Claim Library · Fire and Smoke Claims

Smoke, Soot and Combustion By-Products After a Colorado Fire: Why HB24-1315 Matters

By: Jeffrey S. Aal, A.I.C.

Published: October 6, 2026

Jurisdiction: Colorado; California materials are discussed as comparative background.

A house does not have to burn to the ground to suffer serious fire-related damage.

Smoke, soot, ash, and other combustion by-products can travel well beyond visibly burned areas. They can settle on finishes and contents, enter HVAC systems, migrate into concealed spaces, and leave property owners with one of the hardest questions following a fire:

How do we know when the property has actually been properly evaluated and remediated?

Colorado has been studying that question directly.

In 2024, the Colorado General Assembly enacted House Bill 24-1315, the Study on Remediation of Property Damaged by Fire. The law directed the Colorado Division of Insurance to study how residential properties damaged by smoke, soot, ash, and other fire-related contaminants are inspected, tested, and remediated, and to make recommendations concerning uniform standards. [1]

That distinction is important.

HB24-1315 did not itself create a mandatory remediation standard. It created a formal process for examining why this area has been so difficult and what more consistent standards might look like. [1]

The Problem Is Bigger Than Visible Soot

The legislation followed the Marshall Fire and expressly recognized that fire-generated contamination can involve more than what a homeowner can see or smell.

The General Assembly identified smoke, soot, ash, particulate matter, volatile organic compounds, and other chemicals as contaminants that can enter walls, floors, furnishings, surfaces, and other components of a home. It also recognized the uncertainty homeowners can face when trying to determine whether a smoke- or ash-damaged property has actually been cleaned to a condition that is safe to occupy. [1]

That is one reason fire claims involving combustion by-products can become complicated.

A visual inspection may identify obvious soot deposition. Odor may indicate that something remains. Neither, by itself, necessarily answers the larger questions:

Was the full extent of impact investigated?
Were appropriate contaminants considered?
Were the sampling locations representative?
Was the HVAC system evaluated?
Were porous and nonporous materials treated differently?
Were contents evaluated separately from the structure?
What standard or clearance criterion is being used to decide that remediation is complete?

Those questions matter because a cleaning scope is only as reliable as the assumptions and investigation supporting it.

Colorado Specifically Asked for a Review of Testing and Remediation Practices

HB24-1315 required the study to evaluate methods for inspecting, testing and remediating residential properties affected by smoke, soot, ash and other contaminants.

The statute also required consideration of existing cleaning and restoration practices, industry standards, indoor-air-quality and health considerations, personal property and furnishings, and the extent to which typical homeowners insurance policies cover remediation costs. [1]

The law expressly identified the Institute of Inspection, Cleaning and Restoration Certification, commonly known as IICRC, as one of the standards-setting organizations to be considered. [1]

Colorado also required participation from a broad group of stakeholders, including public-health experts, industrial hygienists, restoration professionals, homeowners, insurers and consumer representatives. [1]

That breadth matters. Fire remediation is not simply a cleaning question. It can involve building science, chemistry, industrial hygiene, restoration methodology, personal-property evaluation, construction sequencing and insurance coverage.

What the Colorado Draft Study Found

The Colorado Division of Insurance contracted with Partners Environmental Consulting to perform the study. The Division issued a draft report, titled Colorado Wildfire Remediation Analysis: Residential Premises and Insurance Impacts Report, in November 2025. [2]

Among the central issues identified in the draft was the absence of a single accepted Colorado regulatory program governing smoke remediation.

The report discussed differing approaches among consultants and restoration professionals and examined contaminants beyond visible soot, char, and ash, including semi-volatile organic compounds and heavy metals, with emerging attention to other compounds such as dioxins, furans, and PFAS. [2]

California public-health reviewers later described the Colorado report as addressing a wide range of contaminants of concern and evaluating the scientific basis for standardized sampling, testing and cleanup protocols. They also noted an important limitation: the draft did not establish one universal testing protocol applicable to every property. [3]

That is an important point for property owners.

There is a difference between saying:

“There is no single test that applies to every fire.”

and saying:

“Testing is unnecessary.”

Those are not the same conclusion.

Fire type, materials burned, distance from the source, weather conditions, building construction, HVAC operation, visible deposition, odor, occupant concerns, and the intended remediation scope can all affect what investigation is appropriate.

