An Industry Still Coming of Age

The property damage restoration industry is relatively young compared to traditional construction trades. Restoration work expanded rapidly during the late 20th century. The regulatory and consensus standards that now govern the industry evolved in parallel with the industry rather than sequentially. Consequently, the property damage restoration industry is constantly changing and will be in the foreseeable future. The industry is driven by new standards, rapidly evolving technologies, and increasingly complex regulations. In this environment, proper training is not optional; it is foundational. 

Regulations Preceded Experience 

Within the restoration industry, many years of experience is often equated with qualification. The assertion that “30 years’ experience” confers professional competence fails to account for the fact that federal occupational and environmental regulations were already in place when many restorers began their careers, and hence available to be understood and applied from the start. Many years of experience does not demonstrate that the regulations and standards were understood and applied. For example, 6-mil polyethylene sheeting is thought by some to be a requirement. While 6-mil might be the right material for the job, it is not always a requirement. With asbestos abatement, the Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1926.1101 specifies 6-mil polyethylene sheeting or equivalent on Class I jobs on the HVAC, glove bags, glove box waist bags, loose friable material in adjacent locations, waste bags, and mini-enclosures but nowhere else. A lack of in-depth understanding of the regulations by those who would rather emulate others than read the regulations has resulted in the widespread dispersal of misinformation. Poor training at the outset is compounded, not corrected, by experience and is then perpetuated. 

The Occupational Safety and Health Act of 1970 established OSHA, creating enforceable worker protection requirements. That same statute also created the National Institute for Occupational Safety and Health (NIOSH, 2023) to conduct research, develop recommended exposure limits, and provide scientific guidance for the prevention of work-related injury and disease. Also established in 1970, the U.S. Environmental Protection Agency (EPA, 2023) is the consolidating federal authority over environmental hazards, including asbestos, lead, and air contaminants, etc.. Together, these agencies form the regulatory and scientific foundation upon which modern restoration work must be performed regardless of individual experience or tradition. Due to the massive amount of regulatory documentation, standards, and guidelines, it is not surprising that restorers may have a hard time staying in compliance. How many restorers actually read the thousands of pages of regulations and standards is an unanswerable question. However, it is clear that a person who has not read and understood the regulations, standards, and guidelines cannot possibly do the work according to the law and current American National Standards Institute (ANSI) published standards. One solution would be to hire a qualified industrial hygienist whose job is to know, understand, apply, and reference these bodies of work. There is a reason the restoration industry is composed of contractors and industrial hygiene firms. Both occupations have separate and unique skills and qualifications.

OSHA first established federal asbestos exposure limits in the early 1970s following the enactment of the Occupational Safety and Health Act of 1970. The federal regulation 29 CFR 1910.93a established in 1971 authorized the agency to enforce occupational exposure standards for hazardous substances including asbestos (OSHA, 1971). Asbestos regulation for the construction industry significantly expanded with the publication of 29 CFR 1926.1101 in 1994, which consolidated and formalized asbestos standards specific to the construction industry (OSHA, 1994). An example of the misguided “experience equals qualification” mindset is the persistent misconception within the restoration industry and among insurance carriers that asbestos was somehow “banned” in 1980, a claim that is widely repeated but factually incorrect. The date 1980 should be shocking considering no comprehensive federal asbestos ban ever took effect at that time. In fact, asbestos-containing materials continue to be manufactured, imported, and used in the United States today (EPA, 2024). With the exception of the 2024 ban, the most significant attempt to prohibit asbestos occurred in 1989, when the EPA promulgated Asbestos Ban and Phase-Out Rule under authority of the Toxic Substances Control Act (EPA, 1989). That rule was largely vacated in 1991 by the U.S. Court of Appeals for the Fifth Circuit, which held that the EPA failed to demonstrate that a comprehensive asbestos ban was the least burdensome regulatory alternative required under TSCA, which left most asbestos containing materials legal in commerce (Corrosion Proof Fittings v. EPA, 1991). As a result, asbestos has remained regulated but not banned through a combination of OSHA exposure regulations, EPA use restrictions, and work-practice requirements for more than three decades (EPA, 1989; OSHA, 1994). These laws established a clear principle that still applies today. Work must be performed in accordance with federal, state, and local law regardless of the date of construction, usual habit (e.g. we have always done it this way), or institutional memory. 

