduction. 

Overall, agency officials reported that 38 of the ongoing projects--or 
nearly 60 percent--address asthma. In this respect, the federal mold 
research portfolio for EPA, HHS, and HUD, ongoing as of October 1, 
2007, appears to be weighted toward addressing research gaps identified 
in the Institute of Medicine's 2000 report, Clearing the Air: Asthma 
and Indoor Air Exposures. The research activities federal officials 
reported as addressing one or more of the asthma-related research gaps 
include studies using animals. For example, one focuses on gestational 
exposure in mice to mold extracts and the effect this exposure has on 
the development of allergy or asthma in adult life; one assesses in 
mice the relative allergenic potency of molds statistically more common 
in water-damaged homes; and another is developing animal models (using 
mice and rats) to evaluate the pulmonary inflammatory response to mold 
products collected from indoor dust samples from buildings where people 
have reported respiratory symptoms and from buildings with no reported 
health complaints.[Footnote 28] Other asthma-related research 
activities are aimed, for example, at better understanding the 
relationship between respiratory symptoms and exposure to water-damaged 
homes in posthurricane New Orleans and at evaluating the respiratory 
health of staff and students attending schools that expose them to 
varying degrees of dampness.[Footnote 29] (Summaries of the 65 research 
activities conducted or sponsored by EPA, HHS, and HUD are provided in 
a supplement to this report--see [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-08-984SP].) 

Many of the projects that address asthma also address sampling and 
measurement methods. Research that provides high-quality, consistent 
methodologies for sampling and measuring mold is essential to progress 
in evaluating the health effects of exposure to mold. For example, the 
Institute of Medicine reported in 2004 that evidence of an association 
between exposure to mold and 15 specific health effects is inadequate 
or insufficient to permit a conclusion regarding the presence of an 
association because of the insufficient quality, consistency, or 
statistical power of the available studies. This report, Damp Indoor 
Spaces and Health, identified the need for standardized metrics and 
protocols. The Institute's earlier 2000 report that focused on asthma 
had previously identified the need to improve exposure assessment 
methods for mold. 

Overall, EPA, HHS, and HUD reported 36 research activities that address 
sampling and exposure assessment methods or standardized metrics and 
protocols. While a number of the research activities address these 
measurement methods as part of investigations focusing on specific 
health effects or other issues related to indoor mold, several focus 
solely or primarily on developing measurement methods. For example, 
HHS's NIOSH is working to develop biomarkers of mold exposure to lead 
to objective, standardized measures of exposure to support reproducible 
and comparable analyses in health studies, including large-scale 
epidemiological studies.[Footnote 30] HHS's National Institute of 
Environmental Health Sciences has three separate studies: (1) 
evaluating available biomarkers of exposure and effect for specific 
molds that may cause systemic toxicity, (2) developing tests for 
allergenic mold species and toxin-producing molds found in water- 
damaged homes that can be used to objectively assess mold exposure in 
buildings, and (3) testing the feasibility of a flexible and low-cost 
measurement method for allergens, including mold.[Footnote 31] Another 
example of ongoing research focusing on mold identification is HHS's 
CDC work to develop and validate DNA-based methods for identification 
and fingerprinting medically important molds because "the absence of a 
robust species/strain identification scheme has hampered the rapid 
identification of novel species and the associated burden of disease." 
[Footnote 32] 

EPA and HUD also reported working on DNA-based assessment methods. 
Specifically, agency officials reported ongoing work using, in part, a 
DNA-based method for analyzing 36 species of mold that EPA developed, 
patented, and has licensed commercial laboratories to perform. Working 
with HUD, EPA used this method to develop a standard sampling and 
analytic process that then led to the development of the Environmental 
Relative Moldiness Index (ERMI) scale for U.S. homes. According to EPA, 
this index provides a simple, objective evaluation of the mold burden 
in a home. EPA reported ongoing epidemiological studies using the ERMI 
scale aimed at determining if the ERMI values can be used to understand 
the risk of asthma or related respiratory symptoms.[Footnote 33] 

While most of the 65 ongoing research activities involving indoor mold 
are addressing asthma and critical data gaps in sampling and 
measurement methods identified in the 2000 and 2004 Institute of 
Medicine reports, some other important data gaps identified in the 2004 
report are being studied to a lesser degree than the gaps identified in 
the 2000 report. Notably, of the 15 data gaps identified in these 
reports, agency officials reported that only 9 research activities 
address to some extent 3 of the gaps identified in the 2004 report that 
follow.[Footnote 34] 

* Research the relationship between mold and dampness and acute 
pulmonary hemorrhage or hemosiderosis in infants. 

* Determine the effects of human exposure to Stachybotrys chartarum in 
indoor environments. 

* Determine, for mycotoxins, the dose required to cause adverse health 
effects in humans via inhalation and skin (dermal) exposure; techniques 
for detecting and quantifying mycotoxins in tissues; or the effects of 
long-term (chronic) exposures to mycotoxins via inhalation. 

Officials from EPA, HHS, and HUD reported only one research activity 
examining the relationship between mold and dampness and acute 
pulmonary hemorrhage or hemosiderosis in infants--a rare but serious 
health condition whose relation to exposure to indoor mold remains 
unsettled, as discussed earlier. This research is aimed at developing 
quantitative biomarkers for the toxin-producing mold species 
Stachybotrys chartarum--a mold that has been implicated in cases of 
acute pulmonary hemorrhage in infants--to facilitate epidemiological 
and other studies examining mold-related health effects.[Footnote 35] 
Sponsored by HHS's National Institute of Environmental Health Sciences, 
this research will support but does not directly address the 2004 
Institute of Medicine's recommendation for research on the relationship 
between mold and dampness and acute pulmonary hemorrhage in infants. 
Specifically, the Institute of Medicine report concluded that the role 
of Stachybotrys chartarum in cases of acute idiopathic pulmonary 
hemorrhage in infants that had been studied remained controversial and 
encouraged HHS's CDC to pursue surveillance and additional research on 
the issue to resolve outstanding questions because this condition has 
serious health consequences. The Institute of Medicine further stated 
that epidemiologic and case studies should take a broad-based approach 
to gather and evaluate information on exposures and other factors that 
would help identify the causes of acute idiopathic pulmonary hemorrhage 
in infants, including dampness and agents associated with damp indoor 
environments and environmental tobacco smoke, among others. According 
to CDC officials, the agency is not currently conducting either 
epidemiological or case studies on acute pulmonary hemorrhage in 
infants.[Footnote 36] 

Five research activities that federal agencies reported were addressing 
the toxin-producing mold species Stachybotrys chartarum were: part of 
two studies on asthma; a study to develop tests for allergenic mold 
species and toxin-producing molds found in water-damaged homes and a 
study to develop quantitative biomarkers to assist epidemiological and 
other research examining mold-related health effects (both discussed 
above as also addressing other data gaps); and a follow-up study 
analyzing archived serum and house dust samples for Stachybotrys 
chartarum and related mycotoxins in the context of the clinical symptom 
profiles previously gathered on the study participants.[Footnote 37] 

The research gap on the health effects of exposure to mycotoxins-- 
toxins that can be produced by certain types of mold and may 
potentially cause adverse health effects--is being addressed to some 
extent by four research activities, according to agency officials. One 
of the activities will assess the potential for molds found in damp or 
water-damaged buildings to cause nervous system or systemic toxicity. A 
second activity aims to develop improved sensors for detecting 
mycotoxins in contaminated food and feed to support proper remedial 
actions.[Footnote 38] A third activity is using an animal model to 
understand the disease pathogenesis of hypersensitivity pneumonitis--a 
relatively rare but potentially serious allergic reaction in 
susceptible persons that can, in its chronic form, result in permanent 
lung damage.[Footnote 39] Lastly, a fourth activity is a study of the 
mechanistic indicators of childhood asthma that uses air, biologic and 
clinical measures as well as molecular biology, chemistry, and gene 
technologies to identify factors that affect individual susceptibility 
to asthmatic responses.[Footnote 40] EPA reported that while this study 
is not directed at mold per se, the secondary data being collected 
could address some other research activities that the Institute of 
Medicine reports identified as relating to sampling and exposure 
assessment and mycotoxins, among others. 

Finally, EPA and HHS reported they had completed 42 mold-related 
research activities between January 1, 2005, and September 30, 2007. 
[Footnote 41] In general, these activities address topics such as 
asthma and sampling and measurement methods, reflected in the portfolio 
of agencies' ongoing research activities. Information on the recently 
completed research activities is provided in a supplement to this 
report (see [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-
984SP]). 

Limited Planning and Coordination of Research Activities May Affect 
Their Ability to Close Data Gaps on the Health Effects of Exposure to 
Indoor Mold: 

While the information on research activities relating to the health 
effects of exposure to indoor mold provides some insight into the 
extent to which federal agencies are addressing scientific data gaps 
identified by the Institute of Medicine in 2000 and 2004, the extent to 
which these ongoing research activities will effectively advance 
scientific knowledge in these areas is not clear. Specifically, the 
research is not guided by an overarching strategic plan or entity that 
would help agencies work together to identify their research priorities 
on the health effects of mold. Instead, agencies generally determine 
independently which research activities they will support using a 
variety of criteria. This lack of clearly articulated, common research 
goals is exacerbated by the limited intra-and inter-agency planning and 
coordination of research activities among federal agencies. Specific 
information that highlights planning and coordination limitations 
follows. 

Selection criteria for research the agencies sponsor are not always 
linked to identified data gaps. Several EPA, HHS, and HUD officials 
indicated that selection of priorities for research can be based on 
various considerations, including agency expertise in a particular area 
or input from external stakeholders. For example, both HHS and HUD 
officials noted that ideas for research priorities can come from former 
grantees. 

A key planning document that several EPA officials reported consulting 
is now outdated. Specifically, the agency's 2005 Program Needs for 
Indoor Environments Research document,[Footnote 42] which outlines the 
agency's research needs for the indoor environment and mold, among 
other topics, reflects input from the Institute of Medicine's 2000 
report but not the more recent 2004 report, which also identified a 
number of important data gaps. EPA officials told us that the agency's 
research related to asthma and mold's health effects has been a 
priority, in part, because this topic was identified in the 2000 
Institute of Medicine report, Clearing the Air: Asthma and Indoor Air 
Exposures. 

Some officials stated that the 2004 Institute of Medicine report on 
indoor mold has not influenced their research priorities on this topic. 
While officials at HHS's NIOSH reported that the Institute of 
Medicine's 2004 report had a "major impact" on what indoor 
environmental quality research their institute conducts, HHS officials 
from two of the National Institutes of Health noted that this report 
did not affect their institutes' internal priorities in this area. One 
official stated that while the publication of this report did not 
change any of their internal priorities, it may have encouraged 
external interest in mold research. 

The process that NIH uses to fund outside research may also limit the 
extent to which identified data gaps are addressed. Specifically, 
federal officials from three different NIH institutes[Footnote 43] that 
sponsored 29 of the 65 ongoing research activities as of October 1, 
2007, reported that 19 were unsolicited--that is, they were initiated 
by investigators outside the institutes.[Footnote 44] Most NIH-funded 
research is initiated by such investigators. These investigators 
submitted research proposals that were of interest to them and thus 
were not necessarily responsive to specific agency priorities. Along 
these lines, officials at one institute said they generally fund indoor 
mold research only because of outside investigators' interest. 
Unsolicited proposals are ranked for funding through a rigorous peer- 
review process for, among other things, scientific merit and the 
significance of the research.[Footnote 45] While the specific topic of 
the research is considered in light of its potential impact on public 
health during peer review, NIH officials said that specific gaps 
identified in the Institute of Medicine's report may well have a lower 
significance relative to the three institutes' many other scientific 
priorities. That is, while the three institutes do solicit research on 
areas considered to be priorities, studies on the health effects of 
exposure to indoor mold have generally not been in this category. 

