Comment #1Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 1-2Paragraph / Figure / Table / Note: 102.1.1.1Comment Type: EditorialComment: The verb "Employee" used in section 102.1.1.1 is nonsensical syntax. Proposed Change: 102.1.1.1 Have Employee or contract with a Quality Assurance Designee (QA Designee) that oversees the Provider’s compliance with Chapter 9 of these Standards and any specific QA requirements for other Provider categories that may apply to a particular organization.
The verb "Employee" used in section 102.1.1.1 is nonsensical syntax.
102.1.1.1 Have Employee or contract with a Quality Assurance Designee (QA Designee) that oversees the Provider’s compliance with Chapter 9 of these Standards and any specific QA requirements for other Provider categories that may apply to a particular organization.
Comment #2Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 6-3 Labeling of HomesComment Type: GeneralComment: Imagine making the cost of QC go down ten fold while at the same time driving quality delivered UP tenfold. To have true and simple quality control, all you have to do is publish ratings. The market will create tools for homeowners that uncovers improperly rated homes. Before even that happens, homeowners will drive QC. If you rate my house, but I can't see the ratings of my neighbors homes, the rating has very little meaning to me. Comparing to some hypothetical "average" house mean? What make the AVERAGE house similar to my SPECIFIC house? What does a rating matter if everyone can't see it? I propose publishing to a Google Map (maybe by providing to Zillow) all but occupant personal information to all structures rated, past and present.
Imagine making the cost of QC go down ten fold while at the same time driving quality delivered UP tenfold.
To have true and simple quality control, all you have to do is publish ratings. The market will create tools for homeowners that uncovers improperly rated homes. Before even that happens, homeowners will drive QC.
If you rate my house, but I can't see the ratings of my neighbors homes, the rating has very little meaning to me. Comparing to some hypothetical "average" house mean? What make the AVERAGE house similar to my SPECIFIC house?
What does a rating matter if everyone can't see it?
I propose publishing to a Google Map (maybe by providing to Zillow) all but occupant personal information to all structures rated, past and present.
Comment #3Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 5Paragraph / Figure / Table / Note: 102.1.2.5Comment Type: GeneralComment: Delete "no less than". No less than could be 3, 5, 10 or 25 years. By deleting, this would bring this section in line with other parts of the standard. Proposed Change: 102.1.2.5 Recertification of Raters or Rating Field Inspectors no less than every three (3) years.
Delete "no less than". No less than could be 3, 5, 10 or 25 years. By deleting, this would bring this section in line with other parts of the standard.
102.1.2.5 Recertification of Raters or Rating Field Inspectors no less than every three (3) years.
Comment #4Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 6Paragraph / Figure / Table / Note: 102.1.4.3Comment Type: GeneralComment: Blower door test should be required for a rating. Proposed Change: 102.1.4.3 Blower Door Test completed on all homes claiming credit for reduced air infiltration following the procedures and proctocols in section 802.
Blower door test should be required for a rating.
102.1.4.3 Blower Door Test completed on all homes claiming credit for reduced air infiltration following the procedures and proctocols in section 802.
Comment #5Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 6Paragraph / Figure / Table / Note: 102.1.4.4Comment Type: GeneralComment: Duct testing should be perfomed for a rating where duct systems are present in the home. Proposed Change: 102.1.4.4 Duct testing completed on all homes where air distribution systems are present claiming credit for reduced air distribution system leakage following the procedures and proctocols in section 803.
Duct testing should be perfomed for a rating where duct systems are present in the home.
102.1.4.4 Duct testing completed on all homes where air distribution systems are present claiming credit for reduced air distribution system leakage following the procedures and proctocols in section 803.
Comment #6Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 7Paragraph / Figure / Table / Note: 102.1.4.5.2Comment Type: EditorialComment: The program, if describing software should state software. If describing the QA Providers HERS Rating program, this should be spelled out. Proposed Change: 102.1.4.5.2 Estimated energy and cost savings of improvements based upon assumptions contained in the home energy rating QA Provider program software.
The program, if describing software should state software. If describing the QA Providers HERS Rating program, this should be spelled out.
102.1.4.5.2 Estimated energy and cost savings of improvements based upon assumptions contained in the home energy rating QA Provider program software.
Comment #7Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 26Paragraph / Figure / Table / Note: 903.1Comment Type: GeneralComment: The Quality Assurance committee should not be able to decide who will provide the quality assurance review. Proposed Change: 903.1 RESNET shall select a number of accredited Rating Quality Assurance Providers (QA Providers) and conduct an annual review of their Quality Assurance records. This QA review may be a review of electronic files submitted to RESNET upon request, an onsite field review, or both. The RESNET Quality Assurance Committee Staff shall determine the number of QA Providers that shall be reviewed on an annual basis and who will provide the quality assurance review.
The Quality Assurance committee should not be able to decide who will provide the quality assurance review.
903.1 RESNET shall select a number of accredited Rating Quality Assurance Providers (QA Providers) and conduct an annual review of their Quality Assurance records. This QA review may be a review of electronic files submitted to RESNET upon request, an onsite field review, or both. The RESNET Quality Assurance Committee Staff shall determine the number of QA Providers that shall be reviewed on an annual basis and who will provide the quality assurance review.
Comment #8Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 46Paragraph / Figure / Table / Note: 908.2.2Comment Type: GeneralComment: If the Ethics and Appeals Committee reports to the Board of Directors, then the QA committee should not have any oversight. Section 908.2.2 should be removed entirely. Proposed Change: 908.2.2 Review and rule on the merits of appeals from the Ethics and Appeals Committee;
If the Ethics and Appeals Committee reports to the Board of Directors, then the QA committee should not have any oversight. Section 908.2.2 should be removed entirely.
908.2.2 Review and rule on the merits of appeals from the Ethics and Appeals Committee;
Comment #9Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 51Paragraph / Figure / Table / Note: 911.2.4Comment Type: EditorialComment: The abbreviation "QA" should be removed. The entire section 911 refers to providers generally, not specifically the QA Provider. Proposed Change: 9101.2.4 For each approved QA Provider accreditation application, RESNET shall issue a unique Accreditation Identification Number (AIN) to the QA Provider. In accordance with 911.1, the accredited Provider will be incorporated into the respective national registry of accredited Providers.
The abbreviation "QA" should be removed. The entire section 911 refers to providers generally, not specifically the QA Provider.
9101.2.4 For each approved QA Provider accreditation application, RESNET shall issue a unique Accreditation Identification Number (AIN) to the QA Provider. In accordance with 911.1, the accredited Provider will be incorporated into the respective national registry of accredited Providers.
Comment #10Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 57Paragraph / Figure / Table / Note: 912.5.4.1Comment Type: EditorialComment: The word Provider's is possessive. The third time this is used is incorrect. Proposed Change: 912.5.4.1 RESNET will inform the Provider’s known clients, Raters, rating software suppliers and any known affected EEP’s of the Provider’s suspended/revoked status. To the extent practicable, the Provider’s shall assist RESNET with notifications;
The word Provider's is possessive. The third time this is used is incorrect.
912.5.4.1 RESNET will inform the Provider’s known clients, Raters, rating software suppliers and any known affected EEP’s of the Provider’s suspended/revoked status. To the extent practicable, the Provider’s shall assist RESNET with notifications;
Comment #11Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 1-9Paragraph / Figure / Table / Note: 102.1.4.7.3.5Comment Type: EditorialComment: Get numbering consistent (section 102.1.4.7.3.5 Fraud, section 102.1.4.7.3.5 Revocation) Proposed Change: Renumber the sections so that numbers aren't repeated.
Get numbering consistent (section 102.1.4.7.3.5 Fraud, section 102.1.4.7.3.5 Revocation)
Renumber the sections so that numbers aren't repeated.
Comment #12Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 6-2Paragraph / Figure / Table / Note: Chapter 6Comment Type: GeneralComment: Delete Chapter 6 in its entirety. Current codes (as published by the ICC) do not allow for sampling of thermal bypass inspections, duct leakage testing, or blower door testing if visual inspection is not performed. As we are aligning with the codes and working with the ICC to get HERS Ratings recognized for code compliance, a sampling process simply won't work and have any credibility with code officials. Proposed Change: Chapter Six RESNET Standards 600 RESNET NATIONAL STANDARD FOR SAMPLED RATINGS 601 GENERAL PROVISIONS 601.1 Purpose Sampling is intended to provide certification that a group of new homes meets a particular threshold such as ENERGY STAR®, energy code compliance, or qualification for an energy efficiency lending program. It is based on pre-analysis of building plans meeting the intended qualification (e.g. a HERS Index threshold), and subsequent random testing and inspections of a sample set of the homes as-built. Certifying a group of homes by sampling entitles the customer to documentation certifying that the homes meet the desired threshold; it does not constitute a confirmed HERS rating on any home. 601.2 Scope This chapter sets out the procedures for the accreditation of Sampling Providers. Accredited Sampling Providers shall assume all warranties and liabilities associated with the sampling of homes. RESNET does not provide any warranty, either explicit or implied, that sampled homes will meet or exceed the threshold specifications for the sample set. There may be instances in which state laws or regulations differ from these Standards. In such instances, state law or regulation shall take precedence over this standard. 602 DEFINITIONS AND ACRONYMS See Appendix B. 603 TECHNICAL REQUIREMENTS FOR SAMPLING 603.1 Compliance Requirements The testing and inspection of homes for minimum rated features shall be conducted in compliance with the procedures for conducting home energy ratings and Builder Option Packages (BOPs) contained in this Standard. 603.2 Homes Eligible to be Sampled The homes being sampled shall be of the same construction type using the same envelope systems. 603.3 Analysis of Homes A Worst-Case Analysis shall be performed on each home plan in the sample set,. If an option or change in the design of the structure is made that differs from those used in the initial analysis in a way that would require more stringent threshold specifications, then that home must be individually rated. At a minimum, a certified Rater shall oversee this process. 603.4 Labeling of Homes ?603.4.1 Every home plan within a given sample set shall be assigned the same HERS Index as determined by the worst-case analysis and threshold specification for theat floor plan for that home. 603.4.2 Every home subjected to this sampling Standard shall be provided with a label in accordance with Section 303.3 of these standards, which contains the following statement: “This home has been certified using a sampling protocol in accordance with Chapter 6 of the RESNET Standards (see http://resnet.us.standards/ www.RESNET.us)”. This label shall be located on the electrical panel and the font shall be a minimum of 10 points. 603.5 Sample Set of Homes Sampling controls may be applied to any sample set of homes within the same subdivision, community or metropolitan area and climate zone (as specified in the most current edition of the IECC), provided the criteria in Item 603.2 are met and: 603.5.1 Each sample set is made up of homes at the same stage of construction (e.g. pre- drywall, final); 603.5.2 For each stage of construction, each sample set will be comprised composed of homes eligible for the applicable sampling controls within a 30 calendar day period. For example: a sample set that is defined for a pre-drywall inspection must include homes that are eligible for that pre-drywall inspection within a given 30-day period. If fewer than seven (7) homes are available for that phase of inspection, the sample set must be cut off at the number of homes that are available within that 30-day period. This sample set need not be carried through to final inspection; in fact, a whole new sample set may be defined for the final inspection phase based on the homes available for that phase within a new, 30-day period applied to that phase of tests and inspections. 603.5.3 Each home subject to sampling is required to be part of an identified set of sampling controls for each test or inspection that is sampled; 603.5.4 Each participating subdivision within a metropolitan area is subject to sampling controls on at least one home in any 90 calendar day period; 603.5.5 Each participating subdivision within a metropolitan area must start a minimum of one home in any 90 calendar day period. 603.6 Application of Sampling The application of the sampling controls in this standard are only required for those tests and inspections that are not conducted on every home. Sampling controls shall be conducted for any tests and inspections not conducted on every home, according to the field testing and inspection requirements of 303.6.2. 603.7 Sampling Controls 603.7.1 A complete set of Sampling Controls shall be performed at a minimum ratio of one (1) test or inspection per seven (7) homes within a given sample set. At a minimum, a certified Rater shall oversee this process. 603.7.2 Sampling Providers may complete the sampling controls collectively on a single home or distribute the tests and inspections across several homes within a given sample set, provided the total number of individual tests and inspections meets or exceeds the minimum ratio set forth in 603.7.1. 603.7.3 To qualify for sampling in a metropolitan area, a builder shall first complete, without any incidence of failure, a complete set of sampling controls on at least seven (7) consecutive homes in that metropolitan area. For this initial phase of testing and inspections, the complete set of sampling controls shall be performed on each of the seven (7) homes. 603.7.3.1 Exception: A builder who has been implementing a sampling process for certifying homes in a specific metropolitan area under the EPA's ENERGY STAR® for Homes program as of January 1, 2008, will be allowed a one time exception to 603.7.3 for that metropolitan area. 603.7.3.12: For each newly started subdivision, sampling may begin for each sampling control only after three (3) of a particular sampling control passes consecutively homes have been completed without any incidence of failure. 603.7.4 Having successfully met the requirements of 603.7.3, a Sampling Provider may complete sampling controls for a builder indefinitely until a “failure” occurs or any of the criteria set forth in 603.2 are no longer met. 603.7.5 A complete set of sampling controls, whether performed on a single home or spread across several homes, must be completed whether or not one or more failure(s) are found. 603.7.6 When an “initial failure” occurs, the failed item(s) shall be tested or inspected in two (2) additional homes selected from the same sample set. Testing and/or inspections for any item(s) that may become inaccessible during the construction process, (e.g. wall insulation) must be timed so additional testing and/or inspections can occur on other homes in the sample set before they become inaccessible for inspection or testing. 603.7.7 When an “additional failure” occurs, in one or more of the two (2) additional homes, the failed item(s) shall be tested or inspected in the remaining four (4) homes selected for the same sample set. 603.7.8 Until the failure is corrected in all identified (failed) homes in the sample set, none of the homes shall be deemed to meet the threshold or labeling criteria. 603.8 Multiple “Additional Failures” Action is required if three (3) “additional failures” occur within a ninety (90) calendar day period. The required action depends on whether those “additional failures” apply to the same failed item or various failed items. 603.8.1 If the multiple “additional failures” all apply to the same failed item, the builder shall submit to 100% inspection of that failed item, for a minimum of seven (7) homes, before resuming sampling of that item. Remaining unrelated sampling controls may be conducted on a sampled basis throughout this process. 603.8.2 If the multiple “additional failures” apply to various failed items, or additional failed items are found during testing and inspection of additional homes, the builder must begin again and complete 603.7.3 at a minimum, before continuing with sampling. 603.8.3 Exception: If a builder conducts a “root cause analysis” on an item or items covered under 603.8.1 or 603.8.2, and submits it in writing to the sampling Provider, sampling may resume as soon as the Provider deems that the solution has been implemented. The “root cause analysis” report shall contain at a minimum: 603.8.3.1 A written description of the problem(s) covered by the analysis; 603.8.3.2 A written explanation of the underlying reason(s) that the problem(s) occurred (e.g. inadequate training of subcontractor(s) or site supervisors, insufficient information or inadequate detail in the plans or specifications, etc); 603.8.3.3 A written description of a clearly defined process to correct the underlying cause(s); 603.8.3.4 A written description of when and how that process has been carried out; 603.8.3.5 A copy of the root cause analysis report shall be kept by the sampling Provider as part of the QA file, for a period of time of three (3) years, consistent with the requirements of 102.1.4.8.2. 603.9 Quality Assurance by Sampling Providers 603.9.1 The Sampling Provider’s Rating Quality Assurance Provider QA Designee shall be responsible for monitoring compliance with the sampling process and maintaining records in accordance with the requirements of Chapter 9. 603.9.2 In addition to the Quality Assurance requirements specified in Chapter 9 for Home Energy Rating Providers, a Sampling Provider’s QUALITY assurance process shall include, at a minimum, the following: 603.9.2.1 All homes that are qualified by the use of sampling shall be considered to be rated homes. QA file review and field monitoring shall be conducted on a percentage of all the homes certified or qualified under sampling, rather than the percentage of tested and inspected homes. 603.9.2.2 The field QA required in Chapter 9 may be conducted on any of the qualified or certified homes within the sample sets, and shall not be limited to the tested and inspected homes. ????????????????????????604 RATING SAMPLING PROVIDER ACCREDITATION CRITERIA ??604.1 Minimum Standards for Home Energy Rating Sampling Provider (Sampling Provider) Accreditation. Home Energy Rating Sampling Providers shall be accredited in accordance with the Accreditation Process specified in Chapter 9 of these Standards. A Sampling Provider must specifically meet the following minimum standards for Accreditation. 604.1.1 All Sampling Providers shall be accredited by RESNET as a Home Energy Rating QA Providers in good standing and must maintain their accreditation in good standing. 604.1.2 A Sampling Provider’s accreditation must be renewed annually by RESNET. 604.1.3 In order to be eligible to be a Sampling Provider, the RESNET- accredited rating QA Provider shall complete a minimum of twenty-five (25) confirmed ratings as an accredited QA Provider that have been documented to be accurate by the Rating QA Provider’s Quality Aassurance Ddesignee. 604.1.4 The Sampling Provider shall demonstrate to RESNET a minimum insurance coverage of $1,000,000 in general liability coverage and $1,000,000 in professional liability coverage. 604.1.5 Builders cannot use the sampling standard to certify or qualify homes in which they have a financial interest. 604.2 Responsibilities of Accredited Sampling Providers 604.2.1 Sampling Providers are responsible for ensuring that all of the Sampling inspections conducted and issued by their sampling program are in compliance with all of the criteria by which the system was accredited. 604.2.2 Sampling Providers are responsible for ensuring that the specifications for the minimum rated features for the sampled homes be communicated to the personnel or trades responsible for completing the work. 604.2.3 Minimum Standards For Sampling Provider’s Operation Policies and Procedures must be written and provide for the following: 604.2.3.1 Field inspections and tracking of all homes in the sample set for verifying threshold technical specifications and tracking failures and re-inspections; 604.2.3.2 Blower Door Testing completed for sample sets in which the threshold specifications include credit for reduced air infiltration lower than the default value; 604.2.3.3 Duct testing completed for sample sets in which the threshold specifications include credit for reduced air distribution system leakage lower than the default value; ?????????????????????????????604.2.3.4 Sampling Inspector discipline procedures that include progressive discipline involving Probation - Suspension – Termination. 605 EFFECTIVE DATES 605.1 Quality Assurance July 1, 2007 – Section 603.9 shall be implemented by all sampling Raters and Providers. 605.2 Effective Date of Standard January 1, 2008 – The remainder of Chapter 6 shall be implemented by all sampling Raters and Providers ?????????????
