What Are the Pass/Fail Criteria for Post-Remediation Mold Clearance?

Clearance is where a mold job is won or lost reputationally. A clean remediation with a sloppy clearance report leaves everyone exposed, and a clearance written by the firm that did the removal carries a built-in conflict the next reader will spot. This page covers what "passing" actually means and how to document it.

What are the pass/fail criteria for post-remediation mold clearance?

There is no single numeric pass score; clearance is a convergence of checks. IICRC S520 addresses post-remediation verification as the step that confirms the remediation met its objective — the work area is dry, the visible growth and contaminated materials are gone, and the air inside the formerly contaminated space is consistent with a normal indoor environment (IICRC, S520). In practice clearance rests on three legs: a visual inspection finding no remaining visible mold or moisture-damaged material, moisture readings showing the materials are dry, and — where air sampling is used — an indoor result comparable to a same-day outdoor control.

"Pass" is the alignment of those three. A space can fail clearance on any one of them: visible debris left behind, a moisture reading that says the wall is still wet, or an air sample that runs high against the outdoor baseline.

Does clearance have a numeric spore-count threshold?

No, and asserting one is the most common clearance-report error. Neither IICRC S520, the EPA, nor the AIHA Green Book sets a numeric "clearance limit" for airborne spores, because no health-based universal threshold exists. The EPA's remediation guidance frames a successful outcome as the absence of visible mold and the return to normal conditions, not a count crossing a line (EPA, Mold Remediation in Schools and Commercial Buildings).

So when air sampling is part of clearance, the criterion is comparative: the indoor sample should be consistent with the same-day outdoor control in both count and species profile, with no indoor amplification of indicator genera and no indoor presence of organisms like Stachybotrys (AIHA, Recognition, Evaluation, and Control of Indoor Mold). A clearance report that states a sample "passed the limit of X spores/m³" is inventing a standard. The defensible version describes the indoor-to-outdoor relationship and the visual and moisture results together.

Why must clearance be independent of the remediator?

Because the person being graded should not be the person grading. The credibility of a clearance rests on the verifier having no financial stake in declaring the job done. IICRC S520 treats post-remediation verification as a distinct function, and many state mold programs codify the separation directly, barring the same firm from both remediating and clearing the same property. A clearance signed by the removal contractor invites exactly the conflict-of-interest challenge that undermines the report in a dispute.

This is the same assessment-remediation independence that runs through the S520 report requirements. The clearance inspector is, in effect, performing a focused assessment of the post-work condition — and the report should read as an independent verification, not a victory lap.

What goes in a defensible clearance report?

A clearance report documents each leg of the verification with evidence. The visual inspection records that the work area, containment, and adjacent areas show no remaining visible growth or moisture damage, with photos. The moisture readings show the previously wet materials are now dry, with the locations and values. If air sampling was performed, the report presents the indoor results against the same-day outdoor control, identifies the method (commonly direct microscopy per ASTM D7391), and states the comparative interpretation. The conclusion — pass or fail — ties back to those documented findings, not to an asserted threshold.

What makes it survive scrutiny is the same thing that makes any report defensible: every conclusion maps to a recorded observation. MoldMind generates the clearance report itself from the second visit's evidence — visual findings, moisture readings and post-remediation samples — so the pass/fail conclusion is traceable to what was recorded rather than smoothed into narrative. Both outcomes are full documents: a passing result and a failing one are written to the same standard, because the report that justifies another round of remediation matters as much as the one that closes the job. The inspector confirms or corrects the determination and approves before anything is issued. See the sample report and the when-each-standard-applies guide for how clearance fits the broader standards map.

Which jurisdictions put clearance-report contents into law?

Three: Texas, New York and the District of Columbia. Everywhere else a licensing statute regulates who may perform the work rather than what the resulting document has to say, and the standards above are guidance — authoritative, widely relied on, but not an enumerated contents list anyone can be cited for omitting.

The three are not equivalent, and the differences are not cosmetic. Texas and the District each enumerate the elements the document must contain, and the two lists overlap without matching. New York mandates the document and prescribes nothing at all about its contents. All three split the requirement by outcome, so a passing report and a failing one are different documents with different names.

The vocabulary differs too, and it shows up on the cover page. Texas and New York call the passing document a passed clearance report (16 TAC §78.140(d); NY Labor Law §947(3)). The District's rules do not use the word "clearance" for the document at all — its defined term is a verification report (20 DCMR §3299.1). A DC report headed "Clearance Report" is using a word its governing rule never applies to the document.