Less than half of the agencies' 65 ongoing research activities are 
being coordinated, either within or outside their agencies. 
Specifically, in responding to our survey of ongoing research 
activities involving the health effects of indoor mold, EPA, HHS, and 
HUD reported that 28 of their 65 research activities are being 
coordinated (see fig. 1). In other work, we identified practices that 
agencies should use when coordinating their activities, including (1) 
defining and articulating a common outcome, (2) identifying and 
addressing needs by leveraging each others' resources, and (3) agreeing 
on agency roles and responsibilities.[Footnote 46] Especially when 
agencies are conducting research activities addressing the same data 
gap, coordination is important to ensure inappropriate duplication of 
efforts does not occur and to best leverage limited federal resources. 
Even in these cases, however, a significant number of activities are 
not being coordinated. For example, of the 32 EPA, HHS, and HUD 
research activities seeking to identify which environmental factors, 
such as mold, contribute to the development or exacerbation of asthma, 
federal officials reported that 18 activities are not being 
coordinated. Similarly, agencies are not coordinating on 22 of 36 
research activities related to sampling and measurement methods. 

Figure 1: Coordination of Ongoing Federal Mold Research Activities 
within the Agency or among Other Federal Agencies, as of October 1, 
2007: 

[See PDF for image] 

This figure is a stacked vertical bar graph depicting the following 
data: 

Federal agency: EPA; 
Number of research activities coordinated to some extent: 11; 
Number of research activities not coordinated: 4. 

Federal agency: HHS; 
Number of research activities coordinated to some extent: 12; 
Number of research activities not coordinated: 31. 

Federal agency: HUD; 
Number of research activities coordinated to some extent: 2; 
Number of research activities not coordinated: 5. 

Source: GAO analysis of EPA, HHS, and HUD survey data. 

Note: HHS officials reported coordinating three research activities 
with external organizations only. These activities are listed as not 
coordinated in this figure. 

[End of figure] 

Further, the coordination activities reported by federal officials vary 
widely. In some cases, the federal officials we surveyed reported 
internal and external coordination on a specific research activity. For 
example, an EPA official noted that his unit conducted one of its 
research activities in conjunction with another unit within the agency, 
provided updates regarding the activity to another unit, and 
collaborated with another federal agency to write papers based on this 
research. Coordination was more limited in other cases. Specifically, 
in many cases, research activities were only coordinated within the 
agency--and often, with only one other unit within the agency. For 
example, one NIOSH official reported that, for one activity, his unit 
coordinated with another unit within NIOSH by supplying certain 
instruments. 

Importantly, while agencies sometimes coordinate on individual research 
activities, we did not identify any sustained efforts to coordinate 
agencies' indoor mold research priorities. In the few instances in 
which officials reported that they coordinated with others on research 
priorities, it appeared that these partnerships did not specifically 
address mold-related priorities. For example, while EPA officials told 
us that they recently met with officials from HHS's CDC to discuss 
mutual research opportunities related to the indoor environment, these 
meetings did not address mold research priorities. 

Federal agencies are not using the existing Federal Interagency 
Committee on Indoor Air Quality as a forum to coordinate their research 
activities on indoor mold. As discussed earlier, EPA serves as the 
executive secretary of the Federal Interagency Committee on Indoor Air 
Quality. We found that the committee addresses federal research 
activities on indoor air quality on an informal basis. For example, our 
analysis of the minutes of the 11 committee meetings from February 2005 
to February 2008 shows that agency priorities related to indoor air 
quality research, which could include research on mold, were discussed 
only a few times. In one case, EPA officials described how their agency 
had developed its research needs on indoor environments, which it 
published in a document later in 2005 titled Program Needs for Indoor 
Environments Research. In this case, EPA was not seeking input from 
other agencies on research needs and priorities but rather was 
informing other agencies of decisions EPA had made. Moreover, EPA, HHS, 
and HUD officials who participate in committee meetings told us that 
they had not discussed or sought input on their agency's mold-related 
research priorities during committee meetings. Further, according to 
committee meeting minutes, the information agency officials share at 
committee meetings regarding their mold research is limited to 
describing selected ongoing activities and issues related to their 
funding. When mold-related research was discussed during the 3-year 
period we reviewed, it was usually to provide an update on the status 
of some individual research projects. In several instances, officials 
also used the meetings to advertise the availability of funding for 
research on indoor air quality issues, which could include research on 
mold, or to announce the funding of mold-related research. 

Currently, the committee holds 2-1/2 hour meetings in person and by 
conference call three times a year that interested parties outside the 
federal government can access. The agendas for the meetings are based 
on input to EPA from member and nonmember agencies who propose topics 
they would like to discuss. According to officials from one of the 
participating agencies, the Consumer Product Safety Commission, the 
Federal Interagency Committee on Indoor Air Quality had more 
substantive discussions in the past on research projects, funding, and 
which research priorities needed to be addressed than it does now. 

The role of the Federal Interagency Committee on Indoor Air Quality has 
changed over time. Established in response to congressional committee 
direction in 1983, the committee, according to an EPA report,[Footnote 
47] was to (1) coordinate federal indoor air quality research; (2) 
provide for liaison and the exchange of information on indoor air 
quality research among federal agencies, and with state and local 
governments, the private sector, the general public, and the research 
community; and (3) develop federal responses to indoor air quality 
issues. According to a 1988 report on the structure and operation of 
the committee, the committee comprised 16 member agencies and was co- 
chaired by EPA, the Consumer Product Safety Commission, DOE, and HHS. 
This report noted that considerable agreement existed among member 
agencies that the primary role of the committee was to coordinate 
federal indoor air activities. Further, coordination activities were 
specified to include joint project planning and implementation; 
contributions to and review of member agency indoor plans, reports, and 
publications; communication on technical and nontechnical issues and 
activities; and advising on, and fostering multiagency participation 
in, indoor air program and research activities of individual agencies. 
The committee met quarterly and had standing work groups covering 
indoor air quality research areas to address a diverse range of indoor 
air quality research issues, such as radon, formaldehyde, and allergens 
and pathogens (which include molds). The work groups, which are no 
longer active, were to coordinate research activities in these areas 
and identify future indoor air quality research. EPA used the committee 
to coordinate air quality research and assist in implementing the 
indoor air quality research and development program established by 
Congress in 1986. For example, in 1989 and 1999, EPA used the committee 
to help it develop two reports that identified the individual research 
activities on indoor air quality that federal agencies were conducting. 
EPA has taken the lead in directing committee activities in the past, 
such as chairing meetings, and this role continues today. 

Federal Guidance to the General Public Identifies Various Health 
Effects Associated with Exposure to Indoor Mold, as well as Strategies 
to Limit It, Some of Which Are Inconsistent: 

The Consumer Product Safety Commission, EPA, FEMA, HHS, and HUD 
guidance documents we reviewed identify health effects associated with 
indoor mold in a residential setting but sometimes omit less common but 
serious health effects. Most of the guidance documents recommend 
similar strategies for minimizing mold growth. While guidance documents 
that discuss mold mitigation offer consistent advice about detecting 
mold, some provide conflicting information about cleaning agents and 
the appropriate level of protective equipment individuals need when 
mitigating mold in their homes. 

Federal Guidance Cites Various Adverse Health Effects of Exposure to 
Indoor Mold but in Some Cases Omits Less Common but Serious Effects: 

A majority of the 32 documents we reviewed that provide guidance to the 
general public on the health effects of indoor mold in their homes-- 
issued by the Consumer Product Safety Commission, EPA, FEMA, HHS, 
[Footnote 48] and HUD--identify asthma and upper respiratory tract 
symptoms as potential health effects. In addition, many of these 
federal guidance documents cite unspecified allergic symptoms and skin 
symptoms, such as dermatitis, rashes, and hives. The six adverse health 
effects the Institute of Medicine found to be associated with indoor 
mold in 2004 are included in the 32 guidance documents to varying 
extents. However, all six adverse health effects are included in only 
two guidance documents, although a majority of the guidance was issued 
after the publication of the 2004 Institute of Medicine report. 
[Footnote 49] 

Further, only a few of the 32 guidance documents discuss adverse health 
effects associated with mold that are less common but serious. Such 
health effects include opportunistic infections or fungal colonization 
in immune-compromised individuals and hypersensitivity pneumonitis, a 
relatively rare allergic reaction in susceptible persons characterized 
by fever, chills, dry cough, and a flulike feeling that can, in its 
chronic form, result in permanent lung damage. Because these less 
common but potentially serious adverse health effects are infrequently 
cited in the guidance documents, some individuals consulting these 
guidance documents may not take appropriate precautions when they are 
exposed to indoor mold. Table 1 identifies the potential adverse health 
effects cited in 6 or more of the 32 guidance documents we reviewed. 
(App. V provides a list of the guidance documents we reviewed and 
information on how to access them.) 

Table 1: Potential Adverse Health Effects of Exposure to Indoor Mold 
Cited in Six or More Guidance Documents, by Federal Agency: 

Potential adverse health effects of exposure to indoor mold: Asthma, 
asthma triggers, or asthma symptoms (such as episodes or attacks); 
Number of documents reviewed, by agency: CPSC[A] (2): Number of 
documents citing the health effects: 2; 
Number of documents reviewed, by agency: EPA (12): Number of documents 
citing the health effects: 11; 
Number of documents reviewed, by agency: FEMA (8): Number of documents 
citing the health effects: 6; 
Number of documents reviewed, by agency: HHS (6): Number of documents 
citing the health effects: 4; 
Number of documents reviewed, by agency: HUD (6): Number of documents 
citing the health effects: 6; 
Total number of documents citing the health effects: 27[B]. 

Potential adverse health effects of exposure to indoor mold: Upper 
respiratory tract symptoms[C]; 
Number of documents reviewed, by agency: CPSC[A] (2): Number of 
documents citing the health effects: 2; 
Number of documents reviewed, by agency: EPA (12): Number of documents 
citing the health effects: 4; 
Number of documents reviewed, by agency: FEMA (8): Number of documents 
citing the health effects: 6; 
Number of documents reviewed, by agency: HHS (6): Number of documents 
citing the health effects: 6; 
Number of documents reviewed, by agency: HUD (6): Number of documents 
citing the health effects: 5; 
Total number of documents citing the health effects: 21[B]. 

Potential adverse health effects of exposure to indoor mold: Eye 
symptoms[D]; 
Number of documents reviewed, by agency: CPSC[A] (2): Number of 
documents citing the health effects: 2; 
Number of documents reviewed, by agency: EPA (12): Number of documents 
citing the health effects: 3; 
Number of documents reviewed, by agency: FEMA (8): Number of documents 
citing the health effects: 6; 
Number of documents reviewed, by agency: HHS (6): Number of documents 
citing the health effects: 6; 
Number of documents reviewed, by agency: HUD (6): Number of documents 
citing the health effects: 5; 
Total number of documents citing the health effects: 20[B]. 