Delete Chapter 6 in its entirety. Current codes (as published by the ICC) do not allow for sampling of thermal bypass inspections, duct leakage testing, or blower door testing if visual inspection is not performed. As we are aligning with the codes and working with the ICC to get HERS Ratings recognized for code compliance, a sampling process simply won't work and have any credibility with code officials.
Chapter Six RESNET Standards 600 RESNET NATIONAL STANDARD FOR SAMPLED RATINGS 601 GENERAL PROVISIONS 601.1 Purpose Sampling is intended to provide certification that a group of new homes meets a particular threshold such as ENERGY STAR®, energy code compliance, or qualification for an energy efficiency lending program. It is based on pre-analysis of building plans meeting the intended qualification (e.g. a HERS Index threshold), and subsequent random testing and inspections of a sample set of the homes as-built. Certifying a group of homes by sampling entitles the customer to documentation certifying that the homes meet the desired threshold; it does not constitute a confirmed HERS rating on any home. 601.2 Scope This chapter sets out the procedures for the accreditation of Sampling Providers. Accredited Sampling Providers shall assume all warranties and liabilities associated with the sampling of homes. RESNET does not provide any warranty, either explicit or implied, that sampled homes will meet or exceed the threshold specifications for the sample set. There may be instances in which state laws or regulations differ from these Standards. In such instances, state law or regulation shall take precedence over this standard. 602 DEFINITIONS AND ACRONYMS See Appendix B. 603 TECHNICAL REQUIREMENTS FOR SAMPLING 603.1 Compliance Requirements The testing and inspection of homes for minimum rated features shall be conducted in compliance with the procedures for conducting home energy ratings and Builder Option Packages (BOPs) contained in this Standard. 603.2 Homes Eligible to be Sampled The homes being sampled shall be of the same construction type using the same envelope systems. 603.3 Analysis of Homes A Worst-Case Analysis shall be performed on each home plan in the sample set,. If an option or change in the design of the structure is made that differs from those used in the initial analysis in a way that would require more stringent threshold specifications, then that home must be individually rated. At a minimum, a certified Rater shall oversee this process.
603.4 Labeling of Homes ?603.4.1 Every home plan within a given sample set shall be assigned the same HERS Index as determined by the worst-case analysis and threshold specification for theat floor plan for that home. 603.4.2 Every home subjected to this sampling Standard shall be provided with a label in accordance with Section 303.3 of these standards, which contains the following statement: “This home has been certified using a sampling protocol in accordance with Chapter 6 of the RESNET Standards (see http://resnet.us.standards/ www.RESNET.us)”. This label shall be located on the electrical panel and the font shall be a minimum of 10 points. 603.5 Sample Set of Homes Sampling controls may be applied to any sample set of homes within the same subdivision, community or metropolitan area and climate zone (as specified in the most current edition of the IECC), provided the criteria in Item 603.2 are met and: 603.5.1 Each sample set is made up of homes at the same stage of construction (e.g. pre- drywall, final); 603.5.2 For each stage of construction, each sample set will be comprised composed of homes eligible for the applicable sampling controls within a 30 calendar day period. For example: a sample set that is defined for a pre-drywall inspection must include homes that are eligible for that pre-drywall inspection within a given 30-day period. If fewer than seven (7) homes are available for that phase of inspection, the sample set must be cut off at the number of homes that are available within that 30-day period. This sample set need not be carried through to final inspection; in fact, a whole new sample set may be defined for the final inspection phase based on the homes available for that phase within a new, 30-day period applied to that phase of tests and inspections. 603.5.3 Each home subject to sampling is required to be part of an identified set of sampling controls for each test or inspection that is sampled; 603.5.4 Each participating subdivision within a metropolitan area is subject to sampling controls on at least one home in any 90 calendar day period; 603.5.5 Each participating subdivision within a metropolitan area must start a minimum of one home in any 90 calendar day period. 603.6 Application of Sampling The application of the sampling controls in this standard are only required for those tests and inspections that are not conducted on every home. Sampling controls shall be conducted for any tests and inspections not conducted on every home, according to the field testing and inspection requirements of 303.6.2. 603.7 Sampling Controls
603.7.1 A complete set of Sampling Controls shall be performed at a minimum ratio of one (1) test or inspection per seven (7) homes within a given sample set. At a minimum, a certified Rater shall oversee this process. 603.7.2 Sampling Providers may complete the sampling controls collectively on a single home or distribute the tests and inspections across several homes within a given sample set, provided the total number of individual tests and inspections meets or exceeds the minimum ratio set forth in 603.7.1. 603.7.3 To qualify for sampling in a metropolitan area, a builder shall first complete, without any incidence of failure, a complete set of sampling controls on at least seven (7) consecutive homes in that metropolitan area. For this initial phase of testing and inspections, the complete set of sampling controls shall be performed on each of the seven (7) homes. 603.7.3.1 Exception: A builder who has been implementing a sampling process for certifying homes in a specific metropolitan area under the EPA's ENERGY STAR® for Homes program as of January 1, 2008, will be allowed a one time exception to 603.7.3 for that metropolitan area. 603.7.3.12: For each newly started subdivision, sampling may begin for each sampling control only after three (3) of a particular sampling control passes consecutively homes have been completed without any incidence of failure. 603.7.4 Having successfully met the requirements of 603.7.3, a Sampling Provider may complete sampling controls for a builder indefinitely until a “failure” occurs or any of the criteria set forth in 603.2 are no longer met. 603.7.5 A complete set of sampling controls, whether performed on a single home or spread across several homes, must be completed whether or not one or more failure(s) are found. 603.7.6 When an “initial failure” occurs, the failed item(s) shall be tested or inspected in two (2) additional homes selected from the same sample set. Testing and/or inspections for any item(s) that may become inaccessible during the construction process, (e.g. wall insulation) must be timed so additional testing and/or inspections can occur on other homes in the sample set before they become inaccessible for inspection or testing. 603.7.7 When an “additional failure” occurs, in one or more of the two (2) additional homes, the failed item(s) shall be tested or inspected in the remaining four (4) homes selected for the same sample set. 603.7.8 Until the failure is corrected in all identified (failed) homes in the sample set, none of the homes shall be deemed to meet the threshold or labeling criteria. 603.8 Multiple “Additional Failures” Action is required if three (3) “additional failures” occur within a ninety (90) calendar day period. The required action depends on whether those “additional failures” apply to the same failed item or various failed items.
603.8.1 If the multiple “additional failures” all apply to the same failed item, the builder shall submit to 100% inspection of that failed item, for a minimum of seven (7) homes, before resuming sampling of that item. Remaining unrelated sampling controls may be conducted on a sampled basis throughout this process. 603.8.2 If the multiple “additional failures” apply to various failed items, or additional failed items are found during testing and inspection of additional homes, the builder must begin again and complete 603.7.3 at a minimum, before continuing with sampling. 603.8.3 Exception: If a builder conducts a “root cause analysis” on an item or items covered under 603.8.1 or 603.8.2, and submits it in writing to the sampling Provider, sampling may resume as soon as the Provider deems that the solution has been implemented. The “root cause analysis” report shall contain at a minimum: 603.8.3.1 A written description of the problem(s) covered by the analysis; 603.8.3.2 A written explanation of the underlying reason(s) that the problem(s) occurred (e.g. inadequate training of subcontractor(s) or site supervisors, insufficient information or inadequate detail in the plans or specifications, etc); 603.8.3.3 A written description of a clearly defined process to correct the underlying cause(s); 603.8.3.4 A written description of when and how that process has been carried out; 603.8.3.5 A copy of the root cause analysis report shall be kept by the sampling Provider as part of the QA file, for a period of time of three (3) years, consistent with the requirements of 102.1.4.8.2. 603.9 Quality Assurance by Sampling Providers 603.9.1 The Sampling Provider’s Rating Quality Assurance Provider QA Designee shall be responsible for monitoring compliance with the sampling process and maintaining records in accordance with the requirements of Chapter 9. 603.9.2 In addition to the Quality Assurance requirements specified in Chapter 9 for Home Energy Rating Providers, a Sampling Provider’s QUALITY assurance process shall include, at a minimum, the following: 603.9.2.1 All homes that are qualified by the use of sampling shall be considered to be rated homes. QA file review and field monitoring shall be conducted on a percentage of all the homes certified or qualified under sampling, rather than the percentage of tested and inspected homes. 603.9.2.2 The field QA required in Chapter 9 may be conducted on any of the qualified or certified homes within the sample sets, and shall not be limited to the tested and inspected homes. ????????????????????????604 RATING SAMPLING PROVIDER ACCREDITATION CRITERIA
??604.1 Minimum Standards for Home Energy Rating Sampling Provider (Sampling Provider) Accreditation. Home Energy Rating Sampling Providers shall be accredited in accordance with the Accreditation Process specified in Chapter 9 of these Standards. A Sampling Provider must specifically meet the following minimum standards for Accreditation. 604.1.1 All Sampling Providers shall be accredited by RESNET as a Home Energy Rating QA Providers in good standing and must maintain their accreditation in good standing. 604.1.2 A Sampling Provider’s accreditation must be renewed annually by RESNET. 604.1.3 In order to be eligible to be a Sampling Provider, the RESNET- accredited rating QA Provider shall complete a minimum of twenty-five (25) confirmed ratings as an accredited QA Provider that have been documented to be accurate by the Rating QA Provider’s Quality Aassurance Ddesignee. 604.1.4 The Sampling Provider shall demonstrate to RESNET a minimum insurance coverage of $1,000,000 in general liability coverage and $1,000,000 in professional liability coverage. 604.1.5 Builders cannot use the sampling standard to certify or qualify homes in which they have a financial interest. 604.2 Responsibilities of Accredited Sampling Providers 604.2.1 Sampling Providers are responsible for ensuring that all of the Sampling inspections conducted and issued by their sampling program are in compliance with all of the criteria by which the system was accredited. 604.2.2 Sampling Providers are responsible for ensuring that the specifications for the minimum rated features for the sampled homes be communicated to the personnel or trades responsible for completing the work. 604.2.3 Minimum Standards For Sampling Provider’s Operation Policies and Procedures must be written and provide for the following: 604.2.3.1 Field inspections and tracking of all homes in the sample set for verifying threshold technical specifications and tracking failures and re-inspections; 604.2.3.2 Blower Door Testing completed for sample sets in which the threshold specifications include credit for reduced air infiltration lower than the default value; 604.2.3.3 Duct testing completed for sample sets in which the threshold specifications include credit for reduced air distribution system leakage lower than the default value; ?????????????????????????????604.2.3.4 Sampling Inspector discipline procedures that include progressive discipline involving Probation - Suspension – Termination.
605 EFFECTIVE DATES 605.1 Quality Assurance July 1, 2007 – Section 603.9 shall be implemented by all sampling Raters and Providers. 605.2 Effective Date of Standard January 1, 2008 – The remainder of Chapter 6 shall be implemented by all sampling Raters and Providers ?????????????
Comment #13Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-1Paragraph / Figure / Table / Note: 903.1Comment Type: GeneralComment: This section is vague and weak and doesn't allow for any benchmark that can be measured for success. This is a staff function, not a committee function, and the Board of Directors should set the rate, not the Committee (since the Committee doesn't have any staff oversight responsibilities. We (Board members) set the course and staff makes sure that we get there. Put a number in here, or a percentage- but for heaven's sake, have something concrete and measureable! Proposed Change: 903.1 RESNET shall randomly select a limited number 25% of accredited Rating Quality Assurance Providers (QA Providers) and conduct an annual review of their Quality Assurance records. This QA review may be a review of electronic files submitted to RESNET upon request, an onsite field review, or both. The RESNET Board of Directors Quality Assurance Committee staff shall determine the number of QA Providers that shall be reviewed on an annual basis and who will provide the quality assurance review.
