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Inquiry Into Biotoxin-Related Illnesses in Australia Submission 33

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Inquiry Into Biotoxin-Related Illnesses in Australia Submission 33 COVERING LETTER RE: Inquiry into Biotoxin-related Illnesses in Australia, 1st August 2018 Thank you for the opportunity to make a submission to this inquiry. About Biological Health Services is one of Australia’s leading environmental consultancies and laboratories and provides on-site water damage assessment and mould inspections. We also process samples sent in to us from remediation contractors, assessors, occupational hygienists, tenants and homeowner occupants and from patients under medical or allied health-care from across Australia. I write to you on behalf of Biological Health Services and by way of background will explain who I am. My name is Dr. Cameron Jones and I’m an environmental microbiologist. I have worked in the area of fungal biology (mycology) since 1991 at University as a PhD level academic researcher and lecturer in microbiology and environmental health respectively. More recently, and for close to a decade I have run Biological Health Services which is a commercial indoor air quality and microbiology lab and consultancy and am an active contributor at scientific conferences. I am also an Adjunct Research Fellow at the National Institute of Integrative Medicine and am regularly called upon as an expert witness in mould and water damage disputes. On this basis, I am pleased to make this submission to the Inquiry into Biotoxin-related Illnesses in Australia. Introduction In order to highlight what is common to so many of the disputes surrounding biotoxin- related illness I will recap on how I first became involved in this area. In 2005 I was engaged to perform my first paid indoor air quality and mould inspection for a couple who wanted their home tested. The husband claimed his wife could no longer live inside and was suffering from a range of allergic and auto-immune illnesses which they claimed were a result of unwanted exposure to water damage that was affecting their apartment. The couple had recently arrived from overseas in good health and had purchased a new apartment in the Southbank precinct. On entry to their home there was an immediate strong smell of mould all down the central corridor and extending into the master bedroom and open plan main living areas. Sampling indoors quickly revealed the airspace to be contaminated with high levels of airborne mould. The reason for this was an ongoing leak from the bathroom in the adjoining apartment that was causing water damage to their plasterboard party-wall, skirting and carpet. A dispute between the new owners, their neighbor and the Body Corporate was concurrent with the fear surrounding new and rapid-onset adverse health and property- damage, mould and building-defect claims and the need for successful resolution. 1 This started what has turned into several thousand indoor air quality and mould inspections that I have personally conducted in Victoria, interstate and overseas in residential, commercial and government buildings. Response to the Terms of Reference This submission focusses on many of the Terms of Reference covered by this Inquiry and is supportive of the health and safety issues and broader public health implications. In order to do this, I have prepared a position paper that defines those aspects of water damage and mould biology that can occur within the built environment and I discuss how this is currently approached and managed by different stakeholders. For example, a search of the literature shows an increasing number of publications across different disciplines that focus on water damage, mould and health. However, there is a failure in consensus over many of these facts which can result in overestimating or underestimating the scale of the problem or its management and underpins the fundamental need for this Inquiry. It is my opinion that mould is both an environmental toxin and a threat to property. These are twin aspects of a connected-problem and at present, is not being adequately managed or solved in Australia by Government or various industry or health stakeholders. Because of this lack of consensus over what constitutes normal mould levels versus unhygienic or unsafe mould levels, there is considerable civil dispute over cause and effect and what defines exposure and risk to persons. At the outset it is important to recognize that adverse health claims resulting from water damage are not restricted to biotoxins or in all cases result in chronic inflammation. The challenge for the Inquiry will be to highlight and extend on established scientific facts whilst providing improvements in identification of building-specific factors and linking these with sound medical diagnostics and treatments. This should result in more favorable outcomes both in the clinic and at the home-intervention and property level. My position paper is broken up into 12 sections and addresses the Terms of Reference following the designated numbering scheme: 1. The prevalence and geographic distribution of biotoxin-related illnesses in Australia, particularly related to water-damaged buildings; 2. The prevalence of Chronic Inflammatory Response Syndrome (CIRS) or biotoxin related illness in Australian patients and the treatment available to them; 3. The current medical process of identifying biotoxin-related illness in patients and the medical evaluation of symptom complexes attributed to biotoxins and CIRS; 4. Any intersection with other chronic diseases; 2 5. Investment in contemporary Australian research to discover and provide evidence of CIRS as a chronic, multisystem disease; 6. Research into biotoxin-related illness caused from water damaged buildings; and 7. Any related matters. How the position paper maps back to the Terms of Reference are listed in bold inside square brackets for each Section heading: 1. Introduction [1] 2. What’s in the air? [2] 3. Legal disputes – the Victorian example [1] 4. Whistleblowing, consumer and insurance fraud [3,7] 5. Where is the water? [1,4] 6. What are the symptoms? [3,5] 7. How and what do we measure? [2,4] 8. CIRS – is it just a controversial illness category? [2,6] 9. Unregulated testing methods [2,4,6] 10. Internet-era medical misinformation [2,6] 11. Improved terminology for healthcare providers [3,6] 12. Advocacy and health equity [5,6] Recommendations In the position paper following this letter (the submission) I will elaborate on these themes but my recommendations to the Inquiry are summarized into 6 key areas: 1. Research Establish a fund for Australian research into indoor air quality and mould exposure following water damage or suspect water damage that investigates different building exposure metrics with the aim of cross-correlation with clinical biomarkers (e.g. questionnaires, mycotoxin, allergy, genetic screening, etc.) of exposure. This should enable and foster fundamental, collaborative, multidisciplinary and applied research. Linkage grants and direct financial support with Industry and the University and/or Clinical sectors should be encouraged. 2. Education & Training Training for persons carrying out practical mould remediation and assessment should be moved into the Vocational Education and Training (VET) framework. This is to enhance the calibre and delivery of quality educational content and ensure inclusion of local and international standards, guidelines and 3 educational topics and perspectives. Private RTO’s currently offer non- accredited courses thereby leading to peer-driven consensus bias for the Industry as a whole. Establish online resources and other non-accredited training through incentives for partnership development with industry groups so information verticals can be linked with for example, the Continuing Professional Development system, to foster learning and engagement. 3. Real Estate A working party should be setup to consult and focus on tenancy and owner- occupancy issues surrounding water damage and mould hygiene with the view towards development of checklists, assessment protocols, advice and advocacy options for all stakeholders. This should include representation spanning residential, commercial real estate, investment and property management, strata, social housing, disability and aged care along with mortgage lending/banking, insurance, remediation contractors, builders, individual trades and architects, HVAC specialists, medical/healthcare/scientific, legal and dispute resolution personnel. 4. Communications Improve the terminology and definitions surrounding exposure of persons to water damaged buildings that does not only focus on one aspect of risk (i.e. inflammation) but encompasses all aspects of adverse health linked to indoor moisture including well-established factors like allergy and respiratory distress. At present, the use of ‘CIRS’ is limiting in scope of the problem and is furthermore not accepted by the wider academic or medical community and is seen by some as a fringe-area of medicine. How the definitions, goals and recommendations that develop from this Inquiry are communicated is of the utmost importance. To appropriately message often complex scientific and medical concepts will require development of a suitable communications framework. To this end a working group with expertise in the analysis, research, development and implementation of topic-appropriate communications should be established to ensure that key messages are inclusive and accurate and do not evoke unwanted emotional attachment to marginal group-think. 5. Technical Standards & Guidelines Minimum testing standards and guidelines for the inspection and assessment
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