The ERMI Timeline.
Why the experts tell you NEVER use ERMI. EVER.
Here is a timeline of ERMI development and the repeated, very clear warnings from EPA about not using it.
Each dated item has one or more excerpts from the document to demonstrate the conclusion of that document or author.
There are links to the original documents where available.
The short commentary at the end is mine.
You are encouraged to COMMENT if you have information contrary to any of this. Or if you have new information you think might clarify the serious critique of such a well-known, but very misunderstood technical sampling method.
In the meantime,
DECIDE FOR YOURSELF
why ERMI is NOT Recommended by anyone who knows science and data.
A Collection of comments and quotes, direct from reputable and credible science sources.
INTRO
In the very early 2000’s, a couple very good researchers at the U.S. EPA, developed the ERMI sampling and analysis method. They are considered the “inventors” of ERMI and were granted a patent for their technological achievement. Papers were published, and many scientists, specialists, and experts in the health and environmental sciences reviewed, commented and critiqued the method. Most of them were not complimentary or supportive. Over time, the EPA realized it had to conduct an internal review of their own work, and the use of this novel analysis method. The result was astounding but also satisfying to those who fully understood the application, its shortcomings, and its misuse in the public for-profit sector.
From 2013 until just recently in 2023, The EPA has continually warned the public that ERMI is NOT valid for use as an assessment tool for building damage, mold growth, or impact (risk) on health, or mold exposure.
Leading doctors, naturopaths, health coaches, “IEP”s, remediators, labs, trainers, and even non-profit professional organizations in the “Mold-related” health sector have completely, and repeatedly, and knowingly ignored these warnings and have advised literally thousands of their patients and clients to obtain an ERMI sample and lab analysis. They have done this without being transparent about the problems or the EPA warning to not use ERMI “ever”. I have never met a client who knew that the EPA said it is not to be used.
This has resulted in countless errors, costly decisions, and often, people literally abandoning their homes and possessions. The potential and actual dollar amount of this malpractice is staggering.
There have been no updates and no new information, studies, validating research, or data that suggest this warning has changed, lessened, or been removed since 2023. The supporting commentary and criticisms remain applicable and in full force at the time of this writing, February, 2024.
Keep scrolling to see The ERMI Timeline … but,
While you take a breath to let this sink in before you move on to the gory details, this is a great time to help me develop and deliver more great information on mold, health, and how to keep your home and family healthier and safer!
The Timeline of ERMI
2002
EPA - Patent for MSQPCR for ERMI development
“The U.S. Patent and Trademark Office granted the EPA a patent for MSQPCR in May 2002. The two EPA scientists identified on the patent as the inventors assigned their patent rights to the EPA. “
Under the Federal Technology Transfer Act of 1986, the EPA has licensed MSQPCR to 21 companies between August 2000 and Aug 2013. (Ed., Unknown number of licenses between Aug 2013 and Jan 2024)
2004
EPA - ERMI research and development, related paper published.
“Specific Molds Associated With Asthma in Water-Damaged Homes”, Vesper, Stephen J. PhD; McKinstry, Craig PhD; Yang, Chin PhD; Haugland, Richard A. PhD; Kercsmar, Carolyn M. MD; Yike, Iwona PhD; Schluchter, Mark D. PhD; Kirchner, H Lester PhD; Sobolewski, John MS; Allan, Terrence M. MS; Dearborn, Dorr G. MD, PhD, Journal of Occupational and Environmental Medicine, Aug 2006.
2007
HUD and EPA. - First paper explaining ERMI development.
In 2007, EPA and U.S. Department of Housing and Urban Development researchers developed ERMI as a way to objectively describe the mold burden present in a home.
2013
EPA Office of Inspector General
U.S. EPA, Office of the Inspector General, “Public May Be Making Indoor Mold Cleanup Decisions Based on EPA Tool Developed Only for Research Applications”, Report No. 13-P-0356, August 22, 2013.