This section is vague and weak and doesn't allow for any benchmark that can be measured for success. This is a staff function, not a committee function, and the Board of Directors should set the rate, not the Committee (since the Committee doesn't have any staff oversight responsibilities. We (Board members) set the course and staff makes sure that we get there. Put a number in here, or a percentage- but for heaven's sake, have something concrete and measureable!
903.1 RESNET shall randomly select a limited number 25% of accredited Rating Quality Assurance Providers (QA Providers) and conduct an annual review of their Quality Assurance records. This QA review may be a review of electronic files submitted to RESNET upon request, an onsite field review, or both. The RESNET Board of Directors Quality Assurance Committee staff shall determine the number of QA Providers that shall be reviewed on an annual basis and who will provide the quality assurance review.
Comment #14Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-2Paragraph / Figure / Table / Note: 904.1Comment Type: EditorialComment: Strike the first part of the sentence. If you have to use the phrase "In other words", you are not writing clearly and should just use the "other words". Proposed Change: 904.1 No step in the QA process may be performed by the same individual that performed any part of the testing, inspection or rating of the home being subject to the QA review. In other words, if If an individual performed any part of the inspection or rating process on a home, that individual cannot be the QA Designee or Delegate performing any part of the QA process specific to that home. Any ratings performed by a QA Designee or Delegate that are submitted as part of a Provider’s QA Submission to RESNET shall be reviewed for quality assurance by a separate individual who meets the QA Designee or Delegate requirements established by RESNET.
Strike the first part of the sentence. If you have to use the phrase "In other words", you are not writing clearly and should just use the "other words".
904.1 No step in the QA process may be performed by the same individual that performed any part of the testing, inspection or rating of the home being subject to the QA review. In other words, if If an individual performed any part of the inspection or rating process on a home, that individual cannot be the QA Designee or Delegate performing any part of the QA process specific to that home. Any ratings performed by a QA Designee or Delegate that are submitted as part of a Provider’s QA Submission to RESNET shall be reviewed for quality assurance by a separate individual who meets the QA Designee or Delegate requirements established by RESNET.
Comment #15Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-2Paragraph / Figure / Table / Note: 904.1.2Comment Type: GeneralComment: For a robust Quality Assurance program to exist with any kind of credibility to stakeholders and the general public, there must be clear separation between the entity providing the QA and the entity performing the rating. This includes any financial interest in both ventures, any ownership stakes, or common management. We cannot assume that all QA Providers will do what is called for, and we cannot risk the continuing challenge of "the fox guarding the henhouse". If we are going to sustain the legitimacy we have achieved, we MUST have truly independent, 3rd party QA oversight over the Raters by the QA Providers. It is inherent in our human nature to do what is in our own best interest, even if that goes contrary to the ethical standards we proclaim to uphold. The only way to get close to the ideal is to eliminate the conflict that is embedded in the "in-house" QA Provider model. Proposed Change: 904.1.2 The company (QA Provider) that performs the Quality Assurance reviews shall be completely independent of the company or individual that performed the rating, and shall have no relationship with the Rater or in the rating company other than a business-client relationship.
For a robust Quality Assurance program to exist with any kind of credibility to stakeholders and the general public, there must be clear separation between the entity providing the QA and the entity performing the rating. This includes any financial interest in both ventures, any ownership stakes, or common management.
We cannot assume that all QA Providers will do what is called for, and we cannot risk the continuing challenge of "the fox guarding the henhouse". If we are going to sustain the legitimacy we have achieved, we MUST have truly independent, 3rd party QA oversight over the Raters by the QA Providers.
It is inherent in our human nature to do what is in our own best interest, even if that goes contrary to the ethical standards we proclaim to uphold. The only way to get close to the ideal is to eliminate the conflict that is embedded in the "in-house" QA Provider model.
904.1.2 The company (QA Provider) that performs the Quality Assurance reviews shall be completely independent of the company or individual that performed the rating, and shall have no relationship with the Rater or in the rating company other than a business-client relationship.
Comment #16Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-3Paragraph / Figure / Table / Note: 904.4.1.3.4Comment Type: GeneralComment: BSR/RESNET 301-2013 (the ANSI Final Draft Standard that is replacing Chapter 3), which has gone through public comment already and is complete, does not allow the use of threshold data or Worst Case scenarios for Confirmed Ratings. Sampled Ratings use the threshold specifications from the Worst Case Analysis which are entered into the approved software rating tool. Proposed Change: 904.4.1.3.4 For each Confirmed Rating, confirm that the values entered into the Rating Software for all Minimum Rated Features are either RESNET-defined defaults or are supported by on-site field-confirmed test data using threshold diagnostic values or actual diagnostic values. The values entered into the rating software for a Confirmed Rating are permitted to represent a Worst-Case analysis.
BSR/RESNET 301-2013 (the ANSI Final Draft Standard that is replacing Chapter 3), which has gone through public comment already and is complete, does not allow the use of threshold data or Worst Case scenarios for Confirmed Ratings. Sampled Ratings use the threshold specifications from the Worst Case Analysis which are entered into the approved software rating tool.
904.4.1.3.4 For each Confirmed Rating, confirm that the values entered into the Rating Software for all Minimum Rated Features are either RESNET-defined defaults or are supported by on-site field-confirmed test data using threshold diagnostic values or actual diagnostic values. The values entered into the rating software for a Confirmed Rating are permitted to represent a Worst-Case analysis.
Comment #17Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-6Paragraph / Figure / Table / Note: 904.4.2.7Comment Type: GeneralComment: This is a really bad idea, and should be struck from the Standard. To restrict QA Providers from performing QA on a home in a sampled batch that wasn't tested or inspected throws the entire sampling process into a morass of ethical laughability. Why don't we just allow Google Earth verifications, drive by infiltration testing, or have builders sign an affidavit saying they built the home exactly as designed and specified? As a former builder, I know that the first casualties of the construction process are the plans and specifications. The size of the home is determined by the guy who digs the hole the concrete footing is placed in- everything gets built from that. To remove all non-tested or inspected homes from the QA process in a sampled batch is a thumb in the eye of all that is decent and right in this world. The major role the rater plays is helping the builder maintain their integrity. They promised to build someone an energy efficient home, and we (raters) help them deliver on their promise- and now even QA is getting pulled from that value proposition? Proposed Change: 904.4.2.7 QA field review of Sampled Ratings. For the purposes of calculating the one (1) home or one percent (1%) QA field review requirement for Rater and RFI sampled ratings, all the homes rated by a Rater, or for which an RFI assisted, using sampling shall be considered and not just the number of homes tested and inspected. To ensure that QA is being completed on Raters and Rating Field Inspectors rather than builders, only homes that include field testing and inspection data shall be amongst those considered for QA field review in accordance with 904.4.2.5. For example, if a Rater rating homes using Chapter 6 rates 950 homes in one year, the number of QA field reviews required shall be 10, i.e. 1% of 950 = 9.5, rounded up to the nearest whole number = 10. If of those 950 homes, 400 homes had any field testing and/or inspections completed during construction, then the 10 homes selected for QA field review shall be selected randomly, in accordance with Section 904.4.2.4, from the 400 tested/inspected homes and not the 550 that did not receive any testing or inspections.
This is a really bad idea, and should be struck from the Standard. To restrict QA Providers from performing QA on a home in a sampled batch that wasn't tested or inspected throws the entire sampling process into a morass of ethical laughability. Why don't we just allow Google Earth verifications, drive by infiltration testing, or have builders sign an affidavit saying they built the home exactly as designed and specified?
As a former builder, I know that the first casualties of the construction process are the plans and specifications. The size of the home is determined by the guy who digs the hole the concrete footing is placed in- everything gets built from that. To remove all non-tested or inspected homes from the QA process in a sampled batch is a thumb in the eye of all that is decent and right in this world.
The major role the rater plays is helping the builder maintain their integrity. They promised to build someone an energy efficient home, and we (raters) help them deliver on their promise- and now even QA is getting pulled from that value proposition?
904.4.2.7 QA field review of Sampled Ratings. For the purposes of calculating the one (1) home or one percent (1%) QA field review requirement for Rater and RFI sampled ratings, all the homes rated by a Rater, or for which an RFI assisted, using sampling shall be considered and not just the number of homes tested and inspected. To ensure that QA is being completed on Raters and Rating Field Inspectors rather than builders, only homes that include field testing and inspection data shall be amongst those considered for QA field review in accordance with 904.4.2.5. For example, if a Rater rating homes using Chapter 6 rates 950 homes in one year, the number of QA field reviews required shall be 10, i.e. 1% of 950 = 9.5, rounded up to the nearest whole number = 10. If of those 950 homes, 400 homes had any field testing and/or inspections completed during construction, then the 10 homes selected for QA field review shall be selected randomly, in accordance with Section 904.4.2.4, from the 400 tested/inspected homes and not the 550 that did not receive any testing or inspections.
Comment #18Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-7, 9-8Paragraph / Figure / Table / Note: 904.4.3, 904.4.3.1, 904.4.3.2, 904.4.3.3, 904.4.3.4Comment Type: GeneralComment: For Quality Assurance to exist with any kind of impartiality, there has to be standardization. These sections do not provide that. What we have here is a "Leave it up to the Provider" and "Let the market sort it out" mentality...and that is very wrong, particularly if we are to have any credibility with our stakeholders. These entire sections need to be struck and replaced with language that specifies exactly what type of disciplinary action is to be taken by the QA Provider, ensuring a level playing field across the industry, shoring up our credibility and reputation, and preventing the ethical slips and slides that are inevitable when it is left up to individual Providers to determine what is appropriate. You can't have a standard that doesn't standardize. Proposed Change: 904.4.3 Non-compliance of a reviewed rating shall trigger corrective action. 904.4.3.1 The rating shall be corrected in order to come into compliance with RESNET technical Standards under the supervision of the QA Designee. 904.4.3.2 The QA Designee shall develop and implement a corrective action plan for the Rater of the rating that addresses any underlying problems that led to the non- compliant rating. 904.4.3.3 The Provider shall initiate appropriate disciplinary action on the Rater in accordance with the Provider’s written Rater disciplinary procedures. ???????????????????????????????????????????????????904.4.3.4 Multiple instances of non-compliance with 904.4.2.5 shall, at a minimum, trigger an increased rate of file reviews or onsite inspections of homes and additional appropriate disciplinary action in accordance with the Provider’s written Rater disciplinary procedures. If a Rater fails to correct the rating file within 30 days, that Rater shall be placed on probation until the file is corrected and RESNET shall be notified through the Rater Registry. While on probation, Rater shall have 100% of their software files reviewed, and shall not be restored to Active status until original file is corrected and they have successfully completed 5 consecutive file reviews by the QA Provider.
For Quality Assurance to exist with any kind of impartiality, there has to be standardization. These sections do not provide that. What we have here is a "Leave it up to the Provider" and "Let the market sort it out" mentality...and that is very wrong, particularly if we are to have any credibility with our stakeholders.
These entire sections need to be struck and replaced with language that specifies exactly what type of disciplinary action is to be taken by the QA Provider, ensuring a level playing field across the industry, shoring up our credibility and reputation, and preventing the ethical slips and slides that are inevitable when it is left up to individual Providers to determine what is appropriate.
You can't have a standard that doesn't standardize.
904.4.3 Non-compliance of a reviewed rating shall trigger corrective action. 904.4.3.1 The rating shall be corrected in order to come into compliance with RESNET technical Standards under the supervision of the QA Designee. 904.4.3.2 The QA Designee shall develop and implement a corrective action plan for the Rater of the rating that addresses any underlying problems that led to the non- compliant rating. 904.4.3.3 The Provider shall initiate appropriate disciplinary action on the Rater in accordance with the Provider’s written Rater disciplinary procedures. ???????????????????????????????????????????????????904.4.3.4 Multiple instances of non-compliance with 904.4.2.5 shall, at a minimum, trigger an increased rate of file reviews or onsite inspections of homes and additional appropriate disciplinary action in accordance with the Provider’s written Rater disciplinary procedures. If a Rater fails to correct the rating file within 30 days, that Rater shall be placed on probation until the file is corrected and RESNET shall be notified through the Rater Registry. While on probation, Rater shall have 100% of their software files reviewed, and shall not be restored to Active status until original file is corrected and they have successfully completed 5 consecutive file reviews by the QA Provider.
Comment #19Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-7, 9-8Paragraph / Figure / Table / Note: 904.4.4Comment Type: GeneralComment: Add a new section to cover field reviews that do not meet the standard. Disciplinary action must be standardized to ensure that Raters understand exactly what will be expected of them as a minimum and the consequences that will take place should they deviate from the standards. Proposed Change: 904.4.4 More than 1 field review that is non-compliant shall result in the Rater being suspended by the QA Provider until the issues leading to non-compliance are corrected. RESNET shall be notified through the Rater Registry. While on suspension, the Rater shall not engage in performing any ratings and shall not be restored to Active status until they have successfully completed 1 field review conducted by the QA Provider.
Add a new section to cover field reviews that do not meet the standard. Disciplinary action must be standardized to ensure that Raters understand exactly what will be expected of them as a minimum and the consequences that will take place should they deviate from the standards.
904.4.4 More than 1 field review that is non-compliant shall result in the Rater being suspended by the QA Provider until the issues leading to non-compliance are corrected. RESNET shall be notified through the Rater Registry. While on suspension, the Rater shall not engage in performing any ratings and shall not be restored to Active status until they have successfully completed 1 field review conducted by the QA Provider.
Comment #20Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-7, 9-8Paragraph / Figure / Table / Note: 904.4.5Comment Type: GeneralComment: Add a new section to provide a mechanism for transparency on the disciplinary process. If we do not have transparency on the QA process, it will always be perceived to be smoke and mirrors. For those who say we can't do what I am about to suggest- that is utter non-sense. Nearly every profession that has a code of ethics already has in place a mechanism similar to what I am proposing. For us to say we can't do something like this...we might as well admit that we don't really want to shine the light on our industry and would rather sweep everything under the carpet until our noses touch the ceiling! Proposed Change: 904.4.5 All Raters that have had disciplinary action taken by the QA Provider shall be listed on the RESNET website. This list shall be refreshed monthly.
Add a new section to provide a mechanism for transparency on the disciplinary process. If we do not have transparency on the QA process, it will always be perceived to be smoke and mirrors.
For those who say we can't do what I am about to suggest- that is utter non-sense. Nearly every profession that has a code of ethics already has in place a mechanism similar to what I am proposing. For us to say we can't do something like this...we might as well admit that we don't really want to shine the light on our industry and would rather sweep everything under the carpet until our noses touch the ceiling!
904.4.5 All Raters that have had disciplinary action taken by the QA Provider shall be listed on the RESNET website. This list shall be refreshed monthly.
Comment #21Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-8Paragraph / Figure / Table / Note: 904.5.3Comment Type: GeneralComment: Add a new section to provide a mechanism for transparency on the disciplinary process. If we do not have transparency on the QA process, it will always be perceived to be smoke and mirrors. For those who say we can't do what I am about to suggest- that is utter non-sense. Nearly every profession that has a code of ethics already has in place a mechanism similar to what I am proposing. For us to say we can't do something like this...we might as well admit that we don't really want to shine the light on our industry and would rather sweep everything under the carpet until our noses touch the ceiling! Proposed Change: 904.5.3 All Providers who have been found in significant non-compliance shall be listed on the RESNET website. This list shall be refreshed monthly and the Provider removed from the list when RESNET finds they have attained compliance. Providers who are in significant non-compliance shall not perform any QA work or conduct trainings until they can demonstrate to RESNET they are in compliance.
