Weatherization Assistance Program Health and Safety Guidance

1. Weatherization Assistance Program Health and Safety Guidance Ryan Middleton ryan.middleton@ee.doe.gov

2. WAP Health & Safety • Authority from 10 CFR 440.21 (c) • DOE Issued Revised H&S Guidance WPN 11-6 • Response to concerns with clarity and consistency in how health and safety issues are approached by grantees. • DOE reconvened Health and Safety Committee to review trends and practices of the WAP network to update guidance. • Primary goal of Program remains “energy efficiency”. • Energy-related health & safety measures are those actions necessary to maintain the physical well being of both the occupants and/or weatherization workers where: • Costs are reasonable as determined by DOE in accordance with the grantee’s approved Grantee Plan; AND • The actions must be taken to effectively perform weatherization work; OR • The actions are necessary as a result of weatherization work. • Grantees encouraged to budget H&S costs as a separate category to exclude costs from the overall average per-unit costs and avoid cost justification.

3. Health & Safety Guidance WPN 11-6 • Guides the grantee in creating their H&S Plan, which once approved by DOE, is used as the guiding document for subgrantees. • Addresses Action/Allowability, Testing, Client Education, and Training for the following Health and Safety Categories: • Air Conditioning/Heating Systems • Appliances/Water Heaters • Asbestos • Biologicals/Unsanitary Conditions • Building Structure/Roofing • Code Compliance • Combustion Gases • Drainage • Electrical • Fire Hazards • Air Pollutants • Injury Prevention • Lead Based Paint • Mold/Moisture • Occupant Preexisting/Potential Health Conditions • OSHA and Crew Safety • Pests • Radon • Refrigerant • Smoke/CO Detectors • Solid Fuel Heating • Space Heaters • Spray Polyurethane Foam • Ventilation • Window/Door Replacement

4. H & S Plan Minimum Requirements • Include health and safety expenditure limits, expressed as a percentage of average cost per dwelling unit, w/ justification and related historical experience. • Method to determine when DOE funds will be used and if they cannot, what other treatment will be sought. • System for remedy of potential health and safety issues including when partial weatherization can be conducted. • System for referral to other agencies. • System for determining when deferral is necessary. • Procedures for implementing training requirements. • Outline of testing to be performed based on guidance. • Protocols for informing clients of potential hazards. • Procedures for collecting known or suspected occupant health concerns.

5. H & S Plan Minimum Requirements Cont… • Strategy for implementation of ASHRAE 62.2 in 2012. • Strategy for smoke/CO detector guidance implementation. • Protocols on air conditioning and heating system repair and installation. • Procedures on handling problems resulting from combustion gas testing. • Strategy for implementing OSHA and crew safety guidance. • Protocols for addressing mold found in the client’s home. • Plan for implementing and verifying RRP and LSW compliance.

6. Health & Safety Budget Review • Does the state have a separate H & S budget? • If H & S items are not included in a separate H & S budget or are defined as incidental repairs, they must be addressed as such consistently throughout the state and must be cost justified. • Expenditure limits must be “reasonable” and expressed as an per unit average. • Generally 10%. • Less assumes other funding is being utilized to address H & S. • More requires adequate justification relative to the increase. • 15% and up requires additional DOE group review.

7. Health & Safety Plan Review • As described in §440.16(h), DOE will monitor the plan based on the following criteria: • elimination of such hazards is necessary before, or as a result of, the installation of weatherization materials; and • the grantee sets forth a limitation on the percent of average dwelling unit costs that may be used to mitigate such hazards, which is reasonable in light of the primary energy conservation purpose of the Weatherization Assistance Program. • Meeting the WPN 11-6 Guidance. • Is the required narrative/implementation strategy present? • Is it consistent with H & S guidance (cannot conflict)?

8. Health & Safety Plan Review • Cont. • If an action/testing is “allowed” in guidance grantees can concur, create additional requirements/limitations, or not allow. • If “required” or “not allowed” – states must follow guidance. • Important to consider what the guidance is specifically referring to – in what instances the action is allowed. • Conducting certain actions will trigger specific testing, client education, and training requirements.

9. Health & Safety Guidance Table • Some common themes and requirements that should be considered when utilizing the Guidance Table are as follows: • Where removal or replacement is addressed, proper disposal is required, and allowed as a H & S cost. • Where hazards are identified, clients must be informed in writing and the document must be signed by the client and a copy maintained in the client file. • State and local (or jurisdiction having authority) codes must be followed while installing health and safety measures. • Workers must be qualified and adequately trained according to state and local (or jurisdiction having authority) codes specific to the work being conducted (electrical, plumbing, etc.). • Where Actions/Allowability, Testing, Client Education, and Training are allowed or required, DOE funds may be used unless specified otherwise.