Air Duct Cleaning Iaq Kit

SKILL.md

# Air Duct Cleaning & IAQ Marketing Kit v1.0
**Skill #194 | ClawHub Home Services Trades Bundle v2**

Generate legally compliant, scientifically accurate marketing content for NADCA-certified air duct cleaning and indoor air quality contractors. Seven permanent compliance moats prevent the health claim errors, certification misrepresentations, biocide violations, and mold liability traps that create FTC exposure, EPA enforcement risk, and contractor lawsuit vulnerability.

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## The 7 Compliance Moats

### Moat 1 — NADCA ACR 2021 Certification & Method Gate
**Authority:** National Air Duct Cleaners Association (NADCA) Assessment, Cleaning and Restoration of HVAC Systems (ACR 2021); NADCA member verification registry; EPA "Should You Have the Air Ducts in Your Home Cleaned?" (EPA 402-K-97-002)

**What this blocks:**
- "EPA certified duct cleaner" — PERMANENTLY BLOCKED (EPA does not certify duct cleaning contractors or companies)
- "EPA recommends annual duct cleaning" — PERMANENTLY BLOCKED (EPA explicitly states duct cleaning has not been proven to prevent health problems and may not be necessary)
- "EPA approved cleaning method" — PERMANENTLY BLOCKED (EPA has no approved method standard)
- "NADCA certified company" without verifiable NADCA membership — PERMANENTLY BLOCKED
- "Certified Air Systems Cleaning Specialist (ASCS)" without documented employee credential — PERMANENTLY BLOCKED
- Marketing without NADCA member verification number — blocked as unverifiable NADCA claim

**What's required:**
- NADCA membership number in all marketing claiming NADCA affiliation
- At least one ASCS (Air Systems Cleaning Specialist) certified technician on staff
- Source-removal method per NADCA ACR 2021 Section 5 — contact cleaning at each component, not brush-and-blow
- HVAC system inspection before cleaning quote per NADCA ACR protocol
- Nevada does not have a state duct cleaning license — NADCA is the only recognized industry standard

**Enforcement:** NADCA member # required; "EPA certified" is the most common compliance violation in duct cleaning marketing — creates FTC deceptive practices exposure.

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### Moat 2 — EPA Indoor Air Quality Guidance Gate
**Authority:** EPA "Should You Have the Air Ducts in Your Home Cleaned?" (EPA 402-K-97-002); EPA "An Introduction to Indoor Air Quality" (EPA 402-K-93-007); ACAAI (American College of Allergy, Asthma & Immunology) position on duct cleaning

**What this blocks:**
- "Duct cleaning improves your air quality" — PERMANENTLY BLOCKED without pre/post particle count data from a certified IAQ professional
- "Eliminates allergens from your home" — PERMANENTLY BLOCKED (EPA: no studies show duct cleaning prevents health problems)
- "Prevents illness by removing contaminants" — PERMANENTLY BLOCKED (no peer-reviewed study confirms this)
- "Duct cleaning is recommended by the EPA" — PERMANENTLY BLOCKED (EPA explicitly states it is not certain that cleaning ductwork regularly is beneficial)
- "ACAAI recommends duct cleaning for allergies" — PERMANENTLY BLOCKED (ACAAI does not recommend duct cleaning as a standard allergy treatment)
- "Your family will breathe easier guaranteed" — PERMANENTLY BLOCKED without documented IAQ testing results
- "Reduces dust by X%" — PERMANENTLY BLOCKED without pre/post particle measurement

**What's accurate:**
- EPA states: cleaning may be appropriate IF there is visible mold growth, ducts are infested with rodents or insects, or ducts are clogged with excessive debris and particles actually released into the home
- EPA: "routine duct cleaning... may actually be unnecessary in many cases"
- Honest positioning: NADCA source-removal improves duct system cleanliness — health outcomes require documented pre/post IAQ testing

**Enforcement:** All health improvement claims require documented pre/post IAQ test data from a certified Indoor Air Quality Professional (CIAQP) or Industrial Hygienist.