904.5.3 All Providers who have been found in significant non-compliance shall be listed on the RESNET website. This list shall be refreshed monthly and the Provider removed from the list when RESNET finds they have attained compliance. Providers who are in significant non-compliance shall not perform any QA work or conduct trainings until they can demonstrate to RESNET they are in compliance.
Comment #22Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-9Paragraph / Figure / Table / Note: 905.2.3Comment Type: GeneralComment: This section is a waste of words. Quality Assurance ensures the right process was followed, while Quality Control ensures the right work was done correctly. To require that 5 ratings of the same type had to be performed by the QAD prior to being able to perform QA work on that project is ridiculous. To follow that with "or alternate qualification criteria established by RESNET in consultation with the Quality Assurance Committee" is nebulous and doesn't align with language that should be included in a Standard. If there are alternate criteria, spell it out. If that doesn't exist yet, then don't put it in here. If you feel the urge to put that kind of language in here, that indicates that you feel there is something wrong with the original requirement- so why have it at all? Proposed Change: 905.2.3 To be eligible to QA a particular rating type (e.g. sampled, BOP, survey/audit, EEP), a QA Designee must have completed a minimum of five (5) of that rating or project type or alternate qualification criteria established by RESNET in consultation with the Quality Assurance Committee;
This section is a waste of words. Quality Assurance ensures the right process was followed, while Quality Control ensures the right work was done correctly. To require that 5 ratings of the same type had to be performed by the QAD prior to being able to perform QA work on that project is ridiculous. To follow that with "or alternate qualification criteria established by RESNET in consultation with the Quality Assurance Committee" is nebulous and doesn't align with language that should be included in a Standard. If there are alternate criteria, spell it out. If that doesn't exist yet, then don't put it in here. If you feel the urge to put that kind of language in here, that indicates that you feel there is something wrong with the original requirement- so why have it at all?
905.2.3 To be eligible to QA a particular rating type (e.g. sampled, BOP, survey/audit, EEP), a QA Designee must have completed a minimum of five (5) of that rating or project type or alternate qualification criteria established by RESNET in consultation with the Quality Assurance Committee;
Comment #23Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-9Paragraph / Figure / Table / Note: 905.2.2Comment Type: GeneralComment: The requirement for QAD's to have experience rating 25 homes is CRAZY. You might have learned something about this industry after you've done 150 homes, and you might be able to determine if someone else followed the right process (and where they are likely to screw up) after you've done 250 homes. We have raters that have done 25 ratings in their first week! Are they qualified (if they are really good at taking tests) to be a QAD? Probably not. If you don't have the job experience required to do the second highest level job in the industry and have become an expert (which takes about 10,000 hours of deliberate practice), you just aren't qualified for the job. Proposed Change: 905.2.2 As a certified Home Energy Rater, complete confirmed ratings on a minimum of twenty-five (25) two-hundred-fifty (250) homes prior to becoming a QA Designee;
The requirement for QAD's to have experience rating 25 homes is CRAZY. You might have learned something about this industry after you've done 150 homes, and you might be able to determine if someone else followed the right process (and where they are likely to screw up) after you've done 250 homes. We have raters that have done 25 ratings in their first week! Are they qualified (if they are really good at taking tests) to be a QAD? Probably not.
If you don't have the job experience required to do the second highest level job in the industry and have become an expert (which takes about 10,000 hours of deliberate practice), you just aren't qualified for the job.
905.2.2 As a certified Home Energy Rater, complete confirmed ratings on a minimum of twenty-five (25) two-hundred-fifty (250) homes prior to becoming a QA Designee;
Comment #24Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-11Paragraph / Figure / Table / Note: 905.7.1Comment Type: EditorialComment: If you have to say "In other words..." Just use the other words! Also, QAD Delegates must have more experience rating homes than just 25. If you don't have the experience, you just aren't qualified. Proposed Change: 905.78.1 A QA Delegate must be a certified Home Energy Rater and have completed, on a minimum of twenty-five (25) homes, the portion of the inspection or rating process for which the individual is performing quality assurance tasks. In other words, if If the QA Delegate is repeating on-site testing and inspections as part of the QA process, that individual must have at least performed these tasks on a minimum of twenty seventy-five (25 75) homes.
If you have to say "In other words..." Just use the other words!
Also, QAD Delegates must have more experience rating homes than just 25. If you don't have the experience, you just aren't qualified.
905.78.1 A QA Delegate must be a certified Home Energy Rater and have completed, on a minimum of twenty-five (25) homes, the portion of the inspection or rating process for which the individual is performing quality assurance tasks. In other words, if If the QA Delegate is repeating on-site testing and inspections as part of the QA process, that individual must have at least performed these tasks on a minimum of twenty seventy-five (25 75) homes.
Comment #25Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-21Paragraph / Figure / Table / Note: 908.3Comment Type: EditorialComment: This section and following subsections and sections need to be renumbered. As listed, it appears that the Ethics Committee falls under the QA Committee- and it doesn't. The Ethics Committee is a Standing Committee of the Board of Directors and is completely independent of (for a reason) the QA Committee. Proposed Change: 9078.39 Ethics and Appeals Committee. The Ethics and Appeals Committee shall have the responsibility of investigating ethics and consumer complaints and hearing appeals of an Application or Renewal Application that has been denied, or if a Provider has been placed on probation, or if a Provider’s accreditation has been suspended or revoked. The Committee shall report to the QA Committee RESNET Board of Directors. 9078.39.1 Committee membership. The Ethics and Appeals Committee shall be composed of a minimum of five (5) members, but no more than seven (7) members including the Chair. , nNone of the Committee memberswhom shall also be a member of the Quality Assurance and Ethics Committee. Nomination of the Committee Chair shall be made by the Quality Assurance and Ethics Committee to the RESNET Board for approval. The Chair of the Ethics and Appeals Committee shall nominate the other members of the Committee to the RESNET Board for approval, consisting of a minimum of two (2) being Home Energy Raters and a minimum of two (2) being representatives of Provider organizations.
This section and following subsections and sections need to be renumbered. As listed, it appears that the Ethics Committee falls under the QA Committee- and it doesn't. The Ethics Committee is a Standing Committee of the Board of Directors and is completely independent of (for a reason) the QA Committee.
9078.39 Ethics and Appeals Committee. The Ethics and Appeals Committee shall have the responsibility of investigating ethics and consumer complaints and hearing appeals of an Application or Renewal Application that has been denied, or if a Provider has been placed on probation, or if a Provider’s accreditation has been suspended or revoked. The Committee shall report to the QA Committee RESNET Board of Directors. 9078.39.1 Committee membership. The Ethics and Appeals Committee shall be composed of a minimum of five (5) members, but no more than seven (7) members including the Chair. , nNone of the Committee memberswhom shall also be a member of the Quality Assurance and Ethics Committee. Nomination of the Committee Chair shall be made by the Quality Assurance and Ethics Committee to the RESNET Board for approval. The Chair of the Ethics and Appeals Committee shall nominate the other members of the Committee to the RESNET Board for approval, consisting of a minimum of two (2) being Home Energy Raters and a minimum of two (2) being representatives of Provider organizations.
Comment #26Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-21Paragraph / Figure / Table / Note: 908.2.2Comment Type: EditorialComment: The QA Committee does not have any authority to rule on the merits of appeals from the Ethics Committee. That Committee reports directly to the Board of Directors. Proposed Change: 9078.2.2 Review and rule on the merits of appeals from the Ethics and Appeals Committee;
The QA Committee does not have any authority to rule on the merits of appeals from the Ethics Committee. That Committee reports directly to the Board of Directors.
9078.2.2 Review and rule on the merits of appeals from the Ethics and Appeals Committee;
Comment #27Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-22Paragraph / Figure / Table / Note: 909.2.1Comment Type: EditorialComment: The Chair of the Ethics Committee must be kept informed of all complaints received by RESNET to ensure that they do not fall through the cracks. Proposed Change: 909.2.1 Upon receipt of an ethics complaint, the RESNET Executive Director shall assign a case number and RESNET staff shall review the evidence submitted. The Chair of the Ethics Committee shall be informed. RESNET staff shall consider the documentation contained in 909.1.2 in making a decision whether to proceed or dismiss the complaint, in consultation with the Chair of the Ethics Committee.
The Chair of the Ethics Committee must be kept informed of all complaints received by RESNET to ensure that they do not fall through the cracks.
909.2.1 Upon receipt of an ethics complaint, the RESNET Executive Director shall assign a case number and RESNET staff shall review the evidence submitted. The Chair of the Ethics Committee shall be informed. RESNET staff shall consider the documentation contained in 909.1.2 in making a decision whether to proceed or dismiss the complaint, in consultation with the Chair of the Ethics Committee.
Comment #28Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-6Paragraph / Figure / Table / Note: 904.4.2.7Comment Type: TechnicalComment: I understand that the alteration to the QA standards for field review of sampled ratings (904.4.2.7) were designed to ensure that QA was being done on the Rater not the builder. I also understand that as a QAD it is my prerogative if I want to go beyond the minimums required by the standard. In this case though I think the new standard back tracks too far, and that the minimum required by the alteration is not enough to ensure the quality of the process. When we field QA a home in a sampled set that was not test/inspected by the Rater we are still reviewing their work, not just the builder's. In this case we are not ensuring the quality of their data collection or air diagnostic testing, but the sampling protocol itself which the Rater has a hand in setting up. If we do not field QA homes within a sample set that were not visited by the Rater we cannot know if the Rater and their builder partner should even be using sampling methodology on the project in question. If we want to ensure that HERS is above reproach we should not have a situation where we have a group on homes within a sampled set which neither the certifying Rater nor their QAD was required to verify the accuracy of the sampled data. I will continue to include non-inspected homes in my sampling QA regardless; however I believe that it should be a minimum requirement of the standard, not just an option for those QADs who chose to do it. Thanks in advance for your time in considering this amendment, and the many others that have been reworked over the last several years. Proposed Change: 904.4.2.7 QA field review of Sampled Ratings. For the purposes of calculating the one (1) home or one percent (1%) QA field review requirement for Rater and RFI sampled ratings, all the homes rated by a Rater, or for which an RFI assisted, using sampling shall be considered and not just the number of homes tested and inspected. To ensure that QA is being completed on Raters and Rating Field Inspectors rather than builders, only homes that include field testing and inspection data shall be amongst those considered for QA field review in accordance with 904.4.2.5. The field QA may be conducted on any of the qualified or certified homes within the sample sets. Further in order to provide quality assurance for the Rater's sampling process itself, field QA of homes within the sample set must include homes that were not among those tested and/or inspected by the Rater. For example, if a Rater rating homes using Chapter 6 rates 950 homes in one year, the number of QA field reviews required shall be 10, i.e. 1% of 950 = 9.5, rounded up to the nearest whole number = 10. If of those 950 homes, 400 homes had any field testing and/or inspections completed during construction, then the 10 homes selected for QA field review shall be selected randomly, in accordance with Section 904.4.2.4, from the 400 tested/inspected homes and not the 550 that did not receive any testing or inspections. For example, if a Rater rating homes using Chapter 6 rates 950 homes in one year, the number of QA field reviews required shall be 10, i.e. 1% of 950 = 9.5, rounded up to the nearest whole number = 10. If of those 950 homes, 400 homes had any field testing and/or inspections completed during construction, then 75% of the homes selected for QA field review shall be selected randomly from this group, with the remaining 25% of the QA quota being randomly selected from those 550 homes that were not field tested and/or inspected by the Rater.
I understand that the alteration to the QA standards for field review of sampled ratings (904.4.2.7) were designed to ensure that QA was being done on the Rater not the builder. I also understand that as a QAD it is my prerogative if I want to go beyond the minimums required by the standard. In this case though I think the new standard back tracks too far, and that the minimum required by the alteration is not enough to ensure the quality of the process. When we field QA a home in a sampled set that was not test/inspected by the Rater we are still reviewing their work, not just the builder's. In this case we are not ensuring the quality of their data collection or air diagnostic testing, but the sampling protocol itself which the Rater has a hand in setting up. If we do not field QA homes within a sample set that were not visited by the Rater we cannot know if the Rater and their builder partner should even be using sampling methodology on the project in question. If we want to ensure that HERS is above reproach we should not have a situation where we have a group on homes within a sampled set which neither the certifying Rater nor their QAD was required to verify the accuracy of the sampled data. I will continue to include non-inspected homes in my sampling QA regardless; however I believe that it should be a minimum requirement of the standard, not just an option for those QADs who chose to do it. Thanks in advance for your time in considering this amendment, and the many others that have been reworked over the last several years.
904.4.2.7 QA field review of Sampled Ratings. For the purposes of calculating the one (1) home or one percent (1%) QA field review requirement for Rater and RFI sampled ratings, all the homes rated by a Rater, or for which an RFI assisted, using sampling shall be considered and not just the number of homes tested and inspected. To ensure that QA is being completed on Raters and Rating Field Inspectors rather than builders, only homes that include field testing and inspection data shall be amongst those considered for QA field review in accordance with 904.4.2.5. The field QA may be conducted on any of the qualified or certified homes within the sample sets. Further in order to provide quality assurance for the Rater's sampling process itself, field QA of homes within the sample set must include homes that were not among those tested and/or inspected by the Rater. For example, if a Rater rating homes using Chapter 6 rates 950 homes in one year, the number of QA field reviews required shall be 10, i.e. 1% of 950 = 9.5, rounded up to the nearest whole number = 10. If of those 950 homes, 400 homes had any field testing and/or inspections completed during construction, then the 10 homes selected for QA field review shall be selected randomly, in accordance with Section 904.4.2.4, from the 400 tested/inspected homes and not the 550 that did not receive any testing or inspections. For example, if a Rater rating homes using Chapter 6 rates 950 homes in one year, the number of QA field reviews required shall be 10, i.e. 1% of 950 = 9.5, rounded up to the nearest whole number = 10. If of those 950 homes, 400 homes had any field testing and/or inspections completed during construction, then 75% of the homes selected for QA field review shall be selected randomly from this group, with the remaining 25% of the QA quota being randomly selected from those 550 homes that were not field tested and/or inspected by the Rater.
Comment #29Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: AllParagraph / Figure / Table / Note: AllComment Type: EditorialComment: RESNET has made the poor decision to define "shall" to mean "must". Proposed Change: Each instance of "shall" in this document should be considered in context to be sure the meaning is clear and does not indicate a requirement where a requirement is not intended. This will occur in places where shall was used to mean will, may, should, etc.
RESNET has made the poor decision to define "shall" to mean "must".
Each instance of "shall" in this document should be considered in context to be sure the meaning is clear and does not indicate a requirement where a requirement is not intended. This will occur in places where shall was used to mean will, may, should, etc.
Comment #30Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 1-3Paragraph / Figure / Table / Note: 102.1.2.4.2Comment Type: GeneralComment: 102.1.2.43.2 Documentation of 18 hours of attendance at a RESNET Conference in three (3) years would fulfill this requirement. I do not feel that attending the RESNET conference should be accepted as an equivalent to training. There are many different tracks offered at the conference that are not applicable to Raters and should not be considered an equivalent to training. Proposed Change: Remove section 102.1.2.4.2
102.1.2.43.2 Documentation of 18 hours of attendance at a RESNET Conference in three (3) years would fulfill this requirement.