What must a Texas passed clearance report contain?

Six elements, at 16 TAC §78.140(d). A consultant who determines that remediation has been successful must issue a written passed clearance report to the client at the conclusion of each mold remediation project, and it "must include the following":

  1. a description of relevant worksite observations;
  2. the type and location of all measurements made and samples collected at the worksite;
  3. all data obtained at the worksite, including temperature, humidity, and material moisture readings;
  4. the results of analytical evaluation of the samples collected at the worksite;
  5. copies of all photographs taken by the mold assessment consultant; and
  6. a clear statement that the project has passed clearance.

Two of those "all"s do real work. Elements (2) and (5) mean the report carries the complete record, not a curated selection — a Texas clearance report showing six representative photographs out of forty is short of the rule, and the practical answer is a complete photographic appendix rather than a longer narrative.

Those six sit on top of the assessment duties in §78.140(a)-(c), which decide what there is to report in the first place. The post-remediation assessment uses "visual, procedural, and analytical methods", and if walk-in containment was used during remediation it "shall be conducted while the walk-in containment is in place" — sequencing that has to be arranged with the contractor before the assessor arrives. It determines whether the work area is "free from all visible mold and wood rot" (wood rot is a Texas addition — neither New York's §947(1) nor the District's list names it) and whether all work complied with the protocol and met the clearance criteria the protocol specified. §78.140(b) adds the underlying-cause finding, to the extent feasible, so that the mold "will not return from that remediated cause."

§78.140(c)(2) is the one most often missed: the consultant must use "only the analytical methods and the criteria for evaluating analytical results that were specified in the remediation protocol", unless circumstances beyond the control of the consultant and the contractor require otherwise — and a deviation requires written documentation of the need for it plus the client's approval before the assessment proceeds, not an explanation afterwards. §78.140(c)(3) runs the other way and is worth knowing: where visual inspection reveals deficiencies sufficient to fail clearance, analytical methods need not be used at all.

What must a District of Columbia verification report contain?

Nine elements, at 20 DCMR §3299.1 — and unlike Texas, the District writes them into the definition of the document. They are not a paragraph of the rule you can cite as "§3299.1(a)"; they are the lettered contents of the defined term verification report, which is why a precise citation names the definition. A report missing them is not a defective verification report so much as not a verification report.

Elements (a) to (e) track Texas closely but say "relevant" where Texas says "all": a description of relevant worksite observations; the type and location of relevant measurements made and samples collected; relevant data obtained at the worksite, including temperature, humidity and material moisture readings; the results of analytical evaluation of the samples; and copies of relevant photographs.

Four have no Texas counterpart:

  • (f) if necessary, recommendations of specific professional disciplines that may be needed to determine that the cause and origin of moisture leading to indoor mold growth has been properly remediated;
  • (g) where (f) is used, a statement that the project's verified completion is contingent on those disciplines performing work that remediates the cause and origin of that moisture — so the document cannot assert completion and recommend further specialists without saying how the two relate;
  • (h) an area for the indoor mold remediation professional who worked on the project to enter name, signature, company name and license number, carrying the language "I hereby certify that I completed mold remediation on this project";
  • (i) four clear statements, based on the assessment professional's observation: that all project areas are "free from visible mold, and visible dust and debris as they are related to the project"; that all work was completed in compliance with the remediation protocol; that all identified underlying causes have been remediated so that it is reasonably certain the mold will not return from those same causes; and that the project is verified as complete.

Element (h) makes the District's verification report a jointly executed document — a signature area for the remediation contractor, a different party from the author. It is not the assessor's certification restated, and it must never be pre-filled or auto-signed on the contractor's behalf. That design follows from a deliberate District choice: when the 2021 rulemaking was proposed, a commenter asked DOEE to forbid the same licensee from performing assessment and remediation on one project, and DOEE declined, "due to concerns that requiring separate assessment and remediation professionals could be more burdensome and costly for landlords and could ultimately delay mold remediation for tenants." The independence problem set out above does not disappear in the District — it moves inside the document, where disclosing a dual role is what keeps the report credible to a skeptical reader.

Two further duties sit outside §3299. §3204.6(c) gives ten days after successful completion of remediation activities to provide the verification report to three recipients: the client, the current resident of the unit, and the appropriate indoor mold remediation professional. The resident is the recipient most often missed, and is the point of the 2021 amendment — DOEE added it because "the tenant should be informed when his or her unit is mold-free." §3204.6(d) requires every issued report, protocol or other document to carry the date it was issued and all indoor mold assessment professionals' names, license numbers and, if applicable, business name and addresses.

