Proposed Amendment to Update RESNET CAZ Testing Standard

Comment #1

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: CO/CAZ standard
Comment Type: General

Comment:

I am exceedingly frustrated with RESNET refusing to acknowledge competitive CO/CAZ standard accreditation. The redundancy of not acknowledging the CO/CAZ component within, for example BPI accreditation, or other accreditation; is irrational, wasteful of Rater’s scarce resources, has no bearing on HERS Index; and frankly, is perceived as adolescent organizational behavior.

Comment #2

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: N/A
Comment Type: General

Comment:

I have recently heard about the requirement to have the CAZ testing requirement in order to keep our HERS rating certification. I am a member services advisor for an electric company in Seguin, TX. the few member services advisors do, just like me, have our HERS rating certification for the member's benefit of when they are either buying a new home or wanting to know their HERS score for their home. We provide this to them at no charge, to our GVEC members. Because we are an electric company, we deal with electricity, not gas. I don't not see the reasoning for needing this requuirement in order to keep our HERS rating certificate. I believe that, if in certain cicumstances, that someone like us, work for a electric company or do not do this type of work solely for a living as our job, we shouldn't need to have to take this CAZ testing.

Response:
Reject-

RESNET does not make a distinction among Rater certifications. All certified Raters must meet all of the national minimum requirements for certification in order to be qualified to perform work on any home they may be required to work in.

Comment #3

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 807 and 808
Comment Type: General

Comment:

Good idea.

Response:
Accept

This is a supportive comment that requires no changes to the provisions of the standard.

Comment #4

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Comment Type: General

Comment:Response:
Accept

This is a supportive comment that requires no changes to the provisions of the standard.

Comment #5

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: CO/CAZ standard
Comment Type: Editorial

Comment:

I am in support of this proposal.

If we (RESNET) agree that the ANSI/ACCA 12 QH standard meets our needs, there is no point in wasting resources to re-write, revise, maintain, etc., a redundant standard just to call our own.

Response:
Accept

This is a supportive comment that requires no changes to the provisions of the standard.

Comment #6

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: General coment on standards
Comment Type: General

Comment:

"RESNET will continue to require the CAZ and Work Scope academic exam and the CAZ simulator exam for certification for all Rating Field Inspectors, Raters, Trainers, and Quality Assurance Designees. The Interplay ResCAZ simulator aligns very well with the ANSI/ACCA Standard 12 QH protocols."

The problem with this public comment is that the issue that most people take with this process is that it is not included anywhere in the Chapter 2 standards that new Rater trainees or trainers have to earn these credentials. Also, there is no where in the standards that sasy that existing certified raters need to obtian these standards.

You need to add these sections to the Standards, or else forcing people to go through this process has still not been codified into the standards.

Proposed Change:

204.1.6.2.9.1 New Rater training candidates shall demonstrate competency in these tasks by passing the RESNET Combustion Appliance Test, and The Work Scope Development Tests.

AND

204.1.6.2.10 The effective date for item 204.1.6.10 is Jan 1, 2014. Certified Raters who were certified prior to Jan 1, 2014 shall pass the RESNET Combustion Appliance Test, and The Work Scope Development Tests before Jan 1, 2015.

AND

204.1.5.2.8.1 New RFI training candidates shall demonstrate competency in these tasks by passing the RESNET Combustion Appliance Test, and The Work Scope Development Tests.

AND

202.1.13 All RESNET Training Providers shall augment their training curriculum in order to use combustion gas sensing equipment and recommend methods of fixing leaks. Perform CAZ, spillage, and CO testing in accordance with Worst-Case Depressurization and Combustion Appliance Testing protocols contained in Chapter 8.

AND

202.1.13.1 RESNET Training Providers shall have at least one certified trainer who has passed the RESNET Combustion Appliance Test, and The Work Scope Development Tests in order to demonstrate their ability to instruct on this topic.

AND

202.1.14 The effective date for item 202.1.13 is Jan 1, 2014.

AND

203.1.3.1 The effective date for this item is Jan 1, 2014. Certified Trainers who were certified prior to Jan 1, 2014 shall pass the RESNET Combustion Appliance Test, and The Work Scope Development Tests before Jan 1, 2015.

AND

203.1.3.2 Certified Trainers shall pass the RESNET Combustion Appliance Test, and The Work Scope Development Tests prior to instructing any courses after December 31, 2013.

Response:
Reject

This comment does not address the proposed amendment. The commenter is encouraged to submit a proposed amendment to Chapter 2, following the correct process. Under the proposed amendment, CAZ testing would only be performed by certified Raters and Rating Field Inspectors when required by local code jurisdictions or voluntary programs such as ENERGY STAR New Homes.

Comment #7

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: all
Comment Type: General

Comment:

1. Our Standard calls for inspection of the burners, crossovers, and heat exchangers. ACCA does not.
2. We use the blower door to simulate the fireplace in operation. ACCA wants you to use a camping stove. This is impractical.
3. We test under natural conditions if spillage fails during WCD. ACCA does not.
4. Our standard calls for gas leakage detection. ACCA does not.
5. We have pressure limits for failure where ACCA doesn’t.
6. ACCA limits CO to 9 ppm and 25 ppm for cutoff of testing whereas RESNET limit is set at EPA standard of 35 ppm
7. One negative for RESNET is for direct or power vented appliances CO testing should be done at vent termination. We do not need to be getting on someone’s roof. ACCA states “Sample must be taken at vent connection and around the external perimeter of accessible vent piping joints.”
8. We allow 200 ppm CO for an oven where ACCA allows 100 ppm.

We at GWS agree to this amendment.

Response:
Reject

RESNET’s standard development policy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard.

Comment #8

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Comment Type: General

Comment:

With HERS Ratings having nothing to do with Combustion Safety, I believe that this section and the associated training should be removed from the upcoming Standards Update. Our job as HERS Raters is to model homes for energy usage, not inspect for Indoor Air Quality issues.

This change is going to cause undue financial and time consuming burdens on our company without offering any new benefits to our clients.

If RESNET is trying to stay competitive with other Building Science Certifications, offer the CAZ training as an option among your certifications, not as a requirement to be a HERS Rater. By offering it as a new certification, the market will be able to decide what it needs.

With more and more jurisdictions and utilities looking to HERS Ratings for building code and incentive compliance, there are other areas that RESNET needs to focus its resources.

Thank you for reaching out to your constituents for comments on this subject.

Justin Gibson

Comment #9

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: all
Comment Type: General

Comment:

I totally agree with everything that Justin Gibson has stated in comment #8. In addition, a good HERS rater will not work with a client who wants to put gravity vented combustion appliances inside the living space, I certainly will not.

RESNET should not be in the indoor air quality business, leave that to the code agencies, and the green building programs.

If a rater does the testing, declares that there are no issues, and something shows up later, there could be some liability, some serious liability issues.

Comment #10

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Comment Type: General

Comment:

Our company has expended significant resources to become specialists with indoor air quality through certifications with BPI, Healthy Homes and HUD. We also offer HERS ratings to mostly new and sometimes existing homes. We are trying to carve in niche working with existing homes and BPI seems to be the organization with the most experience, procedures and capability to help us.

Now, why should HERS raters who are concerned about energy be required to get heavily into indoor air quality? It makes no sense, it dilutes their expertise required to do HERS ratings, and for people like me it wastes a great deal of money and time. I would say that RESNET underestimates the value of the HERS ratings to the industry and overestimates the willingness of HERS raters to go places where they have no interest and financial opportunity.

Steve Bradley

Response:
Reject

RESNET does not make a distinction among Rater certifications. All certified Raters must meet all of the national minimum requirements for certification in order to be qualified to perform work on any home they may be required to work in. The requirements for certification have been re-moved from Chapter 8 and placed in Chapter 2, where Raters (and auditors) who are current BPI Building Analysts have been exempted from the field training requirement.

Comment #11

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: 805.2
Comment Type: General

Comment:

BPI-certified pros must take a live exam on combustion testing. There is no reason to require such a person to also take a silly online simulation exam, except to make money for RESNET and InterCAZ. Please reinstate the BPI exemption.

Proposed Change:

REINSTATE:

805.2 If the Auditor has been trained and certified in accordance with a RESNET
approved "equivalent home performance certification program" or the Building
Performance Institute(BPI) Standards, the Auditor may follow protocols in accordance
with those equivalent standards.

Response:
Reject

Thank you for commenting. The requirements for certification have been removed from Chapter 8 and placed in Chapter 2, where Raters (and auditors) who are current BPI Building Analysts have been exempted from the field training requirement. To ensure national consistency, RESNET’s standard development policy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard.

Comment #12

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: RESNET/CAZ
Comment Type: General

Comment:

Stated previoulsy by another but it echos everything I support:

Comment:
BPI-certified pros must take a live exam on combustion testing. There is no reason to require such a person to also take a silly online simulation exam, except to make money for RESNET and InterCAZ. Please reinstate the BPI exemption.

Proposed Change:

REINSTATE:

Comment #13

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: All
Comment Type: General

Comment:

I agree with many of the points made by others, in particular:

1. HERS Ratings are about energy, not indoor air quality. HERS raters without CAZ training should still be able to do HERS ratings. But they should not be required to do CAZ testing. There just needs to be clarification to the Owner that a HERS Rating does not include combustion testing and that if a situation requires it, that it can be provided (as an additional service if the rater is CAZ-certified, or by others who are).

2. Requiring folks with HERS accreditation to do CAZ will be impractical and costly for many. Offer this kind of certification as an option ONLY if you want to manage it. I believe that if this is already being managed by BPI, and that existing homes are more advantageously served by BPI-certified individuals unless they want a HERS Rating.

3. The definition of CAZ-certified should mean BPI-certified OR ACCA/ANSI...QH. If someone has either of these certifications, then a HERS rater should be onsidered as CAZ-Certified.

4. I agree that RESNET should not train or test raters or anyone regarding CAZ testing - BPI is already doing it.

5. I strongly believe that redundancy in CAZ-certification is a bad idea. For those who are already BPI-certified, it is redundant in terms of cost and training. For those who are not, they can get the ACCA/ANSI certification (even though in my opinion, BPIs is better). But even more importantly, it will confuse the market. For example, If I am HERS and BPI-certified and I go into a home where CAZ testing is indicated, which protocol should I follow? Should it be the one the Owner wants? They are seldome if ever qualified to judge. Should it be RESNET? That steps on BPI's toes and creates the potential for confusion for the rater. Just stick with BPI and offer ACCA/ANSI...QH as an alternative.

6. Air quality IS a critical component of home performance and there is potential for liability if these issues are not addressed. Note that requiring or recommending mechanical ventilation is also an issue, and only has teeth for RESNET if an Energy Star Rating is part of the mix.

7. Please, make friends with BPI and vice versa. These are complementary programs and should not be adversaries.

Proposed Change:

REINSTATE:

CONSIDER removing all reference to the RESNET CAZ Certification (ie Combustion Appliance Test), let BPI or equivalent be the defacto standard where CAZ is indicated, and (important)

ADD a Work Scope requirement to give information to the Owner of the importance of resolving any combustion issues, if they are present; In the case of any EEMs being recommended, add a requirement that the home has been CAZ tested by a certified individual and that the results are considered and addressed in the Work Scope as a Health and Safety item.

Comment #14

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 805.2
Comment Type: General

Comment:

Why would you make us take another test for something that we are certified in unless you don't trust BPI.

Response:
Reject

Thank you for commenting. However, since no change has been proposed we cannot take action. The requirements for certification have been removed from Chapter 8 and placed in Chapter 2, where Raters (and auditors) who are current BPI Building Analysts have been ex-empted from the field training requirement.

Comment #15

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: Propased Amendment to update CaZ
Comment Type: General

Comment:

You cannot get the on hands experience that one needs in CAZ testing using a computer SIM. The SIM only gives you a basic feel for the process but can not simulate real time situations. My kids have learned how to use the sims and can perform a CAZ test on it with great accuracy but that does make them qualified to do CAZ testing in the feild. The United States Military teaches pilots how to fly planes in simulators to give them a feel for what will happen in the sky but that does not make them ready to go into combat. Lets use our heads people there are some things that you cannot just let a computer teach, you still need to go out and get your hands dirty. These are peoples lives we are dealing with. I believe that using the SIMS to qualify and individual is a big mistake, which can lead to even a bigger mistake. "SAFETY FIRST"

Comment #16

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1 of amendment
Paragraph / Figure / Table / Note: 805.2
Comment Type: Technical

Comment:Proposed Change:

"805.2 If the Auditor has been trained and certified in accordance with a RESNET approved "equivalent home performance certification program" or the Building Performance Institute(BPI) Standards, the Auditor may follow protocols in accordance with those equivalent standards."

***RESNET is looking to remove the above language, thus generating an additonal expense burden for those who are already certified to perform CAZ testing under the various BPI designations which they have earned and have practised over the years.

I OBJECT TO REMOVING THE HIGHLIGHTED CLAUSE as it is unnecessary to have existing RESNET auditors with BPI credentials and considerable CAZ testing field experience to incur additional and redundant charges without adding to the quality of services offered to the public.

Comment #17

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 480-228-4450
Comment Type: General

Comment:

I support Amendment.

Response:
Accept

Thank you for commenting. This is a supportive comment that requires no changes to the provi-sions of the standard.

Comment #18

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: amendment
Comment Type: General

Comment:

This ammendment is BS!!! This is just another squeeze on our industry and a way for you to make money. Ill keep my BPI as this is a way more valuable cert vs RESNET. If you pass one you should have to do both. Work with BPI already

Response:
Reject

Thank you for commenting. However, since no change has been proposed we cannot take ac-tion. The requirements for certification have been removed from Chapter 8 and placed in Chap-ter 2, where Raters (and auditors) who are current BPI Building Analysts have been exempted from the field training requirement.

Comment #19

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: amendment
Comment Type: General

Comment:

Comment #20

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: 805.1
Comment Type: General

Comment:

First of all - I think it is unfortunate that RESNET is forcing this as a requirement to all raters who hope to continue being raters regardless of whether they will be doing combustion testing or not. I would like to see it changed to an optional add-on certification that accepts BPI certification as equivalent. If its maintained as required for all to remain certified RESNET should still allow BPI certification as equivalent and exempt from at least the simulation exam.