I do not feel that attending the RESNET conference should be accepted as an equivalent to training. There are many different tracks offered at the conference that are not applicable to Raters and should not be considered an equivalent to training.
Remove section 102.1.2.4.2
Comment #31Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 1-5Paragraph / Figure / Table / Note: 102.1.4.3Comment Type: GeneralComment: 102.1.4.3 Blower Door Test completed on all homes claiming credit for reduced air infiltration. Blower door test should be completed on all homes per standard 301 and value used for the confirmed rating. Proposed Change: 102.1.4.3 Blower Door Test completed on all homes claiming credit for reduced air infiltration. The in field verified value will be used in generating the confirmed rating.
102.1.4.3 Blower Door Test completed on all homes claiming credit for reduced air infiltration.
Blower door test should be completed on all homes per standard 301 and value used for the confirmed rating.
102.1.4.3 Blower Door Test completed on all homes claiming credit for reduced air infiltration. The in field verified value will be used in generating the confirmed rating.
Comment #32Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 1-5Paragraph / Figure / Table / Note: 102.1.4.4Comment Type: GeneralComment: 102.1.4.4 Duct testing completed on all homes claiming credit for reduced air distribution system leakage. Duct testing should be performed on every home per standard 301 Proposed Change: 102.1.4.4 Duct testing completed on all homes claiming credit for reduced air distribution system leakage. In field verified number should be used to generate confirmed rating
102.1.4.4 Duct testing completed on all homes claiming credit for reduced air distribution system leakage.
Duct testing should be performed on every home per standard 301
102.1.4.4 Duct testing completed on all homes claiming credit for reduced air distribution system leakage. In field verified number should be used to generate confirmed rating
Comment #33Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 6-2Paragraph / Figure / Table / Note: 603Comment Type: TechnicalComment: I believe the addition of 603.4 is needed to confirm that sampled ratings CANNOT be used to demonstrate code compliance with the IECC. Proposed Change: 603.4 Code Complaince Under no circumstances can a sampled rating be used to demonstrate code complaince with the IECC. Only Confirmed Ratings shall be used in current and future options in demonstrating compliance to the IECC.
I believe the addition of 603.4 is needed to confirm that sampled ratings CANNOT be used to demonstrate code compliance with the IECC.
603.4 Code Complaince
Under no circumstances can a sampled rating be used to demonstrate code complaince with the IECC. Only Confirmed Ratings shall be used in current and future options in demonstrating compliance to the IECC.
Comment #34Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-1Paragraph / Figure / Table / Note: 903.1Comment Type: GeneralComment: Number of Providers that will conduct an annual review of their QA records should be identified Proposed Change: 903.1 RESNET shall randomly select 25% a limited number of accredited Rating Quality Assurance Providers (QA Providers) and conduct an annual review of their Quality Assurance records. This QA review may be a review of electronic files submitted to RESNET upon request, an onsite field review, or both. The RESNET Board of Directors Quality Assurance Committee shall determine the number of QA Providers that shall be reviewed on an annual basis and who will provide the quality assurance review.
Number of Providers that will conduct an annual review of their QA records should be identified
903.1 RESNET shall randomly select 25% a limited number of accredited Rating Quality Assurance Providers (QA Providers) and conduct an annual review of their Quality Assurance records. This QA review may be a review of electronic files submitted to RESNET upon request, an onsite field review, or both. The RESNET Board of Directors Quality Assurance Committee shall determine the number of QA Providers that shall be reviewed on an annual basis and who will provide the quality assurance review.
Comment #35Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 1-4Comment Type: GeneralComment: This is an element that should remain the direct purview of Provider organizations. While it is clear of the direction and purpose that is intended, the use of this is not helpful across the entire nation. Not all raters directly interface with homeowners or electrical utilities where this would be of use. In my experience of a standard situation of new construction, very rarely is there a need to verify a raters identity in the field therefore this credit only adds additional burden and cost to most raters and providers. It should certainly be strongly suggested but not a global requirement. Proposed Change: Completely remove 102.1.2.7.1
This is an element that should remain the direct purview of Provider organizations. While it is clear of the direction and purpose that is intended, the use of this is not helpful across the entire nation. Not all raters directly interface with homeowners or electrical utilities where this would be of use. In my experience of a standard situation of new construction, very rarely is there a need to verify a raters identity in the field therefore this credit only adds additional burden and cost to most raters and providers.
It should certainly be strongly suggested but not a global requirement.
Completely remove 102.1.2.7.1
Comment #36Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 1-7Comment Type: GeneralComment: 102.1.4.7.1.3-4: People are human and will make a mistake from time-to-time. Setting probation at one violation is awefully strict. Proposed Change: alter the wording of "one or more provisions" to "5 or more provisions in a 180 day period". The 180 day period allows for cost efficiencies with smaller raters needing to be QA'd.
102.1.4.7.1.3-4: People are human and will make a mistake from time-to-time. Setting probation at one violation is awefully strict.
alter the wording of "one or more provisions" to "5 or more provisions in a 180 day period". The 180 day period allows for cost efficiencies with smaller raters needing to be QA'd.
Comment #37Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 1-7Comment Type: GeneralComment: 102.1.4.7.2.3: "Multiple" is too vague of a word which some could slant to their favor. Proposed Change: change "multiple probations" to "Two or more probations"
102.1.4.7.2.3: "Multiple" is too vague of a word which some could slant to their favor.
change "multiple probations" to "Two or more probations"
Comment #38Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-32Paragraph / Figure / Table / Note: 913.2Comment Type: TechnicalComment: Twenty business days too drawn out. Can be reasonably accomplished in ten business days. Allows more expedited resolution of issue. Proposed Change: 913.2 Within five (5) business days after receipt of an appealable action by RESNET, the Appellant shall notify the RESNET Executive Director of their intent to appeal. The Appellant shall then have twenty ten (2 10) business days after the date of notice to submit appeal documentation to the RESNET Executive Director.
Twenty business days too drawn out. Can be reasonably accomplished in ten business days. Allows more expedited resolution of issue.
913.2 Within five (5) business days after receipt of an appealable action by RESNET, the Appellant shall notify the RESNET Executive Director of their intent to appeal. The Appellant shall then have twenty ten (2 10) business days after the date of notice to submit appeal documentation to the RESNET Executive Director.
Comment #39Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-33Paragraph / Figure / Table / Note: 913.5Comment Type: TechnicalComment: Twenty business days to notify all parties too drawn out. Can be reasonably accomplished in ten business days. Thirty business days to hold hearing too drawn out. Can reasonably be done in 10 business days. Allows more expedited resolution of issue. Proposed Change: 913.5 At the time of noticing its appeal, the Appellant may request a telephonic hearing, which gives the Appellant the opportunity to provide oral arguments in favor of their appeal. In such an event, RESNET shall, not later than twenty ten (2 10) business days after the filing of the notice of appeal, notify all parties to the appeal of the date of the hearing, which shall be held as expeditiously as possible, but not later than thirty ten (3 10) business days after the receipt of the notice of appeal.
Twenty business days to notify all parties too drawn out. Can be reasonably accomplished in ten business days.
Thirty business days to hold hearing too drawn out. Can reasonably be done in 10 business days.
Allows more expedited resolution of issue.
913.5 At the time of noticing its appeal, the Appellant may request a telephonic hearing, which gives the Appellant the opportunity to provide oral arguments in favor of their appeal. In such an event, RESNET shall, not later than twenty ten (2 10) business days after the filing of the notice of appeal, notify all parties to the appeal of the date of the hearing, which shall be held as expeditiously as possible, but not later than thirty ten (3 10) business days after the receipt of the notice of appeal.
Comment #40Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-33Paragraph / Figure / Table / Note: 913.6Comment Type: TechnicalComment: Thirty business days too drawn out. Can be reasonably accomplished in ten business days. Allows more expedited resolution of issue. Proposed Change: 913.6 Within 30 10 (3 10) business days of receiving the appeal, or the date of a hearing, the Ethics and Appeals Committee or Board of Directors shall render a decision on the appeal.
Thirty business days too drawn out. Can be reasonably accomplished in ten business days. Allows more expedited resolution of issue.
913.6 Within 30 10 (3 10) business days of receiving the appeal, or the date of a hearing, the Ethics and Appeals Committee or Board of Directors shall render a decision on the appeal.
Comment #41Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-12Paragraph / Figure / Table / Note: 905.9Comment Type: TechnicalComment: Whistle blower protection must also shield a certified rater who reports quality assurance violation by a provider. Proposed Change: 905.9 QA Designee and Certified Home Energy Rater Whistle Blower Protection 905.9.1 A Rating QA Provider shall not retaliate against a QA Designee or Certified Home Energy Rater in the terms and conditions of their status with the Provider for any of the following reasons because that QA Designee or rater: 905.9.1.1 Reporting to a supervisor, to RESNET or to a federal, state or local agency what the QA Designee or rater believes in good faith to be a violation of the RESNET Standards and/or a local, state or federal law; or 905.9.1.2 Participation in good faith in any resulting investigation or proceeding;, or 905.9.1.3 Exercises his or her rights under any state or federal law(s) or regulation(s) to pursue a claim or take legal action to protect the QA Designees’ or raters rights. 905.,9.2 RESNET may take disciplinary action (up to and including revocation) against a QA Provider who in its assessment has engaged in retaliatory conduct in violation of this policy.
Whistle blower protection must also shield a certified rater who reports quality assurance violation by a provider.
905.9 QA Designee and Certified Home Energy Rater Whistle Blower Protection
905.9.1 A Rating QA Provider shall not retaliate against a QA Designee or Certified Home Energy Rater in the terms and conditions of their status with the Provider for any of the following reasons because that QA Designee or rater:
905.9.1.1 Reporting to a supervisor, to RESNET or to a federal, state or local agency what the QA Designee or rater believes in good faith to be a violation of the RESNET Standards and/or a local, state or federal law; or 905.9.1.2 Participation in good faith in any resulting investigation or proceeding;, or 905.9.1.3 Exercises his or her rights under any state or federal law(s) or regulation(s) to pursue a claim or take legal action to protect the QA Designees’ or raters rights.
905.,9.2 RESNET may take disciplinary action (up to and including revocation) against a QA Provider who in its assessment has engaged in retaliatory conduct in violation of this policy.
Comment #42Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-32Paragraph / Figure / Table / Note: 912.5.4.2Comment Type: TechnicalComment: Section 913.4 already includes a provision for a petition to a stay of action, this section is not required. In addition Certified Home Energy Raters must comply with the RESNET Standards. It is proposed that the rater have whistle blower protection. If the rater knows the provider is in violation of standard and does noting then the rater is a party of the transgression. Proposed Change: 912.5.4.2 Raters working with a Provider whose accreditation is revoked or suspended may be granted a period of time thirty (30) days in which to complete ratings in progress with the Provider. RESNET shall establish the time frame for transition and any limitations on work performed by the Provider and Rater during the transition period.
Section 913.4 already includes a provision for a petition to a stay of action, this section is not required. In addition Certified Home Energy Raters must comply with the RESNET Standards. It is proposed that the rater have whistle blower protection. If the rater knows the provider is in violation of standard and does noting then the rater is a party of the transgression.
912.5.4.2 Raters working with a Provider whose accreditation is revoked or suspended may be granted a period of time thirty (30) days in which to complete ratings in progress with the Provider. RESNET shall establish the time frame for transition and any limitations on work performed by the Provider and Rater during the transition period.
Comment #43Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 9-32Paragraph / Figure / Table / Note: 913.5Comment Type: TechnicalComment: Clatifies at what level request for hearing should be addressed. It is appropriate that this request be part of the RESNET Ethics and Appeals Committee but not the RESNET Board. The RESNET Board review should be to ensure due process was followed not having 20 individuals decide merits of complaint. Proposed Change: 913.5 At the time of noticing its appeal to the RESNET Ethics and Appeals Committee, the Appellant may request a telephonic hearing before the RESNET Ethics and Appeals Committee, which gives the Appellant the opportunity to provide oral arguments in favor of their appeal.
Clatifies at what level request for hearing should be addressed. It is appropriate that this request be part of the RESNET Ethics and Appeals Committee but not the RESNET Board.
The RESNET Board review should be to ensure due process was followed not having 20 individuals decide merits of complaint.
913.5 At the time of noticing its appeal to the RESNET Ethics and Appeals Committee, the Appellant may request a telephonic hearing before the RESNET Ethics and Appeals Committee, which gives the Appellant the opportunity to provide oral arguments in favor of their appeal.
Comment #44Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 3Paragraph / Figure / Table / Note: 102.1.2.2.1Comment Type: TechnicalComment: This section refers to a change that would require that one of the probationary ratings be field supervised by a QAD. I agree that the probationary rating process needs to have more teeth, however I don't believe that this is the right direction and could have unintended consequence. The costs alone to pay a QAD to come supervise the first probationary rating could steer a company to only having RFI's and now we have less well rounded people doing rating work instead of the opposite intent of the proposed requirement. Proposed Change: I think this is a better fit in the training practice rating requirements, particularly with it being supervised. If the training requirements were strengthened with an addition of field practice ratings on an actual house and requiring a confirmed rating as one of the practice ratings, then I think we meet the intent of this proposal without additional travel costs to the rater candidate. Plus having testing and evaluation, and simulated exams on top of that, we would have people better prepared for the probationary rating phase. I know this falls outside the scope of the QA revisions and in the realm of training requirements, but I propose that in the meantime we add a requirement in the probationary rating process that the candidate submit photo documentation of the confirmed probationary ratings and at minimum must include a picture of the gauge and equipment setup along with photos of other minimum rated features. This would allow the QAD to "replicate the rating" in the process, catch deficiencies in the test setup or visual inspection and still meet the intent of the strengthening the certification process with better prepared raters, without requiring much if any additional costs to the process. This way we may not have the detrimental effect in the end of driving people away from more costly certification and towards the Rating Field Inspector model with less rounded field staff performing rating work. Nonetheless I think the RFI process needs to also be strengthened with similar requirements before considering this additional cost to certification. Since the RFI model has more room for blurred lines in communication and with the unintended consequences mentioned above, I would argue we should look at strengthening the RFI process so that the decision to become a rater or RFI is not driven solely by costs, but by knowledge and skillsets.
This section refers to a change that would require that one of the probationary ratings be field supervised by a QAD. I agree that the probationary rating process needs to have more teeth, however I don't believe that this is the right direction and could have unintended consequence. The costs alone to pay a QAD to come supervise the first probationary rating could steer a company to only having RFI's and now we have less well rounded people doing rating work instead of the opposite intent of the proposed requirement.
I think this is a better fit in the training practice rating requirements, particularly with it being supervised. If the training requirements were strengthened with an addition of field practice ratings on an actual house and requiring a confirmed rating as one of the practice ratings, then I think we meet the intent of this proposal without additional travel costs to the rater candidate. Plus having testing and evaluation, and simulated exams on top of that, we would have people better prepared for the probationary rating phase.