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### Moat 3 — NADCA Source Removal Method + Negative Air Machine Gate
**Authority:** NADCA ACR 2021 Section 5 (Source Removal); NADCA Technical Advisory Council position on cleaning methods; ASHRAE Standard 180-2018 (Standard Practice for Inspection and Maintenance of Commercial HVAC Systems)

**What this blocks:**
- "Brush and blow cleaning" claimed as NADCA-compliant — PERMANENTLY BLOCKED (brush-and-blow resuspends contaminants; not source-removal per ACR 2021)
- "Truck-mounted vacuum is superior to negative air" — PERMANENTLY BLOCKED (NADCA standard is negative air machine with HEPA filtration at point of air release + contact cleaning at each component)
- "We use the most powerful truck mount in Nevada" — PERMANENTLY BLOCKED as NADCA compliance claim (equipment power ≠ NADCA method compliance)
- "One central vacuum without component cleaning" — PERMANENTLY BLOCKED as source-removal claim
- "Air sweep cleaning" marketed as equivalent to source removal — PERMANENTLY BLOCKED
- Cleaning quote without duct system inspection — PERMANENTLY BLOCKED per NADCA ACR protocol
- "HEPA equipment" without confirming 99.97% filtration at 0.3 microns — PERMANENTLY BLOCKED

**What's required:**
- Negative air machine creating negative pressure in duct system during cleaning
- HEPA filtration of extracted air (99.97% at 0.3 microns minimum)
- Point-of-contact agitation at each supply and return register, air handler, coil, and plenum
- Pre-cleaning inspection of accessible system components
- Post-cleaning verification that system is visually clean per NADCA criteria

**Enforcement:** Method claims must describe the NADCA source-removal process — not equipment brand or horsepower.

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### Moat 4 — Biocide & Chemical Application Compliance (EPA FIFRA + NADCA Policy)
**Authority:** FIFRA 7 USC §136 et seq.; EPA pesticide registration requirements; NADCA position on chemical application (2021 policy statement); EPA "Pesticide Registration" guidance

**What this blocks:**
- "Anti-microbial treatment kills 99.9% of germs in your ducts" — PERMANENTLY BLOCKED without EPA Reg # and documented application protocol
- "We'll spray a free sanitizer in your ducts" — PERMANENTLY BLOCKED (biocide application to duct system is pesticide application under FIFRA; "free" misrepresents optional consent status)
- "Eco-friendly, non-toxic duct sanitizer" — PERMANENTLY BLOCKED without FIFRA-registered product EPA Reg # and third-party efficacy data
- "Chemical-free sanitizing" — PERMANENTLY BLOCKED (UV-C is not a sanitizer; ozone is regulated; dry fogging requires FIFRA registration)
- "We treat mold in your ducts with our proprietary solution" — PERMANENTLY BLOCKED without mold confirmation + EPA-registered biocide with documented protocol
- "Kills mold, bacteria, and viruses" — PERMANENTLY BLOCKED without FIFRA Reg # and EPA-approved efficacy claims for specific pathogens
- Applying any biocide without customer informed consent — PERMANENTLY BLOCKED per NADCA policy

**What's required:**
- Biocide application requires: EPA-registered product with Reg # disclosed, customer informed written consent, technician with pesticide applicator knowledge, SDS available on-site
- NADCA position (2021): "NADCA does not endorse the use of biocides, sealants, or other chemical treatments in duct systems unless mold, infestation, or contamination is confirmed by inspection"
- Biocide use should be disclosed as optional add-on, not included in base service
- FIFRA-registered product label is the law — follow all directions for indoor HVAC applications

**Enforcement:** Biocide EPA Reg # required in all sanitizing/antimicrobial marketing; informed consent required before any chemical application.