Wildfire Smoke and Structure-Fire Smoke Are Not Necessarily the Same Problem

Another issue receiving increasing attention is the difference between a wildland fire and a fire in the wildland-urban interface.

When homes, vehicles, plastics, electronics, treated building materials, household chemicals and other manufactured products burn, the resulting contaminant profile can be different from smoke generated primarily by vegetation.

The Colorado draft study considered this distinction and recommended that future protocols account for differences between wildland fires and wildland-urban-interface fires. [2]

That does not mean every standing home near a wildfire is contaminated to the same degree. It means the investigation should be based on the actual loss conditions rather than an assumption that all smoke exposure is equivalent.

Why This Matters in an Insurance Claim

From a claim-adjustment standpoint, the most important development may be the increasing focus on methodology.

A disagreement over fire contamination should not automatically become a contest between two conclusions:

“The house is clean.”

“The house is contaminated.”

The more useful questions are factual.

What areas were inspected?
What areas were not inspected?
What contaminants were considered?
What samples were taken?
Where were they taken?
Why were those locations selected?
What analytical methods were used?
What background or comparison data were considered?
What materials are proposed for cleaning?
What materials are proposed for removal?
How will the HVAC system be addressed?
How will contents be handled?
What constitutes successful remediation?
How will that result be verified?

Those questions allow the parties to evaluate the actual methodology rather than simply arguing over competing conclusions.

“Cleanable” Is Not the End of the Analysis

A material may technically be cleanable and still raise practical questions.

The relevant analysis can include the material involved, contamination pathway, accessibility, cleaning method, likelihood of successful remediation, cost, risk of cross-contamination, ability to verify the result and the consequences if the first remediation attempt fails.

Contents require the same discipline.

Soft goods, furniture, electronics, food, porous materials and hard-surface contents do not necessarily present the same remediation issues. A defensible contents evaluation should distinguish among categories rather than treating everything inside the building as a single cleaning problem.

The Colorado study was directed to consider cleaning, repair and remediation not only of structures, but also personal property and home furnishings. [1]

Standards Are Still Developing

Property owners should be cautious about statements that suggest Colorado has already adopted one mandatory statewide smoke-remediation protocol.

The sources reviewed for this article describe a study and recommendations, rather than an adopted, universal statewide smoke-remediation protocol.

HB24-1315 required a study and recommendations. The November 2025 report was identified as a draft. The stakeholder process continued afterward, and publicly available 2026 materials identify additional review of a second version of the study at a September 8, 2026 stakeholder meeting. [4]

The broader discussion is also no longer confined to Colorado. California's Department of Insurance incorporated the Colorado draft study and stakeholder comments into its own Smoke Claims and Remediation Task Force work during 2025 and 2026. [5]

The science and the standards are still developing.

That makes careful documentation more important, not less.

What Colorado Property Owners Can Do After a Smoke or Fire Loss

If your home has been affected by smoke, soot, ash, or other combustion by-products, preserve the evidence before major cleaning or demolition changes the conditions. Document conditions only when it is safe to do so, and follow access restrictions and instructions from fire, building, and public-health officials.

Photograph visible residues and affected areas. Keep records of odors and where they occur. Preserve reports, sampling results, scopes, estimates, and remediation protocols. Ask what portions of the structure and HVAC system were evaluated. Ask what materials or contents were excluded from an inspection and why.

Most importantly, ask for the basis of conclusions.

If someone says an area is unaffected, ask how that was determined.

If someone says a material can be cleaned, ask what cleaning method is proposed and how success will be evaluated.

If testing is recommended, understand what is being tested, where samples will be collected and what the results can and cannot establish.

If testing is rejected, ask for the technical basis for that decision.

The objective is not testing for the sake of testing or demolition for the sake of demolition. It is to develop enough reliable information to determine an appropriate, documented and executable remediation scope.

The Larger Lesson From HB24-1315

Colorado's decision to commission this study reflects something property owners and restoration professionals have confronted for years:

Fire contamination can be technically complex, and the absence of uniform standards can create uncertainty about what to inspect, what to test, what to clean, what to replace, and when the work is complete.

HB24-1315 does not resolve every one of those questions.

It does, however, make them much harder to dismiss.

For homeowners dealing with a smoke, soot, ash or combustion-by-product claim, the practical lesson is straightforward: the investigation matters, the methodology matters, and the documentation matters.

A remediation conclusion should explain not only what someone believes should be done, but why.