I know this falls outside the scope of the QA revisions and in the realm of training requirements, but I propose that in the meantime we add a requirement in the probationary rating process that the candidate submit photo documentation of the confirmed probationary ratings and at minimum must include a picture of the gauge and equipment setup along with photos of other minimum rated features. This would allow the QAD to "replicate the rating" in the process, catch deficiencies in the test setup or visual inspection and still meet the intent of the strengthening the certification process with better prepared raters, without requiring much if any additional costs to the process. This way we may not have the detrimental effect in the end of driving people away from more costly certification and towards the Rating Field Inspector model with less rounded field staff performing rating work.
Nonetheless I think the RFI process needs to also be strengthened with similar requirements before considering this additional cost to certification. Since the RFI model has more room for blurred lines in communication and with the unintended consequences mentioned above, I would argue we should look at strengthening the RFI process so that the decision to become a rater or RFI is not driven solely by costs, but by knowledge and skillsets.
Comment #45Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 28Paragraph / Figure / Table / Note: 904.4.1.3.4Comment Type: TechnicalComment: I must have missed this change in the last review of this chapter, but don't recall this being a part of the standard before. What value does a worst case rating practice provide to our industry or the client to be considered a confirmed rating? It also does not reward/encourage builders or trades to improve their current practices if all they get credit for are their worst case projections at the projected rating stage. I'm not a fan of the term worst case but that's a whole other topic of conversation (the term worst does not sit well with some builders). Last but not least calling this a confirmed rating is confusing to the QAD. If this practice is allowed it needs a different rating type to make it clear to the QAD that the actual test/inspection data will not be the same as the data in the REM file so that QA of the rating can be done appropriately. Otherwise this could have consequences of failing the 2 point thresholds if the QAD uses actual test data and the rater used worst case data in their confirmed file. Again, I don’t see the value of this practice in reducing the accuracy of a confirmed rating but if there is some value there should be a different rating type (Lazy Confirmed Rating?) along with a statement required on certificates that this rating type uses minimum thresholds that were verified on site, but that the data in the rating does not represent actual data for that home. Proposed Change: I argue that for the sake of less confusion we should do away with accepting this practice and stay with 2 rating types sampled and confirmed rating types. However, if there is some value to "confirmation of worst case rating thresholds" without giving credit to the builder than I propose this becomes a 3rd official rating type of "Worst Case" with the aforementioned requirements on the certificates.
I must have missed this change in the last review of this chapter, but don't recall this being a part of the standard before.
What value does a worst case rating practice provide to our industry or the client to be considered a confirmed rating? It also does not reward/encourage builders or trades to improve their current practices if all they get credit for are their worst case projections at the projected rating stage.
I'm not a fan of the term worst case but that's a whole other topic of conversation (the term worst does not sit well with some builders).
Last but not least calling this a confirmed rating is confusing to the QAD. If this practice is allowed it needs a different rating type to make it clear to the QAD that the actual test/inspection data will not be the same as the data in the REM file so that QA of the rating can be done appropriately. Otherwise this could have consequences of failing the 2 point thresholds if the QAD uses actual test data and the rater used worst case data in their confirmed file.
Again, I don’t see the value of this practice in reducing the accuracy of a confirmed rating but if there is some value there should be a different rating type (Lazy Confirmed Rating?) along with a statement required on certificates that this rating type uses minimum thresholds that were verified on site, but that the data in the rating does not represent actual data for that home.
I argue that for the sake of less confusion we should do away with accepting this practice and stay with 2 rating types sampled and confirmed rating types. However, if there is some value to "confirmation of worst case rating thresholds" without giving credit to the builder than I propose this becomes a 3rd official rating type of "Worst Case" with the aforementioned requirements on the certificates.
Comment #46Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 30Paragraph / Figure / Table / Note: 904.4.2.2.1Comment Type: TechnicalComment: I like the addition of allowing QA on RFI's to count towards QA on the rater where in the process the primary roles and process are overseen in the visit. However, I think additional language needs to be added to require on site QA on a rater if that rater also performs field inspections. Proposed Change: Add the following language: However, in the case that a Rater also performs field inspection(s) on home(s) an on site review of 1% of those inspections must also occur subject to the requirements in 904.4.2.1
I like the addition of allowing QA on RFI's to count towards QA on the rater where in the process the primary roles and process are overseen in the visit. However, I think additional language needs to be added to require on site QA on a rater if that rater also performs field inspections.
Add the following language:
However, in the case that a Rater also performs field inspection(s) on home(s) an on site review of 1% of those inspections must also occur subject to the requirements in 904.4.2.1
Comment #47Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 31Paragraph / Figure / Table / Note: 904.4.2.5Comment Type: EditorialComment: I think clarification needs to be provided for the addition of the MF projects QA requirements. Does this imply that all MF projects require QA? Or is it implying that only if MF units are selected then they require QA of top and bottom unit? Right now as written in the context of the feasibility of selection I would imply that "if selected" for QA a top and bottom floor must be field reviewed, however maybe the intent is to require 1% QA on all MF units as their own category, which if read out of context the statement does read that way? If the intent is to require QA, this should be it's own subsection of that paragraph to differentiate that item as a requirement. Proposed Change: Provide clarification on the addition of "For multifamily projects, QA field review shall include at least one top floor end unit and one bottom floor end unit" statement to clarify the confusion mentioned in above comments.
I think clarification needs to be provided for the addition of the MF projects QA requirements.
Does this imply that all MF projects require QA?
Or is it implying that only if MF units are selected then they require QA of top and bottom unit?
Right now as written in the context of the feasibility of selection I would imply that "if selected" for QA a top and bottom floor must be field reviewed, however maybe the intent is to require 1% QA on all MF units as their own category, which if read out of context the statement does read that way?
If the intent is to require QA, this should be it's own subsection of that paragraph to differentiate that item as a requirement.
Provide clarification on the addition of "For multifamily projects, QA field review shall include at least one top floor end unit and one bottom floor end unit" statement to clarify the confusion mentioned in above comments.
Comment #48Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: Chapters 1, 6, 9 and Appendix BParagraph / Figure / Table / Note: 'See Proposed Ammendments'Comment Type: GeneralComment: Dear ‘Standards Review Committee/Team’: It was my pleasure to attend the committee meetings during 2013 RESNET Conference in Orlando. We learned there that this was the place to submit our comments, recommendations etc. Please allow me to present to you our idea and recommendation for a new chapter of the Standard: We are interested in refining the new ANSI Standard to include consideration of Residential Factory Built Housing production. Energy Star currently provides a method to certify production of Residential Factory Built Housing production which accommodates a two phase process for the required (1) In-Plant and (2) Site Completion Energy Rater inspections to achieve the HERS Rating. This program recognizes the controlled conditions of In-plant production under a Third Party certified quality control program. This also allows reasonable sampling by the HERS Rater which controls the cost for the Factory Built Housing Producer. The RESNET Standard Sampling process under Chapter 6 requires one in seven (1 in 7) Rater Inspection of site homes which is far more intensive than Energy Star Allows for in-plant production. Again, this recognizes the Independent Third Party Inspections that occur during the factory assembly process plus the manufacturers approved quality control program inspection. So that the Factory Built Homes Industry is not left out of the RESNET Standard, we are recommending that the following criteria be included in the new/upgraded ANSI Standard. (See Attached Chapter 11 Draft) Please give this recommendation for inclusion of a new Chapter 11 into the RESNET Standard your serious support. Otherwise, Energy Star Homes will enjoy the EPA sampling approach while HERS Rated factory produced homes will face excessive cost for compliance. (Please see sample differentials on a 7 home per day and 7 homes per week production comparison of Rater costs.) _____________________________________________________ Attach – 1 8/27/12 MODULAR HOME PRODUCTION SAMPLE: 7 HOMES PER DAY HERS SAMPLING E-STAR SAMPLING Production Cost Production Cost 1st week 1st week 7/day $1,000 7/day $0 7/day $1,000 7/day $0 7/day $1,000 7/day $0 7/day $1,000 7/day $0 7/day $1,000 7/day $0 2nd week $5,000 2nd week $0 3rd week $5,000 3rd week $0 4th week $5,000 4th week $0 One month cost $20,000 One month cost $0 Five month cost $100,000 Five month cost $1,000 TOTAL COST: 6 month cost $120,000 6 month cost: $1,000 ______________________________________________________ Attach – 2 8/27/12 MODULAR HOME PRODUCTION SAMPLE: 7 HOMES PER WEEK HERS SAMPLING E-STAR SAMPLING Production Cost Production Cost 1st week 1st week 7/week $1,000 7/week $0 2nd week $1,000 2nd week $0 3rd week $1,000 3rd week $0 4th week $1,000 4th week $0 One month cost $4,000 One month cost $0 Five month cost $20,000 Five month cost $1,000 TOTAL COST: 6 month cost $24,000 6 month cost: $1,000 Very truly yours, TRA CERTIFICATION INT’L Thomas R. Arnold, President Proposed Change: Proposed additions two current Standards & Corresponding Chapter: 104.3: (See our PROPOSED “Chapter 11 – Factory Built Housing”) 603.7.1 Add: (See our PROPOSED “Chapter 11 – Factory Built Housing”) 603.7.3.1 Exception: (See our PROPOSED “Chapter 11 – Factory Built Housing”) 606 Add: (See our PROPOSED “Chapter 11 – Factory Built Housing”) 906.2.1 Add: (See our PROPOSED “Chapter 11 – Factory Built Housing”) APPENDIX B; Add Page B-8 (Definition of “Factory Built Housing”) ____________________________________________________ CHAPTER 11 RESNET STANDARDS 1100 RESNET Standard for Factory Built Housing Energy Performance Verification 1101 IN-PLANT VERIFICATION SAMPLING PROTOCOL. A plant may conduct in-plant verification of plant-installed measures through sampling, subject to the following conditions: 1101.1 In-plant visually inspected measures. Measures that are completed in the plant that are visually inspected cannot be sampled (i.e., 100% inspection rate). 1101.2 In-plant testing of building enclosure air-tightness. 1101.2.1 Testing. The building air leakage shall be tested in accordance with proper procedures. 1101.2.2 Sampling. Compliance under this section can be demonstrated by the testing of representative homes as follows: 1101.2.2.1 The factory home builder shall initially test in the plant and verify for compliance three (3) homes representative of the range of building configurations built by the plant. 1101.2.2.2 Subsequent in-plant testing of homes can be sampled at a rate of not less than one home in every seven (1 in 7) selected for compliance with this standard; or 1101.2.2.3 Subsequent in-plant testing of homes can be sampled at a rate of not less than one home every six months, one single and/or one multi-section (inclusive of the types of homes the plant produces, both single and multi-section) selected for compliance with these requirements. 1101.2.2.4 All homes included under the sampling rate defined in Section 1101.2.2.3 shall also be visually inspected for compliance with the following prescriptive requirements: -A continuous air barrier installed on all exterior walls. -Mating surfaces equipped with a continuous, plant-installed durable gasket. -Penetrations to unconditioned space fully sealed with solid blocking or flashing. -Gaps and penetrations I the thermal envelope sealed with caulk, foam or gasket, including the following: ducts, flue shafts, plumbing, piping, electrical wiring, bathroom and kitchen exhaust fans flanges, recessed lighting fixtures flanges adjacent to unconditioned apace and light tubes junction boxes adjacent to unconditioned space. -Rough openings around windows and exterior doors sealed with caulk, putty tape or foam. Page: 11-1 ___________________________________________________ -Doors adjacent to unconditioned space (e.g., attics, garages, basements) or ambient conditions gasketed or made substantially air-tight. -Attic access panels an drop-down stairs equipped with gaskets (i.e., not caulked) to produce continuous air seal. 1101.3 In-Plant testing of air distribution system leakage. 1101.3.1 Testing. The air distribution system leakage shall be tested in accordance with the proper procedure. 1101.3.2 Sampling. Compliance under this section can be demonstrated by the testing of representative homes as follows: 1101.3.2.1 The factory home builder shall initially test in the plant and verify for compliance three (3) homes representative of the range of air distribution system designs built by the plant. 1101.3.2.2 Subsequent in-plant testing of homes can be sampled at a rate of not less than one home in every seven (1 in 7) selected for compliance with this standard; or 1101.3.2.3 Subsequent in-plant testing of homes can be sampled at a rate of not less than once very three months, one single and/or one multi-section (inclusive of the types of homes the plant produces, both single and multi-section) selected for compliance with this standard. 1101.3.2.4 All homes included under the sampling rate defined in Section 1101.3.2.3 shall also be visually inspected for compliance with the following prescriptive requirements: -Connections and routing of ductwork completed without kinks or sharp bends. -No excessive coiled or looped flexible ductwork. -Flexible ducts in unconditioned space not installed in cavities smaller than outer duct diameter; in conditioned space not installed in cavities smaller than inner duct diameter. -Flexible ducts supported at intervals as recommended by manufacturer but at a distance ≤4 feet. -HVAC ducts may pass perpendicularly through exterior walls but shall not be run within exterior walls unless at least R-6 continuous insulation is provided on exterior side of the cavity. 1101.3.2.5 Exclusions. In-plant testing of duct leakage is excluded from this section for the following conditions and must follow the on-site verification sampling protocol in accordance with Section 1102.3: -Homes that consist of vertically stacked modules. -Duct systems primarily installed at the building site. 1101.3.2.6 Builder guidance. Manufacturers shall be required to provide guidance to builders and home installers in regard to proper site installation of exterior installed ducts. Page 11-2 ________________________________________________ 1101.4 In-plant testing of air pressure balances 1102.4 On-site testing of air pressure balances, mechanical ventilation air flow and combustion appliance safety. 1102.4.1 Testing. Air pressure balances between bedrooms and adjacent living spaces, mechanical ventilation air flow and combustion appliance safety shall be tested in accordance with acceptable procedures. 1102.4.2 Sampling. Compliance under this section can be demonstrated by field testing representative homes at a rate of not less than one home in every seven (1 in 7) selected for compliance with this standard. 1102 ON-SITE VERIFICATION SAMPLING PROTOCOL 1102.1 On-site verification rate of inspected and tested measures that are completed at the building site can be sampled as defined in this section, with the following exceptions: 1102.1.1 Initial homes built. The first two (2) homes built by an approved builder/dealer shall be inspected and tested. These homes may count toward the required sampling rate. 1102.1.2 Application of sampling rates: Compliance under this section is also subject to the following conditions: -The sampling rate is required for each unique manufacturer and builder/dealer combination. -In order to maintain the sampling rate, the builder shall test no less than one home in each 90-day period. If 90 days elapse between homes sampled, the next home built is subject to testing. 1102.1.3 Other measures. Measures that are completed at the building site and categorized as a renewable cannot be sampled. 1102.2 On-site testing of building enclosure air-tightness. 1102.2.1 Testing. The building air leakage shall be tested in accordance with proper procedures. 1102.2.2 Sampling. Compliance under this section can be demonstrated by field testing representative homes at a rate of not less than one home in every seven (1 in 7) selected for compliance with this standard. All homes included under this sampling rate shall also be visually inspected for compliance with the following prescriptive requirements: -Remove protruding nails and/or staples from the marriage wall of the home. Page 11-3 ____________________________________________________ -All sill plates adjacent to conditioned space sealed to foundation or sub-floor with caulk, foam or equivalent material. Place a foam gasket beneath the sill plate if resting atop concrete or masonry and adjacent to conditioned space. -The drywall to top plate connection sealed at tall attic/wall interfaces using caulk, foam, drywall adhesive (but not other construction adhesives), or equivalent material. Apply sealant either directly between drywall and top plate or to the seam between the two fro the attic above. -In multi-family buildings, fully sealed at all exterior boundaries the gap between the drywall shaft wall (i.e. common wall) and the structural framing between units. -Penetrations to unconditioned space fully sealed with solid blocking or flashing. -Gaps and penetrations I the thermal envelope sealed with caulk, foam or gasket, including the following: ducts, flue shafts, plumbing, piping, electrical wiring, bathroom and kitchen exhaust fans, recessed lighting fixtures adjacent to unconditioned space and light tubes adjacent to unconditioned space. 1102.3 On-site testing of air distribution system leakage. 1102.3.1 Testing. Field testing of air distribution system leakage in accordance with proper procedures is required when either of the following apply: -Homes that consist of vertically stacked modules -Duct systems primarily installed at the building site 1102.3.2 Sampling. Compliance under this section can be demonstrated by field testing representative homes at a rate of not less than one home in every seven (1 in 7) selected for compliance with these requirements. If not included in the initial two homes inspected and tested the first occurrence of a home that consists of vertically stacked modules or with duct systems primarily installed at the building site shall be inspected and tested. 1102.3.3 Plant installed ducts. On-site testing is not required for plant installed ducts. In addition, compliance with this section requires manufacturers to provide guidance to builders and home installers in regard to proper site installation of exterior installed ducts required to complete the duct system. 1102.4 On-site testing of air pressure balances, mechanical ventilation air flow and combustion appliance safety. 1102.4.1 Testing. Air pressure balances between bedrooms and adjacent living spaces, mechanical ventilation air flow and combustion appliance safety shall be tested in accordance with acceptable procedures. 1102.4.2 Sampling. Compliance under this section can be demonstrated by field testing representative homes at a rate of not less than one home in every seven (1 in 7) selected for compliance with this standard. Page 11-4 ----------------Bottom of document ------------
Dear ‘Standards Review Committee/Team’:
It was my pleasure to attend the committee meetings during 2013 RESNET Conference in Orlando. We learned there that this was the place to submit our comments, recommendations etc. Please allow me to present to you our idea and recommendation for a new chapter of the Standard:
We are interested in refining the new ANSI Standard to include consideration of Residential Factory Built Housing production.
