APCIA Statement on Passage of Legislation Creating Smoke Claim Remediation Standards

SACRAMENTO, CA - The American Property Casualty Insurance Association (APCIA) issued the following statement regarding the California Legislature's approval of AB 1642 and AB 1795. This statement can be attributed to Karen Collins, APCIA vice president, property & environmental. Karen served as one of two insurer representatives on the California Department of Insurance's (CDI) Smoke Claims and Remediation Task Force.

"APCIA recognizes the significant effort that policymakers, the CDI, consumer representatives, public health experts, remediation professionals, and the insurance industry have invested in addressing the complex issue of smoke damage following wildfires. We appreciate CDI's leadership in convening the Smoke Claims and Remediation Task Force, on which APCIA participated, to better understand the challenges facing wildfire survivors and identify opportunities for clearer guidance around testing, remediation, and restoration.

"Wildfire smoke claims involve complex science, evolving research, and deeply personal circumstances for affected families. One of the fundamental challenges facing consumers, regulators, remediation professionals, and insurers has been the absence of universally accepted standards for evaluating and addressing smoke impacts in residential properties. While important implementation work remains, AB 1642 and AB 1795 represent a meaningful step toward clearer guidance on smoke damage claims. As regulations are developed, it will be critical that standards are grounded in credible science, valid methodologies, and the best available technical expertise. APCIA remains committed to working in good faith with policymakers, regulators, consumers, and scientific experts to support standards that protect consumers, improve transparency and understanding, and help maintain affordable and available insurance coverage for Californians.

"Wildfire survivors deserve compassion, clarity, and confidence that their homes have been appropriately evaluated, remediated, and restored using credible, science-based approaches. Our shared goal is a system that provides consumers with clear answers, supports effective remediation, and can be implemented consistently and sustainably over the long term."

Additional Background: Wildfire Smoke Claims, Remediation, and the Importance of Credible Science

APCIA and its member companies extend deep concern to families and communities affected by wildfires. Wildfire recovery is enormously challenging, and insurers remain committed to assisting policyholders throughout the claims process and recovery.

APCIA supports continued public attention on this issue and offers additional scientific and policy context to help consumers, policymakers, and the media better understand these complex matters.

Commitment to Families and Clear Communication

Returning home after a wildfire is an emotional and difficult milestone. Insurers understand these concerns and work to ensure remediation follows established professional methods. The goal is to ensure that homes are appropriately remediated and restored to pre-loss conditions. It is important to recognize that indoor environments naturally contain some level of background particulate matter and chemical compounds, and pre-loss conditions are not the same as a sterile or contaminant-free environment.

Scientific Considerations

• Timing matters. Post-remediation clearance testing reflects conditions shortly after professional cleaning. Testing conducted many months later can be influenced by normal household activity, ventilation, outdoor soil and dust, seasonal environmental conditions, and other factors unrelated to the original remediation.
• Recontamination occurs naturally. Once residents return, normal daily activities can reintroduce particles into indoor spaces, regardless of how thorough the original remediation was. This is a well-recognized challenge in evaluating indoor environmental conditions over time.
• Many substances have multiple potential sources . Heavy metals and other substances can originate from a wide range of environmental and consumer sources. Some contaminants, including lead and arsenic, are widely documented in outdoor environments and soils throughout many communities.
• Outdoor and Indoor Sources. Many substances evaluated after a wildfire may also be present in residential environments from everyday indoor and outdoor sources. Particulate matter, metals, and numerous chemical compounds can originate from building materials, furnishings, consumer products, cooking activities, fireplaces, vehicle emissions, outdoor air infiltration, and other common sources. As a result, environmental testing often requires technical analysis to distinguish between normal background conditions and impacts that may be attributable to a specific wildfire event.

Taken together, these scientific considerations illustrate why interpreting environmental sampling results can be challenging and why the detection of a substance alone does not necessarily establish its source, timing, or relationship to a particular wildfire event. These realities do not diminish the very real concerns that families experience following a wildfire.

Coverage and the Importance of Credible Science

When smoke damage is covered under a policy, insurers routinely provide professional cleaning, remediation, and additional living expenses when appropriate.

A broader challenge has been that no single, universally accepted scientific standard existed for wildfire smoke testing and remediation during many recent wildfire events. As a result, environmental professionals, remediation contractors, consumers, regulators, and insurers sometimes relied on differing methodologies and approaches when evaluating smoke impacts. Moreover, there are no formally established scientific standards for the majority of contaminants found in residential environments. This includes particulate matter, many classes of chemical compounds, and most heavy metals, except in limited circumstances where standards exist, such as certain lead and asbestos applications.

In recent years, substantial progress has been made in developing professional guidance for evaluating and remediating wildfire smoke impacts. In 2025, the American Industrial Hygiene Association (AIHA) released an updated Technical Guide for Wildfire Impact Assessments, outlining best practices for inspection, evaluation, sampling, and restoration decision-making. The guide emphasizes visual and odor-based assessments, targeted testing when warranted, and consideration of factors such as time, distance from the fire, and property-specific characteristics. It received AIHA's 2025 Critics' Choice Award, recognizing it as the most consequential peer-reviewed scientific publication of the year. That same year, the Institute of Inspection Cleaning and Restoration Certification (IICRC), Restoration Industry Association (RIA), and Cleaning Industry Research Institute (CIRI) issued an updated Technical Guide for Wildfire Restoration, providing a structured framework for remediation pathways and post-restoration evaluation. Building on these advances, the ANSI-accredited IICRC S700 Standard for Fire and Smoke Damage Restoration is currently undergoing revision to more fully address wildfire-related losses, including smoke impacts from large-scale wildland-urban interface (WUI) fires. Once finalized, the updated standard is expected to provide a more comprehensive, consensus-based baseline for professional practice. Even with these important developments, significant scientific and methodological questions remain, underscoring the importance of continued collaboration among regulators, public health experts, remediation professionals, scientists, and insurers.

It is also important to note that property insurance generally pays to repair or replace covered physical property and to address covered physical loss. Insurance policies are designed to respond to specific covered events and damages, and claims are evaluated based on the facts of each individual loss and the terms of the applicable policy.

Insurers recognize that wildfire smoke claims involve complex science, evolving research, and deeply emotional circumstances. APCIA continues to work with state agencies, scientific organizations, remediation experts, and other stakeholders to support rigorous, peer-reviewed, consensus-based standards that provide clarity and confidence for consumers.

Insurers are committed to helping consumers better understand:

• What professional remediation can reasonably achieve;
• What "normal background conditions" mean in real-world environments;
• Capabilities and limitations of various testing methods; and
• Why defensible, science-based standards matter for both consumer protection and long-term insurance affordability and availability.