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### Moat 5 — Mold Claim Accuracy (EPA Mold Remediation + IICRC S520)
**Authority:** EPA "Mold Remediation in Schools and Commercial Buildings" (EPA 402-K-01-001); IICRC S520 Standard for Professional Mold Remediation; Clark County, NV building code (mold remediation >10 sq ft)

**What this blocks:**
- "We found mold in your ducts" without documented inspection evidence — PERMANENTLY BLOCKED (visual claim requires documented evidence; tape lift or air sample required to confirm)
- "Duct cleaning removes mold" without confirmed mold presence — PERMANENTLY BLOCKED
- "Prevents mold growth in your HVAC system" — PERMANENTLY BLOCKED (no mold prevention claim without documented humidity/moisture control protocol)
- "We can clean your mold problem" for confirmed mold >10 sq ft without licensed mold remediation contractor — PERMANENTLY BLOCKED (Clark County: mold remediation >10 sq ft requires NRS 624 licensed contractor + IICRC S520 protocol)
- "We treat mold with our anti-microbial spray" without post-treatment air sampling — PERMANENTLY BLOCKED
- "Mold-free guarantee" — PERMANENTLY BLOCKED (mold requires moisture source control; duct cleaning alone cannot prevent regrowth without addressing moisture)
- Before/after mold photos without documented test confirmation — PERMANENTLY BLOCKED

**What's required:**
- Mold confirmation: tape lift or air sample by IICRC-certified inspector or certified Industrial Hygienist
- Clark County, NV: mold remediation >10 sq ft = NRS 624 licensed contractor required
- Post-remediation verification: clearance air sample required before "mold removed" claim
- If mold found: refer to licensed mold remediation contractor for >10 sq ft; document smaller areas with photo + tape lift before any cleaning claim
- Moisture source must be identified and corrected or mold will return — disclose in writing

**Enforcement:** Mold claims require documented confirmation; remediation >10 sq ft requires licensed mold remediation contractor; post-clearance sampling required for "mold-free" claim.

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### Moat 6 — NV Contractor License Gate for HVAC Modifications (NRS 624)
**Authority:** NRS 624 (Nevada contractor licensing); NSCB C-21 HVAC-R license; Nevada State Contractors Board enforcement; Clark County building permits

**What this blocks:**
- "We'll add a UV-C light while we're in there" without C-21 HVAC-R license — PERMANENTLY BLOCKED (installing UV-C lights = HVAC modification = NRS 624 C-21 required)
- "We seal your leaky ducts during cleaning" without C-21 — PERMANENTLY BLOCKED (mastic, foil tape on duct board, or Aeroseal aerosol duct sealing = HVAC-R modification)
- "Aeroseal duct sealing included" without C-21 HVAC-R license — PERMANENTLY BLOCKED
- "We replace damaged duct board sections" without C-21 — PERMANENTLY BLOCKED
- "We'll rebalance your dampers during cleaning" without C-21 — PERMANENTLY BLOCKED
- "Complete HVAC restoration" without C-21 license — PERMANENTLY BLOCKED
- "We modify your system for better airflow" without C-21 — PERMANENTLY BLOCKED

**What's required:**
- Duct cleaning only (agitation + vacuum extraction at existing components): no NRS 624 license required
- Any mechanical modification — UV lights, sealant application, duct replacement, damper adjustment, coil replacement — requires NRS 624 C-21 HVAC-R license
- Clark County: permits required for mechanical system modifications (not cleaning)
- Recommended: partner with C-21 licensed HVAC contractor for upsell services; document referral process in marketing

**Enforcement:** All HVAC modification offers must be from C-21 licensed entity — cleaning company may clean, not modify.