Energy Star currently provides a method to certify production of Residential Factory Built Housing production which accommodates a two phase process for the required (1) In-Plant and (2) Site Completion Energy Rater inspections to achieve the HERS Rating. This program recognizes the controlled conditions of In-plant production under a Third Party certified quality control program. This also allows reasonable sampling by the HERS Rater which controls the cost for the Factory Built Housing Producer.
The RESNET Standard Sampling process under Chapter 6 requires one in seven (1 in 7) Rater Inspection of site homes which is far more intensive than Energy Star Allows for in-plant production. Again, this recognizes the Independent Third Party Inspections that occur during the factory assembly process plus the manufacturers approved quality control program inspection. So that the Factory Built Homes Industry is not left out of the RESNET Standard, we are recommending that the following criteria be included in the new/upgraded ANSI Standard. (See Attached Chapter 11 Draft)
Please give this recommendation for inclusion of a new Chapter 11 into the RESNET Standard your serious support. Otherwise, Energy Star Homes will enjoy the EPA sampling approach while HERS Rated factory produced homes will face excessive cost for compliance. (Please see sample differentials on a 7 home per day and 7 homes per week production comparison of Rater costs.)
_____________________________________________________
Attach – 1 8/27/12
MODULAR HOME PRODUCTION
SAMPLE: 7 HOMES PER DAY
HERS SAMPLING E-STAR SAMPLING Production Cost Production Cost 1st week 1st week 7/day $1,000 7/day $0 7/day $1,000 7/day $0 7/day $1,000 7/day $0 7/day $1,000 7/day $0 7/day $1,000 7/day $0
2nd week $5,000 2nd week $0 3rd week $5,000 3rd week $0 4th week $5,000 4th week $0
One month cost $20,000 One month cost $0
Five month cost $100,000 Five month cost $1,000
TOTAL COST: 6 month cost $120,000 6 month cost: $1,000
______________________________________________________
Attach – 2 8/27/12
SAMPLE: 7 HOMES PER WEEK
HERS SAMPLING E-STAR SAMPLING Production Cost Production Cost 1st week 1st week 7/week $1,000 7/week $0 2nd week $1,000 2nd week $0 3rd week $1,000 3rd week $0 4th week $1,000 4th week $0
One month cost $4,000 One month cost $0
Five month cost $20,000 Five month cost $1,000
TOTAL COST: 6 month cost $24,000 6 month cost: $1,000
Very truly yours, TRA CERTIFICATION INT’L Thomas R. Arnold, President
Proposed additions two current Standards & Corresponding Chapter:
104.3: (See our PROPOSED “Chapter 11 – Factory Built Housing”)
603.7.1 Add: (See our PROPOSED “Chapter 11 – Factory Built Housing”)
603.7.3.1 Exception: (See our PROPOSED “Chapter 11 – Factory Built Housing”)
606 Add: (See our PROPOSED “Chapter 11 – Factory Built Housing”)
906.2.1 Add: (See our PROPOSED “Chapter 11 – Factory Built Housing”)
APPENDIX B; Add Page B-8 (Definition of “Factory Built Housing”)
____________________________________________________
1100 RESNET Standard for Factory Built Housing Energy Performance Verification
1101 IN-PLANT VERIFICATION SAMPLING PROTOCOL. A plant may conduct in-plant verification of plant-installed measures through sampling, subject to the following conditions:
1101.1 In-plant visually inspected measures. Measures that are completed in the plant that are visually inspected cannot be sampled (i.e., 100% inspection rate).
1101.2 In-plant testing of building enclosure air-tightness.
1101.2.1 Testing. The building air leakage shall be tested in accordance with proper procedures.
1101.2.2 Sampling. Compliance under this section can be demonstrated by the testing of representative homes as follows:
1101.2.2.1 The factory home builder shall initially test in the plant and verify for compliance three (3) homes representative of the range of building configurations built by the plant.
1101.2.2.2 Subsequent in-plant testing of homes can be sampled at a rate of not less than one home in every seven (1 in 7) selected for compliance with this standard; or
1101.2.2.3 Subsequent in-plant testing of homes can be sampled at a rate of not less than one home every six months, one single and/or one multi-section (inclusive of the types of homes the plant produces, both single and multi-section) selected for compliance with these requirements.
1101.2.2.4 All homes included under the sampling rate defined in Section 1101.2.2.3 shall also be visually inspected for compliance with the following prescriptive requirements:
-A continuous air barrier installed on all exterior walls. -Mating surfaces equipped with a continuous, plant-installed durable gasket. -Penetrations to unconditioned space fully sealed with solid blocking or flashing. -Gaps and penetrations I the thermal envelope sealed with caulk, foam or gasket, including the following: ducts, flue shafts, plumbing, piping, electrical wiring, bathroom and kitchen exhaust fans flanges, recessed lighting fixtures flanges adjacent to unconditioned apace and light tubes junction boxes adjacent to unconditioned space. -Rough openings around windows and exterior doors sealed with caulk, putty tape or foam.
Page: 11-1
___________________________________________________
-Doors adjacent to unconditioned space (e.g., attics, garages, basements) or ambient conditions gasketed or made substantially air-tight. -Attic access panels an drop-down stairs equipped with gaskets (i.e., not caulked) to produce continuous air seal.
1101.3 In-Plant testing of air distribution system leakage.
1101.3.1 Testing. The air distribution system leakage shall be tested in accordance with the proper procedure.
1101.3.2 Sampling. Compliance under this section can be demonstrated by the testing of representative homes as follows:
1101.3.2.1 The factory home builder shall initially test in the plant and verify for compliance three (3) homes representative of the range of air distribution system designs built by the plant.
1101.3.2.2 Subsequent in-plant testing of homes can be sampled at a rate of not less than one home in every seven (1 in 7) selected for compliance with this standard; or
1101.3.2.3 Subsequent in-plant testing of homes can be sampled at a rate of not less than once very three months, one single and/or one multi-section (inclusive of the types of homes the plant produces, both single and multi-section) selected for compliance with this standard.
1101.3.2.4 All homes included under the sampling rate defined in Section 1101.3.2.3 shall also be visually inspected for compliance with the following prescriptive requirements:
-Connections and routing of ductwork completed without kinks or sharp bends. -No excessive coiled or looped flexible ductwork. -Flexible ducts in unconditioned space not installed in cavities smaller than outer duct diameter; in conditioned space not installed in cavities smaller than inner duct diameter. -Flexible ducts supported at intervals as recommended by manufacturer but at a distance ≤4 feet. -HVAC ducts may pass perpendicularly through exterior walls but shall not be run within exterior walls unless at least R-6 continuous insulation is provided on exterior side of the cavity.
1101.3.2.5 Exclusions. In-plant testing of duct leakage is excluded from this section for the following conditions and must follow the on-site verification sampling protocol in accordance with Section 1102.3:
-Homes that consist of vertically stacked modules. -Duct systems primarily installed at the building site.
1101.3.2.6 Builder guidance. Manufacturers shall be required to provide guidance to builders and home installers in regard to proper site installation of exterior installed ducts.
Page 11-2
________________________________________________
1101.4 In-plant testing of air pressure balances
1102.4 On-site testing of air pressure balances, mechanical ventilation air flow and combustion appliance safety.
1102.4.1 Testing. Air pressure balances between bedrooms and adjacent living spaces, mechanical ventilation air flow and combustion appliance safety shall be tested in accordance with acceptable procedures.
1102.4.2 Sampling. Compliance under this section can be demonstrated by field testing representative homes at a rate of not less than one home in every seven (1 in 7) selected for compliance with this standard.
1102 ON-SITE VERIFICATION SAMPLING PROTOCOL
1102.1 On-site verification rate of inspected and tested measures that are completed at the building site can be sampled as defined in this section, with the following exceptions:
1102.1.1 Initial homes built. The first two (2) homes built by an approved builder/dealer shall be inspected and tested. These homes may count toward the required sampling rate.
1102.1.2 Application of sampling rates: Compliance under this section is also subject to the following conditions:
-The sampling rate is required for each unique manufacturer and builder/dealer combination. -In order to maintain the sampling rate, the builder shall test no less than one home in each 90-day period. If 90 days elapse between homes sampled, the next home built is subject to testing.
1102.1.3 Other measures. Measures that are completed at the building site and categorized as a renewable cannot be sampled.
1102.2 On-site testing of building enclosure air-tightness.
1102.2.1 Testing. The building air leakage shall be tested in accordance with proper procedures.
1102.2.2 Sampling. Compliance under this section can be demonstrated by field testing representative homes at a rate of not less than one home in every seven (1 in 7) selected for compliance with this standard. All homes included under this sampling rate shall also be visually inspected for compliance with the following prescriptive requirements:
-Remove protruding nails and/or staples from the marriage wall of the home.
Page 11-3
-All sill plates adjacent to conditioned space sealed to foundation or sub-floor with caulk, foam or equivalent material. Place a foam gasket beneath the sill plate if resting atop concrete or masonry and adjacent to conditioned space. -The drywall to top plate connection sealed at tall attic/wall interfaces using caulk, foam, drywall adhesive (but not other construction adhesives), or equivalent material. Apply sealant either directly between drywall and top plate or to the seam between the two fro the attic above. -In multi-family buildings, fully sealed at all exterior boundaries the gap between the drywall shaft wall (i.e. common wall) and the structural framing between units. -Penetrations to unconditioned space fully sealed with solid blocking or flashing. -Gaps and penetrations I the thermal envelope sealed with caulk, foam or gasket, including the following: ducts, flue shafts, plumbing, piping, electrical wiring, bathroom and kitchen exhaust fans, recessed lighting fixtures adjacent to unconditioned space and light tubes adjacent to unconditioned space.
1102.3 On-site testing of air distribution system leakage.
1102.3.1 Testing. Field testing of air distribution system leakage in accordance with proper procedures is required when either of the following apply:
-Homes that consist of vertically stacked modules -Duct systems primarily installed at the building site
1102.3.2 Sampling. Compliance under this section can be demonstrated by field testing representative homes at a rate of not less than one home in every seven (1 in 7) selected for compliance with these requirements. If not included in the initial two homes inspected and tested the first occurrence of a home that consists of vertically stacked modules or with duct systems primarily installed at the building site shall be inspected and tested.
1102.3.3 Plant installed ducts. On-site testing is not required for plant installed ducts. In addition, compliance with this section requires manufacturers to provide guidance to builders and home installers in regard to proper site installation of exterior installed ducts required to complete the duct system.
Page 11-4
----------------Bottom of document ------------
Comment #49Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: allParagraph / Figure / Table / Note: allComment Type: GeneralComment: RESNET does not have a standard named “Quality Assurance Standard”. The email announcing the public comment period, title line of the online comment form, the comment form, and the online list of comments received-- all refer to the “RESNET Quality Assurance Standard”. What is the “RESNET Quality Assurance Standard”? Proposed Change: Clarify very specifically what the “RESNET Quality Assurance Standard” is. Restart the comment process.
RESNET does not have a standard named “Quality Assurance Standard”.
The email announcing the public comment period, title line of the online comment form, the comment form, and the online list of comments received-- all refer to the “RESNET Quality Assurance Standard”.
What is the “RESNET Quality Assurance Standard”?
Clarify very specifically what the “RESNET Quality Assurance Standard” is. Restart the comment process.
Comment #50Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: ??Paragraph / Figure / Table / Note: ??Comment Type: GeneralComment: The “Title” in the cover memo refers to “Other Standards”. What “Other Standards”? Proposed Change: Either identify the “Other Standards” or remove the words “Other Standards”. In either case be clear what is up for public comment.
The “Title” in the cover memo refers to “Other Standards”. What “Other Standards”?
Either identify the “Other Standards” or remove the words “Other Standards”. In either case be clear what is up for public comment.
Comment #51Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: all - generalComment Type: GeneralComment: Thank you for this opportunity to comment on the revisions to the QA Standard. Many positive improvements have been made but that further refinement will further improve the RESNET name and program. Currently the Standard lacks consistency of terminology. For example, some of the following terms are defined (highlighted) and some are not. Also, in some cases it appears that there are as many as six different terms for the same position. This makes the Standard very hard to follow. Please use one term per position consistently throughout the Standard. Please define those terms not defined or replace with a defined term. • Building Performance Auditor (BPA) (Home Energy Rater) (Rater) (Rater/Auditor) (Certified Rater) • Quality Assurance Designee (QA Designee) • Rating Field Inspector • Rater Candidate • Delegate • Accredited Rater Training Provider (Training Provider) (Rater Trainer) • Rater Field Inspector Candidate • Rating Client • Rater’s Employer • Quality Assurance Committee • Rating Sampling Provider (Sampling Provider) • Accredited Sampling Provider • Sampling Inspector • RESNET • Contractor Education and Qualification Provider (CEQ Provider) • EnergySmart Contractor • Certified Contractor • EnergySmart Home Performance Team (EnergySmart Team) • Representative • Complaint Resolution Officer (CRO) • Executive Director • EnergySmart Project Manager • Independent Rater/Auditor • Final Verifier • Client • RESNET staff • Primary QA Designee • Accredited Rating Quality Assurance Provider (Rating Provider) (Rating Quality Assurance Provider) (QA Provider) (Provider) (Accredited Provider) • Comprehensive Home Energy Rating System Building Performance Auditor (CHERS BPA) Perhaps it is because the terms for roles are not consistent or clearly defined but it is very hard to follow the processes described in the Standard. To make this very clear, please provide a flow chart of the rating process. Please provide a flow chart of the resolution of a compliant. Delete Chapter 6, Sampled Ratings and all references to chapter 6. Unless there is analysis of each home there is no way of knowing whether or not it is performing to the level claimed. I would be appalled to learn that my house was given a rating based on the performance of another house. There are many positive changes in this revised Standard. However, unless the changes are executed the program will not improve. Staff needs to be added and held accountable for the execution of the QA program. Perhaps there should be an assigned number of QA Providers for every so many Raters to ensure there are enough resources to enforce this standard.