What does New York require in a clearance report?

New York mandates the document and prescribes nothing about what goes in it. Labor Law §947(3) is the entire content requirement: a licensee "who determines that remediation has been successful shall issue a written passed clearance report to the client at the conclusion of each mold remediation project." The eight enumerated elements New York does prescribe live in Labor Law §945 and attach to the remediation plan, not to any clearance document — reading them across is a common and confident mistake.

What §947 regulates is the assessment behind the report. §947(1) requires the post-remediation assessment to determine whether the work area is "free from all visible mold" and whether all work was completed in compliance with the remediation plan and remediation work plan and meets the clearance criteria specified in the plan. §947(2) adds the underlying-cause finding, and where the underlying cause has not been remediated, requires a recommendation to the client as to the type of contractor who could remedy the source of the mold or the moisture causing it.

One drafting detail matters if you quote the statute inside the report: New York's §947(2) ends "will not return from that remediated area", where the parallel Texas provision at §78.140(b) ends "will not return from that remediated cause." Quote whichever governs the property. Merging the two into one sentence attributes wording to a statute that does not carry it.

Because §947 adds no elements, a report built to the Texas and District lists already exceeds what New York asks of the passing document. New York's one added duty lands on the other path.

What must the report say when the project does not pass?

All three jurisdictions call the failing document a final status report, and none of them treats it as the passing report with a sentence deleted.

  • Texas (§78.140(e)) — the items listed in (d)(1)-(5), everything but the pass statement, plus "any conclusions that the consultant has drawn", issued to the client and to the remediation contractor or company performing the project.
  • District of Columbia (§3299.1) — a separately defined six-element document: relevant worksite observations; the type and location of relevant measurements and samples; relevant data such as temperature, humidity and material moisture readings; the results of analytical evaluation; copies of relevant photographs; and "any conclusions that the indoor mold assessment professional has drawn." It drops the contractor's certification area and all four (i) statements and adds conclusions, so it is not a subset of the verification report. §3204.6(c) attaches the same ten days and the same three recipients to it.
  • New York (§947(4)) — the licensee "shall issue a written final status report to the client and to the remediation licensee and recommend to the client that either a new assessment be conducted, that the remediation plan as originally developed be completed, or the underlying causes of mold be addressed, as appropriate." Read closely, that three-way recommendation is a duty on the licensee rather than a prescribed element of the report — §947 enumerates contents for neither document — but the recommendation that is still on the record a year later is the one written into the final status report, not the one made in a covering email.

The triggers differ, and it is worth reading them precisely. Texas §78.140(e) and DC §3204.6(c) both tie the final status report to the assessor ceasing to be involved with the project before it passes; New York's §947(4) ties it to the determination alone. The defensible practice is to produce the full failure document whenever the project does not pass, whoever stays on the job — it is the report that justifies another round of remediation, and it is the one most likely to be read adversarially later.

MoldMind issues the passing document as a Passed Clearance Report in Texas and New York and as a Verification Report in the District of Columbia, with the District's contractor certification area rendered blank for the contractor to sign, and it writes the final status report on the failure path to the same standard. A compliance panel beside the draft lists the elements the property's jurisdiction calls for and flags the ones it cannot find — a checklist that catches omissions, not a compliance guarantee. The determination and the signature remain the inspector's. State licensing details are on the Texas, New York and District of Columbia pages.

Sources

  • IICRC, S520 Standard for Professional Mold Remediation — post-remediation verification framework.
  • EPA, Mold Remediation in Schools and Commercial Buildings — success defined as no visible mold and return to normal conditions.
  • AIHA, Recognition, Evaluation, and Control of Indoor Mold — comparative indoor-versus-outdoor clearance interpretation.
  • 16 TAC §78.140 (TDLR) — Texas clearance criteria, the six passed-clearance-report elements, and the final status report.
  • 20 DCMR §3299.1 (DOEE) — the District's definitions of "verification report" (nine lettered elements) and "final status report" (six), effective 5/7/2021.
  • 20 DCMR §3204.6 (DOEE) — ten-day delivery to the client, the current resident of the unit, and the remediation professional; issued-document date, names, license numbers and addresses.
  • NY Labor Law §947 — post-remediation assessment, the passed clearance report, and the final status report's three-way recommendation.

Sources

Write the report in minutes, not hours.

MoldMind turns your field notes, photos, and lab results into a standards-compliant report you review and approve. Try MoldMind free — 3 jobs, no card.