Excerpts from “What We Found”
“(The) review (was conducted) from December 2012 to June 2013 in accordance with generally accepted government auditing standards.”
“The EPA readily acknowledged that it had not validated or peer reviewed MSQPCR or ERMI for public use. The agency said it considers MSQPCR and ERMI to be research tools not intended for public use. ... In our view, ...licensee’s advertising could mislead the public into thinking that these research tools are EPA-approved methods for evaluating indoor mold.”
…not intended for public use…
“We substantiated the allegation that firms were using the mold index tool although the EPA had not validated the tool for public use.”
“Consequently, there is a risk that the public may make inappropriate decisions or take unnecessary actions regarding indoor mold on the belief that MSQPCR and ERMI results were based on research tools fully validated and endorsed by the EPA for public use.
“Since the EPA does not regulate indoor mold, there are no regulatory requirements regarding the development of indoor mold quantification technology or its use.
“...if samples from the same home were sent to two or more MSQPCR licensed labs, there is no guarantee that the homeowner would get the same test results.
“If mold samples are not collected in accordance with the sampling procedures used to develop the ERMI, the results would be of questionable value.
…the results would be of questionable value…
“Consequently, homeowners and building owners are at risk of spending tens of thousands of dollars to remediate their homes or buildings based on test results that may or may not be accurate. Further, other homeowners and building owners may not take needed remedial actions to address indoor mold risks based on the test results.”
See webpage, https://www.epa.gov/office-inspector-general/report-public-may-be-making-indoor-mold-cleanup-decisions-based-epa-tool
2015
R. SHOEMAKER: Essay on the Dave Asprey/Bulletproof ERMI Lab Scandal.
Self-published by Shoemaker on his website, his company and brand, “Surviving Mold”.
Summary and comment of this essay by JSA:
In 2015, there was an EPA investigation into non-valid EMSL results and lack of lab quality controls.
Shoemaker writes about the FLAWED Analysis results and the EPA “Investigation” of ERMI. BUT he conveniently FORGETS to mention that years prior the EPA said do NOT do what Asprey is offering to his customers? WTF? No really – WTF?
This is absolutely amazing. Why bother with worrying about lab results if they lab should NOT be done in the first place?
Ironic isn’t it? That Ritchie Shoemaker goes out of his way to write a seemingly serious critique of the LAB method, but NOT on the COLLECTION method, or lack of building/environment CHARACTERIZATION, etc.
A rational, objective, and non-biased critique of this scandal would start with, and focus on the fact that prior to this scandal, the patent-holder of ERMI said MULTIPLE times and places, “do NOT use ERMI for assessments”.
Both the essay author, Shoemaker, and the lab, and the promoter (BulletProof and Shoemaker) knew about ERMI long before 2015.
…they all (BulletProof, Asprey, Shoemaker, and EMSL) ignore that fact that ERMI was not valid and they ALL continued to sell, market, and profit…
Which would obviously stop the marketing and sales of the sample. But instead, they all (BulletProof, Asprey, Shoemaker, and EMSL) ignore that fact that ERMI was not valid and they ALL continued to sell, market, and profit from the promotion, recommendation, and sale of ERMI sampling. This is almost too much to comprehend. I thing there’s a word for this – unethical.
And, Shoemaker then promotes Asprey/Bulletproof analysis as USEFUL if you just request a re-do? Hmm... can you say “conflict of interest”? “self-promotion”? “mutual admiration society”?
2015
…MSQPCR and ERMI have not been peer reviewed or validated for public use…
EPA Inspector General
“Report at a glance”
“...there is a risk that the public may make inappropriate decisions regarding indoor mold on the belief that MSQPCR and ERMI results were based on research tools fully validated and endorsed by the EPA for public use
“We also recommend that the EPA remove or clarify potentially misleading statements on its webpage, and finalize a fact sheet on indoor mold, MSQPCR and ERMI to inform the public that MSQPCR and ERMI have not been peer reviewed or validated for public use.