Potential adverse health effects of exposure to indoor mold: Skin 
symptoms[E]; 
Number of documents reviewed, by agency: CPSC[A] (2): Number of 
documents citing the health effects: 1; 
Number of documents reviewed, by agency: EPA (12): Number of documents 
citing the health effects: 2; 
Number of documents reviewed, by agency: FEMA (8): Number of documents 
citing the health effects: 5; 
Number of documents reviewed, by agency: HHS (6): Number of documents 
citing the health effects: 5; 
Number of documents reviewed, by agency: HUD (6): Number of documents 
citing the health effects: 4; 
Total number of documents citing the health effects: 16[B]. 

Potential adverse health effects of exposure to indoor mold: Allergies 
or allergic reactions (symptoms not otherwise specified); 
Number of documents reviewed, by agency: CPSC[A] (2): Number of 
documents citing the health effects: 0; 
Number of documents reviewed, by agency: EPA (12): Number of documents 
citing the health effects: 7; 
Number of documents reviewed, by agency: FEMA (8): Number of documents 
citing the health effects: 4; 
Number of documents reviewed, by agency: HHS (6): Number of documents 
citing the health effects: 3; 
Number of documents reviewed, by agency: HUD (6): Number of documents 
citing the health effects: 1; 
Total number of documents citing the health effects: 15. 

Potential adverse health effects of exposure to indoor mold: Wheeze; 
Number of documents reviewed, by agency: CPSC[A] (2): Number of 
documents citing the health effects: 1; 
Number of documents reviewed, by agency: EPA (12): Number of documents 
citing the health effects: 1; 
Number of documents reviewed, by agency: FEMA (8): Number of documents 
citing the health effects: 5; 
Number of documents reviewed, by agency: HHS (6): Number of documents 
citing the health effects: 5; 
Number of documents reviewed, by agency: HUD (6): Number of documents 
citing the health effects: 2; 
Total number of documents citing the health effects: 13[B]. 

Potential adverse health effects of exposure to indoor mold: Cough; 
Number of documents reviewed, by agency: CPSC[A] (2): Number of 
documents citing the health effects: 2; 
Number of documents reviewed, by agency: EPA (12): Number of documents 
citing the health effects: 2; 
Number of documents reviewed, by agency: FEMA (8): Number of documents 
citing the health effects: 4; 
Number of documents reviewed, by agency: HHS (6): Number of documents 
citing the health effects: 2; 
Number of documents reviewed, by agency: HUD (6): Number of documents 
citing the health effects: 2; 
Total number of documents citing the health effects: 10[B]. 

Potential adverse health effects of exposure to indoor mold: Difficulty 
breathing or trouble breathing; 
Number of documents reviewed, by agency: CPSC[A] (2): Number of 
documents citing the health effects: 1; 
Number of documents reviewed, by agency: EPA (12): Number of documents 
citing the health effects: 1; 
Number of documents reviewed, by agency: FEMA (8): Number of documents 
citing the health effects: 3; 
Number of documents reviewed, by agency: HHS (6): Number of documents 
citing the health effects: 2; 
Number of documents reviewed, by agency: HUD (6): Number of documents 
citing the health effects: 4; 
Total number of documents citing the health effects: 10[B]. 

Potential adverse health effects of exposure to indoor mold: Infections 
(including those affecting people who have chronic lung disease); 
Number of documents reviewed, by agency: CPSC[A] (2): Number of 
documents citing the health effects: 0; 
Number of documents reviewed, by agency: EPA (12): Number of documents 
citing the health effects: 1; 
Number of documents reviewed, by agency: FEMA (8): Number of documents 
citing the health effects: 3; 
Number of documents reviewed, by agency: HHS (6): Number of documents 
citing the health effects: 6; 
Number of documents reviewed, by agency: HUD (6): Number of documents 
citing the health effects: 0; 
Total number of documents citing the health effects: 10. 

Potential adverse health effects of exposure to indoor mold: Adverse 
effects to the nervous system[F]; 
Number of documents reviewed, by agency: CPSC[A] (2): Number of 
documents citing the health effects: 1; 
Number of documents reviewed, by agency: EPA (12): Number of documents 
citing the health effects: 1; 
Number of documents reviewed, by agency: FEMA (8): Number of documents 
citing the health effects: 3; 
Number of documents reviewed, by agency: HHS (6): Number of documents 
citing the health effects: 0; 
Number of documents reviewed, by agency: HUD (6): Number of documents 
citing the health effects: 4; 
Total number of documents citing the health effects: 8[B]. 

Potential adverse health effects of exposure to indoor mold: Shortness 
of breath; 
Number of documents reviewed, by agency: CPSC[A] (2): Number of 
documents citing the health effects: 1; 
Number of documents reviewed, by agency: EPA (12): Number of documents 
citing the health effects: 1; 
Number of documents reviewed, by agency: FEMA (8): Number of documents 
citing the health effects: 3; 
Number of documents reviewed, by agency: HHS (6): Number of documents 
citing the health effects: 3; 
Number of documents reviewed, by agency: HUD (6): Number of documents 
citing the health effects: 0; 
Total number of documents citing the health effects: 7[B]. 

Potential adverse health effects of exposure to indoor mold: Fungal 
colonization or opportunistic infections in immune-compromised 
individuals; 
Number of documents reviewed, by agency: CPSC[A] (2): Number of 
documents citing the health effects: 0; 
Number of documents reviewed, by agency: EPA (12): Number of documents 
citing the health effects: 1; 
Number of documents reviewed, by agency: FEMA (8): Number of documents 
citing the health effects: 0; 
Number of documents reviewed, by agency: HHS (6): Number of documents 
citing the health effects: 5; 
Number of documents reviewed, by agency: HUD (6): Number of documents 
citing the health effects: 1; 
Total number of documents citing the health effects: 6[B]. 

Potential adverse health effects of exposure to indoor mold: 
Hypersensitivity pneumonitis; 
Number of documents reviewed, by agency: CPSC[A] (2): Number of 
documents citing the health effects: 1; 
Number of documents reviewed, by agency: EPA (12): Number of documents 
citing the health effects: 4; 
Number of documents reviewed, by agency: FEMA (8): Number of documents 
citing the health effects: 0; 
Number of documents reviewed, by agency: HHS (6): Number of documents 
citing the health effects: 2; 
Number of documents reviewed, by agency: HUD (6): Number of documents 
citing the health effects: 1; 
Total number of documents citing the health effects: 6[B]. 

Source: GAO analysis of selected federal guidance. 

Notes: Other health effects stemming from exposure to indoor mold, 
including fatigue, fever, dizziness, and gastrointestinal tract 
problems, are cited in five or fewer guidance documents. Health effects 
of exposure to indoor mold that are cited in only one document include 
aches and pains, lung irritation, and death. 

[A] Consumer Product Safety Commission. 

[B] The sum of the guidance documents does not equal the total number 
of guidance documents citing the health effect because two documents, 
"Healthy Indoor Air for America's Homes" and "The Inside Story: A Guide 
to Indoor Air Quality," were issued by multiple federal agencies. 

[C] Symptoms can include nasal congestion, sneezing, runny/itchy/ 
stuffed up nose, throat irritation, and sore throat. 

[D] Symptoms can include redness, watery eyes, irritation, and burning. 

[E] Symptoms can include dermatitis, itching, rashes, hives, and 
irritation. 

[F] Symptoms can include headaches, memory loss, and mood changes. 

[End of table] 

Moreover, most of the federal guidance documents we reviewed describe 
populations that may be particularly sensitive to indoor mold. However, 
few of the documents identify all of the populations that should take 
extra precautions to limit exposure to indoor mold. According to an HHS 
guidance document, these populations include the immune-compromised as 
well as those with asthma, chronic lung diseases, and allergies to 
mold. Immune-compromised individuals include organ transplant 
recipients, HIV patients, individuals with leukemia or lymphoma, and 
those undergoing cancer chemotherapy or other immunosuppressant drug 
therapies. HHS also recommends "due caution" for children, pregnant 
women, and the elderly who are exposed to indoor mold. Although some of 
the guidance documents identify several of these populations, some list 
only one or two. As a result, individuals consulting these guidance 
documents, especially those who are particularly vulnerable to mold 
exposure, may not be fully apprised of the risks associated with such 
exposure. 

We recognize that the guidance documents we reviewed may address health 
effects and particularly sensitive populations in varying levels of 
detail because of differences in purpose and intended audience. For 
example, several EPA guidance documents targeted toward particular 
populations, such as teens, the elderly, and people with low literacy 
levels, are limited in their scope and level of detail. In contrast, 
HHS's document, Mold Prevention Strategies and Possible Health Effects 
in the Aftermath of Hurricanes and Major Floods,[Footnote 50] which is 
targeted to the general public as well as to public health officials, 
includes a detailed discussion of numerous potential health effects 
that may result from exposure to indoor mold. Although not all guidance 
documents need to provide a comprehensive list of all of the potential 
health effects of exposure to indoor mold, the information provided 
should be sufficient to alert the public about potential adverse health 
effects of exposure to indoor mold, highlight specific populations that 
are particularly vulnerable to such exposure, and not conflict among 
documents. 

Guidance on Minimizing Indoor Mold Growth in Homes Is Generally 
Consistent: 

Most of the 32 guidance documents issued by the Consumer Product Safety 
Commission, EPA, FEMA, HHS, and HUD that we reviewed describe how to 
minimize indoor mold growth in the home. These documents generally 
advise that residents reduce indoor moisture or humidity levels, and 
their recommendations for doing so are generally consistent. A majority 
of these guidance documents recommend that residents keep areas dry and 
address moisture sources, such as leaks or spills. Some of the guidance 
documents also recommend managing specific sources of moisture or 
humidity by, for example, preventing water from entering the house, 
ventilating and cleaning kitchens and baths to reduce moisture buildup, 
and repairing and insulating pipes. In addition, a majority of the 
documents recommend promptly drying wet items. Nearly half of the 
documents that provide more specific recommendations note that porous 
items, such as carpets, must be dried within 48 hours to avoid the 
growth of mold and say that if more than 48 hours have elapsed, these 
items should be discarded. 

A number of the guidance documents that address strategies to minimize 
indoor mold growth also advise residents to maintain indoor relative 
humidity within specific ranges because high relative humidity can lead 
to water condensation on indoor surfaces, such as walls and windows, 
which can support mold growth. However, we note that the humidity 
ranges specified by the guidance documents vary. For example, while all 
the guidance documents that address relative humidity recommend 
maintaining it at 60 percent or below, one FEMA document recommends 
maintaining the relative humidity below 40 percent, and three guidance 
documents issued by HHS recommend a relative humidity range between 40 
percent and 60 percent.[Footnote 51] Such differences in guidance to 
the public could cause some confusion about this aspect of minimizing 
indoor mold growth. 

Guidance on Mitigating Exposure to Indoor Mold Is Sometimes 
Inconsistent about Cleanup Agents and Protective Clothing and 
Equipment: 

A majority of the guidance documents we reviewed provide information to 
the public about mitigating exposure to indoor mold. Many of the 
documents agree that if mold can be either seen or smelled, it should 
be removed. Recommendations on detecting mold are broadly consistent 
with information in a 2001 EPA report on mold mitigation in schools and 
commercial buildings, which is cited by a number of the guidance 
documents as a resource for mitigation of residential mold growth. 
[Footnote 52],[Footnote 53] Further, the eight guidance documents that 
discuss sampling or testing to measure the quantity or type of mold in 
the indoor environment advise against it in most circumstances because 
the results of such testing may not be useful. For example, one of 
these documents explains that no standardized method exists either to 
measure the magnitude of exposure to mold or to relate a particular 
level of exposure to adverse health effects. Another guidance document 
notes that it is generally not necessary to determine the species of 
mold present.[Footnote 54] Finally, many of the guidance documents that 
discuss mitigation note that if the mold is extensive (for example, if 
it covers more than 25 square feet) or if it is found in the heating or 
air conditioning systems, residents should consult further guidance, 
such as EPA's Mold Remediation in Schools and Commercial Buildings, or 
hire a professional contractor. 