Even if the above comment is rejected, section 805.1 must be changed to allow RESNET-accredited raters and auditors who are performing combustion appliance testing within some other non-RESNET related program to follow the standard of the program they are working under when its not RESNET. For example, a RESNET rater who also holds BPI certification goes into a house for a Home Performance program that requires BPI and other program specific standards be followed ... the way the standard appears to be written in section 805.1 the auditor would be in conflict with this standard if they were to carry out the duties of the HP program to their rules.

Proposed Change:

BPI certification is considered equivalent and allows rater to be exempt from the 25 quesiton exam and the Interplay CAZ simulation exam.

805.1 These protocols contained in ANSI/ACCA 12 QH, Appendix A Sections A4 (Carbon
Monoxide Test) and A5 (Depressurization Test for the Combustion Appliance Zone (CAZ))
shall be followed by RESNET-accredited Raters and Auditors (hereinafter referred to
collectively as “Auditors”) performing combustion appliance testing add words here to allow testing to other standards where there is other jursdication

Response:
Reject

The proposed language regarding the academic and simulation exams is not part of the proposed amendment that is commented on. RESNET also already recognizes local jurisdictions override our Standards (Section 101.1.1). RESNET’s standard development policy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard.

Comment #21

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 805.2
Comment Type: General

Comment:

There should be no reason not to allow BPI building analysis certification to be eqivalent to meeting performance standards competency requirements for CAZ testing. Not allowing this certification puts unneeded expense and burden on raters to reprove this competencie.

Proposed Change:

Removal of 805.2

Comment #22

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: 805.2
Comment Type: General

Comment:

I have always valued my association with RESNET, and have held the RESNET standards in the highest regard. However, it is my extreme frustration with the infighting between RESNET and BPI that my comments are directed. We are being forced into double sets of testing, certification, examination; wasting valuble time and money. Rather than having a battle between the org's, we should spend our limited resources on NEW standards and protocol that will justify our professional focus, improve customer satisfaction, and reward out industry with an improved outcomes.

Please rescind the proposed CAZ testing requirements for reasons already opinioned by others; namely: time and money.

If CAZ testing is deemed a priority for RESNET, reinstate 805.2

Proposed Change:

805.2 If the Auditor has been trained and certified in accordance with a RESNET

approved "equivalent home performance certification program" or the Building

Performance Institute(BPI) Standards, the Auditor may follow protocols in accordance

with those equivalent standards.

Comment #23

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Comment Type: General

Comment:

I have no arguement with the various CAZ testing methodologies, ACCA, BPI or RESNET. My arguement is that there is no process in place to give existing raters credit for homes successfully tested and retrofit. I have many clients who are happy and safe in their tight, comfortable homes, yet there is no way for me to get aknowledgment from the various organizations for this body of work. Meanwhile there will be a requirement for me to take classes and tests, at my expense, to prove to you that I know what to do. I bekieve you need to think about the work we have all done and not make use jump through more hoops to attain a standard you have just devised that we have been meeting for years.

Response:
Reject

Thank you for commenting. However, since no change has been proposed we cannot take ac-tion.

Comment #24

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Comment Type: General

Comment:

Reinstate 805.2.

BPI certification should be an acceptable option for a HERS rater.

And a simulation exam is not equivalent to a field exam, athough simulation IS an excellent way to train people. If RESNET wants to demonstrate the legitimacy of a combustion exam it must be authentic - ie it needs to be taken in the field.

Comment #25

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: n/a
Paragraph / Figure / Table / Note: general
Comment Type: General

Comment:

People who have gone through BPI should be exempt. Plus HERS Raters are performance testing and rating a home. Most do not have a license to work with GAS Appliances. Now you are really exposing the HERS Rater to liability if something goes wrong after a CAS test. This a bad idea.

Comment #26

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: CAZ TESTING
Comment Type: Technical

Comment:

Dear Committee,

Having been working in the home performance industry for several years as both a trainer and as an industry professional I have concerns with regard to the type of testing standard being considered.

I believe that there is room for both testing requirements. First, using a computer generated model is a great way to become familiar with the different types of systems and the changes that can occur do to specific features and set ups of the home. However, I think that a hands on practical is the best way to insure someone is capable of setting the home up, seeing the differences that can occur through worst case, and how to properly identify the changes that need to be made if there are issues with the CAZ.

That said, I think that there should be a requirement in passing the online "Intercaz" model; but there should also be the requirement to pass the field performance model as well. We know that every field location isnt the best or even functional for that matter. Maybe there should be some accountability just as a Provider for RESNET views the ratings of a HES Rater, there should be something in place for the CAZ testing as well.

This is an area that is critical to the health and safety of the occupants which I think is more important than a rated efficiency!

Mark A. Lera

Comment #27

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: all
Comment Type: Editorial

Comment:

I have taken the BPI traings and passed both the BPI written & practical live exams. It is ludicrous that RESNET would not accept this certification for CAZ testing requirements. Why is RESNET including CAZ testing in HERS raters training requirements at all? Please explain.

John Young, LEED AP

Comment #28

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Comment Type: General

Comment:

I do not agree that RESNET-accredited HERS raters should be required to perform CAZ testing. HERS raters provide energy modeling services as well as certain third-party verification and testing rquired to provide objective and reproducable information regarding energy requirements in our built environment. We should not be required to opine on the health and safety issues of combustions appliances installed in buildings. In fact, in some homes that I provide HERS rating services for, the natural gas or propane used for combustion appliances is not even turned on at the point in time when I perform the final field verification and testing.

Proposed Change:

Comment #29

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Comment Type: General

Comment:

I have been teaching the BPI CAZ protocol for years. To require that I attend training before I am able to challenge a test is infuriating to me! If the RESNET protocol is that much different than the BPI protocol there must be something that changed with physics and chemistry in the past year. To have two different standards for professionals who often overlap certifications is fine but if the methods used to determine limits are different then there is probably something wrong with the methods.
I see this as little more than a waste of resources for Raters and another way to generate income for RESNET.

Response:
Reject

Thank you for commenting. The requirements for certification have been removed from Chapter 8 and placed in Chapter 2, where Raters (and auditors) who are current BPI Building Analysts have been exempted from the field training requirement. RESNET’s standard development poli-cy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard.

Comment #30

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 805
Comment Type: Editorial

Comment:

While combustion safety is important, this adds a redundant layer that is more directly and appropriately addressed by overlapping programs and codes. I worry that the additional layer will confuse market participants as to the value proposition of HERS, which I believe is specific to the index, and further burden raters and potential raters with cost and time investments unrelated to energy performance. Recent calls to Southeastern HERS training providers found only one provider currently offering classes for HERS raters due to low demand. I cannot imagine this new measure will increase demand for raters, or increase the prevlance of the rating system in the marketplace.

Response:
Reject

Thank you for commenting. However, since no change has been proposed we cannot take action.

Comment #31

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Comment Type: General

Comment:

I do not agree with this requirement because it is taking HERS away from its original mission - to measure the home's energy efficiency. CAZ testing is not a part of the HERS rating so why should a rater have to be certified to do CAZ testing? In addition, if being proficient in CAZ testing is deemed so important, then proof of BPI certification should be sufficient. To require certification in something rarely used by raters and then to not accept BPI certification of that training seems only designed to feather RESNETS pockets at the expense of its raters.

Comment #32

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: Section 805 Through 809
Comment Type: Technical

Comment:

I oppose the amendment.

I submitted the following recommended revision of the RESNET standard at the end of December, 2013 . That submission starts in paragraph colored blue below.

I think that it is quite likely that my submission was among the causes for Brett Dillon's consideration of this issue and OWING TO THE LARGE NUMBER OF MY SUGGESTED CHANGES AND THEIR MERIT may have decided to reconsider RESNET's participation in CAZ testing altogether. In my next post, I will extend these remarks with my opinions about his recommendation.

However, since I'm an Energy Rater Trainer and wish to keep my certification, I submitted the following to make my job easier. That is, if we are going to keep CAZ testing, we should make our standard match our simulation.

Moreover, I for one believe that a major part of the effect of RESNET's standard and the industry it supports is in service to RETROFITS of existing homes. As such, anything that substantially affects that job is rightly within RESNET's scope of interest. Moreover, I believe that there is a set of obligations on anyone making recommendations on how to improve a home... regardless of whether the intent is to improve comfort, health, durability, safety or energy consumption. That obligation is JUST LIKE A DOCTOR... first, do no harm... It is not ok to cause one problem while you're focusing on another. More on that in my next post.

RESNET's CAZ test and Work Scope Standard
Excerpt from RESNET's Mortgage Standard 2013.
http://www.resnet.us/standards/RESNET_Mortgage_Industry_National_HERS_Standards.pdf
The text in black is from the RESNET Standard obtained from the PDF file by OCR software. The colored text represent edits suggested by Myron Katz (and his colleagues and wife) based on experience obtained from practicing with the RESNET/Interplay Energy simulator, a careful reading of the RESNET Standard and AGA standards, and personal professional experience, all with the intent of creating a clearer, easier to understand, easier to teach and more precise document. As my PhD thesis advisor once said, "Don't make your document an IQ test!"
Text in italics is not recommended for inclusion in the revised standard, but is placed in this document for explanatory purposes.
805 Work Scope and Combustion Safety Procedures
805.1 These protocols shall be followed by RESNET-accredited Raters and Auditors (hereinafter referred to collectively as "Auditors") performing combustion-appliance testing or writing work-scopes for repairs which result from these tests. ["Work Scope" was not a term used by RESNET before the advent of BPI's usage with CAZ testing. RESNET should make it clear that "Work Scope" only applies to the results of CAZ testing.]
805.2 If the Auditor has been trained and certified in accordance with a RESNET-approved "equivalent home performance certification program" or the Building Performance Institute (BPI) Standards, the Auditor may follow protocols in accordance with either of those ?equivalent standards. [Hardly equivalent! Unlike RESNET's CAZ test, BPI measures draft, sets 25 ppm and 400 ppm as diagnostically significant and clearly limits testing of equipment to those with draft hoods. RESNET apparently expects its Auditors to be familiar with or know how to look up manufacturer's CO concentration production on a model-by-model basis. Moreover, RESNET's resulting work scope is far more comprehensive and complex.]
805.3 RESNET-accredited Training Providers shall train HERS Auditors on these protocols through either field exercise or through simulated conditions. A written exam administered by a RESNET-accredited Trainer is also required, provided by RESNET. The test shall cover the content of these guidelines with a minimum of 25 questions. A minimum score of 80% is required to pass.
805.4 Prior to conducting any test that affects the operating pressures in the home, the Auditor shall inquire whether a person that has acute or chronic environmental sensitivities (asthma, allergies, chemical or mold sensitivity, etc.) is present in or resides in the home. If such a person is present, the Auditor shall not perform such tests without written disclosure & consent from the affected party (or responsible adult). The written disclosure shall state (at a minimum) that "during the period of testing, some amount of dust, particles, mold spores or soil gases already present in or near the home may become airborne within the home." Without a signed disclosure, the Auditor shall either reschedule the test for a time when they will not be present, or ask them to leave the home during the testing process. The Auditor shall also inquire as to the presence of pets that may potentially be affected by testing procedures. [No aspect of this paragraph can be found in the simulation software.][Mold spores can become airborne because of depressurization. This can be very dangerous to mold allergic people. It does not matter whether the person who is at the home during the test is the sensitive to mold occupant.]
806 Gas Leakage Test
806.0 If there is a noticeable odor indicating natural gas buildup within the home, the occupants and Auditor shall leave the home and the appropriate authorities and utility providers shall be notified from outside the home. [No aspect of this paragraph can be found in the simulation software.] The Auditor should use a gas detector upon entry into the home to detect the presence of natural gas. If a significant gas leak (RESNET should define " significant" in this sentence.) is suspected or confirmed, turn off all thermostats, ensure that switches are not operated while exiting and no ignition devices or appliances are left on. [No aspect of the previous sentence can be found in the simulation software.] The audit shall not proceed until the proper authorities have deemed it safe to re-enter the home.
806.1 If there is no noticeable odor indicating gas buildup within the home, the Auditor shall determine if there are gas leaks in accessible fittings and connections of natural gas appliances within the home, and natural gas/liquid propane supply lines, following these protocols. [The latter means that it's ok to skip checking a gas line behind a very hard to move stove or if the movement of that stove poses a significant risk to damage the kitchen floor.]
• Inspect all fittings and joints in accessible supply lines and appliance connectors and confirm suspected leaks with leak-detection fluid. Indicate in the Work Scope the location of the confirmed leaks.
• Identify for repair or replacement any kinked, corroded or visibly worn flexible gas lines and any flexible connectors manufactured prior to 1974. [No aspect of the last sentence of this paragraph can be found in the simulation software.]
806.2 Equipment needed