Mold Regulation and the Shift Toward Formal Oversight

Mold remediation further illustrates the industry’s maturation. For many years mold work existed in a regulatory gray area, often addressed through guidance rather than enforceable law. That began to change with state-level action, most notably New York’s Mold Program, codified under New York State Labor Law, Chapter 55, Article 32, which established licensing, training, and work practice requirements for mold assessment and remediation contractors (New York State Department of Labor, 2015). The passage of such laws signaled a broader shift: restoration activities were no longer viewed as informal cleaning services but as regulated environmental work. Today more states such as but not limited to Florida and Texas have mold laws. In states with no mold laws, the ANSI/IICRC S520 is often used to challenge whether the contractor complied with the standard practice.

The Role of ANSI/IICRC Standards

The first edition of the IICRC S500 Standard and Reference Guide for Water Damage Restoration was published in 1994. The IICRC S520 Standard and Reference Guide for Professional Mold Remediation was first published in 2003 and represented one of the first formal, consensus-based efforts to define professional mold remediation practices within the property damage restoration industry (Institute of Inspection, Cleaning and Restoration Certification [IICRC], 2003). Prior to this publication, as mentioned previously, mold remediation practices were largely guided by informal recommendations, and a laissez-faire mentality rather than a unified standard. The release of S520 marked a significant transition toward standardized work practices and engineering controls based on consensus and seminal works. The current S520 issued in 2024 is an example of the progression of the ever-changing restoration industry bringing a breath of fresh air compared with the “we have always done it this way” rationale. in January 2026, a bipartisan federal legislative proposal, the Military Occupancy Living Defense (MOLD) Act explicitly identified the ANSI/IICRC S520 Standard for Professional Mold Remediation as the required standard of care for mold remediation activities in covered military housing. The proposed legislation would mandate compliance with ANSI/IICRC S520 and require that mold assessors and remediation professionals maintain independent, third-party certifications, including IICRC credentials, specifically the Applied Microbial Remediation (AMRT) and Mold Remediation Specialist (MRS) certifications when performing work in military residential environments. This legislation is  more evidence supporting the need for education based on ANSI/IICRC standards.

Experience Is Not Compliance

Experience has value but should be paired with an in-depth understanding of regulatory compliance, comprehension of the standards, along with current facts, and evidence-based training. Performing work the same way for decades does not confer legitimacy if those methods fail to conform with current OSHA regulations, EPA regulations, applicable ANSI standards, and current peer reviewed science. Courts, regulators, and insurers increasingly evaluate restoration work based on documented adherence to recognized requirements, not anecdotal experience. Training must emphasize not only how work is performed, but why specific procedures are required per the current laws and standards.

Reading is a Professional Obligation

One of the most overlooked components of training and learning is reading. Equipment owner’s manuals, OSHA regulations, EPA regulations, consensus documents, and seminal works, are not optional background materials. These are all primary components of one’s professional responsibility. Equipment manufacturers explicitly require operators to understand limitations, maintenance requirements, and safety warnings. Failure to read and follow these documents exposes workers to injury and companies to liability. How many people have read the entire owner’s manual for their moisture meter or were even given a copy of it? Does everyone check the calibration of a meter and document that it is within calibration tolerances before and after each job? Again, these questions can never be answered. One suggestion for training is to give the employee a copy of the manual, have them read it, and then come to work the next day and train the crew in how to use the meter. This method of training would ensure that the employee understands the “how and why” pertaining to the use and function of the meter. This assumes that the rest of the crew has the knowledge to guide the new employee by correcting mistakes and clarifying misunderstandings. 

Reading is also foundational to learning itself. Educational psychology has long recognized that learning begins with understanding, followed by retention, and ultimately application. Bloom’s Taxonomy describes learning as a hierarchical process progressing from knowledge and comprehension to application, analysis, synthesis and evaluation (Bloom et al., 1956). Training that skips foundational understanding in favor of rote demonstration undermines long-term competence.

People Learn Differently and Training Should Reflect That

Not all workers learn or retain information the same way. Some individuals are strong visual learners, others learn best through hands-on demonstration, and some retain information most effectively through reading and reflection etc. Effective training programs should acknowledge these differences and incorporate multiple instructional modalities, including written materials, visual demonstrations, and supervised field practice. OSHA (2019) emphasizes the importance of training methods that workers can understand and apply in real-world scenarios. Research from the Harvard Graduate School of Education (2022) demonstrated that learning is most effective when instruction incorporates multiple instructional approaches, including reading, visual explanation, discussion, and hands-on practice, rather than relying solely on testing or demonstration. Such multi-modal instruction improves comprehension, retention, and the transfer of knowledge to real-world tasks especially in applied, technical professions.