While a majority of the guidance documents we reviewed discuss how to 
remove mold once a problem has been identified, there is some 
inconsistency about which cleaning agents to use. For example, two 
guidance documents recommend using detergent to clean mold. On the 
other hand, HHS's Mold Prevention Strategies and Possible Health 
Effects in the Aftermath of Hurricanes and Major Floods advises that 
bleach may be warranted if the mold growth is due to floodwater, which 
can be contaminated. Another guidance document, issued by EPA, also 
advises that bleach be used when individuals who are particularly 
susceptible to adverse health effects from mold, such as those who are 
immune-compromised, are exposed to indoor mold. In contrast, six of the 
guidance documents we reviewed, including several of the HHS documents, 
recommend the use of bleach irrespective of certain populations or 
whether the mold growth is due to flooding. According to EPA's 2001 
report on mold mitigation, mold growing on hard (nonporous) surfaces 
should be scrubbed with water and detergent and then vacuumed.[Footnote 
55] This report recommends using bleach only in limited circumstances-
-such as when immune-compromised individuals are present--because 
bleach, a biocide, is toxic to humans. These differences among guidance 
documents could lead to confusion among the general public about the 
safest and most effective way to remove mold. For example, if bleach is 
not necessary in most instances, using it unnecessarily could lead to 
avoidable problems, since bleach itself is a hazardous substance that 
can generate toxic fumes if it is mixed with ammonia-based cleaners. 

In addition, many of the guidance documents we reviewed discuss using 
personal protective equipment while removing mold but, in some cases, 
recommend different levels of protection for the general public as well 
as for certain populations that may be more sensitive to mold exposure. 
For example, as figure 2 shows, the guidance documents provide 
inconsistent recommendations for the general public about wearing 
respiratory protection, eye protection, and skin (dermal) protection 
(such as long-sleeved shirts and long pants) for cleanups of limited 
mold contamination.[Footnote 56] 

Figure 2: Varying Levels of Personal Protection for Cleaning Limited 
Mold Contamination, as Recommended by Selected Federal Guidance: 

[See PDF for image] 

This figure contains illustrations of varying levels of personal 
protection for cleaning limited mold contamination, as recommended by 
selected federal guidance. The illustrations provide the following 
information: 

Recommended by three guidance documents: 
* gloves: 
* respiratory protection. 

Recommended by six guidance documents: 
* gloves; 
* respiratory protection; 
* eye protection. 

Recommended by six guidance documents: 
* gloves; 
* respiratory protection; 
* eye protection: 
* dermal protection. 

Source: GAO analysis of selected federal guidance. 

Note: The guidance variously defines "limited" mold contamination as 
areas ranging from up to 10 square feet to up to 100 square feet. 

[End of figure] 

In addition, although 26 guidance documents caution that certain 
populations may be more sensitive to mold, only 2 of them, issued by 
HHS in 2005 and 2006, provide specific recommendations about the 
varying levels of personal protection that such populations should use 
under various circumstances. The HHS documents state that, when 
inspecting or assessing damage, individuals with certain lung diseases 
should wear respirators, while healthy individuals need no special 
protection for these tasks. However, these documents warn that 
individuals with "immunosuppression," such as those undergoing cancer 
treatment or those who have leukemia or lymphoma, should wear a 
respirator, gloves, and safety goggles when inspecting or assessing 
damage. Further, those with "profound immunosuppression"--such as those 
with HIV infection--should avoid all exposure to mold. 

Guidance documents also provide inconsistent information about the 
types of respiratory protection to use when cleaning up mold. Of the 15 
guidance documents that recommend the use of respiratory protection 
during cleanup, 6 list items such as dust masks, which do not protect 
against mold because it can pass through them. Nine of the documents 
suggest "N-95 respirators," which filter 95 percent of airborne 
particles and can protect against inhaling mold. Moreover, only 3 of 
the guidance documents recommending the use of N-95 respirators discuss 
the need for proper fit--which could impact their effectiveness, 
according to the HHS's NIOSH, the federal agency that approves these 
respirators. Furthermore, only 1 guidance document, issued by HHS, 
warns that respirator use may not be appropriate if an individual has a 
pre-existing medical condition that makes it difficult to breathe while 
wearing a respirator. 

A number of agency officials said they revisit the content of their 
guidance documents following significant new scientific discoveries or 
in response to events such as major flooding or hurricanes. We note 
that in the past few years, important updated information on the health 
effects of exposure to indoor mold and ways to protect against 
unnecessary exposure has been provided in three documents: the 
Institute of Medicine's 2004 report and two HHS guidance documents on 
mold issued in 2005 and 2006 in the aftermath of the hurricanes and 
major floods on the Gulf Coast.[Footnote 57] Nevertheless, some of the 
guidance documents we reviewed do not yet reflect important updated 
information that these publications provide. Overall, despite the 
useful information provided in the federal guidance we reviewed, some 
omissions and inconsistencies could cause some individuals to be 
exposed to indoor mold unnecessarily. 

Conclusions: 

While the current research activities on indoor mold conducted or 
sponsored by EPA, HHS, and HUD address identified health-related 
research gaps to varying degrees, these activities are largely 
uncoordinated within and across agencies, and many are generated by 
independent researchers rather than by agency solicitations for 
specific research. This limited coordination contributes to the lack of 
standardized, quantitative methods for measuring exposure to mold that 
has impeded the advancement of knowledge about health effects and may 
result in unnecessary duplication of research efforts. Without more 
systematic coordination of planned and ongoing research activities, 
future research may not be prioritized to best fill data gaps or be of 
sufficient quality and consistency to more definitively support 
conclusions about any associations to indoor mold and adverse health 
effects. Specifically, the Institute of Medicine was unable to 
associate a number of adverse health effects with exposure to mold 
because the available studies were of "insufficient quality, 
consistency, or statistical power to permit a conclusion regarding the 
presence of an association." 

An existing interagency committee--the Federal Interagency Committee on 
Indoor Air Quality--could provide an effective vehicle for enhancing 
the coordination of research activities. As the executive secretary and 
co-chair, EPA guides the activities of this committee, which was 
established in response to congressional direction to, among other 
things, coordinate federal indoor air quality research and foster 
information sharing among, for example, federal agencies and the 
public. While the committee provides a forum for informal information 
sharing, it has not been used in recent years to support systematic 
coordination of federal research priorities or agendas for indoor air 
research. Since the Federal Interagency Committee on Indoor Air Quality 
was established in the 1980s, significant advances in communications 
technologies, such as the Internet, have transformed the exchange of 
information--for example, through Web pages and hyperlinks to documents 
and Web sites. These communications advances can facilitate the 
coordination among federal agencies, state and local governments, the 
private sector, the research community, and the general public that the 
Federal Interagency Committee on Indoor Air Quality was established to 
accomplish. 

Overall, the federal guidance documents we reviewed that provide 
information to the general public about the health effects of exposure 
to indoor mold, ways to minimize mold growth, and safe and effective 
methods for cleaning up provide generally useful information. However, 
some documents do not sufficiently advise the general public about some 
potentially serious health effects, and others provide inconsistent 
information about cleaning agents and appropriate protective gear. 
Regarding protective gear, some documents do not provide information 
about how populations that are particularly vulnerable to adverse 
health effects should protect themselves. In fact, populations with 
certain immunosuppression conditions should avoid exposure to mold but 
many guidance documents do not state this. As a result, the public may 
not be sufficiently aware of the health risks they or their family 
members may face, and they may also be confused about how to approach 
cleaning up mold in their homes. 

Recommendations for Executive Action: 

We recommend that the Administrator, EPA, use the Federal Interagency 
Committee on Indoor Air Quality to accomplish the following two 
actions. 

* Help articulate and guide research priorities on indoor mold across 
relevant federal agencies, coordinate information sharing on ongoing 
and planned research activities among agencies, and provide information 
to the public on ongoing research activities to better ensure that 
federal research on the health effects of exposure to indoor mold is 
effectively addressing research needs and efficiently using scarce 
federal resources. 

* Help relevant agencies review their existing guidance to the public 
on indoor mold--considering the audience and purpose of the guidance 
documents--to better ensure that it sufficiently alerts the public, 
especially vulnerable populations, about the potential adverse health 
effects of exposure to indoor mold and educates them on how to minimize 
exposure in homes. The reviews should take into account the best 
available information and ensure that the guidance does not conflict 
among agencies. 

Agency Comments and Our Evaluation: 

We provided the Consumer Product Safety Commission, EPA, FEMA, HHS, and 
HUD with a draft of this report and the related supplement (GAO-08- 
984SP) for the agencies' review and comment. In its response, EPA 
generally agreed with our recommendations that it use the Federal 
Interagency Committee on Indoor Air Quality to, among other things, 
help articulate and guide research priorities on indoor mold across 
relevant federal agencies and help relevant agencies review their 
existing guidance to the public on indoor mold to better ensure that it 
sufficiently alerts the public about the potential adverse health 
effects of exposure to indoor mold and educates the public on how to 
minimize exposure in homes. In commenting on the draft report, HUD and 
the Consumer Product Safety Commission also generally supported our 
recommendations to EPA. FEMA did not provide comments on the report, 
and HHS's comments did not address our recommendations to EPA. The 
Consumer Product Safety Commission, EPA, HHS, and HUD also provided 
technical comments on our report, and HHS provided a technical comment 
on the supplement; their comments were incorporated, as appropriate. 

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to the Acting 
Chairman, Consumer Product Safety Commission; Administrator, EPA; 
Administrator, FEMA; Secretary, HHS; Secretary, HUD; and other 
interested parties. We will also make copies available to others upon 
request. In addition, the report will be available at no charge on the 
GAO Web site at [hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-3841 or stephensonj@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. GAO staff who made major contributions 
to this report are listed in appendix VI. 

Sincerely yours, 

Signed by: 

John B. Stephenson: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

The objective of this review was to assess federal agencies' activities 
to minimize and mitigate the health effects of exposure to indoor mold. 
Specifically, we examined (1) what recent reviews of the scientific 
literature have concluded about the health effects of exposure to 
indoor mold; (2) the extent to which federal research addresses data 
gaps related to the health effects of exposure to indoor mold; and (3) 
what guidance key federal agencies are providing to the public on the 
health risks of exposure to mold, and on minimizing and mitigating that 
exposure, and the extent to which the guidance is consistent. Our 
review focuses on the health effects and guidance to the general public 
related to indoor mold in homes and does not address occupational 
exposures or technical guidance documents targeted to specialized 
audiences, such as medical professionals and emergency response 
workers. 