• Combustible gas detector capable of measuring 20 ppm
• Leak detection fluid (non-corrosive), to be used to confirm leaks with bubbles.
• Borescope, to see behind/under a stove, furnace or water heater in order to do inspections relevant to the 2nd part of 806.1.
807 Worst Case Depressurization Test
This test procedure
1. measures the pressure in the Combustion Appliance Zone (CAZ) in natural and worst case depressurization conditions,
2. measures the CO concentration of the air going up the flew downstream of each combustion appliance in the CAZ in both pressure regimes,
3. provides visual evidence of potential spillage under natural and worst case depressurization conditions, and
4. generates the information needed to create a work scope which will specify the work of other contractors.
The purpose of this test is to measure problems in a particular home that will allow creation of a work scope containing notices and recommendations designed to protect a home's occupant from the dangers of CO poisoning.   [By providing a clear statement of purpose, the reader is better able to grasp what is going on in this complicated procedure.]
This test is designed to be done by a single Auditor who will walk through the home alternatively using four tools: manometer, CO meter, smoke pencil and clipboard. The standard procedure assumes that one common hallway, possibly connected via open stairways, connects the conditioned living area as one pressure-zone that opens to every room of the home. Pressure measurements will be only taken within this "hallway" and the CAZ; both measurements are with respect to outside. Homes that do not conform to this configuration may create unplanned-for complexities that are outside of the scope of this test, unless the auditor has a wireless-enabled manometer which will allow the pressure testing to proceed with a stationary placement of the manometer in the CAZ. Best practice recommends setup of the manometer at the onset of this test to measure pressure WRT outside using the hose conduit on the blower door to access outside.   [Stating the intended mechanics of the testing environment helps the prospective Auditor visualize the process in advance in order to make subsequent learning on site and/or via the simulator that much easier to learn.]
807.0 Definition of a Combustion Appliance Zone and Eligible Appliances
807.0 A CAZ is any volume of a home that 1) contains an eligible appliance for this test, and 2) is subject to depressurization sufficient to threaten CO-related health problems. [It is always a good idea to define key terms!]
[Sections 807.0.1 and 807.0.2 were inserted to replace : If there are any vented combustion appliances that appear to the auditor to primarily use indoor air as the source of combustion air to vent combustion gases, and said appliances are not classified as a category 3 or 4 according to NFPA standard 54, i.e., do not have integral fans to induce a positive vent static pressure, [Why not say what you mean instead of asking the reader to go off looking up standards that are hard to find and even harder to read?] then a worst case depressurization test shall be performed using the following protocol.
["3.3.230* Vented Appliance, Category I. An appliance that operates with a nonpositive vent static pressure and with a vent gas temperature that avoids excessive condensate production in the vent.
3.3.231 Vented Appliance, Category II. An appliance that operates with a nonpositive vent static pressure and with a vent gas temperature that may cause excessive condensate produc¬tion in the vent.
3.3.232 Vented Appliance, Category III. An appliance that operates with a positive vent static pressure and with a vent gas temperature that avoids excessive condensate production in the vent.
3.3.233 Vented Appliance, Category IV. An appliance that operates with a positive vent static pressure and with a vent gas temperature that may cause excessive condensate production in the vent."
NPFA Standard 54] Kenneth Ripberger pointed out that even fan-induced vented equipment normally installed in a home is Category I or II.]
807.0.1 An eligible appliance for this test is any vented combustion appliance that appears to the Auditor to primarily use indoor air as the source of combustion air to vent combustion gases. Excluded from this category are appliances such as those found in a fireplace in a living-room-like setting or used for cooking or clothes drying. A gas water heater and a naturally vented or 80% gas furnace are all eligible appliances. However, neither a clothes dryer, stove, oven nor a gas space-heater which is vented into a fireplace's chimney or flue are eligible appliances for this purpose. [The Auditor has basically no way of knowing that an appliance installed in a fireplace is ineligible without this paragraph—that is, unless he has done a lot of reading of codes or deeply understands NFPA standard 54. The same can be said about a stove or a dryer.]
807.0.2 "Subject to depressurization sufficient to threaten CO-related health problems" means any combination of deficiencies in equipment performance and the home's tendency to allow the CAZ to depressurize which can result in sufficient CO release into the home to potentially degrade human health via CO poisoning. Thus, a closet weather-stripped and sealed on all six sides which contains a water heater and its own passive intake and exhaust ducts to outside, in a manner compliant with NFPA standard 54, is not a CAZ zone that needs to be tested under this standard. Similarly, a sealed-combustion (i.e., 90%) gas furnace does not cause the room in which it is installed to be deemed a CAZ. Direct vent gas water heaters utilize a doubly-sealed combustion air and flue system with integral intake and exhaust combustion airstreams have been specially designed and certified to be safe as free-standing appliances in a home, whether or not located in separate rooms, even though such appliances are atmospherically vented. [The Auditor needs to know which appliances, if properly installed, do not warrant CAZ testing. Similarly, the Auditor should be made aware of Combustion Closet through the front door of this standard instead through the back door.]
807.0.3 A home has as many CAZs as there are rooms with eligible appliances and such rooms simultaneously exhibit different pressures. For example, a home with a water heater in a basement and a furnace in a garage will have at least two CAZs. [Without this paragraph, the Auditor may think that a home as at most one CAZ.]
807.1 Preliminary to Entering a Home
The Auditor will perform the following before entering the home.
807.1.1 "Zero out" and then wear a CO alarm to alert the Auditor of the presence of a CO concentration of > 35 ppm. The Auditor will also wear eye goggles.
807.1.2 "Zero out" the CO meter and Gas detectors
807.1.3 Check the toolbox for a smoke pencil.
807.1.4 Be prepared to install a blower door.
807.1.5 Carry a manometer and tubing long enough to allow inspection of the entire home or a wireless-enabled manometer.
807.1.6 Carry a note-taking tool or clipboard.
[All of these are features of the CAZ simulation software. If you want the Auditor to do these things, they should be mandated in the standard as well as in the simulation.]
807.2 Identification of CAZs and Verification of Safety, Proper Installation and Maintenance
807.2.0 Explore the home and locate all eligible appliances. Determine and number the CAZs. If the water heater and space-heating equipment are both eligible appliances and in separate rooms, note on your clipboard.
807.2.1 Check each CAZ for the presence of flammable or explosive material near a combustion source. [No aspect of this paragraph can be found in the simulation software. The RESNET standard does not tell the Auditor what to do if such material if found, I recommend:] If such materials are found, have the home's occupant remove them. [In fact, this issue is tested upon in the multiple choice test! If so, state this in the standard.]
807.2.2 Visually inspect the venting system for proper size and horizontal pitch and determine that there are no observable existing or potential blockages,restrictions, leaks, corrosion or other deficiencies that could cause an unsafe condition. [What is the recommendation or effect if deficiencies are found? Here is a suggestion.] If such situations exist, [do not do the CAZ test and instead put "vent repair" into the work scope.] [or] do the CAZ test and put "vent repair" into the work scope. [No aspect of this paragraph can be found in the simulation software.] [It should be noted that the simulation software sometimes shows the water heater and furnace sharing the same vent and other simulations show two, independent vents. Neither the RESNET standard nor the software provide any suggestion that these two cases should be treated differently or how that should be done. As a deep novice to these tests, but a student of physics, I think these conditions affect the test, but as much as I might conjecture about their interrelationship, I'd rather see an improvement to this standard coming from an experienced auditor.]
807.2.3 Inspect burners and crossovers for blockage and corrosion. [No aspect of this paragraph is tested in the simulation software.]
807.2.4 Inspect furnace heat exchangers for cracks, openings and excessive corrosion. [No aspect of this paragraph can be found in the simulation software. But the software allows the removal of some furnace parts of some furnace types for closer inspection. What's up with that?]
807.3 Measure Baseline, i.e. Natural, Pressurization for each CAZ
807.3.1 Close all interior doors, and exterior doors and windows of the home; this includes any interior doors between the CAZ and the remainder of the home.
807.3.2 When possible, close fireplace dampers. [Note that closing fireplace dampers is not possible in the simulation.]
807.3.3 Turn off all combustion appliances, air handlers and exhaust fans.. [Air handler should be off as well. However, none of clocks, ceiling fans or TVs need be off.]
807.3.4 Measure the baseline pressure difference of a CAZ with respect to (WRT) outside and record it as the baseline pressure for this CAZ. [Two such tests are needed if there are two CAZs; this information must be segregated for later use.]
807.4 Setup and Measure Worst Case Depressurization (WC) Pressure
807.4.1 Turn on all exhaust fans in the home (i.e., kitchen range hood, bath exhaust fans, clothes dryer, etc.) that exhaust air to the outside of the building envelope, but do not turn on any other vented appliances. Although each vented appliance should be expected to induce an airflow to outside and act similarly to an exhaust fan, none of them should to be in operation at the onset of the test procedure. Close every interior door in the home except the door between the central hallway and the CAZ. [Since some combustion appliances exhaust air to outside with the aid of an exhaust fan, the added sentences are needed. Moreover, testing of the combustion appliances must be done in a systematic fashion starting with them all off and the proceeding one appliance at a time.]
807.4.2 If there is a ducted HVAC system, turn on the air handler at the thermostat by setting it to "Fan On" but do not turn on heating or cooling, i.e., do not start a boiler, furnace or compressor. If operation of the air handler makes the CAZ more positive (i.e., less negative), turn it off. [Some homes do not have ducted systems for space heating or cooling; such systems include those that employ boilers, ductless mini-splits, window air conditioners, etc. Nevertheless, such homes can have CAZs which need testing.]
807.4.3 If there are olperable fireplaces present, install a blower door, set it to cruise and exhaust air to outside at 300 CFM (times the number of fireplaces) to simulate the exhaust flow normally generated by a fireplace in operation. [This multiply suggestion seems most general and applicable to homes with more than one fireplace... also not so rare a situation. Where I live, most fireplaces have been blocked off and made inoperable.]
807.4.4 Find the combination of open and closed interior doors which causes the CAZ to have the lowest pressure. Open any combination of doors which causes the lowest pressure in the CAZ. Best practice is to use a serial approach: start from the interior doors to the central hallway furthest from the CAZ and work your way back to it. Finally, also test whether closing the door to the CAZ lowers the pressure in the CAZ. [These instructions about how to do it will greatly speed up learning this skill. What's wrong with putting them in the standard?]
807.4.5 Record the Worst Case Depressurization pressure, of the CAZ WRT outside.
807.5 Specify Pressure Relief Measures if Net Worst Case Value > 5 Pa
807.5 Net Worst Case Value (NWC) is the net change in pressure difference within each CAZ WRT outside between the baseline and worst case depressurization conditions, i.e.
NWC = Baseline pressure - WC pressure.
[The simulation software calculates NWC as WC - Baseline pressure, even though the previous sentence (without the clarifying equation) clearly means the (first version of the) clarifying equation. HOWEVER: the assumption used in the simulation software is a confusing interpretation because it is a non-conventional way to make sense of stated difference: normally what comes first in a statement of a difference is not made negative before addition but the second term is made negative before addition. This alternative and non-conventional interpretation of difference can be justified as a possible interpretation ONLY because of the original version of the next paragraph: which had lesser than instead of greater than. However, all of these negatives makes for great confusion. I think it is better to use and easier to explain this idea using the first version of the clarifying equation above and change the simulation software accordingly. The following paragraph continues along the same path.]
Note: NWC is always positive. Record the position of doors and condition of fans and air handler. When the NWC in any CAZ pressure is greater than the limits specified in 807.12, the work scope shall specify remediation through pressure-balancing, duct-sealing, installing transfer grilles, placing exhaust fans on timers, bringing the ducts into conditioned space and/or other pressure-relief measures (809.3), as applicable.
807.6 Test and Record Spillage and CO of each eligible appliance in a CAZ
807.6 Turn on the eligible, vented, combustion appliance in the CAZ with the smallest Btu/hr input capacity. Operate the appliance for 5 minutes, then measure CO concentration levels according to the Carbon Monoxide Test procedure (808) and check the appliance's flue gas spillage using a smoke pencil at the draft hood. ["draft diverter" is not a defined term in the NFPA standard.] If the smoke is not fully drawn up the flue in a steady-state manner, the appliance has spillage under worst case depressurization. Record if there is spillage and record the CO sample.)
807.7 Specify Pressure Relief or Equipment Repair if Spillage or CO sample > 100
807.7 When spillage occurs or CO exceeds the limits specified in 808.8, the work scope shall specify remediation, including equipment repair or replacement or building pressure remediation, as applicable. If both spillage and high CO are found during the test, the homeowner should be notified of the conditions and told that the appliance needs immediate remediation. 809.2.4 and 809.3.4 taken together completely summarize the work scope specification table.
807.8 Progressively Turn on, Test, and Specify Work Scope for the Next Higher Input Capacity-Eligible Appliance While Previously-tested Combustion Appliances are Operating
807.8 Turn on each of the other eligible combustion appliances, one at a time, in order of increasing BTU/hr input within the CAZ and repeat steps 807.6 and 807.7 on each. Each test will be performed while all previously-tested appliances of lesser BTU/hr input level are left on. All worst case depressurization tests will be completed before any natural pressurization tests begin. [Myron does not recall that the simulation software tests this aspect of the testing regime; namely, it seems that the simulated measurements of one eligible appliance are insensitive to the operation of other eligible appliances.] [The implied meaning of the original version of the RESNET standard was presented in too subtle a fashion. I have clearly asserted an aggressive interpretation to end this potential confusion.]
807.9 If an appliance passes both spillage and CO tests during WC testing, no further testing of that appliance is necessary. [The simulation software will provide a higher score if natural pressure testing is not done if that appliance passes both tests during WC testing.] However, if spillage or high CO occurs in any appliance(s) under WC depressurization, retest that appliance under natural conditions.
807.10 Test Eligible Appliances in Natural Pressure Conditions
807.10.0 Natural pressure means the same thing as Baseline pressure. This is the pressure experienced in a CAZ under the most common situation, i.e., when all interior doors are closed and no appliances or fans are causing airflows to outside — thereby depressurizing parts of the home. ["Baseline" and "Natural" pressure testing are terms found in the RESNET standard or the simulation software; they mean the same thing. Make this clear to the Auditor.]
807.10.1 Turn off all combustion appliances.
807.10.2 Turn off all exhaust fans as well as the air handler of any ducted HVAC system.
807.10.3 Close all the interior doors.
807.10.4 Let the vent(s) cool.
807.10.5 Test CO and spillage in the same manner described in 807.6 and 807.8 except under these, natural pressurization conditions.
807.11.1 Effects of Tests Done in Natural Pressure Conditions on Work Scope
807.11.1 If a test failed under WC, but passes under natural conditions, the work scope shall specify building pressure remediation (809.1.7) as applicable.
807.11.2 If an appliance fails under natural conditions, the Auditor shall notify the homeowner of the problem, and the work scope shall specify remediation, including equipment or vent system repair or replacement, as applicable.
807.12 Appliance CAZ Worst Case Depressurization Limits
If an eligible appliance is in a CAZ that experiences a NWC less than the indicated pressure (see below), "appliance CAZ Worst Case Depressurization" passes.
15 Pa for pellet stoves with exhaust fans and sealed vents
5 Pa for an atmospherically-vented oil or gas appliance (classified as a category 1 or 2 according to NFPA standard 54) including such appliances as oil power burner; fan-assisted or induced-draft gas; solid-fuel-burning appliance other than pellet stoves with exhaust fans and sealed vents. [Although the simulation tests the Auditor on this issue, the software does not differentiate atmospherically-vented appliances from fan-assisted appliances when creating a work scope. It is not clear whether it matters, but the Auditor sees "atmospherically vented" in every case. This is confusing and/or irrelevant... Which one is it?] It should be noted that this value indicates whether the appliance is installed in a CAZ that experiences pressure extremes greater than that which is industry-specified for a properly installed and maintained appliance. Although this test is a measure of the interactions of the home on the pressure on the CAZ, success is dependent upon the type of appliance within the CAZ.
807.13 Maximum Safe CO levels During CAZ Testing
If ambient CO levels exceed 35 ppm at any time: 1) Stop all testing and turn the combustion appliances off. 2) Open all the exterior doors and windows. 3) No one should enter the home until the CO levels drop below 35 ppm. and 4) The combustion appliance which is causing the excessive increase in CO levels must be identified and repaired or replaced by a qualified technician prior to completing the combustion appliance tests.
808 Carbon Monoxide Testing
Test all spaces in the home (including common hallway, living room, and kitchen as well as attached garages, crawlspaces, and basements) containing combustion appliances for carbon monoxide using the following protocols. Although common usage defines "ambient air" as outside air, "ambient air," as used frequently in 808, always refers to inside air that has acquired the industry-standard, "normally to be expected" CO concentration. [The current RESNET standard uses "ambient" in both ways: to mean outside and later to mean inside. ]
808.0 A Baseline CO test is different from CO Monitoring and both procedures differ from an Ambient CO test. Baseline CO testing (808.4) differs from CO Monitoring (808.3) in that the former will provide a measurement while the second provides an alert. Baseline CO testing essentially shares the same goal as Ambient CO testing (808.7.5), i.e., quantifying the CO concentration in the home. However, the goal of Ambient CO testing is to approximate a "worst case" for baseline CO testing. None of these three tests use a probe. [Of the three, only a baseline CO test is not possible in the simulation; however, both CO Monitoring and a Ambient CO test are required to obtain the highest score in a simulation.][It is clear from the words in black that the original RESNET standard asserted the need for Baseline CO testing even though that skill is not tested in the simulation. Moreover, I think baseline CO testing is a very good idea. However, the implications of such a test are not spelled out in the RESNET standard.]
808.1 CO testing Equipment used shall:
• Be capable of measuring carbon monoxide (CO) levels from 0 to 2,000 ppm (parts per million)
• Have a resolution of 1 ppm
• Have an accuracy rate of + 5 ppm
• Be calibrated annually by the manufacturer (or using manufacturer's instructions) and evidence of the calibration shall be submitted to the Rating Provider's Quality Assurance Designee.
• Include both a CO concentration meter or combustion analyzer, and an independent device to sound an alarm indicating "dangerously high CO concentration." Use the former for making measurements as will be described and the latter set to warn the Auditor to leave the home if the CO level exceeds 35 ppm. [Although the industry does not refer to the CO detector in alarm mode as an "alarm, it calls it a detector; that is unfortunate and confusing. This confusion is not limited to the terminology used by Auditors but it also used by the manufacturers of CO equipment designed to provide the alarm. If I were to allowed to choose their names, I'd call a detector the device which provides a metered output and an alarm which only provides a ALARM or NO ALARM i.e., binary response.]
• Include a CO meter/combustion analyzer capable of two measuring modes: 1) via a probe designed to be placed in a gas flue, and 2) a non-probe measurement of the air surrounding the meter.
808.2 Zero both the carbon monoxide meter and CO alarm while outside the building and away from any combustion outlets and automobile traffic areas.
808.3 CO Monitoring (of) Inside Air
808.3 CO monitoring (as opposed to testing) of ambient air shall be performed continuously from the time before the Auditor enters the home to the final step of section 807 during both the Worst Case Depressurization Test and under natural pressure conditions. This is an "all or nothing" experiment; thus, an alarm alerting that the CO concentration exceeds 35 ppm is all that is needed. [Just like the simulation software, I believe that best practice has the detector that makes measurements to be an independent piece of equipment from the device that provides the alarm.]
808.4 Baseline CO Test of Inside Air
808.4 In order to establish a baseline CO concentration measurement of inside air, take a series of measurements of CO levels within the home upon entering. Baseline CO testing setup: 1) Open all interior doors and close all exterior doors and windows. 2) Turn off all exhaust fans, 3) Measure the baseline (inside) CO level in the living space and in the CAZ as one zone. 4) Do not measure near combustion appliances while they are operating. 5) If changes occur, record the final reading while all interior doors are open, all exterior doors and windows closed and all combustion appliances turned off. Changes in CO readings observed during this walkthrough and initial set-up will help the Auditor find any problems in subsequent combustion safety testing steps. [Baseline CO measurement is not possible in the simulation software.][A Utube instruction video provided many of the parameters sited herein. Did I get them right?]
808.5 CO Measurements for Atmospherically-vented Appliances
808.5.1 Use a probe to take a measurement of vent gases upstream of and before the combustion gases reach the draft hood.
808.5.2 The appliance must operate for at least 5 minutes before taking a CO concentration measurement sample of flue gases (i.e., a CO sample). [Definition of CO sample.]
808.5.3 Take a CO sample during WC depressurization test (807.6) and/or under natural conditions (807.10.5). Record the CO level.
808.6 CO Measurements for Power-vented Appliances
808.6.1 Place CO detector's probe about 1 foot downstream (i.e., above) the appliance. Since power-vented appliances are not installed with a draft hood, a testing hole in the flue vent must be used. If not already available, drill at least a 1/2" diameter hole through both the outer vent pipe wall and the inner pipe. When testing is complete, cover/plug the holes with aluminum tape or via another RESNET-approved method. This hole will be used for both the CO and spillage tests. [Drilling should be specified and with details. Did I get them right?]
808.6.2   The appliance must operate for at least 5 minutes before taking a CO sample.
808.6.2 Take a CO sample during WC worst-case depressurization test conditions (807.6) or under natural conditions (807.10.5). Record the CO level.
808.7 Ambient CO Test and CO Tests of Unvented LP- or Natural Gas Ovens and Stove Tops
Although most oven ranges in homes are placed below code-compliant and properly installed hoods that vent combustion gases to outside and, moreover, most of these hoods incorporate power-assist fans, this standard calls such ovens "unvented appliances." [Unvented appliances is a poor choice of what they are, but if you're going to call them that, please be forthright about it.]
808.7.1 Open a window or door to the outside.
808.7.2 Remove any foil or cooking utensils within the oven.
808.7.3 Verify that the oven is not in self-cleaning mode.
808.7.4 Turn the oven on to highest temperature setting.
808.7.5 Close the oven door and (without the using the CO meter probe) begin measuring the CO levels in the kitchen, 5 feet from the oven, at countertop height. Record CO levels. This is an Ambient CO test of the home. [Otherwise missing clear statements of the definitions of the former and latter terms.] Hereinafter are the specifications for Unvented Appliance Testing.
808.7.6 Using the CO meter probe, measure the CO levels within the oven gas flue.
808.7.6.1 Samples must be taken while the oven burners are firing.
808.7.6.2 Operate oven burners for at least 5 minutes before sampling flue gases.
808.7.6.3 If CO sample levels are higher than 100 ppm, repeat the flue gas sampling until the CO levels stop falling. [808.7.6.3 is not simulated.]
808.7.6.4 Record the steady-state CO reading in ppm and then turn off the oven.
808.7.6.5 Although testing stovetop burners is not required by RESNET's current CAZ testing procedures, it is part of the automated simulation.
808.8 If measured CO levels of the combustion exhaust gases are higher than 100 ppm (200 for the oven), or an appliance produces more than the manufacturer's specifies for CO production (whichever is lower), the appliance fails the test and the work scope shall specify replacement or repair of the appliance, and the homeowner shall be notified of the need for service by a qualified technician. (809.2.4)