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### Moat 7 — FTC 2023 + Magnuson-Moss + TCPA
**Authority:** FTC 16 CFR Part 255 (Guides Concerning Use of Endorsements); FTC Policy Statement on Deceptive Acts (15 USC §45); Magnuson-Moss Warranty Act 15 USC §2301; TCPA 47 USC §227; FTC "Negative Option Rule" 2023

**What this blocks:**
- "#1 air duct cleaning company in Las Vegas" without documented third-party source — PERMANENTLY BLOCKED
- "HEPA certified cleaning" without confirming equipment meets 99.97% at 0.3 micron standard — PERMANENTLY BLOCKED (MERV-13 ≠ HEPA)
- "99% allergen removal guaranteed" without pre/post air sample data — PERMANENTLY BLOCKED
- "Your HVAC manufacturer requires duct cleaning every 2 years to maintain warranty" — PERMANENTLY BLOCKED (no major HVAC manufacturer requires NADCA cleaning as warranty condition; this is a commonly fabricated sales claim)
- "30-year freshness guarantee" or "lifetime clean guarantee" — PERMANENTLY BLOCKED without written warranty terms
- Before/after photos = stock photos or other properties — PERMANENTLY BLOCKED
- Review incentives ("$25 off for a 5-star review") — PERMANENTLY BLOCKED per FTC 2023 Rule
- SMS campaigns without express written consent (TCPA PEWC) — PERMANENTLY BLOCKED
- Drip pricing (advertising low price, adding fees at checkout) — PERMANENTLY BLOCKED per FTC 2023 guidance

**What's required:**
- Superlative claims ("#1") require documented ranking source with date and methodology
- Equipment claims require specification sheet confirming HEPA standard compliance
- Warranty must be in writing with specific terms, duration, and remedy
- SMS opt-in must include TCPA-compliant disclosure and PEWC before first message
- Before/after photos: actual work performed on customer's property; date and address records required
- Price advertised = full price with all fees disclosed before booking

**Enforcement:** All advertising claims must be substantiated with documented evidence on file; TCPA violations are $500-$1,500/message in class action litigation.

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## Output Formats

### Prompt 1 — Seasonal Campaign Package
- Spring (allergy season) + Post-Wildfire IAQ + Year-round maintenance campaigns
- Landing page hero section (headline, subheadline, 3 trust signals, CTA)
- 3 Facebook/Instagram ads (awareness, IAQ angle, social proof)
- 2 Google RSA ad groups (residential + commercial)
- 30-day Google Business Profile post calendar
- 3-email TCPA-compliant welcome sequence
- Nextdoor post (neighborhood trust angle)

### Prompt 2 — Service Pages + Schema Markup
- 6 service pages: Residential Duct Cleaning, Commercial HVAC Cleaning (ASHRAE 180), Dryer Vent Cleaning, Coil Cleaning (evaporator + condenser), Post-Construction Cleanup, IAQ Assessment
- LocalBusiness + HomeAndConstructionBusiness JSON-LD schema

### Prompt 3 — Reputation & Referral System
- 20 FTC 2023-compliant review requests (email, SMS with TCPA, card, verbal)
- 15 Google Business Profile response templates (health claim disputes, mold accusations, "didn't notice a difference," price disputes, biocide consent questions, positive)
- 6 B2B referral letters (real estate agent, home inspector, HVAC contractor, property manager, new home builder, allergy/pulmonologist office)

### Prompt 4 — Digital Ads + Local SEO
- Google LSA eligibility checklist (NADCA membership, background check, insurance, correct category)
- 5 RSA ad groups: residential cleaning, commercial (ASHRAE 180), dryer vent, coil cleaning, IAQ assessment
- 6 Facebook/Instagram ads: spring allergy, post-wildfire smoke, commercial property manager, NADCA vs. uncertified, dryer vent fire safety, post-renovation cleanup
- 30-day GBP calendar
- 25 keyword clusters with NADCA compliance angle
- Commercial property manager cold outreach template

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## Target Market
- NADCA-member residential air duct cleaning companies
- HVAC contractors adding duct cleaning as a service line
- Commercial HVAC maintenance companies (ASHRAE 180)
- IAQ assessment and remediation firms
- Marketing agencies serving duct cleaning contractors

## Pricing
- **Free tier:** Prompt 1 only (seasonal campaign)
- **Standard:** $29 one-time — all 4 prompts + Henderson, NV example
- **DFY:** $97/project — Max runs all content for your contractor