To determine what recent reviews of the scientific literature have 
concluded about the health effects of exposure to indoor mold, we 
primarily relied on the findings in the National Academies' Institute 
of Medicine comprehensive report issued in 2004, Damp Indoor Spaces and 
Health. To identify more recent reviews of the health effects of 
exposure to indoor mold, we conducted a literature search. We searched 
for reviews and meta-analyses, rather than individual studies, 
published in English in 2005, 2006, and 2007, primarily using PubMed, a 
bibliographic database service of the U.S. National Library of 
Medicine. We conducted 19 different searches of PubMed using 
combinations of the following search terms: mold, exposure, health, 
indoor, glucan, microbial volatile organic compounds, mycotoxins, 
ergosterol, hemolysins, fungal extracellular polysaccharides, fungal/ 
hyphal fragments, allergens, stachybotrys, acute ideopathic pulmonary 
hemorrhage, acute pulmonary hemorrhage and infants, and hemosiderosis. 
As part of these searches, we used PubMed's Clinical Queries option to 
find Systematic Reviews, which cover a broad set of articles that build 
consensus on biomedical topics. We also conducted a search for reviews 
and meta-analyses using the search strategy "mold AND (exposure OR 
indoor OR health)" in 15 other databases providing comprehensive 
worldwide coverage of scientific and technical journals on relevant 
topics. We reviewed the abstracts of all search results and obtained 
copies of the publications for which no abstracts were available, 
unless the available information indicated that the publication was 
unrelated to our review. We evaluated the relevance of the abstracts 
and publications and identified those that addressed the health effects 
of exposure to indoor mold and its constituents or products, excluding 
those that addressed dietary exposures, exposures in industrial or 
agricultural settings, publications focused on yeasts, case studies of 
mold in particular locations, and any publications that were clearly 
not meta-analyses or reviews of the scientific literature. Twenty of 
the reviews met our criteria (see app. II for a list of these reviews). 
To assess the credibility, reliability, and methodological soundness of 
these publications, a senior GAO analyst with a doctorate in 
epidemiology reviewed each of the publications and any additional 
methodological information obtained from the authors and considered 
such factors as the bibliographies of evidence cited, the journals in 
which the articles were published, and the extent to which they are 
primary authors of other relevant articles. We did not examine the 
references cited by these studies as part of our analysis. Some of the 
reviews may be based on primary sources (for example, epidemiologic 
studies), while others may also be based on sources that are themselves 
reviews of the scientific literature (for example, the 2004 Institute 
of Medicine report). We concluded that all 20 reviews were sufficiently 
reliable for the purposes of this report. 

We also used the 2004 Institute of Medicine report to help identify 
areas where additional research is needed to address scientific data 
gaps primarily related to the health effects of exposure to indoor mold 
other than asthma, as well as the institute's 2000 report, Clearing the 
Air: Asthma and Indoor Air Exposures, which focused on gaps related to 
asthma. We conducted in-depth reviews of these reports, including their 
methodology and conclusions, and we summarized the research needs they 
identified related to the health effects of exposure to indoor mold. 

To obtain information on federal research related to the health effects 
of exposure to indoor mold, we conducted two surveys of officials at 
the Environmental Protection Agency (EPA), the Department of Health and 
Human Services (HHS), and the Department of Housing and Urban 
Development (HUD) from November 2007 to May 2008. We used one survey to 
(1) identify research activities related to the health effects of 
indoor mold ongoing as of October 1, 2007, and (2) determine the extent 
to which these research activities address the 15 data gaps identified 
in the 2000 and 2004 Institute of Medicine reports related to the 
health effects of exposure to indoor mold. Respondents completed a 
survey for each individual research activity ongoing as of October 1, 
2007. We also used this survey to identify the extent to which these 
activities were coordinated both within and across agencies. We 
conducted a second survey of these agencies to collect basic 
information on their mold-related research activities completed from 
January 1, 2005, to September 30, 2007. Overall, we received 
information on 107 research activities from 37 EPA, HHS, and HUD 
officials. We received responses to our surveys from all relevant 
officials and agency entities. Summaries of the research activities 
conducted or sponsored by EPA, HHS, and HUD are provided in a 
supplement to this report (see [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-08-984SP]). 

We surveyed officials at EPA, HHS, and HUD because of these agencies' 
past and current participation in mold research. Specifically, we 
identified these agencies based on federal reports to Congress 
summarizing efforts to improve indoor air quality and interviews with 
federal officials involved in this research, among other things. We 
took a number of steps to ensure that our surveys would obtain reliable 
information from the appropriate agencies and officials regarding 
federal research activities on the health effects of exposure to indoor 
mold. For example, to ensure that we sent surveys to all agency 
officials involved in indoor mold-related research activities, we 
provided audit liaisons and agency respondents with a list of the units 
and officials in their agencies that we had identified as being 
relevant. We also asked audit liaisons to verify that we had not 
omitted any relevant units within their agencies and confirm whether 
other agency officials identified during our interviews as potentially 
involved in indoor mold-related research activities were involved with 
relevant activities. When an audit liaison identified a new agency 
respondent involved in indoor mold-related research activities, the 
individual was provided with copies of our surveys. (See app. IV for 
information on the units we contacted at these agencies.) We pretested 
our survey questions by sending them to two researchers from EPA and 
the National Institutes of Health (NIH) and incorporating their 
feedback into the final surveys. To increase the response rate, we 
followed up with agency officials to obtain responses from all relevant 
parties. We also performed a series of reliability tests on the data we 
received, including (1) examining agency submissions to exclude any 
that were either duplicates or did not meet our criteria and (2) 
checking for missing data or discrepancies. When we identified 
discrepancies or inconsistencies in the data, we followed up with 
relevant agency officials. In addition, we interviewed EPA, HHS, and 
HUD officials to determine the extent to which they coordinate their 
research projects and their priorities for mold-related research. To 
assess the extent to which the Federal Interagency Committee on Indoor 
Air Quality has been used to coordinate federal research activities 
related to the health effects of exposure to indoor mold, we reviewed 
relevant reports and the minutes of committee meetings dating from 
February 2005 to February 2008, and we interviewed EPA and other 
officials involved with the committee. 

To determine what guidance key federal agencies are providing to the 
general public on the health risks of exposure to indoor mold, and on 
minimizing mold growth and mitigating exposure to mold in their homes, 
and the extent to which the guidance is consistent, we focused our 
review on the five federal agencies that provide information to the 
general public on health risks and minimizing and mitigating exposure 
to contaminants, including mold. The guidance we reviewed includes fact 
sheets, brochures, booklets, and Web pages.[Footnote 58] Specifically, 
we reviewed guidance on the health effects of mold in a residential 
setting issued by the Consumer Product Safety Commission, EPA, HUD, 
HHS, and the Federal Emergency Management Agency (FEMA) that was 
identified primarily through online searches of federal Web sites and 
interviews with relevant program officials.[Footnote 59] We selected 
guidance to the general public that addresses health effects associated 
with indoor mold using a nonprobability sample.[Footnote 60] We did not 
include technical documents targeted to specialized audiences, such as 
medical professionals or emergency response workers.[Footnote 61] Of 
the 78 guidance documents that met our initial criteria, we selected 32 
for detailed review on the basis of their content, purpose, and the 
extent to which they specifically addressed indoor mold. (In some 
cases, the documents broadly address indoor air contaminants but only 
briefly mention mold.) Specifically, of the 34 mold-related guidance 
documents FEMA issued to the general public responding to specific 
disasters since 2004, we selected 8 for our review; we excluded the 
other 26 because they contain essentially similar information. Further, 
we included in our review the 8 guidance documents issued by the 
Consumer Product Safety Commission and HUD that address health effects 
associated with indoor mold; however, we excluded some guidance 
documents issued by EPA and HHS primarily because they were similar to, 
and thus duplicative of, other documents already included in our 
review. We provided agency officials with an opportunity to review our 
list of guidance documents and suggest additional documents for 
inclusion in our review. We added relevant documents, as suggested. 
(See app. V for the guidance documents included in our review.) 
Additionally, we interviewed officials from the five agencies issuing 
the guidance to determine their procedures for developing and issuing 
guidance documents. The guidance documents we analyzed are publicly 
available and can be accessed through the agencies' Web sites. 

We conducted this performance audit from January 2007 to September 2008 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

[End of section] 

Appendix II: Recent Reviews of the Health Effects of Mold: 

The following list of recent reviews of the health effects of mold 
includes two Institute of Medicine reports and 20 other reviews. 

Borchers A.T., Chang C., Keen C.L., and M.E. Gershwin. "Airborne 
Environmental Injuries and Human Health." Clinical Reviews in Allergy 
and Immunology, vol. 31, no. 1 (2006): 1-102. 

Bush R.K., Portnoy J.M., Saxon A., Terr A.I., and R.A. Wood. "The 
medical effects of mold exposure." The Journal of Allergy and Clinical 
Immunology, vol. 117, no. 2 (2006): 326-33. 

Douwes J. "(1-->3)-Beta-D-glucans and respiratory health: a review of 
the scientific evidence." Indoor Air, vol. 15, no. 3 (2005): 160-9. 

Etzel R.A. "Indoor and outdoor air pollution: Tobacco smoke, moulds and 
diseases in infants and children." International Journal of Hygiene and 
Environmental Health, vol. 210, no. 5 (2007): 611-6. 

Fisk, W.J., Lei-Gomez Q., and M.J. Mendell. "Meta-analyses of the 
associations of respiratory health effects with dampness and mold in 
homes." Indoor Air, vol. 17, no. 4 (2007): 284-96. 

Gray, M. "Molds and Mycotoxins: Beyond Allergies and Asthma." 
Alternative Therapies in Health and Medicine, vol. 13, no. 2 (2007): 
S146-52. 

Green B.J., Tovey E.R., Sercombe J.K., Blachere F.M., Beezhold D.H., 
and D. Schmechel. "Airborne fungal fragments and allergenicity." 
Medical Mycology, vol. 44, no. S1 (2006): S245-55. 

Habiba A. "Acute idiopathic pulmonary haemorrhage in infancy: Case 
report and review of the literature." Journal of Paediatrics and Child 
Health, vol. 41, no. 9-10 (2005): 532-3. 

Hope, A.P., and R.A. Simon. "Excess dampness and mold growth in homes: 
An evidence-based review of the aeroirritant effect and its potential 
causes." Allergy and Asthma Proceedings, vol. 28, no. 3 (2007): 262-70. 

Institute of Medicine, Clearing the Air: Asthma and Indoor Air 
Exposures. Washington, D.C.: National Academy Press, 2000. 

Institute of Medicine, Damp Indoor Spaces and Health. Washington, D.C.: 
The National Academies Press, 2004. 

Jarvis B.B., and J.D. Miller. "Mycotoxins as harmful indoor air 
contaminants." Applied Microbiology and Biotechnology, vol. 66, no. 4 
(2005): 367-72. 

Khalili B., Montanaro M.T., and E.J. Bardana Jr. "Inhalational mold 
toxicity: fact or fiction? a clinical review of 50 cases." Annals of 
Allergy, Asthma & Immunology, vol. 95, no. 3 (2005): 239-46. 

Lai K.-M. "Hazard Identification, Dose-Response and Environmental 
Characteristics of Stachybotryotoxins and Other Health-Related Products 
from Stachybotrys." Environmental Technology, vol. 27, no. 3 (2006): 
329-35. 

Laumbach R.J., and H.M. Kipen. "Bioaerosols and sick building syndrome: 
particles, inflammation, and allergy." Current Opinion in Allergy and 
Clinical Immunology, vol. 5, no. 2 (2005): 135-9. 

Mazur L.J., and J. Kim; Committee on Environmental Health, American 
Academy of Pediatrics. "Spectrum of Noninfectious Health Effects From 
Molds." Pediatrics, vol. 118, no. 6 (2006): e1909-26. 

Nuesslein T.G., Teig N., and C.H. Rieger. "Pulmonary haemosiderosis in 
infants and children." Paediatric Respiratory Reviews, vol. 7, no. 1 
(2006): 45-8. 