809 Work Scope for Contractors
809.1 Requirements
809.1.1 All work must meet applicable codes and regulations for the jurisdiction.
809.1.2 When air sealing is being performed on an occupied home, the work scope shall specify CAZ depressurization testing to be performed at the end of each workday. [Is CAZ testing really limited to occupied homes? Why not previously occupied or yet to be occupied? They are not worthy of testing?]
809.1.3 The work scope for recommended improvements will be determined by the Auditor and shall be based upon the findings of the assessment, the client's needs and budget, and priorities identified during combustion appliance testing, subject to health and safety requirements.
809.1.4 The work scope shall clearly identify for the client any remedial actions which require prompt attention, affect safety, or require a licensed trade.
809.1.5 The work scope shall provide sufficient specification that the client may obtain reasonably comparable bids from alternative sources for making recommended improvements.
809.1.6 All scopes of work shall include this statement: "The estimated energy use and savings information contained in the audit report does not constitute a guarantee or warranty of actual energy cost or usage."
809.1.7 The work scope shall be developed based on the Auditor's diagnosis and analysis. Emphasis shall be on:
• bringing air distribution system components inside the building enclosure when it is feasible, or sealing and insulating ducts when it is not
• transitioning from gas-fired heating to electric heat pumps; this applies both to space heating and water heating
• choosing replacement equipment that optimizes moisture control in cooling mode
• replacing switches that control bathroom exhaust fans with 5-minute crank-timer controls
• improving airflow and total HVAC system efficiency as applicable
• upgrades to the building enclosure as applicable
• improvements to lighting and appliances as applicable
809.1.8 The scopes shall reflect the "house as a system" approach, recognizing measure interaction. The following statement shall be included whenever a fireplace or combustion appliance is located within the building enclosure:
"This work scope is not a list of recommendations that may be implemented independently; any exclusions or variations to this scope may increase the risk of flue gas spillage, back-drafting, carbon monoxide production and/or moisture problems within the home."
809.1.9 When specifying equipment replacement, new equipment sizing shall be based on the proposed, upgraded condition of the building enclosure and duct system.
809.1.10 The work scope shall call for post-work, combustion-appliance testing in accordance with these guidelines when any work affecting enclosure, duct tightness or building pressures is implemented. [Why state 809.1.10 in light of 809.1.2?]
809.2 Work Scope: Carbon Monoxide
809.2.1 Any defective appliance which is an excessive source of the CO must be repaired or replaced and the problem corrected prior to commencing work on other tasks on the work scope, unless remediation of the CO production is specifically related to one or more of those tasks (such as duct repairs that will correct the cause of a large negative pressure in the CAZ). [RESNET should define "excessive source" with a metric. I recommend the following:] An excessive source is one that causes an ambient CO test to exceed 35 ppm or a baseline CO test to exceed 20 ppm.
809.2.2 If there are combustion appliances within the building envelope, a carbon monoxide alarm should be specified to be installed in the main area of each floor according to applicable building codes and manufacturer's recommendations, typically, in the hallway outside each bedroom area.
809.2.3 If measured CO levels are higher than 100 ppm (200 for oven), or an appliance fails to meet manufacturer's specifications for CO production (whichever is lower), the work scope shall specify replacement or repair of the appliance, and the homeowner shall be notified of the need for service by a qualified technician.
809.2.4 If an eligible appliance fails the WC CO test (809.2.3), the work scope shall state: "Notify homeowner and recommend immediate equipment remediation and/or replacement." This paragraph together with 809.3.4 provide all that must be understood to construct the Work Scope table of recommendations.
809.3 Work Scope: Worst Case Depressurization
809.3.1 If the results of the Worst Case Depressurization Test indicate the potential for backdrafting by failing the CAZ pressure limits (807.12) or spillage test, remediation of the failure must be addressed in the work scope, through one or more of the following (as applicable): targeted air- and duct-sealing, room pressure balancing, exhaust fan makeup air, or appliance replacement (with power-,,direct-vented equipment or electric heat pumps). As an alternative, the combustion appliance zone may be isolated by creating a sealed combustion closet containing the combustion appliances that has the proper amount of combustion air supplied to it according to the applicable version of the IRC. Adequate sealing for isolation purposes shall include air sealing and duct sealing (especially of adjacent platform or cavity return ducts) and confirmed by another CAZ depressurization test.
809.3.2 The work scope should specify replacement of combustion appliances installed with draft hoods with high-efficiency sealed-combustion, direct vent, power vented or heat pump appliances when feasible. If the home has unvented combustion appliances used for space heating, the Auditor shall recommend they be disconnected and replaced with safer heating appliances as described.
809.3.3 If unvented combustion appliances used for space heating are not removed or replaced with vented combustion appliances or electric appliances, the work scope shall not specify measures that affect the air tightness of the envelope, including air sealing, duct sealing, sidewall insulation, or window replacements. Duct sealing outside the thermal envelope may be specified in IECC climate zones 1-3.
809.3.4 If an eligible appliance fails the WC spillage test but passes at least one spillage or CO test the work scope shall state: "Recommend building pressure remediation, as applicable." This paragraph together with 809.2.4 provide all that must be understood to construct the Work Scope table of recommendations.

Response:
Reject

Thank you for commenting. However, this extensive comment should be proposed as an alternative amendment to the RESNET Standards. You did not follow the process for submitting a proposed amendment in your email to Steve Baden. To ensure national consistency, RESNET’s standard development policy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard.

Comment #33

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: Section 805 Through 809
Comment Type: Technical

Comment:

2nd Comment on Amendment.

As I stated in the previous comment, I am opposed to the amendment.

Since over 90% of the inefficiency of homes is within the existing homes, RESNET must focus on retrofits. That requires understanding & testing for both CO and H2O and making recommendations that at least do no harm.