Thank you for this opportunity to comment on the revisions to the QA Standard. Many positive improvements have been made but that further refinement will further improve the RESNET name and program.
Currently the Standard lacks consistency of terminology. For example, some of the following terms are defined (highlighted) and some are not. Also, in some cases it appears that there are as many as six different terms for the same position. This makes the Standard very hard to follow. Please use one term per position consistently throughout the Standard. Please define those terms not defined or replace with a defined term. • Building Performance Auditor (BPA) (Home Energy Rater) (Rater) (Rater/Auditor) (Certified Rater) • Quality Assurance Designee (QA Designee) • Rating Field Inspector • Rater Candidate • Delegate • Accredited Rater Training Provider (Training Provider) (Rater Trainer) • Rater Field Inspector Candidate • Rating Client • Rater’s Employer • Quality Assurance Committee • Rating Sampling Provider (Sampling Provider) • Accredited Sampling Provider • Sampling Inspector • RESNET • Contractor Education and Qualification Provider (CEQ Provider) • EnergySmart Contractor • Certified Contractor • EnergySmart Home Performance Team (EnergySmart Team) • Representative • Complaint Resolution Officer (CRO) • Executive Director • EnergySmart Project Manager • Independent Rater/Auditor • Final Verifier • Client • RESNET staff • Primary QA Designee • Accredited Rating Quality Assurance Provider (Rating Provider) (Rating Quality Assurance Provider) (QA Provider) (Provider) (Accredited Provider) • Comprehensive Home Energy Rating System Building Performance Auditor (CHERS BPA)
Perhaps it is because the terms for roles are not consistent or clearly defined but it is very hard to follow the processes described in the Standard. To make this very clear, please provide a flow chart of the rating process. Please provide a flow chart of the resolution of a compliant.
Delete Chapter 6, Sampled Ratings and all references to chapter 6. Unless there is analysis of each home there is no way of knowing whether or not it is performing to the level claimed. I would be appalled to learn that my house was given a rating based on the performance of another house.
There are many positive changes in this revised Standard. However, unless the changes are executed the program will not improve. Staff needs to be added and held accountable for the execution of the QA program. Perhaps there should be an assigned number of QA Providers for every so many Raters to ensure there are enough resources to enforce this standard.
Comment #52Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: mostParagraph / Figure / Table / Note: mostComment Type: GeneralComment: RESNET has not used the naming and numbering conventions required by the RESNET “Standards Development Policy and Procedures Manual”. RESNET “Standards Development Policy and Procedures Manual” states in Section 10.7 “The document shall be identified as to the stage of the document (i.e. NWI, WD, CD, DS, FDS).” And “All standards being developed shall be document controlled and have a numbering system to identify the document, the stage of development and the version of the document.” The review document has a footer with the wrong date. Chapters One, Four, Six, Nine and Ten are identified in the footer as “RESNET Standards, 2006”. 2006 is not the correct date. Proposed Change: Identify the document with a number and version. Use the correct date for the version. Use a file name that identifies the stage of development. Restart the comment process.
RESNET has not used the naming and numbering conventions required by the RESNET “Standards Development Policy and Procedures Manual”.
RESNET “Standards Development Policy and Procedures Manual” states in Section 10.7 “The document shall be identified as to the stage of the document (i.e. NWI, WD, CD, DS, FDS).”
And “All standards being developed shall be document controlled and have a numbering system to identify the document, the stage of development and the version of the document.”
The review document has a footer with the wrong date. Chapters One, Four, Six, Nine and Ten are identified in the footer as “RESNET Standards, 2006”. 2006 is not the correct date.
Identify the document with a number and version. Use the correct date for the version. Use a file name that identifies the stage of development. Restart the comment process.
Comment #53Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: allParagraph / Figure / Table / Note: allComment Type: GeneralComment: What is up for comment? Just the modifications shown in the downloaded file? The existing and modified text in the downloaded file? The whole chapters? Any chapter or section with “Quality Assurance” in its title or text? RESNET does not yet have any consensus standards, chapters or documents that include the scope of the specific changes set out for public comment. Modifying portions of a non-consensus standard, chapter or document would not make the whole document consensus. Reviewing some portions of a chapter and not other portions would not make the whole chapter a consensus chapter. Does RESNET expect the resulting document / chapters to be consensus? It seems clear that to get a consensus document or chapter the whole document or chapter would have to be specifically put up for public comment. Proposed Change: Clarify what is up for comment. Clarify the status of the document that will result from this cycle of public comments. If RESNET intends for a standard, document or chapter to be consensus, specifically put the whole document or chapter out for public comment.
What is up for comment? Just the modifications shown in the downloaded file? The existing and modified text in the downloaded file? The whole chapters? Any chapter or section with “Quality Assurance” in its title or text?
RESNET does not yet have any consensus standards, chapters or documents that include the scope of the specific changes set out for public comment.
Modifying portions of a non-consensus standard, chapter or document would not make the whole document consensus. Reviewing some portions of a chapter and not other portions would not make the whole chapter a consensus chapter.
Does RESNET expect the resulting document / chapters to be consensus? It seems clear that to get a consensus document or chapter the whole document or chapter would have to be specifically put up for public comment.
Clarify what is up for comment.
Clarify the status of the document that will result from this cycle of public comments. If RESNET intends for a standard, document or chapter to be consensus, specifically put the whole document or chapter out for public comment.
Comment #54Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: severalParagraph / Figure / Table / Note: severalComment Type: GeneralComment: A trademarked name is legally restricted to the use of the owner of the trademark. HERS is a trademarked term. RESNET has legally registered “HERS” as belonging to RESNET. A definition of trademark: A name, symbol, or other device identifying a product, officially registered and legally restricted to the use of the owner or manufacturer. http://www.thefreedictionary.com/trademark A registered trademark is a commercial term. Both RESNET and ANSI state: “In connection with standards that relate to the determination of whether products or services conform to one or more standards, the process or criteria for determining conformity can be standardized as long as the description of the process or criteria is limited to technical and engineering concerns and does not include what would otherwise be a commercial term.” From the “Commercial Terms and Conditions” Section of both RESNET’s Standards Development Policy and Procedures Manual and the ANSI Essential Requirements:?Due process requirements for American National Standards Proposed Change: Use a generic term that is not trademarked rather than “HERS” throughout any ANSI consensus standard. Or release the trademark on the term “HERS”.
A trademarked name is legally restricted to the use of the owner of the trademark. HERS is a trademarked term. RESNET has legally registered “HERS” as belonging to RESNET.
A definition of trademark: A name, symbol, or other device identifying a product, officially registered and legally restricted to the use of the owner or manufacturer. http://www.thefreedictionary.com/trademark
A registered trademark is a commercial term. Both RESNET and ANSI state:
“In connection with standards that relate to the determination of whether products or services conform to one or more standards, the process or criteria for determining conformity can be standardized as long as the description of the process or criteria is limited to technical and engineering concerns and does not include what would otherwise be a commercial term.”
From the “Commercial Terms and Conditions” Section of both RESNET’s Standards Development Policy and Procedures Manual and the ANSI Essential Requirements:?Due process requirements for American National Standards
Use a generic term that is not trademarked rather than “HERS” throughout any ANSI consensus standard. Or release the trademark on the term “HERS”.
Comment #55Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: manyParagraph / Figure / Table / Note: manyComment Type: GeneralComment: RESNET should eliminate proprietary terms from its consensus standards. Both RESNET and ANSI state: “… The appearance that a standard endorses any particular products, services or companies must be avoided. Therefore, it generally is not acceptable to include manufacturer lists, service provider lists, or similar material in the text of a standard or in an annex (or the equivalent). …” From the “Commercial Terms and Conditions” Section of both RESNET’s Standards Development Policy and Procedures Manual and the ANSI Essential Requirements. The text put out for review has many instances of explicitly naming RESNET’s procedures, lists, and organizational structures thereby requiring only RESNET products, the RESNET organizational structure or RESNET-approved individuals and organizations. RESNET products and events are named frequently; for example a “RESNET conference” in 102.1.2.4.2, the “RESNET National Rater Test” in 102.1.2.4.3, the “RESNET Code of Ethics” in 102.1.2.6.2, the “RESNET Building Directory” in 102.1.2.7.1.7, “RESNET staff” in 102.1.2.7.4, “RESNET complaint resolution process” in 102.1.4.7.1, “RESNET Building Registry” in 102.1.4.7.3.5.4, “RESNET National Buildings Registry” in 102.1.4.10, and many others. Proposed Change: Proprietary requirements and wording needs to be removed or replaced with non-proprietary text. RESNET specific references could be moved to non-consensus documents for RESNET use.
RESNET should eliminate proprietary terms from its consensus standards. Both RESNET and ANSI state: “… The appearance that a standard endorses any particular products, services or companies must be avoided. Therefore, it generally is not acceptable to include manufacturer lists, service provider lists, or similar material in the text of a standard or in an annex (or the equivalent). …” From the “Commercial Terms and Conditions” Section of both RESNET’s Standards Development Policy and Procedures Manual and the ANSI Essential Requirements.
The text put out for review has many instances of explicitly naming RESNET’s procedures, lists, and organizational structures thereby requiring only RESNET products, the RESNET organizational structure or RESNET-approved individuals and organizations.
RESNET products and events are named frequently; for example a “RESNET conference” in 102.1.2.4.2, the “RESNET National Rater Test” in 102.1.2.4.3, the “RESNET Code of Ethics” in 102.1.2.6.2, the “RESNET Building Directory” in 102.1.2.7.1.7, “RESNET staff” in 102.1.2.7.4, “RESNET complaint resolution process” in 102.1.4.7.1, “RESNET Building Registry” in 102.1.4.7.3.5.4, “RESNET National Buildings Registry” in 102.1.4.10, and many others.
Proprietary requirements and wording needs to be removed or replaced with non-proprietary text. RESNET specific references could be moved to non-consensus documents for RESNET use.
Comment #56Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: Chapters 9 and 10Paragraph / Figure / Table / Note: Chapters 9 and 10Comment Type: GeneralComment: Most of Chapters Nine and Ten seem inappropriate to a non-proprietary consensus standard. The RESNET procedures for discipline, probation, suspension, revocation, and the like in Chapter Nine are specific to RESNET and do not belong in a consensus standard. These topics, all legitimate concerns, could be moved to RESNET specific document(s). Chapter Ten is about “RESNET EnergySmart Contractors”, “EnergySmart Projects”, “EnergySmart Contractor Registry”, “EnergySmart teams”, … Is the term “EnergySmart” to be limited those who work with RESNET or can anyone use those terms? Chapter Ten is proprietary and does not belong in a consensus standard. These, all legitimatly part of the RESNET buisiness model, could be moved to RESNET specific document(s). Proposed Change: Move most or all of Chapters Nine and Ten into a RESNET specific document.
Most of Chapters Nine and Ten seem inappropriate to a non-proprietary consensus standard.
The RESNET procedures for discipline, probation, suspension, revocation, and the like in Chapter Nine are specific to RESNET and do not belong in a consensus standard. These topics, all legitimate concerns, could be moved to RESNET specific document(s).
Chapter Ten is about “RESNET EnergySmart Contractors”, “EnergySmart Projects”, “EnergySmart Contractor Registry”, “EnergySmart teams”, … Is the term “EnergySmart” to be limited those who work with RESNET or can anyone use those terms? Chapter Ten is proprietary and does not belong in a consensus standard. These, all legitimatly part of the RESNET buisiness model, could be moved to RESNET specific document(s).
Move most or all of Chapters Nine and Ten into a RESNET specific document.
Comment #57Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: 6-6Paragraph / Figure / Table / Note: 604.1.5Comment Type: GeneralComment: Section 604.1.5 states “Builders cannot use the sampling standard to certify or qualify homes in which they have a financial interest.” Almost by definition builders have a financial interest in homes they build. Is this wording an error, or does RESNET intend to make sampling usable only to non-profit builders? Presumably somebody hired by the builder to do sampling is the builder “using sampling”? Proposed Change: Delete section 604.1.5. 604.1.5 Builders cannot use the sampling standard to certify or qualify homes in which they have a financial interest.
Section 604.1.5 states “Builders cannot use the sampling standard to certify or qualify homes in which they have a financial interest.”
Almost by definition builders have a financial interest in homes they build. Is this wording an error, or does RESNET intend to make sampling usable only to non-profit builders? Presumably somebody hired by the builder to do sampling is the builder “using sampling”?
Delete section 604.1.5.
604.1.5 Builders cannot use the sampling standard to certify or qualify homes in which they have a financial interest.
Comment #58Amendment: Proposed Amendment to Update RESNET Quality Assurance StandardPage Number: unknownParagraph / Figure / Table / Note: unknownComment Type: GeneralComment: If the future RESNET standard mixes consensus and non-consensus material, the two types of material should be separated as required by ANSI. From the “ANSI Essential Requirements: Due process requirements for American National Standards”-- Section 4.4 “Designation of American National Standards”: Portions of a published document that were not approved through the ANS consensus process … shall be (1) clearly identified at the beginning and end of each such portion of the document, or (2) such information shall be overprinted on the cover page. These portions of the document shall be marked with the following, or similar, explanatory language: “The information contained in this (portion of a document) is not part of this American National Standard (ANS) and has not been processed in accordance with ANSI’s requirements for an ANS. As such, this (portion of a document) may contain material that has not been subjected to public review or a consensus process. In addition, it does not contain requirements necessary for conformance to the standard.” Proposed Change: Separate consensus and non-consensus material in a future standard as required by ANSI.
If the future RESNET standard mixes consensus and non-consensus material, the two types of material should be separated as required by ANSI.
From the “ANSI Essential Requirements: Due process requirements for American National Standards”-- Section 4.4 “Designation of American National Standards”: Portions of a published document that were not approved through the ANS consensus process … shall be (1) clearly identified at the beginning and end of each such portion of the document, or (2) such information shall be overprinted on the cover page. These portions of the document shall be marked with the following, or similar, explanatory language: “The information contained in this (portion of a document) is not part of this American National Standard (ANS) and has not been processed in accordance with ANSI’s requirements for an ANS. As such, this (portion of a document) may contain material that has not been subjected to public review or a consensus process. In addition, it does not contain requirements necessary for conformance to the standard.”
Separate consensus and non-consensus material in a future standard as required by ANSI.
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