Phipatanakul W. "Environmental Factors and Childhood Asthma." Pediatric 
Annals, vol. 35, no. 9 (2006): 646-56. 

Seltzer J.M., and M.J. Fedoruk. "Health Effects of Mold in Children." 
Pediatric Clinics of North America, vol. 54, no. 2 (2007): 309-33, viii-
ix. 

Susarla S.C., and L.L. Fan. "Diffuse alveolar hemorrhage syndromes in 
children." Current Opinion in Pediatrics, vol. 19, no. 3 (2007): 314- 
20. 

Portnoy J.M., Kwak K., Dowling P., VanOsdol T., and C. Barnes. "Health 
effects of indoor fungi." Annals of Allergy, Asthma & Immunology, vol. 
94, no. 3 (2005): 313-20. 

Richardson G., Eick S., and R. Jones. "How is the indoor environment 
related to asthma?: literature review." Journal of Advanced Nursing, 
vol. 52, no. 3 (2005): 328-39. 

[End of section] 

Appendix III: EPA, HHS, and HUD Ongoing Research Activities Addressing 
Data Gaps Identified by the Institute of Medicine: 

[Refer to PDF for image] 

This figure contains a series of stacked horizontal bar graphs 
depicting the following information: 

Identify environmental factors that either lead to the development of 
asthma or precipitate symptoms in subjects who already have asthma 
using good measures of fungal exposure[A]: 
EPA research activities reported: 9; 
HHS research activities reported: 19; 
HUD research activities reported: 4; 
Total: 32. 

Improve sampling and exposure assessment methods for mold and its 
components (such as research that will help lead to standardization of 
protocols for sample collection, transport, and analysis; or develop or 
improve methods of personal airborne exposure measurement, DNA-based 
technology, or assays for bioaerosols, etc.)[B]: 
EPA research activities reported: 4; 
HHS research activities reported: 23; 
HUD research activities reported: 5; 
Total: 32. 

Determine the association of dampness problems with asthma development 
and symptoms by researching the causative agents (e.g., molds, dust 
mite allergens) and documenting the relationship between dampness and 
allergen exposure[A]: 
EPA research activities reported: 5; 
HHS research activities reported: 16; 
HUD research activities reported: 1; 
Total: 22. 

Identify fungal allergens or patterns of cross-reactivity among fungal 
allergens: 
EPA research activities reported: 11; 
HHS research activities reported: 11; 
HUD research activities reported: 0; 
Total: 22. 

Collect and analyze data on the interactions among multiple indoor 
agents (such as mold, pesticides, and volatile organic compounds) and 
environmental factors (such as humidity, temperature, and ventilation): 
EPA research activities reported: 3; 
HHS research activities reported: 15; 
HUD research activities reported: 3; 
Total: 21. 

Develop information on the possible adverse health effects of dampness-
related emissions of mold spores from building materials and 
furnishings: 
EPA research activities reported: 2; 
HHS research activities reported: 16; 
HUD research activities reported: 0; 
Total: 18. 

Determine how to measure the effectiveness and health effects of mold 
remediation efforts: 
EPA research activities reported: 5; 
HHS research activities reported: 9; 
HUD research activities reported: 1; 
Total: 15. 

Better characterize the possible influence of the duration of moisture 
damage on health:
EPA research activities reported: 4; 
HHS research activities reported: 7; 
HUD research activities reported: 2; 
Total: 13. 

Develop standardized metrics and protocols to assess the nature, 
severity, and ex-tent of dampness and effectiveness of specific 
measures for dampness reduction[B]: 
EPA research activities reported: 4; 
HHS research activities reported: 7; 
HUD research activities reported: 2; 
Total: 13. 

Advance the understanding of specific bioaerosols in relation to asthma 
by studying the epidemiology of building-related asthma in problem 
buildings where there are excess chest complaints among occupants in 
comparison to buildings where there are not complaints; or provide 
exposure-response studies of many building environments and 
populations: 
EPA research activities reported: 3; 
HHS research activities reported: 7; 
HUD research activities reported: 0; 
Total: 10. 

Assess the effects of housing interventions (such as prevention or 
remediation of moisture problems, etc.) on dampness and adverse health 
effects, including the extent to which interventions are associated 
with a decrease in the occurrence of adverse health effects, and 
identify effective and efficient intervention strategies: 
EPA research activities reported: 3; 
HHS research activities reported: 5; 
HUD research activities reported: 1; 
Total: 9. 

Better characterize the effectiveness of various means of protection 
used during mold remediation activities: 
EPA research activities reported: 1; 
HHS research activities reported: 3; 
HUD research activities reported: 1; 
Total: 5. 

Determine the effects of human exposure to Stachybotrys chartarum in 
indoor environments: 
EPA research activities reported: 2; 
HHS research activities reported: 3; 
HUD research activities reported: 0; 
Total: 5. 

Determine, for mycotoxins, the dose required to cause adverse health 
effects in humans via inhalation and dermal exposure; techniques for 
detecting and quantifying mycotoxins in tissues; or the effects of long-
term (chronic) exposures to mycotoxins via inhalation: 
EPA research activities reported: 1; 
HHS research activities reported: 3; 
HUD research activities reported: 0; 
Total: 4. 

Research the relationship between mold and dampness and acute pulmonary 
hemorrhage or hemosiderosis in infants: 
EPA research activities reported: 0; 
HHS research activities reported: 1; 
HUD research activities reported: 0; 
Total: 1. 

Source: GAO analysis of EPA, HHS, and HUD survey data. 

Notes: These data are for the 65 federal mold research activities 
ongoing as of October 1, 2007. Federal officials reported which of the 
data gaps identified by the 2000 and 2004 Institute of Medicine reports 
their research activities are addressing. Each activity can address 
multiple data gaps. 

In fact, many of the activities are reported to address three or more 
gaps. Summaries of the 65 research activities conducted or sponsored by 
EPA, HHS, and HUD are provided in a supplement to this report (GAO-08- 
984SP). 

Agency officials reported that eight federal mold research activities 
currently being conducted do not directly address any of the data gaps 
identified by the 2000 and 2004 Institute of Medicine reports. Some of 
these studies were directed at medical treatments and others were 
focused on other potential causes of asthma. For example, one study is 
evaluating whether chronic rhinosinusitis is induced by an abnormal 
immune response to mold and therefore whether an anti-fungal agent will 
be an effective treatment of the disease. Another study is developing 
and validating DNA-based methods for identification and fingerprinting 
medically important fungi. Several of these research activities focused 
on asthma. For example, two studies, one of children in El Paso and 
another of children in Detroit, are primarily focused on the role of 
residential proximity to roadways in the development of childhood 
asthma but also collected data on indoor exposures, including home 
dampness and the presence of visible molds. Another study being 
conducted is designed to test the hypothesis that asthma control in low 
income, urban adolescents and young adults can be improved with the 
addition of exhaled nitric oxide as a marker for treatment guidance to 
conventional asthma management guidelines; a secondary purpose of this 
study is to examine the role of allergy to molds in influencing the 
effectiveness of the asthma management plan. 

[A] Asthma data gaps identified by the 2000 and 2004 Institute of 
Medicine reports. 

[B] Measurement methods data gaps identified by the 2000 and 2004 
Institute of Medicine reports. 

[End of figure] 

[End of section] 

Appendix IV Federal Agency Program Offices Contacted Regarding Their 
Mold-Related Research: 

[End of section] 

We obtained information on federal research related to the health 
effects of exposure to indoor mold from three key agencies--EPA, HHS, 
and HUD. We obtained and analyzed information and interviewed program 
managers and other officials responsible for research at these 
agencies. Following are the offices, centers, and other program units 
we surveyed regarding their mold-related research.[Footnote 62] 

Environmental Protection Agency: 

Office of Air and Radiation:
* Office of Radiation and Indoor Air:
- Indoor Environments Division:
- Radiation and Indoor Environments National Laboratory:
- National Air and Radiation Environmental Laboratory: 

Office of Research and Development:
* Office of the Assistant Administrator:
* National Health and Environmental Effects Research Laboratory:
- Experimental Toxicology Division:
- Human Studies Division:
* National Exposure Research Laboratory:
- Microbiological and Chemical Exposure Assessment Research Division:
* National Risk Management Research Laboratory:
- Air Pollution Prevention and Control Division:
* National Homeland Security Research Center:
* National Center for Environmental Research:
* National Center for Environmental Assessment: 

Office of Prevention, Pesticides, and Toxic Substances:
* Office of Pesticide Programs:
- Antimicrobials Division:
- Field and External Affairs Division:
- Special Review and Reregistration:
- Office of Pollution Prevention and Toxics:
- Environmental Assistance Division: 

Office of the Administrator:
*Office of Children's Health Protection and Environmental Education:
- Child and Aging Health Protection Division: 

Office of Solid Waste and Emergency Response: 

Department of Health and Human Services: 

Centers for Disease Control and Prevention: 

Office of Chief Science Officer: 

Coordinating Office for Terrorism Preparedness and Emergency Response: 

Coordinating Center for Health Information and Service:
* National Center for Health Marketing: 

Coordinating Center for Infectious Diseases:
* National Center for Immunization and Respiratory Diseases:
- Influenza Coordination Unit: 

Coordinating Center for Environmental Health and Injury Prevention:
* National Center for Environmental Health:
- Division of Environmental Hazards and Health Effects; Air Pollution 
and Respiratory Health Branch:
- Division of Emergency and Environmental Health Services: Lead 
Poisoning Prevention Branch:
* Agency for Toxic Substances and Disease Registry:
- Division of Health Assessment and Consultation: Cooperative Agreement 
and Program Evaluation Branch:
* Division of Health Studies: 

National Institute for Occupational Safety and Health:
* Office of the Director:
- Office of the Associate Director for Science:
- Office of Extramural Coordination and Special Projects:
* Health Effects Laboratory Division:
- Pathology and Physiological Research Branch:
- Allergy and Clinical Immunology Branch:
* Division of Surveillance, Hazard Evaluations, and Field Studies:
- Hazard Evaluations and Technical Assistance Branch:
- Industrywide Studies Branch:
* Division of Respiratory Disease Studies:
- Field Studies Branch:
- Laboratory Research Branch: 

National Center for Zoonotic, Vector-Borne, and Enteric Diseases:
* Division of Foodborne, Bacterial and Mycotic Diseases:
- Mycotic Diseases Branch: 

National Institutes of Health: 

National Human Genome Research Institute:
* Office of Population Genomics: 

National Institute of Allergy and Infectious Diseases:
* Division of Clinical Research:
* Division of Microbiology and Infectious Diseases:
* Division of Allergy, Immunology, and Transplantation:
- Office of Program Planning, Operations and Scientific Information:
- Asthma, Allergy and Inflammation Branch: 

National Heart, Lung, and Blood Institute:
* Division of Lung Diseases:
* Division for the Application of Research Discoveries: 

National Institute of Environmental Health Sciences:
* Office of the Director:
* Division of Extramural Research and Training:
* Division of Intramural Research:
- National Toxicology Program:
- Environmental Diseases and Medicine Program:
- Clinical Research Program:
* Office of Translational Research: 

Office of the Assistant Secretary for Health: 

Office of Public Health and Science:
* Office of the Surgeon General:
* Commissioned Corps of the U.S. Public Health Service:
- Chief Professional Officer:
Medical:
Environmental Health:
Health Services:
Scientist: 

Office of the Assistant Secretary for Administration and Management: 

Program Support Center:
* Federal Occupational Health:
- Environmental Health Services: 

Department of Housing and Urban Development: 

Office of the Assistant Secretary for Policy Development and Research:
* Office of Deputy Assistant Secretary for Research, Evaluation, and 
Monitoring:
- Affordable Housing Research and Technology Division: 

Office of Healthy Homes and Lead Hazard Control:
* Policy and Standards Division: 

Office of Public and Indian Housing:
* Office of Public Housing Investments:
- Office of Capital Improvements:
* Office of Native American Programs:
* Real Estate Assessment Center:
- Physical Inspection Quality Assurance Division: 

Office of Housing:
* Office for Regulatory Affairs and Manufactured Housing:
- Office of Manufactured Housing Programs: 

[End of section] 

Appendix V: Selected Publicly Available Federal Guidance Related to 
Mold: 

Consumer Product Safety Commission and the American Lung Association, 
Biological Pollutants in Your Home (Bethesda, Md., 1990). [hyperlink, 
http://www.cpsc.gov/cpscpub/pubs/425.html] (accessed May 8, 2008). 