I have been a member of RESNET for more than 15 years and have seen it go through many changes. MANY of them are not to my liking. However, what has kept me a member of RESNET nonetheless are these features:
1. Extreme desire and attention to process to maintain democratic process.
2. Public comment on most issues is the rule, not the exception.
3. Committees are created to handle complicated and important issues and the makeup of those committees seems to be well considered and forthright.
4. Quality Control is of utmost importance. And most importantly:
5. The RESNET standard is dearly held, nurtured and a model for all of our industry.

My experience with BPI has none of these features. In fact, last year, I was explicitly solicited by one of the sister organizations which co-hosted our last conference to ask RESNET to take a stand against the BPI CAZ standard. RESNET refused. Among the problems with BPI’s CAZ ANSI standard was process. Many organizations co-signed a letter to ANSI complaining that BPI’s process was not inclusive or responsive and as such the BPI CAZ standard was suspect and appropriately representative of our industry. RESNET refused to sign that letter.

ANSI received the letter but did not take action to remediate this. ACCA found that their best course was to create their own standard. RESNET had already embarked on the same path; RESNET should not forsake this mission.

I am not a member of ACCA but I have applied to be a trainer for BPI. When I learned how easy it was, how low the bar for acceptance and the dubious quality assurance, I decided to retract my application to train for BPI.

Later, I learned about BPI’s definition of “Calibration”. As a mathematician and an energy rater and/or rater trainer for more than 15 years, I can tell you that this is both bad science and worse mathematics. Not only has BPI promulgated this on to our industry, BPI has made this an ANSI standard!

Who will fix these problems if not RESNET? Who has the stake, the track record and the need?

Where I live, the problem is H2O much more than CO. That is, when I make a recommendation for the purpose of lowering energy use, I must keep the moisture problem up front and more important than the energy problem – no matter what the homeowner asserts. Even more so should any energy rater regarding CO!

Soon, if my southeastern US colleagues get up and get going, we should be making “demands” upon the RESNET standard regarding moisture testing as strongly as others have made demands for CO testing.

Response:
Reject

Thank you for commenting. However, since no change has been proposed we cannot take action.

Comment #34

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: all
Paragraph / Figure / Table / Note: 805-809
Comment Type: General

Comment:

When I first heard about this plan to add Combustion Safety testing at the trainer roundtable in 2012, I was against it as part of the mandatory required HERS certification. Apparently, there was little industry demand to become a CHERS rater likely because of little builder/consumer demand for this testing in new homes. I am of the group that believes that this testing, while valuable shouldn't be required as part of the standard Rater certification and should be an extra certification option. If the goal is for every HERS rater to hold some certification in any area of home evaluation that has some merit to it, the how long until all raters are required to be mold certified? How about radon? Maybe we should all hold level 1 thermography certification too?

Proposed Change:

Strike sections 805-809 of the National Mortgage Industry Home Energy Rating Standards.

Response:
Reject

Last year, HERS Raters were involved in over 50% of new homes sold which represents a significant number of opportunities to improve indoor air quality and safety. Chapter 2 requires Rating Field Inspectors and Home Energy Raters to be trained in performing CAZ and CO testing and the proposed amendment aligns that intent with the ANSI Standard for performing those tests. This proposed comment does not address the requirement to be trained and simply striking the suggested sections would create a situation where the training is required but there are no referenced standards for how to conduct the training or what that training should cover.

Comment #35

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 4
Comment Type: General

Comment:

Hello,

I am commenting on the CAZ field test being simulated on computer. HVAC systems can be intimidating to people.It is important that people have experience around them and feel comfortable working with them.There are so many different situations with each system its imperitive that the person doing the safety test and the occupants are not in harms way. I believe the CAZ test should be a hands on field test so the procture can get a feel for the persons apptitude. You never know what your going to run into and its important to be able to look for dangers and keep everyone safe.

Thanks,

David H.Hiscocks 4256448

Comment #36

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 4
Comment Type: General

Comment:

Hello,

Thanks,

David H.Hiscocks 4256448

Comment #37

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: 806
Comment Type: Technical

Comment:

I am in full support of limiting confusion and conflicting or duplicative standards. I do not feel this amendment goes far enough. ACCA Standard 12 also has standards for the testing of combustible gas lines. The only thing missing from the ACCA standard is the specific inspection and identification of flexible gas lines that may need replacement. I suggest that we refer to the ACCA standard for combustible gas testing as well and work with them to incorporate this item into that standard. (I admit that I have been reading my own version and it may be out of date. The flexible gas line addendum may already have been incorporated as well.)

Proposed Change:

805.1 These protocols contained in ANSI/ACCA 12 QH, Appendix A Sections A4 (Carbon
Monoxide Test) and A5 (Depressurization Test for the Combustion Appliance Zone (CAZ)) shall be followed by RESNET-accredited Raters and Auditors (hereinafter referred to collectively as “Auditors”) performing combustion appliance testing ~~or writing work scopes for repairs~~. In addition, the protocols contained in ANSI/ACCA 12 QH, section 3.3.2 (Gas/Oil Leakage Testing) shall be followed by Auditors performing combustible gas and oil line testing.

~~806 Gas Leakage Test~~

806.1 If there is a noticeable odor indicating gas buildup within the home, the occupants and Auditor shall leave the house and the appropriate authorities and utility providers shall be notified from outside the home.
806.2 The Auditor should use a gas detector upon entry into the home to detect the presence of natural gas. If gas is suspected or confirmed, ensure that switches are not operated while exiting and no ignition concerns are present. The audit shall not proceed until the proper authorities have deemed it safe to re-enter the home. If there is no noticeable odor indicating gas buildup within the home, the Auditor shall determine if there are gas leaks in the fittings and connections of natural gas appliances within the home and natural gas/liquid propane supply lines following these protocols.
806.3 Inspect all fittings and joints in supply lines and appliance connectors and confirm suspected leaks with leak-detection fluid. Identify for repair or replacement any kinked, corroded or visibly worn flexible gas lines and any flexible connectors manufactured prior to 1974.
806.4 Equipment needed
• Combustible gas detector capable of measuring 20 ppm
• Leak detection fluid (non-corrosive)

Response:
Accept

Recommend accepting this comment as modified to reference ANSI/ACCA 12 QH-2014 in its entirety to ensure national consistency.

Modified comment:

805.1 The protocols contained in ANSI/ACCA 12 QH-2014, Appendix A Sections A3 (Carbon Monoxide Test) and A4 (Depressurization Test for the Combustion Appliance Zone (CAZ)) shall be followed by RESNET-accredited Raters and Auditors (hereinafter referred to collectively as “Auditors”) performing combustion appliance testing or writing work scopes for repairs. In addition, the protocols contained in ANSI/ACCA 12 QH-2014, section 3.2.2 (Gas/Oil Leakage Test-ing) shall be followed by Auditors performing combustible gas and oil line testing.

~~806 Gas Leakage Test~~

806.1 If there is a noticeable odor indicating gas buildup within the home, the occupants and Auditor shall leave the house and the appropriate authorities and utility providers shall be notified from outside the home.

806.2 The Auditor should use a gas detector upon entry into the home to detect the presence of natural gas. If gas is suspected or confirmed, ensure that switches are not operated while exiting and no ignition concerns are present. The audit shall not proceed until the proper authorities have deemed it safe to re-enter the home. If there is no noticeable odor indicating gas buildup within the home, the Auditor shall determine if there are gas leaks in the fittings and connections of natural gas appliances within the home and natural gas/liquid propane supply lines following these protocols.

806.3 Inspect all fittings and joints in supply lines and appliance connectors and confirm sus-pected leaks with leak-detection fluid. Identify for repair or replacement any kinked, corroded or visibly worn flexible gas lines and any flexible connectors manufactured prior to 1974.

806.4 Equipment needed
• Combustible gas detector capable of measuring 20 ppm
• Leak detection fluid (non-corrosive)

Comment #38

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: All
Comment Type: General

Comment:

As stated previously, we are in support of the amendment. However, there is a comment attached to the amendment that I would like to address, specifically in light of reading through all the comments that have been posted thus far. The comment states, "We should continue to require the CAZ and Work Scope academic exam and the CAZ simulator exam for certification for all Rating Field Inspectors, Raters, Trainers, and Quality Assurance Designees (amendment for latter has been proposed)."

There have been several comments in support of making CAZ an add-on optional training and testing. One might consider that this is roughly equivalent to an EEP type of situation where it is incumbent on the Rater to fully understand and meet all requirements of the EEP prior to performing work under that program. However, performing analysis on existing homes and providing recommended improvements is not an EEP, it is a core part of the RESNET HERS Rater standards and required as part of every HERS Rater's training and certification. It is negligent to provide improvement recommendations without consideration of the life-safety consequences of making those improvements. Many comments call this an Indoor Air Quality issue, but this is far more serious and it is a life-safety issue. All HERS Raters are qualified to perform the testing and improvement analysis required to qualify existing homes for EEMs and so it is incumbent on RESNET as a standard-setting organization to ensure Certified HERS Raters understand combustion safety testing protocols and standards.

I am in support of allowing those who have been trained and/or certified under BPI to skip the training. However, I support the required testing. I am in support of this testing because BPI lacks sufficient quality assurance processes to provide confidence in that credential. I am a certified Building Analyst and Envelope Specialist. I am a BPI Written and Field Proctor in both of these certifications and I am a Super Proctor who orients other Field Proctors for BPI. I was a Training Affiliate for BPI until they decided to disavow any connection with training. I have raised concerns with BPI for about a decade now about their quality assurance processes and have been sorely disappointed in their response. I am buoyed by the RESNET focus on ensuring Raters have CAZ knowledge for the reasons I stated above, and in the move to utilize and support the ACCA standard in this area. RESNET should continue to work with ACCA to ensure their standard is comprehensive and RESNET should test Raters to ensure they understand how to apply that standard.

Proposed Change:

Continue to work closely with ACCA so that all of 806, 807, and 808 can be removed and we just refer to that standard. Require CAZ testing of all Raters and Rating Field Inspectors as suggested.

Response:
Accept

Thank you for commenting. This is a supportive comment that requires no changes to the provi-sions of the standard. RESNET has appointed a working group composed of representatives of the American Gas Association, AHRI and testing equipment manufacturers to make recommen-dations to ACCA for changes to their standard.

Comment #39

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: n/a
Paragraph / Figure / Table / Note: Proposed Amendment to Update RESNET CAZ Testing Standard
Comment Type: General

Comment:

Overall, this is a bad idea to require someone with a BPI certificate to pass yet another test that is almost identical. HERS rating doesn't pay that well for so many of us who do not do major developments. Every HERS rater in and around Taos, NM has dropped out due to the high cost of doing business versus the low amount of customers.

As a result of having no HERS raters, our town council was going to suspend the requirement for HERS rating all together. As a newly minted rater, I talked them out of making that decision until later. CAZ testing for those holding certification already does not serve the purpose of RESNET, the HERS raters, the environment or the people living in unrated houses. If you must have a requirement, why not grandfather those of us who have passed certification via BPI CAZ testing? I have invested so much money and so far have received zero income that it is hard to come up with more for you to duplicate a test I already took and passed.

Melissa Ames

Taos, NM

Comment #40

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: 805.1
Comment Type: Technical

Comment:

Advanced Energy believes that combustion safety procedures are an important part of building performance. If different certifying organizations create different standards, confusion and inconstancy may be created in the marketplace. This is the last thing that any technician needs when he or she is completing a combustion safety test which if done incorrectly could miss a potential deadly situation. For these reasons Advanced Energy supports all certifying bodies to align their combustion safety testing procedures with the Standard Work Specifications for Single-Family Home Energy Upgrades. Advanced Energy feels that unifying under one standard is a step in the right direction for our industry.

Proposed Change:

Response:
Reject

Thank you for commenting. However, since no change has been proposed we cannot take action. The proposed change is a philosophical statement, not a proposed change to the proposed amendment. To ensure national consistency, RESNET’s standard development policy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard. We encourage all involved in the industry to adopt the consensus-based American National Standard. The requirements for certification have been removed from Chap-ter 8 and placed in Chapter 2, where Raters (and auditors) who are current BPI Building Analysts have been exempted from the field training requirement.

Comment #41

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: 805.2
Comment Type: Technical

Comment:

Do not delete 805.2 (or equivalent program including BPI)

Proposed Change:

Keep 805.2

Response:
Reject

To ensure national consistency, RESNET’s standard development policy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard. The requirements for certification have been removed from Chapter 8 and placed in Chapter 2, where Raters (and auditors) who are current BPI Building Analysts have been ex-empted from the field training requirement.

Comment #42

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 2
Paragraph / Figure / Table / Note: 807.2
Comment Type: Technical

Comment:

Do not lose 807.2 (visual inspection of venting)

Proposed Change:

Do not lose 807.2 (visual inspection of venting)

Response:
Reject

To ensure national consistency, RESNET’s standard development policy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard, which contains a requirement for visual inspection of venting.

Comment #43

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 31
Paragraph / Figure / Table / Note: A5.3
Comment Type: Technical

Comment:

A5.3 discusses turning on of fans (including the air handler), but it doesn’t mention to compare with the air handler fan off (to account for supply or return dominant duct leakage and location)

Proposed Change:

A5.3 discusses turning on of fans (including the air handler), but it doesn’t mention to compare with the air handler fan off (to account for supply or return dominant duct leakage and location)

Response:
Reject

This comment is on ANSI/ACCA Standard 12, not the proposed amendment under consideration. Proposed amendments to ANSI/ACCA Standard 12 should be directed to ACCA.

Comment #44

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 31
Paragraph / Figure / Table / Note: A5.7
Comment Type: Technical

Comment:

A5.7 talks about fireplace damper being closed or “camping stove, etc” simulator used.? Is this a trustworthy and professional device?

Proposed Change:

Remove "or a simulator must be operating in the fire place (Camping stove, etc.) with fire place damper open."

Response:
Reject

This comment is on ANSI/ACCA Standard 12, not the proposed amendment under consideration. Proposed amendments to ANSI/ACCA Standard 12 should be directed to ACCA.