See webpage, https://www.epa.gov/sites/default/files/2015-09/documents/20130822-13-p-0356_glance.pdf
2016
EPA National Exposure Research Laboratory
Science in Action, 2016, by David Kryak, PhD, EPA National Exposure Research Laboratory
“(the MSQPCR and ERMI) have not been validated for non-research purposes.“
See webpage, https://www.epa.gov/sites/default/files/2016-01/documents/ermi_0.pdf
2021
…ERMI has not been validated for public use in homes, schools, or other buildings…
EPA National Exposure Research Laboratory
Science in Action ERMI fact sheet, David Kryak, Ph.D., EPA National Exposure Research Laboratory
“At this point in its development, the ERMI should be used only for research. The ERMI has not been validated for routine public use in homes, schools, or other buildings. “
https://19january2021snapshot.epa.gov/sites/static/files/2017-04/documents/ermi_fact_sheet.pdf
2021
EPA Center for Environmental Measurement and Modeling
“ERMI” by Kevin Oshima, Ph.D., EPA Center for Environmental Measurement and Modeling,
“EPA does not recommend the routine public use of ERMI in homes, schools, or other buildings.
“ERMI has been peer reviewed for research purposes but has not been validated for non-research purposes. For this reason, EPA does not recommend the routine public use of ERMI in homes, schools, or other buildings. “
“Inspection for (visible and historical) water damage and (visible) mold (growth) remain the key to current EPA mold-assessment guidance.
2023
“Should I test using ERMI? ”No.”
EPA Mold info:
Q: “Should I test or sample for mold in my home using the Environmental Relative Moldiness Index, or ERMI?
A: “No. The Environmental Relative Moldiness Index, or ERMI, developed by U.S. Environmental Protection Agency researchers, is a research tool and is not recommended for use except as a research tool.
See webpage, https://www.epa.gov/mold/should-i-test-or-sample-mold-my-home-using-environmental-relative-moldiness-index-or-ermi
2024
ACGIH (pre-publication)
Bioaerosols, 2nd Ed., Chapter 10 Data Interpretation:
The Environmental Relative Moldiness Index (ERMI) was developed by researchers from the US Environmental Protection Agency (EPA) and US Department of Housing and Urban Development by developing an index to determine an ERMI-based scale of relative moldiness to correlate potential health effects and categories of mold found in residential carpeting. However, the EPA states that ERMI is a research tool only and “does not recommend the routine public use of ERMI in homes, schools, or other buildings.”
Now Is the Time - SIGNUP for NOTIFICATIONS of NEW POSTS and VALUABLE INFORMATION from MoldLogic and Scott Armour!
Quick Comments by JSA
I have provided these and similar comments over various dates for many years via TEXT/FB posts and in-person with clients and people looking for honest, reference-supported answers.
ERMI, there is no data or evidence that relates the point on the curve to any illness. The colors are simply quartiles of the data - this means, green is the 25% of homes with an ERMI score under negative 4 (lowest). yellow range is the middle 50% of scores (between -4 and 6), and red is the last 25% of homes, which had an ERMI score above 6. The numbers correlate to no quantification such as type or amount of mold growth or water damage or illness. The research did not follow up on anything - it was a one-time study but EPA stopped it. So your interpretation of ERMI should be based more than just the index number - you should focus on three things:
a thorough understanding of the building conditions using a visual inspection,
a damage/construction/repair history,
and operations/functions review and analysis.
The HERTSMI-2 score is only for Shoemaker medical protocols when a physician prescribes cholestyramine to "remove mycotoxins". It is based on his own research that he says predicts whether a patient will respond positively. (NOTE: no other medical doctors use it for this purpose as it has not been validated nor approved by FDA for this treatment - talk to your physician about these details.) Additionally, it is limited in some ways. He is very confident that HERTSMI scores higher than 15 will have very poor outcomes - i.e., the patient will not respond to the cholestyramine detox treatment and will remain ill. Scores under 15 do not provide strong significant statistical confidence for predicting recovery outcome. So my advice, don't sweat the lower numbers, and don't use ERMI unless you have a very very good assessor who knows how to inspect, etc.