Consumer Product Safety Commission and the Environmental Protection 
Agency, The Inside Story: A Guide to Indoor Air Quality (Washington, 
D.C., 1995). [hyperlink, http://www.epa.gov/iaq/pubs/insidest.html] 
(accessed May 8, 2008). 

Environmental Protection Agency, Addressing Indoor Environmental 
Concerns During Remodeling (Washington, D.C., 2007). [hyperlink, 
http://www.epa.gov/iaq/homes/hip-concerns.html] (accessed May 9, 2008). 

Environmental Protection Agency, Age Healthier Breathe Easier 
(Washington, D.C., 2004). [hyperlink, 
http://www.epa.gov/aging/resources/factsheets/ahbe_english_2004_0330.pdd
] (accessed May 9, 2008). 

Environmental Protection Agency, A Brief Guide to Mold, Moisture, and 
Your Home (Washington, D.C., 2002). [hyperlink, 
http://www.epa.gov/mold/moldguide.html] (accessed May 9, 2008). 

Environmental Protection Agency, Cleaning Up After a Flood: Addressing 
Mold Problems (Washington, D.C., 2005). [hyperlink, 
http://www.epa.gov/katrina/outreach/mold.pdf] (accessed May 9, 2008). 

Environmental Protection Agency, Controlling Moisture (Washington, 
D.C., 2007). [hyperlink, http://www.epa.gov/iaq/homes/hip-
moisture.html] (accessed May 9, 2008). 

Environmental Protection Agency, Live, Learn, Play--Tune in to Your 
Health and Environment (Washington, D.C., 2004). [hyperlink, 
http://yosemite.epa.gov/ochp/ochpweb.nsf/content/dirt.htm] (accessed 
May 9, 2008). 

Environmental Protection Agency, Flood Cleanup--Avoiding Indoor Air 
Quality Problems (Fact Sheet) (Washington, D.C., 2003). [hyperlink, 
http://www.epa.gov/mold/pdfs/floods.pdf] (accessed May 9, 2008). 

Environmental Protection Agency, Flood Cleanup and the Air in your Home 
(Washington, D.C., 2006). [hyperlink, 
http://www.epa.gov/mold/flood/index.html] (accessed May 9, 2008). 

Environmental Protection Agency, What are ten things I need to know 
about mold? (Washington, D.C., 2008). [hyperlink, 
http://iaq.custhelp.com/cgi-bin/iaq.cfg/php/enduser/std_alp.php] 
(accessed May 9, 2008). 

Environmental Protection Agency, What You Can Do to Protect Children 
from Environmental Risks (Washington, D.C., 2002). [hyperlink, 
http://yosemite.epa.gov/ochp/ochpweb.nsf/content/tips.htm] (accessed 
May 9, 2008). 

Environmental Protection Agency; Department of Agriculture, Cooperative 
State Research, Education, and Extension Service; Department of Housing 
and Urban Development; Montana State University Extension Service; and 
Alabama Cooperative Extension System at Auburn University, Healthy 
Indoor Air for America's Homes (Bozeman, Mont., 2007). [hyperlink, 
http://www.montana.edu/wwwcxair/] (accessed May 9, 2008). 

Department of Health and Human Services, Centers for Disease Control 
and Prevention, Molds in the Environment (Atlanta, 2005). [hyperlink, 
http://www.cdc.gov/mold/faqs.htm] (accessed May 9, 2008). 

Department of Health and Human Services, Centers for Disease Control 
and Prevention, Facts About Mold And Dampness (Atlanta, 2005). 
[hyperlink, http://www.cdc.gov/mold/dampness_facts.htm\ (accessed May 
9, 2008). 

Department of Health and Human Services, Centers for Disease Control 
and Prevention, Mold Questions and Answers: Questions and Answers on 
Stachybotrys chartarum and other molds (Atlanta, 2004). [hyperlink, 
http://www.cdc.gov/mold/stachy.htm] (accessed May 9, 2008). 

Department of Health and Human Services, Centers for Disease Control 
and Prevention, Protect Yourself from Mold (Atlanta, 2006). [hyperlink, 
http://www.bt.cdc.gov/disasters/mold/protect.asp] (accessed May 9, 
2008). 

Department of Health and Human Services, Centers for Disease Control 
and Prevention, Mold Prevention Strategies and Possible Health Effects 
in the Aftermath of Hurricanes and Major Floods (Atlanta, 2006). 
[hyperlink, http://www.cdc.gov/mmwr/preview/mmwrhtml/rr5508a1.htm] 
(accessed May 9, 2008). 

Department of Health and Human Services, Centers for Disease Control 
and Prevention, Population-Specific Recommendations for Protection From 
Exposure to Mold in Buildings Flooded After Hurricanes Katrina and 
Rita, by Specific Activity and Risk Factor (Atlanta, 2005). [hyperlink, 
http://www.bt.cdc.gov/disasters/mold/report/pdf/2005_moldtable5.pdf] 
(accessed May 9, 2008). 

Department of Homeland Security, Federal Emergency Management Agency, 
Dealing with Mold and Mildew in Your Flood Damaged Home (Washington, 
D.C., 2005). [hyperlink, 
http://www.fema.gov/pdf/rebuild/recover/fema_mold_brochure_english.pdf] 
(accessed May 9, 2008). 

Department of Homeland Security, Federal Emergency Management Agency, 
Got Mold? Clean, Disinfect and Dry (Wichita, Kans., 2007). [hyperlink, 
http://www.fema.gov/news/newsrelease.fema?id=37791] (accessed May 9, 
2008). 

Department of Homeland Security, Federal Emergency Management Agency, 
Mold Can Be A Danger When Evacuees Return Home (Baton Rouge, La., 
2005). [hyperlink, http://www.fema.gov/news/newsrelease.fema?id=19302] 
(accessed May 9, 2008). 

Department of Homeland Security, Federal Emergency Management Agency, 
Mold--A Growing Threat (Andover, Mass., 2006). [hyperlink, 
http://www.fema.gov/news/newsrelease.fema?id=26898] (accessed May 9, 
2008). 

Department of Homeland Security, Federal Emergency Management Agency, 
Mold: A Health Hazard (Montgomery, Ala., 2005). [hyperlink, 
http://www.fema.gov/news/newsrelease.fema?id=20379] (accessed May 9, 
2008). 

Department of Homeland Security, Federal Emergency Management Agency, 
Mold: Potential Threat to Health and Homes (Austin, Tex., 2005). 
[hyperlink, http://www.fema.gov/news/newsrelease.fema?id=19767] 
(accessed May 9, 2008). 

Department of Homeland Security, Federal Emergency Management Agency, 
Prompt Cleanup Of Mold And Mildew Is Essential (Newington, N.H., 2006). 
[hyperlink, http://www.fema.gov/news/newsrelease.fema?id=27186] 
(accessed July 1, 2008). 

Department of Homeland Security, Federal Emergency Management Agency, 
Water-Damaged Homes May Harbor Mold Problem (Washington, D.C., 2007). 
[hyperlink, http://www.fema.gov/news/newsrelease.fema?id=36536] 
(accessed May 9, 2008). 

Department of Housing and Urban Development, About Mold and Moisture 
(Washington, D.C., 2007). [hyperlink, 
http://www.hud.gov/offices/lead/healthyhomes/mold.cfm] (accessed May 9, 
2008). 

Department of Housing and Urban Development, Healthy Homes Program 
(Washington, D.C., 2003). [hyperlink, 
http://www.hud.gov/offices/lead/library/hhi/HH_Brochure_Revised.pdf] 
(accessed May 9, 2008). 

Department of Housing and Urban Development, Mold and Moisture 
Prevention: A Guide for Residents in Indian Country (Washington, D.C., 
2004). [hyperlink, 
http://www.hud.gov/offices/pih/ih/codetalk/docs/moldprevention.pdf] 
(accessed May 9, 2008). 

[End of section] 

Department of Housing and Urban Development, Mold (Washington, D.C., 
2005). [hyperlink, 
http://www.hud.gov/offices/lead/library/hhi/Mold.pdf] (accessed May 9, 
2008). 

Department of Housing and Urban Development; Department of Agriculture, 
Cooperative State Research, Education, and Extension Service; and 
University of Wisconsin Healthy Homes Partnership, Help Yourself to a 
Healthy Home (Washington, D.C., 2002). [hyperlink, 
http://www.hud.gov/offices/lead/library/hhi/HYHH_Booklet.pdf] (accessed 
May 9, 2008). 

[End of section] 

Appendix VI: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

John B. Stephenson, (202) 512-3841 or stephensonj@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Christine Fishkin, Assistant 
Director; Krista Breen Anderson; Nancy Crothers; Benjamin Howe; Richard 
P. Johnson; Nico Sloss; and Ruth Solomon made key contributions to this 
report. Linda Choy; Michael Derr; Alice Feldesman; Terrance Horner; 
Armetha Liles; Luann Moy; and Anne Rhodes-Kline also made important 
contributions. 

[End of section] 

Footnotes: 

[1] In this report, we use the term "mold" to refer to the large number 
of species of fungi. 

[2] National Institute of Environmental Health Sciences, "A Spreading 
Concern: Inhalational Health Effects of Mold," Environmental Health 
Perspectives (June 2007). 

[3] Department of Health and Human Services, Centers for Disease 
Control and Prevention, Mold Prevention Strategies and Possible Health 
Effects in the Aftermath of Hurricanes and Major Floods (Atlanta, 
2006). 

[4] The National Academies comprises four organizations: the National 
Academy of Sciences, the National Academy of Engineering, the Institute 
of Medicine, and the National Research Council. 

[5] Institute of Medicine, Damp Indoor Spaces and Health (Washington, 
D.C.: The National Academies Press, 2004). 

[6] Institute of Medicine, Clearing the Air: Asthma and Indoor Air 
Exposures (Washington, D.C.: National Academy Press, 2000). 

[7] GAO, Hurricane Katrina: EPA's Current and Future Environmental 
Protection Efforts Could Be Enhanced by Addressing Issues and 
Challenges Faced on the Gulf Coast, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-07-651] (Washington, D.C.: June 25, 2007). 

[8] Pub. L. No. 99-499, Title IV, §§ 401 to 405 (1986). 

[9] GAO, Indoor Air Pollution: Federal Efforts Are Not Effectively 
Addressing a Growing Problem, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO/RCED-92-8] (Washington, D.C.: Oct. 15, 1991). 