Comment #45

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 31
Paragraph / Figure / Table / Note: A5.9.2
Comment Type: Technical

Comment:

A5.9.2 talks about operating the next larger appliance with a smaller appliance operating at the same time through a shared exhaust.
There is no section in Appendix A that describes CAZ testing under “natural conditions” after spillage has failed under “depressurization test”. Would it be preferable to include a test under natural conditions in addition to depressurization?

Proposed Change:

Response:
Reject

This comment is on ANSI/ACCA Standard 12, not the proposed amendment under consideration. Proposed amendments to ANSI/ACCA Standard 12 should be directed to ACCA.

Comment #46

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: Section 805 and 805.1
Comment Type: Technical

Comment:

• The proposed change results in referencing an ACCA document that is still under review. The specific section of that ACCA document is part of a red-lined version, indicating that it is still not finalized. As such, it is not possible to know what method would be adopted through this proposed change. Additionally, stakeholders would not be able to access the referenced ACCA procedure until that document is finalized. The proposed change should not be made until the ACCA document is finalized and it is possible to understand the impacts of the change.

• Is RESNET no longer requiring competency in work scope development? It appears as if that component of the standard has just been removed. Is it being moved to a separate section?

Proposed Change:

805 Work Scope and Combustion Safety Procedures

Response:
Accept

Accept as modified by response to comment #36.

Modified comment:

805.1 The protocols contained in ANSI/ACCA 12 QH-2014, Appendix A Sections A3 (Carbon Monoxide Test) and A4 (Depressurization Test for the Combustion Appliance Zone (CAZ)) shall be followed by RESNET-accredited Raters and Auditors (hereinafter referred to collectively as “Auditors”) performing combustion appliance testing or writing work scopes for repairs. In addition, the protocols contained in ANSI/ACCA 12 QH-2014, section 3.2.2 (Gas/Oil Leakage Test-ing) shall be followed by Auditors performing combustible gas and oil line testing.

Comment #47

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: 805.3
Comment Type: Technical

Comment:

We recognize Chapter 2 is also out for public comment. We suggest that the training standard be solidified prior to eliminating the training requirement from Chapter 8. In addition, the passing score is currently eliminated from the draft of Chapter 2.
The Interplay ResCAZ simulator works well as one of many training tools but is not a substitute for experiential learning with actual test equipment, work flow on a job site, or problem solving in a real combustion appliance zone.

805#a: RESNET should work with BPI and industry partners to identify nationally-recognized certifications which include verification of field proficiency in combustion safety testing. RESNET Standards will need to state clearly which certifications fall under the hands-on training exemption, in addition to BPI Analyst.
805#b: RESNET must be clear as to exactly when a Rater, Rater Field Inspector or other professional is required to follow this standard. This must be linked to required QA procedures in Chapter 9. Also, RESNET should clearly articulate the value proposition to stakeholders of performing these tests as part of a scope of work for all levels of building assessment, from Code Verification to confirmed HERS Ratings. RESNET must make a simultaneous revision to the Quality Assurance (field and file review) requirements in Chapter 9 which clearly outlines what data must be reported to the Provider, whether or not the combustion appliance zone testing must be included as a component of a field QA visit, and any additional clarifications.

Proposed Change:

805.3 RESNET-accredited Training Providers shall train Auditors on these
Standards through field exercise, classroom and through simulated conditions. This training mush include a minimum of two hours of field training using test equipment meeting this Standard on in a combustion appliance zone with at least one atmospherically vented combustion appliance. This training should also include at least four hours of classroom and verified simulation training. A passing score of 80% or higher on the RESNET Combustion Appliance Simulation Test and the Work Scope Development written exam administered by a RESNET-accredited Trainer is also required, provided by RESNET. The test shall cover the content of these guidelines with a minimum of 25 questions. A minimum score of 80% is required to pass.

INSERT 805.#a Auditors and Auditor candidates shall be exempt from the training mandated by Section 805.3, if the Auditor has been previously certified, and is in good standing with the Building Performance Institute (BPI) in a designation that includes field testing of competency in combustion appliance zone testing (e.g., Building Analyst Professional, Envelope Professional, Heating Professional). Auditors are allowed to “challenge” the simulation and work scope development written exam administered by a RESNET-accredited Trainer. All Auditors certified by RESNET prior to January 1, 2014 must achieve passing scores on both of these exams prior to January 1, 2015. All current Auditor candidates must achieve passing scores on both of these exams in order to become RESNET Auditors.

INSERT 805.#b The protocol in section 805.1 shall be followed by Auditors whenever inspecting a home which contains a vented combustion appliance that uses indoor air to vent combustion gases, for the purpose of performing a confirmed HERS Rating, Home Energy Survey, Home Energy Audit or other service as required by the Program having jurisdiction.

Response:
Reject

Chapter 8 is the technical standard, while Chapter 2 is the training standard. These proposed changes in this comment should be proposed by the commenter as an amendment to Chapter 2, following the proper process for submitting amendments to the RESNET Standards.

Comment #48

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 2-4
Paragraph / Figure / Table / Note: 807 and 808
Comment Type: Technical

Comment:

• 807 and 808: There is no assurance that ACCA will accept the material in Sections 807 and/or 808 of Addendum 2 as a proposed amendment to their ANSI Standard protocols for CO Testing and Depressurization Test of the Combustion Appliance Zone if submitted by RESNET. RESNET should only strike these sections once the material is incorporated into the ACCA Standard.

Proposed Change:

Strike Sections 807 and 808 under the following assumptions:
• The Standards Development Committee will supply ACCA with Sections 807 and 808 of Addendum 2 as a proposed amendment to their ANSI Standard protocols for CO Testing and Depressurization Test of the Combustion Appliance Zone
• Combustion safety testing equipment requirements (Section 808.2) are satisfied by ANSI/ACCA 12 QH, Appendix A Sections A4 and A5 and clearly stated in Chapter 8 of the RESNET standards.

Response:
Reject

To ensure national consistency, RESNET’s standard development policy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard. The commenter should propose an amendment to ACCA for their standard, AN-SI/ACCA Standard 12 QH-2014.

Comment #49

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: ALL
Paragraph / Figure / Table / Note: 805.1, 805.2, 805.3, 807, 808
Comment Type: Technical

Comment:

I agree that RESNET should not be in the business of creating its own CAZ standards. Therefore, I support removing the RESNET language from sections 807 & 808 and referencing other recognized and accepted standards.

However, I do not support removing the reference to the BPI Standard and referencing only the ANSI/ACCA standard for the following reasons:

BPI Technical Standards are nationally accepted, recognized and referenced by most federal, state and utility home performance and weatherization programs. BPI Technical Standards and are also well known and understood by the majority of HERS Raters. That is due to the fact that Most HERS Raters are BPI certified, have been fully trained to perform CAZ testing, and have gone through rigorous and highly defensible written and field exams. Some Raters have been recertified by BPI many times over, hold multiple BPI certifications and have performed hundreds of audits and inspections. They are seasoned professionals who know how to do the job and do not need a simulation exam to prove it.

So, why reference a standard that no one knows and does not align with what we believe to be practical testing standards (see Comment #7)? It is well known that the only reason BPI Standards are not currently referenced are purely political. This doesn't mean it still can't be done and that it is not a good idea.

RESNET standards should recognize the BPI Technical Standards as equivalent and allow for BPI BA certification to serve as an equivalent certification. It is the most pragmatic and easy path to take, and will result in the least (as in close to zero) resistance from the HERS Rater community. In fact, the community may erect a monument and throw a huge parade in your honor if you will simply do the right thing and keep the BPI reference in the standard, and recognize BPI certified professionals as having met the requirements for certification under the RESNET Standard. To strike the BPI Standard and require all BPI certified HERS raters to be trained and tested is a huge and unnecessary financial burden that many cannot bear in a slumping marketplace, not to mention unfair and indefensible. There are better uses for our time, resources and money than requiring people to go through this unjustifiable process for no practical benefit whatsoever. When you look at this on a macro scale, you are talking about tens of thousands of wasted man hours and resources; time that could be spent improving homes, learning something new and valuable, earning money or connecting with friends, family and children. It just doesn't make any sense at all.

I do not have an issue with referencing the ANSI/ACCA Standard as well. There is no law that says both cannot be recognized as equivalent. If the ANSI/ACCA standard is recognized, however, it should include an amendment that addresses the comments in Comment #7.

Also, the background/rationale comment should be amended to state "We should ~~continue to~~ require the CAZ and Work Scope academic exam and the CAZ
simulator exam for certification for all Rating Field Inspectors, Raters, Trainers, and
Quality Assurance Designees, unless they hold a current BPI BA certification, which should be recognized as equivalent."

There is no current requirement for Raters, Trainers or QADs to take and pass any exams in Chapter 2, although this has not stopped RESNET from forcing it upon everyone (see Comment #6). There is an amendment out for public review to require this, but it has not yet been approved. However, as I stated above, if the rater is BPI BA certified, that certification should be allowed to meet this testing requirement since it is an actual practical exam in a real world situation and requires much more training, skill, experience and knowledge to pass than a simulation that can be easily learned by young children (see Comment #15).

Proposed Change:

805.1 These protocols contained in the Building Performance Institute (BPI) Technical Standards for Building Analysts or ANSI/ACCA 12 QH, Appendix A Sections A4 (CarbonMonoxide Test) and A5 (Depressurization Test for the Combustion Appliance Zone (CAZ)) shall be followed by RESNET-accredited Raters and Auditors (hereinafter referred to collectively as “Auditors”) performing combustion appliance testing ~~or writing workscopes for repairs~~.

REINSTATE:

805.2 If the Auditor has been trained and certified in accordance with a RESNET
approved "equivalent home performance certification program" or the Building
Performance Institute (BPI) Standards, the Auditor may follow protocols in accordance
with those equivalent standards.

AND

805.3 RESNET-accredited Training Providers shall train HERS ~~Auditors~~ Field Inspectors (RFI), Raters, Trainers and QADs on these protocols through either field exercise or
through simulated conditions. A written exam administered by a RESNET-accredited Trainer is also required, provided by RESNET. The test shall cover the content of these guide lines with a minimum of 25 questions. A minimum score of 80% is required to pass. in accordance with Chapter 2 of the RESNET Standards. If the RFI, Rater, Trainer or QAD has been trained and certified in accordance with BPI Standards, then that certification shall be deemed equivalent if the certification is current on or after the effective date of this amendment.

AND

204.1.5.2.8 .....BPI Technical Standards or ANSI/ACCA 12 QH, Appendix A, Sections A4 and A5.

AND

204.1.6.2.9 .....BPI Technical Standards or ANSI/ACCA 12 QH, Appendix A, Sections A4 and A5.

AND

Address the impractical issues with the ACCA/ANSI standard as mentioned in Comment #7.

Also, the background/rationale, paragraph four, should be amended to state:

"We should ~~continue to~~ require the CAZ and Work Scope academic exam and the CAZ
simulator exam or equivalent field exam for certification for all Rating Field Inspectors, Raters, Trainers, and Quality Assurance Designees, unless they hold a current BPI BA certification, which should be recognized as equivalent."

Response:
Reject

Thank you for commenting. The requirements for certification have been removed from Chapter 8 and placed in Chapter 2, where Raters (and auditors) who are current BPI Building Analysts have been exempted from the field training requirement. RESNET’s standard development policy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard.

The commenter is encouraged to submit a proposed amendment to Chapter 2 following the proper procedure.

Comment #50

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Comment Type: General

Comment:

I think it is an absolute disgrace if there in not full reciprocity between BPI and ResNet on this issue. If someone is a BPI BA – there is no reason they should have to spend time, energy and money to go through any testing/certification with ResNet.

Response:
Reject-

Thank you for commenting. The requirements for certification have been removed from Chapter 8 and placed in Chapter 2, where Raters (and auditors) who are current BPI Building Analysts have been exempted from the field training requirement. To ensure national consistency, RES-NET’s standard development policy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard.

Comment #51

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: all
Comment Type: General

Comment:

The RESNET Standard should point to recognized standards (such as the ACCA/ANSI 12 QH) whenever possible. This will promote a more uniform testing and documentation of results that may be used by various groups and organizations.

While I do not totally agree with the ACCA/ANSI 12 QH standard, I think that RESNET should abandon all attempts to write standards and procedures that are different from this document. After all, RESNET helped developed it (see cover page of the standard). So if we don't like it, we rewrite only the parts we don't like? Either embrace it or write our own - don't jump around. We have had to many abrupt changes to standard in to short a time. (if this were an ocean liner - it would have all the passengers throw overboard by now)

Let's abandon writing a parallet existing standard - if broke, then let's fix it. Or pick up our toys and go play by ourselves.

Concerning the BPI testing - it should be accepted as an equivalent as long as the individual is currently in good-standing. The exception is that RESNET needs money and is using this as an excuse to collect some.

As it should be noted that this applies to existing buildings. (presumably going to be retrofitted).

Response:
Accept

Thank you for commenting. This comment is supportive and requires no changes to the standards.

Comment #52

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 808.7
Comment Type: Technical

Comment:

We should not be dictating oven co standards.

We should simply fill out a form indicating resultsof the oven testing,especially as some of the manufactures allow very high levels of co during "start up".

We should not be in the business of indicating what is safe - as any co isn't really safe.

Response:
Reject

Thank you for commenting. However, since no change has been proposed we cannot take action.

Comment #53

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: CO/CAZ Standard
Comment Type: General

Comment:

We are supportive only if it reduces the need for multiple certifications. As a rater in NY we are frustrated by the need to keep up 2 certifications, BPI and Resnet. The costs of certification continue to rise, provider fees go up, and the rater continues to get squeezed in a shrinking marketplace. The focus on doing a good job as a rater and helping a builder is getting lost with organizations fighting for getting more and more money out of a rater.

I agree with comment #8. The problem is right now we need to keep 2 certifications in NY.

Response:
Accept

Thank you for commenting. This is a supportive comment that requires no changes to the provi-sions of the standard.

Comment #54

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: all
Comment Type: General

Comment:

Stop diminishing the value of my BPI certifications. Simulated CAZ testing? My young kids play driving simulations on a game console but that doesn't mean I'm giving them my keys and car to use.

