October 24, 2016
A reader asks, “Does the EPA or the FHA have the responsibility for setting the TLVs for mold spores in the air? What if the mold count is higher outside than inside?”
The FHA does not set or regulate such health issues, deferring instead to federal, state, or local authority where applicable. According to the Environmental Protection Agency’s official site, we learn the following about mold as it relates to exposure in buildings (in general):
“Is sampling for mold needed? In most cases, if visible mold growth is present, sampling is unnecessary. Since no EPA or other federal limits have been set for mold or mold spores, sampling cannot be used to check a building’s compliance with federal mold standards. Surface sampling may be useful to determine if an area has been adequately cleaned or remediated. Sampling for mold should be conducted by professionals who have specific experience in designing mold sampling protocols, sampling methods and interpreting results.”
That information can be found at https://www.epa.gov/mold/mold-testing-or-sampling.
A quick check of the FHA loan rules for single family home loans in HUD 4000.1 turns up two references to mold-one specifically mentioning it in the overall context of the FHA appraisal:
“The Appraiser must report known environmental and safety hazards and adverse conditions that may affect the health and safety of the occupants, the Propertys ability to serve as collateral, and the structural soundness of the improvements. Environmental and safety hazards may include defective lead-based paint, mold, toxic chemicals, radioactive materials, other pollution, hazardous activities, and potential damage to the Structure from soil or other differential ground movements, subsidence, flood, and other hazards.”
If mold is present and detected by the FHA appraiser, it is entirely likely that the appraiser will recommend corrections/repairs to fix the issue.
However, FHA appraisers are not mold experts and just because a property “passes” an FHA appraisal does not mean the property is free of mold or any other problem. Borrowers will need to pay for an optional home inspection to determine whether or not a home has defects or other issues that could affect the borrower’s use of the property once the loan has closed.
Borrowers who want to learn more about mold and EPA advice about it should download the EPA’s guide, A Brief Guide To Mold, Moisture, And Your Home which is a downloadable .pdf file.