Hands-on training is essential in restoration, but it must be founded on current standards and regulations. Demonstrating how to set containment or operate drying equipment is insufficient if workers do not understand why certain controls are required, when deviations are prohibited, and which regulations govern their actions. Field training should reinforce not replace formal instruction and reading.

 While the restoration industry is still relatively young it is no longer in its infancy and it will continue to evolve. As regulations change such as the OSHA silica regulations and standards continue to be updated and changed, training must move beyond tradition and habit toward intentionally informed professional development. Promoting reading, regulatory literacy, and learning theory is not academic excess; it is essential to worker safety, legal compliance, and professional credibility. In the property damage restoration industry learning should not be optional. Experience matters if it is founded on scientific knowledge and applicable laws and standards.

Precision Matters: Why Citation and Verification Are Professional Obligations

In professional practice, statements such as “according to OSHA” or “per the S500” mean absolutely nothing unless they are accompanied by specific citations to the applicable regulation, section, or standard. OSHA requirements are enforceable only as written in statute or regulation, and ANSI/IICRC standards derive their authority from precise language, scope, and defined terminology. Vague references undermine technical accuracy, complicate the facts, and lend exposure to regulatory and legal risk. OSHA (2015) has consistently emphasized that employers are responsible for understanding and applying the specific provisions of applicable standards, not generalized interpretations or informal summaries.

The need for precision is increasingly important today due to the growing prevalence of misinformation and oversimplification, especially through social media, blogs, online forums, and word-of-mouth. Researchers (Vosoughi et al., 2018) have demonstrated that professional and technical misinformation spreads readily through informal channels detached from primary sources, e.g. seminal works with no contextual limitations. In the restoration industry, the lack of citation and references can lead to the normalization and widespread distribution of incorrect practices based on anecdote rather than evidence. Statements repeated frequently like those previously mentioned relating to asbestos and the date 1980, despite lacking citation can take on the appearance of the truth, a phenomenon well documented in cognitive and information science literature (Lewandowsky et al., 2012).

Professional skepticism, therefore, is not cynicism but rather a necessary discipline. Like a good scientist, we should all be skeptical of what we hear and, in some cases, skeptical of what we read. Ask questions like “according to who or based on what”. We must trace information back to the primary sources, including federal regulations, consensus standards, and peer-reviewed literature, and verify that cited requirements are current and applicable. The American Psychological Association (2020) has long emphasized that credible professional communication depends on transparent sourcing and verifiable evidence, particularly when claims may influence health, safety, or legal outcomes. In the restoration industry, accuracy is not an academic exercise; it is a core component of due diligence, regulatory compliance, and ethical professional conduct.

References

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Corrosion Proof Fittings v. Environmental Protection Agency, 947 F.2d 1201 (5th Cir. 1991).

Harvard Graduate School of Education. (2022). How people learn: Designing education for deep understanding. https://www.gse.harvard.edu/ideas/usable-knowledge/18/01/how-people-learn

Institute of Inspection, Cleaning and Restoration Certification. (2003). IICRC S520 standard and reference guide for professional mold remediation (1st ed.). IICRC.

Institute of Inspection, Cleaning and Restoration Certification. (2026, January 15). New military housing bill puts IICRC’s certifications and mold standard front and center [Press release]. https://www.iicrc.org

Lewandowsky, S., Ecker, U. K. H., Seifert, C. M., Schwarz, N., & Cook, J. (2012). Misinformation and its correction: Continued influence and successful debiasing. Psychological Science in the Public Interest, 13(3), 106–131. https://doi.org/10.1177/1529100612451018

National Institute for Occupational Safety and Health. (2023). About NIOSH. Centers for Disease Control and Prevention. https://www.cdc.gov/niosh/about

New York State Department of Labor. (2015). Article 32: Mold program. https://dol.ny.gov/mold-program

Occupational Safety and Health Act of 1970, 29 U.S.C. § 651 et seq.

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Occupational Safety and Health Administration. (2015). Training requirements in OSHA standards (OSHA Publication 2254-09R 2015). U.S. Department of Labor. https://www.osha.gov/publications/osha2254.pdf

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U.S. Environmental Protection Agency. (1989). Asbestos; manufacture, importation, processing, and distribution in commerce prohibitions; final rule (54 Fed. Reg. 29460).

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U.S. Environmental Protection Agency. (2024). EPA finalizes ban on ongoing uses of chrysotile asbestos. https://www.epa.gov/newsreleases/epa-finalizes-ban-ongoing-uses-chrysotile-asbestos 

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