Comment #55

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1/1/1/1
Comment Type: Editorial

Comment:

I do not support this amendment and agree with comment #20

Proposed Change:

Comment #56

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: the entire idea
Comment Type: General

Comment:

Though I have great respect for RESNET, I cannot understand why this organization feels the need to vary from the BPI training and standards already in place and which Raters have been trained.

If there is a concern for quality assurance, I can only speak for New York State. Here we have a rigorous QA process in place which covers both new and existing homes. As I write this, my work is being QA'd by Honeywell who represents NYSERDA. All of our work--including CAZ testing--is reviewed and replicated by the QA entity. If I did something wrong it is brought to my attention by the QA entity.

Why we have to pay still another fee for something for which we have already been trained is, in my opinion poor judgement and a bad decision by RESNET.

I cannot refrain from thinking that there is an ongoing competition between RESNET and BPI and the poor Rater is 'stuck' in the middle.

Unless you can provide a compelling reason for marching down this path, specifically what is lacking in the BPI CAZ testing protocols, I have to express my opposition and--quite frankly--must respectfully request closing the door on what appears to me like a sibling rivalry between RESNET and BPI.

Response:
Reject

The requirements for certification have been removed from Chapter 8 and placed in Chapter 2, where Raters (and auditors) who are current BPI Building Analysts have been exempted from the field training requirement. RESNET’s standard development policy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard.

Comment #57

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 8-19
Paragraph / Figure / Table / Note: 805 CAZ testing
Comment Type: Technical

Comment:

I fully support that RESNET is not in a position to create any set of combustion safety standards that is any better or different than what is currently out there and I do feel that RESNET is attempting to cover a mistake from not having this in the standards to begin with. I do not support removing the BPI accreditation exception and only referencing ANSI/ACCA standards as the BPI is a nationally recognized and highly referenced organization with many Raters like myself holding several certifications in BPI. I don't understand why I need to prove myself once again do another organization that I have the knowledge and technical skills in assessing and dealing with combustion safety issues. This seems to be nothing but a way for RESNET to wash their hands on their own mistake and gouge Raters for more money. Please allow persons like myself to use their already accredited credentials from the “other guys” as proof to RESNET that I am fully capable of keeping occupants safe.

Proposed Change:

Add the utilization of BPI standards in addition to ANSI/ACCA standards to perform proper combustion safety testing and allow the certifications and accreditations from the National recognized and often referenced organization, that many raters currently hold, as proof they can perform these tests/inspections.

Response:
Reject

Thank you for commenting. The requirements for certification have been removed from Chapter 8 and placed in Chapter 2, where Raters (and auditors) who are current BPI Building Analysts have been exempted from the field training requirement. RESNET’s standard development policy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard.

Comment #58

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Comment Type: General

Comment:

I do not support this amendment. CAZ testing does not impact a HERS score, and should remain as a separate protocol.

Response:
Reject

Thank you for commenting. However, since no change has been proposed we cannot take action.

Comment #59

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Comment Type: General

Comment:

I oppose this bill, adding these tests will not save any lives or make homes safer. HERS Ratiners most often work on new homes and do not perform test outs of existing homes. Therefore it should be the contractors responsibility to verify that that the home is safe since Raters will not necessarily be in the home after any improvements are made.

Comment #60

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: 3
Comment Type: Editorial

Comment:

These new standards are less stringent that BPI which we must apply to projects. As such, it is potentially a sub standard list of redundant testing with attached fees and loss of valuable time.

At the end of the day; we desing and model buildings. HVAC Contractors install equipment to Code and Commission it.

We are constantly transferring liabilities from the GC and the HVAC Contractors back to the Rater.

This stuff makes no reasonalbe sense to me when you have codes, standards and special standards.

Tom Vitale

En-Tech Associates, Inc.

Comment #61

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: 3
Comment Type: Editorial

Comment:

These new standards are less stringent that BPI which we must apply to projects. As such, it is potentially a sub standard list of redundant testing with attached fees and loss of valuable time.

At the end of the day; we desing and model buildings. HVAC Contractors install equipment to Code and Commission it.

We are constantly transferring liabilities from the GC and the HVAC Contractors back to the Rater.

This stuff makes no reasonalbe sense to me when you have codes, standards and special standards.

Tom Vitale

En-Tech Associates, Inc.

Comment #62

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: 3
Comment Type: Editorial

Comment:

These new standards are less stringent that BPI which we must apply to projects. As such, it is potentially a sub standard list of redundant testing with attached fees and loss of valuable time.

At the end of the day; we desing and model buildings. HVAC Contractors install equipment to Code and Commission it.

We are constantly transferring liabilities from the GC and the HVAC Contractors back to the Rater.

This stuff makes no reasonalbe sense to me when you have codes, standards and special standards.

Tom Vitale

En-Tech Associates, Inc.

Comment #63

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: 3
Comment Type: Editorial

Comment:

These new standards are less stringent that BPI which we must apply to projects. As such, it is potentially a sub standard list of redundant testing with attached fees and loss of valuable time.

At the end of the day; we desing and model buildings. HVAC Contractors install equipment to Code and Commission it.

We are constantly transferring liabilities from the GC and the HVAC Contractors back to the Rater.

This stuff makes no reasonalbe sense to me when you have codes, standards and special standards.

Tom Vitale

En-Tech Associates, Inc.

Comment #64

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: 3
Comment Type: Editorial

Comment:

These new standards are less stringent that BPI which we must apply to projects. As such, it is potentially a sub standard list of redundant testing with attached fees and loss of valuable time.

At the end of the day; we desing and model buildings. HVAC Contractors install equipment to Code and Commission it.

We are constantly transferring liabilities from the GC and the HVAC Contractors back to the Rater.

This stuff makes no reasonalbe sense to me when you have codes, standards and special standards.

Tom Vitale

En-Tech Associates, Inc.

Comment #65

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: 3
Comment Type: Editorial

Comment:

These new standards are less stringent that BPI which we must apply to projects. As such, it is potentially a sub standard list of redundant testing with attached fees and loss of valuable time.

At the end of the day; we desing and model buildings. HVAC Contractors install equipment to Code and Commission it.

We are constantly transferring liabilities from the GC and the HVAC Contractors back to the Rater.

This stuff makes no reasonalbe sense to me when you have codes, standards and special standards.

Tom Vitale

En-Tech Associates, Inc.

Comment #66

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: 3
Comment Type: Editorial

Comment:

These new standards are less stringent that BPI which we must apply to projects. As such, it is potentially a sub standard list of redundant testing with attached fees and loss of valuable time.

At the end of the day; we desing and model buildings. HVAC Contractors install equipment to Code and Commission it.

We are constantly transferring liabilities from the GC and the HVAC Contractors back to the Rater.

This stuff makes no reasonalbe sense to me when you have codes, standards and special standards.

Tom Vitale

En-Tech Associates, Inc.

Comment #67

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: co/caz
Comment Type: Editorial

Comment:

This is getting out of hand and is does seem a lot like someone feels creating competitive standards is a great revenue stream for a few and only hurts the cretins who are too dumb to become trainers or administrators.

Speaking of administrators, it makes their job easier if they just force cretins to bend to their whims rather than learn what other standards are and figure out how to allow similar standards to be recognized.

why are there competing standards anyway? What is needed is a safe, efficient, durable comfortable home. it seems to me the standards are workign in the same environment to create the same result. Why woudl there be any root differences? Are the differences subjective opinion or factual? Who benefits through the differences? Follow the money.

I hope some day government realizes their ideals are being corrupted by the administrators and it is time to let market forces drive the system. Let government use PSA's and speaches to advocate conservation and better building practice. Let government set the standards through the codes. Get government out of administering these programs. then BPI and RESNET will wither and die, but firms who have done the market transforamtion that was proposed in 2000 will prosper.

Response:
Reject

Thank you for commenting. RESNET’s standard development policy is that where an accepta-ble ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard.

Comment #68

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: 1
Comment Type: General

Comment:

I am firmly against CAZ testing as part of a HERS rating. As a rater I would be hard pressed to remain in the profession if the requirement to complete CAZ testing during a rating takes effect. As a RESNET member I feel that it has been a misuse of scare resources to study imolementing CAZ testing into the standard.

Comment #69

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 4
Paragraph / Figure / Table / Note: 3
Comment Type: General

Comment:

completely disagree with modifications to testing buildings. completely disagree with additional testing required to maintain certifications.

its criminal to continue writing regulations, increase costs to pass tests. it does nothing to serve the better good.

if areas of the country are without guidance simply go to the BPI Website.

Proposed Change:

completely disagree with modifications to testing buildings. completely disagree with additional testing required to maintain certifications.

its criminal to continue writing regulations, increase costs to pass tests. it does nothing to serve the better good.

if areas of the country are without guidance simply go to the BPI Website.

Response:
Reject

Thank you for commenting. The requirements for certification have been removed from Chapter 8 and placed in Chapter 2, where Raters (and auditors) who are current BPI Building Analysts have been exempted from the field training requirement. RESNET’s standard development poli-cy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard.

Comment #70

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 4
Paragraph / Figure / Table / Note: 3
Comment Type: General

Comment:

completely disagree with modifications to testing buildings. completely disagree with additional testing required to maintain certifications.

its criminal to continue writing regulations, increase costs to pass tests. it does nothing to serve the better good.

if areas of the country are without guidance simply go to the BPI Website.

Proposed Change:

completely disagree with modifications to testing buildings. completely disagree with additional testing required to maintain certifications.

its criminal to continue writing regulations, increase costs to pass tests. it does nothing to serve the better good.

if areas of the country are without guidance simply go to the BPI Website.

Response:
Reject

Thank you for commenting. The requirements for certification have been removed from Chapter 8 and placed in Chapter 2, where Raters (and auditors) who are current BPI Building Analysts have been exempted from the field training requirement. RESNET’s standard development poli-cy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard.

Comment #71

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 4
Paragraph / Figure / Table / Note: 3
Comment Type: General

Comment:

completely disagree with modifications to testing buildings. completely disagree with additional testing required to maintain certifications.

its criminal to continue writing regulations, increase costs to pass tests. it does nothing to serve the better good.

if areas of the country are without guidance simply go to the BPI Website.

Proposed Change:

completely disagree with modifications to testing buildings. completely disagree with additional testing required to maintain certifications.

its criminal to continue writing regulations, increase costs to pass tests. it does nothing to serve the better good.

if areas of the country are without guidance simply go to the BPI Website.

Response:
Reject

Thank you for commenting. The requirements for certification have been removed from Chapter 8 and placed in Chapter 2, where Raters (and auditors) who are current BPI Building Analysts have been exempted from the field training requirement. RESNET’s standard development poli-cy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard.

Comment #72

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: CO/CAZ Standard
Comment Type: General

Comment:

The proposed changes to the testing, and verifier certification process, are not practical for field verifiers of new homes. The verifiers who are BPI Building Analysts already are trained in a rigorous CAZ testing protocol. The ACCA standards are not widely used, and adoption of this would add costs that we'll have to pass on to our builders. If builders have to pay more to obtain a HERS rating fewer builders will elect to go this route, which will result in a missed opportunity for our industry as some of those builders will end up building less efficient homes if they aren't working with a HERS Rater.

Earth Advantage, Inc. is opposed to this new requirement.

Comment #73

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: CO/Caz Standard
Comment Type: General

Comment:

I do not agree with the proposed standard. It is obviuos that the BPI certification is not good enough for RESNET. Having both certifications is like to dogs fighting. We are getting standarded to death. Leave it alone.

Response:
Reject

Thank you for commenting. However, since no change has been proposed we cannot take action.

Comment #74

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Comment Type: General

Comment:Proposed Change:

I am inagreement with a previous comment by Justin Gibson;

" With HERS Ratings having nothing to do with Combustion Safety, I believe that this section and the associated training should be removed from the upcoming Standards Update. Our job as HERS Raters is to model homes for energy usage, not inspect for Indoor Air Quality issues. "

Any CAZ testing requirement should be simply for the safety of the rater entering a unknown environment to conduct testing.

John Barrows

Response:
Reject

Thank you for commenting. RESNET does not make a distinction among Rater certifications. All certified Raters must meet all of the national minimum requirements for certification in order to be qualified to perform work on any home they may be required to work in. Therefore, all Raters that are going to be certified must meet all of the national standards for certification to be quali-fied to do the work on any home they may work in.

Comment #75

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: 805.1
Comment Type: General

Comment:

This new requirement is nothing short of BIZARRE. I already have my BPI BA and EP and I'm a proctor.

To now have to spend my time and my money to be recertified for CAZ testing is just wrong. If I'm already BPI certified, just accept it OK?

It really brings into GRAVE DOUBT the commitment of RESNET board to the needs and concerns of its members.

But look, you obviously have us over a barrel. So I imagine you'll just go right bloody ahead with it. But if you stay the course, I and many many other raters will remember this.

Proposed Change:

Eliminate the retesting requirement for BPI certified members.

JUST DO IT.

Response:
Reject

Thank you for commenting. The proposed change belongs to Chapter 2 and should not be considered on this proposed amendment under consideration. The requirements for certification have been removed from Chapter 8 and placed in Chapter 2, where Raters (and auditors) who are current BPI Building Analysts have been exempted from the field training requirement. All Raters that are going to be certified must meet all of the national standards for certification to be qualified to do the work on any home they may work in. The commenter is encouraged to propose an amendment to Chapter 2, following the proper procedure.

Comment #76

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: CAZ/CO simulator exam 805/807/808 etc
Comment Type: General

Comment:

I disagree with requiring a computer-simulation-based exam. I have been a Certified Energy Auditor since 1981, but many people from my generation lack experience playing video games. I have done many hundreds of combustion safety checks, energy audits and inspections, etc., and am a licensed mechanical contractor and BPI BA, yet when I tried InterCAZ I was frustrated by the computer interface. The computer simulation itself was too difficult to learn, even though I already knew how to do combustion safety testing. I feel a computer simulation exam is a poor substitute for hands-on field testing at a real house or other test facility, and could discriminate against folks over a certain age. RESNET may wish to consider potential age-discrimination problems related to requiring a computer simulation exam before pursuing this change.