[10] According to CDC officials, it is not yet possible to establish 
mold exposure limits for indoor air. 

[11] Information on state laws comes from data assembled by the 
National Association of Mutual Insurance Companies (NAMIC) at 
[hyperlink, http://www.namic.org]. 

[12] L.J. Mazur, J. Kim, and Committee on Environmental Health, 
American Academy of Pediatrics, "Spectrum of Noninfectious Health 
Effects From Molds," Pediatrics, vol. 118, no. 6 (2006). 

[13] Two of the reviews focused primarily on clinical cases encountered 
by the authors. For a list of the studies we reviewed, see appendix II. 

[14] The authors of this report acknowledged that, because of the 
presence of other potential disease-causing agents indoors, it is not 
possible to definitively attribute a causal relationship to any one 
specific agent in indoor environments. 

[15] A meta-analysis uses statistical methods to combine data from 
different but comparable research studies, in order to provide a 
quantitative summary estimate on the size and variability of an 
association. 

[16] W.J. Fisk, Q. Lei-Gomez, and M.J. Mendell, "Meta-analyses of the 
associations of respiratory health effects with dampness and mold in 
homes," Indoor Air, vol. 17, no. 4 (2007). 

[17] J.M. Seltzer and M.J. Fedoruk, "Health Effects of Mold in 
Children," Pediatric Clinics of North America, vol. 54, no. 2 (2007). 

[18] A. Habiba, "Acute idiopathic pulmonary haemorrhage in infancy: 
Case report and review of the literature," Journal of Paediatrics and 
Child Health, vol. 41, no. 9-10 (2005); and S.C. Susarla and L.L. Fan, 
"Diffuse alveolar hemorrhage syndromes in children," Current Opinion in 
Pediatrics, vol. 19, no. 3 (2007). 

[19] T.G. Nuesslein, N. Teig, and C.H. Rieger, "Pulmonary 
haemosiderosis in infants and children," Paediatric Respiratory 
Reviews, vol. 7, no. 1 (2006). 

[20] R.A. Etzel, "Indoor and outdoor air pollution: Tobacco smoke, 
moulds and diseases in infants and children," International Journal of 
Hygiene and Environmental Health, vol. 210, no. 5 (2007). 

[21] In addition to the 2006 American Academy of Pediatrics review and 
Seltzer and Fedoruk (2007), A.T. Borchers, C. Chang, C.L. Keen, and 
M.E. Gershwin, "Airborne Environmental Injuries and Human Health," 
Clinical Reviews in Allergy & Immunology, vol. 31, no. 1 (2006); K.-M. 
Lai, "Hazard Identification, Dose-Response and Environmental 
Characteristics of Stachybotryotoxins and Other Health-Related Products 
from Stachybotrys," Environmental Technology, vol. 27, no. 3 (2006); 
and J.M. Portnoy, K. Kwak, P. Dowling, T. VanOsdol, and C. Barnes, 
"Health effects of indoor fungi," Annals of Allergy, Asthma & 
Immunology, vol. 94, no. 3 (2005). 

[22] B.B. Jarvis and J.D. Miller, "Mycotoxins as harmful indoor air 
contaminants," Applied Microbiology and Biotechnology, vol. 66, no. 4 
(2005). 

[23] R.K. Bush, J.M. Portnoy, A. Saxon, A.I. Terr, and R.A. Wood, "The 
medical effects of mold exposure," The Journal of Allergy and Clinical 
Immunology, vol. 117, no. 2 (2006). 

[24] Although our review focuses on the research needs directly related 
to indoor mold and human health, the 2000 and 2004 Institute of 
Medicine reports identified a variety of other research needs related 
to dampness, mold, and buildings. 

[25] Other methods to protect building occupants and workers may 
involve containment efforts to control the dispersal of mold through 
the building during remediation, which can disturb building materials 
and release mold (particularly its spores) into the air. 

[26] Clearing the Air and Damp Indoor Spaces and Health. 

[27] We aggregated the research needs on the health effects of exposure 
to indoor mold that were identified in the 2000 and 2004 Institute of 
Medicine reports into 15 groups of related needs. 

[28] These studies are titled "The Effect of Gestational Exposure to 
Mold on Allergy Induction in a Mouse Model," "Study of Putative 
Asthmagenic Molds," and "Development of an Animal Model to Evaluate the 
Contribution of the Fungal Product, -glucan, on the Pulmonary 
Inflammatory Potential of Indoor Dust Samples." 

[29] These studies are titled "Health Effects of Exposure to Water- 
Damaged New Orleans Homes Six Months After Hurricanes Katrina and Rita" 
and "Building-Related Asthma Research in Maine Public Schools." 

[30] This research activity is titled "The Development of Monoclonal 
Antibody-Based Immunodiagnostics for Fungal Hemolysins as Potential 
Biomarkers of Fungal Exposure." 

[31] These studies are titled "Toxicology Studies of Mold Exposures," 
"Fluorescent Multiplex Array for Indoor Allergens (which is using 
enzyme immunoassay and multiplex array technology)," and "Aptamer-Based 
Microarray for the Detection of Environmental Allergens." 

[32] While HHS did not classify this ongoing research, "Study on 
Identification and Typing (Fingerprinting) Medically Important Fungal 
Organisms Using DNA," as meeting the data gaps on sampling or 
measurement methods identified by the Institute of Medicine reports, we 
believe that the information from this research activity has the 
potential to address important measurement gaps. 

[33] These research activities are titled "Study on Asthma and 
Environmental Factors, Which Included an Application of the ERMI Index" 
and "Determining the National Distribution of Selected Contaminants 
(Including Mold) in the Residential Environment (i.e., the American 
Healthy Homes Survey)." The ERMI scale can describe the mold burden in 
any home on the basis of its relative position compared with the entire 
U.S. housing stock. 

[34] One of the nine research activities is addressing two of the three 
data gaps to some extent. To avoid double counting, this research 
activity is counted once. 

[35] This study is titled "Study on Biomarkers for Exposure to 
Stachybotrys Chartarum." 

[36] According to a CDC official, from January 2004 to June 2005, the 
agency undertook a "chart review" of pulmonary hemorrhage designed to 
determine if existing computerized information sources (such as 
hospital discharge and vital statistics data) or other information 
could be used for national surveillance of acute pulmonary hemorrhage 
in infants. After evaluating hospital records in six cities, CDC's 
preliminary conclusions are that national data sets are not reliable 
for this purpose and that local data sources should be used instead. 

[37] These studies are titled "Head-off Environmental Asthma in 
Louisiana," "Relative Potency of Mold Extraction in a Mouse Model," 
"Fluorescent Multiplex Array for Indoor Allergens," "Study on 
Biomarkers for Exposure to Stachybotrys Chartarum," and "Urban Moisture 
and Mold Program-Continuation Project." 

[38] These activities are titled "Toxicology Studies of Mold Exposures" 
and "Allosteric DNAzyme Sensors for Practical Detection of Mycotoxins." 

[39] This study is titled "The Role of Neutrophils in Hypersensitivity 
Pneumonitis." 

[40] This study is titled "Mechanistic Indicators of Childhood Asthma 
(MICA) Study." 

[41] HUD did not report any completed mold-related research activities 
during this time frame. 

[42] EPA, Program Needs for Indoor Environments Research, EPA 402-B-05- 
001 (March 2005). 

[43] These are the National Institute of Environmental Health Sciences; 
the National Heart, Lung, and Blood Institute; and the National 
Institute of Allergy and Infectious Diseases. 

[44] One of the 29 research activities was funded partly by an 
unsolicited grant and partly by a solicited cooperative agreement. We 
considered this activity as both unsolicited and solicited. 

[45] An NIH official said that after the peer-review process is 
completed, proposals are given a merit score, which is based on factors 
such as the qualifications of the researcher and the level of 
innovation and significance of the research. Funding is then allocated 
to research activities in priority order based on this ranking. 

[46] GAO, Results-Oriented Government: Practices That Can Help Enhance 
and Sustain Collaboration among Federal Agencies, [hyperlink, 
http://www.gao.gov/cgi-bin/getrpt?GAO-06-15] (Washington, D.C.: Oct. 
21, 2005). 

[47] EPA, Report to Congress on Indoor Air Quality: Volume I: Federal 
Programs Addressing Indoor Air Quality, EPA/400/1-89/001B (August 
1989). 

[48] All the HHS guidance documents we reviewed were issued by CDC. 

[49] The six adverse health effects identified by the Institute of 
Medicine are the exacerbation of asthma symptoms, upper respiratory 
tract symptoms, cough, wheeze, hypersensitivity pneumonitis, and 
opportunistic infections and fungal colonization in immune-compromised 
individuals. 

[50] Department of Health and Human Services, Centers for Disease 
Control and Prevention, Mold Prevention Strategies and Possible Health 
Effects in the Aftermath of Hurricanes and Major Floods (Atlanta, 
2006). 

[51] Department of Homeland Security, Federal Emergency Management 
Agency, Dealing with Mold and Mildew in Your Flood Damaged Home 
(Washington, D.C., 2005). Department of Health and Human Services, 
Centers for Disease Control and Prevention, Mold Questions and Answers: 
Questions and Answers on Stachybotrys chartarum and other molds 
(Atlanta, 2004); Facts About Mold And Dampness (Atlanta, 2005); and 
Molds in the Environment (Atlanta, 2005). 

[52] EPA, Mold Remediation in Schools and Commercial Buildings 
(Washington, D.C., June 2001). 

[53] Guidance documents typically referred readers to this report if 
mold removal exceeds 10 square feet, although it also addresses mold 
cleanups of less than 10 square feet. 

[54] As discussed earlier in this report, however, litigants attempting 
to show that exposure to indoor mold has resulted in adverse health 
effects generally need to demonstrate to courts that a specific species 
of mold caused a specific adverse health outcome. 

[55] EPA, Mold Remediation. 

[56] The smallest areas addressed by guidance documents we reviewed 
vary from up to 10 square feet to up to 100 square feet. 

[57] Department of Health and Human Services, Centers for Disease 
Control and Prevention, Mold Prevention Strategies and Possible Health 
Effects in the Aftermath of Hurricanes and Major Floods (Atlanta, 2006) 
and Population-Specific Recommendations for Protection From Exposure to 
Mold in Buildings Flooded After Hurricanes Katrina and Rita, by 
Specific Activity and Risk Factor (Atlanta, 2005). 

[58] We use the term guidance to describe non-binding communications 
agencies issue to the public for educational purposes. 

[59] We considered guidance to be issued by an agency if the agency is 
identified as its author or the guidance displays the agency's logo. 
Guidance documents can be sponsored by multiple federal agencies, and 
some of the guidance we reviewed was also sponsored by agencies other 
than those mentioned above, such as the Department of Agriculture. 

[60] Nonprobability samples cannot be used to generalize or make 
inferences about a population. In this instance, we cannot generalize 
the results of our review of federal guidance to all federal guidance 
to the general public on the health effects of indoor mold issued by 
the Consumer Product Safety Commission, EPA, FEMA, HHS, and HUD. 

[61] For example, we examined guidance from the Occupational Safety and 
Hazard Administration of the Department of Labor, but excluded it from 
our analysis because the mold-related information in this guidance was 
tailored to an occupational and professional context only. 

[62] We contacted at least one person in each program office. Officials 
in some of the program offices listed in this appendix responded that 
they were not conducting or sponsoring any mold research. In addition, 
some of the officials we contacted involved with indoor mold research 
had left their agencies; their offices are not represented in this 
appendix. 

[End of section] 

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