Testing and sampling is very complex - the interpretation requires more than just the lab results. The most important thing is the assessment: 1. physical inspection of every nook and cranny of the home, 2. building history of damage, water, repairs, 3. building function/operations review and analysis , and 4. occupant health survey.
Putting these FOUR things in place first
will get you more and better info than any sampling.
There are so many reasons not to do a home test of any kind. There are equally so many reasons not to pay an inspector to do tests of any kind.
Once you do the other parts of the assessment, then you can figure out an "hypothesis", which is a question – and if you can't predict how the sample will answer a question (or won’t or can’t answer the question), you shouldn’t take it.
All sampling must increase the power of your decision-making.
FOOTNOTE
Just a quick bit of background reference info on ERMI - because you can never have too many facts!
Vesper, S., L. Wymer, D. Cox, G. Dewalt, E. Pinzer, W. Friedman, AND P. Ashley. The Environmental Relative Moldiness Index reveals changes in mold contamination in United States homes over time. JOURNAL OF OCCUPATIONAL AND ENVIRONMENTAL HYGIENE. Taylor & Francis, Inc., Philadelphia, PA, 18(1):35-41, (2021).
Comparison of AHHS I (2004) vs AHHS II (2019)
The Environmental Relative Moldiness Index (ERMI) was created (2007) using dust samples taken during the first American Healthy Homes Survey (AHHS I) conducted by the Department of Housing and Urban Development (HUD) in 2004, which sampled 1,096 homes selected to be representative of the U.S. housing stock.
In 2019, HUD completed AHHS II by sampling 695 homes.
https://cfpub.epa.gov/si/si_public_record_Report.cfm?Lab=CEMM&dirEntryId=350617
Scott, Thank you for taking the time to put together this great resource!
Will you please comment on companies that are rebranding and repackaging ERMI with significant upsells, up to $724/test, like TheDustTest.com?
They provide their own "Mold Code" results - Code 1 to Code 5 with different percentile ranking of Mold in your home vs "Other Homes"
Their marketing claim why their test is better than ERMI:
"The Dust Test gives you better actionable data such as, how many sources of mold does my home likely have? How likely is it that my home contains mycotoxins? All based upon years of real home inspection and testing data to provide you contextually relevant information that you can actually use."
I’m a 4-3-53 (Shoemaker’s “dreaded genotype” that he claimed he could never get well because any exposure will always again trigger the inflammatory cascade - note: that’s not accurate as I AM well after a long journey back to health, even in the house that made me sick), but to stay well I do have to live in a clean house - I am the most blessed to have one now after my family believed me and did about $100k of remediation. But because of my sensitivity, I can tell (depending on how bad the problem is) within 1 second, 5 minutes, an hour, or after symptoms that night, if a building is safe for healing or not. (Though some people can heal in places I cannot be, like a friend who has a fairly high amount of Stachy (per the ERMI) in building materials in the walls - she is getting well but I tank after 5 minutes in her house - likely due to that genetic difference). So far, the HERTSMI-2 scores seem to be a visual representation of what I feel in a space, with a very high correlation to whether or not I could stay in a building very long. Air tests, on the other hand, had “normal” levels of mold, according to one inspector, while our house was literally killing me. I would argue the HERTSMI is useful for those without my spidey-sense to get some kind of information about what they are looking at with a building. But it definitely can’t be the only thing relied on…when inspecting a new home, after the initial boxes you mentioned are checked, the sensitive person needs to spend some hours there and watch for symptoms during and afterward, or you can end up like my friends who tried to move cross-country based on a good ERMI, but within a week their most sensitive family-member was so sick she was in the hospital!