Comment #77

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: All
Comment Type: Editorial

Comment:

I agree with many of the comments in that there already are standards which we should refer to and follow. If the ANSI/ACCA standard needs improvement then we should work with them to improve it. A much easier task than developing and refining our own.

As we continue to grow and become the accepted standard in home performance ratings we will be better served by accepting standards from partner associations like ANSI ACCA and ASHRAE among others.

I am not as invoived as I should be but from my readings I get the impression that we are in some ways competing with BPI so rather than dilute our efforts we should remain focused.

We, RESNET, must devote our energies to the already succesful HERS Rating and to the time when a HERS Rating is as commonplace as a Home Inspection.

Which approach better serves this goal,developing our own, or following others and one will not always be right but here it seems to be following ANSI/ACCA

Response:
Thank you for commenting. This is a supportive comment that requires no changes to the provisions of the standard.

Comment #78

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 30
Paragraph / Figure / Table / Note: A4.5.1
Comment Type: Technical

Comment:

The existing text states that samples for direct vent appliances should be taken at vent connections and around external perimeter of accessible piping joints. Direct vent appliances are positive pressure. The vent system should be air tight. The only place a CO sample can be taken would be at the exterior vent termination.

Proposed Change:

A4.5.1 Sample must be taken at external vent termination. connection and around the external perimeter of
accessible vent piping joints

Response:
Reject

This proposed change is referring to ANSI/ACCA Standard 12 and is not a proposed change to the proposed amendment under consideration. The commenter is encouraged to propose an amendment to ACCA.

Comment #79

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 31
Paragraph / Figure / Table / Note: A5.3
Comment Type: Technical

Comment:

This section describes how to place a home in worst case depressurization (WCD). This particular step lumps exhaust fan de-pressurization assessment with the possible affect of turning on an air handler. Exhaust fans will always result in de-pressurization, but turning on an air handler fan may result in either pressurization of the CAZ or de-pressurization depending on where duct leakage occurs and how the duct system is laid out. De-pressurization by exhaust fans could be counter acted by turning on the air handler with the result being the house does not end up in WCD. These steps should be separate and the de-pressurization of the CAZ evaluated after all the exhaust fans have been turned on and interior doors set and then the air handler should be turned on and the interior doors reset. This will ensure the CAZ is in WCD.

Proposed Change:

Turn on all indoor fans: bathroom exhaust, range hood, clothes dryer, powered attic
ventilation fans (with the exception of a whole house exhaust fans). and furnace/ air
handler/ fan coil. Close interior doors to any room that does not contain an exhaust fan or appliance and evaluate the CAZ de-pressurization wrt outside.

Now turn on the air handler fan on high. Re-set the interior doors, closing any door to rooms that show positive pressure wrt the CAZ and leaving open any door to rooms that show negative pressure wrt the CAZ. Evaluate the CAZ pressure wrt outside.

Comment #80

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 30
Paragraph / Figure / Table / Note: A4.4
Comment Type: Technical

Comment:

"A4.4.1 For atmospherically vented appliances: Take a measurement of combustion gases at the flue before the draft diverter and around the external perimeter of accessible vent piping joints.
Should give guidance on what to do with fan assisted appliances that do not have draft diverters

Proposed Change:

"A4.4.1 For atmospherically vented appliances: Take a measurement of combustion gases at the flue before the draft diverter and around the external perimeter of accessible vent piping joints. For Fan Assisted appliances test location within 12" of equipment outlet.

"

Comment #81

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 808.2
Paragraph / Figure / Table / Note: 808.2
Comment Type: Technical

Comment:

While technically already being eliminated (808.2) with the amendment, this comment refers to all references to calibration in the standard. Mandatory annual calibration of equipment is another excessive expense to raters being institutionalized by RESNET with this standard. RESNET's expertise states that I should have my manometer calibrated every year. I have two manometers over 5 years old that are calibration checked every year per TEC's standard. They are still within tolerance. In addtion, TEC has already moved their calibration suggestion to two years instead of the one year set by RESNET.

Proposed Change:

• Be calibrated annually by the manufacturer (or using manufacturer’s instructions) and
evidence of the calibration shall be submitted to the Rating Provider Quality Assurance
Designee

For ALL calibration requirements, leave the time frame out of the standard and rely on the manufacturer's expertise and recommended calibration timing and procedure. They certainly know their equipment better than RESNET.

Response:
Reject

This comment is not pertinent to the proposed amendment under consideration. The commenter is encouraged to propose an amendment to the RESNET Standards, following the proper procedure.

Comment #82

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 0
Comment Type: Editorial

Comment:

I am against this new standard.

I took my BPI training and HERS training in 2002. In New York it is almost standard to have sealed combustion heating systems and power vented hot water heaters in new homes. I do all the CAZ required testing because it is required. However I see this as the protocal agencies justifying their exsistance.

Is the new RESNET standard that much better than the BPI standard that you require more certification time and money from us. I'll do it because I have to but I feel it's just another way to make us pay more.

Response:
Reject

Thank you for commenting. The requirements for certification have been removed from Chapter 8 and placed in Chapter 2, where Raters (and auditors) who are current BPI Building Analysts have been exempted from the field training requirement. All Raters that are going to be certified must meet all of the national standards for certification to be qualified to do the work on any home they may work in. To ensure national consistency, RESNET’s standard development poli-cy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard.

Comment #83

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 8-20
Paragraph / Figure / Table / Note: 806.3
Comment Type: Technical

Comment:

Revision of ACCA Standard 12 QH has been revised in 2013 and 2014 for general consistency with mandatory requirements for the National Fuel Gas Code (NFGC), ANSI Z223.1/NFPA 54, the governing national consensus standard for fuel gas systems, as they would apply to existing piping systems. In order to maintain consistency with other provisions of ACCA Standard 12 QH and alleviate potential burdens of auditors from referring to multiple standards, use of the ACCA Standard 12 QH procedures represent a reasonable and consistent compromise without having to use the NFGC directly. RESNET standards activities undertaken by the RESNET-sponsored Combustion Appliance Testing Standards Amendment Drafting Committee (CAT-SADC) prior to the solicitation of comments on combustion appliance testing had, as its work scope, gas system inspection as well as gas appliance venting testing.

Proposed Change:

Delete Section 806.3 in its entirety and replace with the following:

806.3 Inspect all gas lines in accordance with procedures found in Section 3.2.2 of ACCA Standard 12 QH - 2015.

Response:
Reject

Reject in favor of response to comment #37.

Comment #84

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 1
Paragraph / Figure / Table / Note: 805.2
Comment Type: General

Comment:

For the same reasons numerous previous commenters have already stated, recognize other professional CO/CAZ certifications.

Proposed Change:

REINSTATE:

Response:
Reject

To ensure national consistency, RESNET’s standard development policy is that where an ac-ceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard. The training requirements are part of Chapter 2 and are not part of this proposed amendment commented on. The requirements for certification have been removed from Chap-ter 8 and placed in Chapter 2, where Raters (and auditors) who are current BPI Building Analysts have been exempted from the field training requirement.

Comment #85

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 807 & 808
Comment Type: General

Comment:

I am in this business since 7 years and always wondered why we have to to re-invent the wheel again and again in this industry. Seriously!

As a BPI certified contractor (since 2008) and QA Inspector, I hold multiple certifications and have performed more than 1000 audits and ratings in the last 7 years. As an experienced and ALREADY CERTIFIED contractor I am absulately comfortable to performing CAZ testing without any extra (RESNET) certification. I do not need any new organization's approval on something that I already know.

This business is hard enough for all of us already. RESNET is suposed to protect it's own members and not make thier life more difficult.

1. Should rating include CAZ testing?

Absolutely, I believe every home should be tested for CAZ! It takes 5-10 more minutes of your time. I am more than happy to do it. I don't know why it is such a big deal, especially if you can save lifes with it! In some cases you can meet with very weird situations when a simple CAZ test can show serious problems. For example how an 800 CFM rated range hood can screw up the entire house.

2. RESNET should not train or test raters or anyone regarding CAZ testing - BPI is already doing it! Just in case I will write it down if someone doesn't know it:

BPI - Combustion Safety Test Procedure for vented appliances

Follow their process and you are done! It is simple!

Why do we have to make it more difficult?

Sincerely: Szabi Fekete

Proposed Change:

REINSTATE:

CONSIDER removing all reference to the RESNET CAZ Certification (ie Combustion Appliance Test), let BPI or equivalent be the defacto standard where CAZ is indicated, and (important)

ADD a Work Scope requirement to give information to the Owner of the importance of resolving any combustion issues, if they are present.

Comment #86

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 8-20 to 8-22
Paragraph / Figure / Table / Note: 807
Comment Type: Technical

Comment:

AGA supports the suggestion of RESNET to defer short-term combustion appliance testing (also referred to as combustion appliance zone – CAZ – testing) to other standards such as ACCA 12 HQ - 2015. However, RESNET may want to consider broader agreement with the ACCA 12 Standard in terms of its application and not mechanical replication of test steps.

AGA specifically recommends reference to ACCA 12 HQ - 2015 and the sections of that standard cited in the proposed revision based on the following salient points:

• None of the short-term combustion appliance test procedures currently available, including those referenced in Building Performance Institute (BPI) Guidelines for Home Energy Professionals, BPI Standard 1100, BPI Draft Standard 1200, National Fuel Gas Code, ANSI Z223.1/NFPA 54 (for which AGA serves as the ANSI secretariat), RESNET Mortgage Industry Standard, or ACCA 12 QH have been systematically validated with field data or by other means. In fact, a report from Lawrence Berkeley National Laboratory (LBNL), “Assessment of Literature Related to Combustion Appliance Venting Systems, “ (V. Rapp, et. al. 2012) cites general deficiencies of current short-term test methods for reliably identifying potentially hazardous appliance installation conditions, including potential for both “false positives” and “false negatives.” In this environment, no basis exists for selecting one series of short-term tests over another.

• In light of these issues, and even with potential deficiencies in the Appendix A tests of ACCA 12 QH, the requirements of ACCA 12 QH in Section 3.2.5 appropriately call for short-term combustion appliance tests “where required by the AHJ” and using the Appendix A procedures or alternate “methodology/procedure per the AHJ.” This discretion allows the AHJ to determine the need for short-term combustion tests over and above meeting minimum requirements for safe installation and operation and discretion in use of test methods as more validation of methods becomes available.

• The importance of AHJ involvement and discretion is also important to weigh consideration of minimum code requirements and the potential value added by short-term combustion tests. Based on Building America discussions meeting such as the 2012 seminar in San Antonio, Texas held in conjunction with the ASHRAE Summer Meeting, safe installation of combustion appliances where minimum code compliance is verified has not identified cases where minimum code compliance was accompanied by improper venting of atmospherically-vented combustion appliances. In fact, short-term combustion tests should not be considered alone without evaluating associated code compliance, particularly following building envelope improvements might alter availability of combustion and ventilation air.

• Some auditing interests have responded to the issue of code compliance that auditors are not “code enforcers” and may not have competencies to review combustion appliance installations for basic code requirements. Where this applies, the AHJ may be essential to maintain minimum combustion appliance safety performance. Alternatively, parallel qualification of auditors for evaluating basic compliance with minimum codes (such as through training and certification to the International Codes Council “Gas Inspector” credential requirements) may be needed. Performance of short-term combustion tests alone is not sufficient to protect occupants from combustion appliance malfunctions.

Proposed Change:

I propose an alternative to the amendment for consideration by RESNET. Delete exisitng standard Section 807 in its entirety and replace with the following:

807 The auditor shall test atmospherically-vented combustion appliances in accordance with procedures found in Sections 3.2.4, 3.2.5, 3.2.6 and Appendices 4.0 and 5.0 of ACCA Standard 12 QH (2015).

Actual text from ACCA Standard 12 QH - 2015 could be substituted for the references provided in the Section 807 text above.

In any case, the motivations and intentions behind the amendment as proposed represent an important step in trying to bring consistency across various documents in review of combustion appliances and the role of auditors.

Response:
Reject in favor of response to comment #37.

Comment #87

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 808
Paragraph / Figure / Table / Note: 8-22 to 8-24
Comment Type: General

Comment:

Section 3.2.1 of ACCA Standard 12 QH has been recently revised to incorporate appliance-specific emission rate thresholds approved for the NFGC (ANSI Z223.1/NFPA 54) 2015 Edition. RESNET standards activities undertaken by the RESNET-sponsored Combustion Appliance Testing Standards Amendment Drafting Committee (CAT-SADC) prior to the solicitation of comments on combustion appliance testing had, as its work scope, carbon monoxide testing as well as gas appliance venting testing.

Proposed Change:

I propose an alternative to the amendment for consideration by RESNET.

808 The auditor shall test gas-fired appliances for carbon monoxide emissions performance in accordance with Section 3.2.1 and Appendices 3.6 and 3.8 of ACCA Standard 12 QH - 2015.

Actual text from ACCA Standard 12 QH - 2015 could be substituted for the references provided in the Section 807 text above.

Response:
Reject

Thank you for commenting. RESNET’s standard development policy is that where an acceptable ANSI standard exists, RESNET will use that standard instead of creating another standard. In this case, ANSI/ACCA Standard 12 QH-2014 is deemed to be an acceptable standard. However, we believe that this modification satisfies the commenter’s intent:

805.1 The protocols contained in ANSI/ACCA 12 QH-2014, Appendix A Sections A3 (Carbon Monoxide Test) and A4 (Depressurization Test for the Combustion Appliance Zone (CAZ)) shall be followed by RESNET-accredited Raters and Auditors (hereinafter referred to collectively as “Auditors”) performing combustion appliance testing or writing work scopes for repairs. In addition, the protocols contained in ANSI/ACCA 12 QH-2014, section 3.2.2 (Gas/Oil Leakage Test-ing) shall be followed by Auditors performing combustible gas and oil line testing.

~~806 Gas Leakage Test~~

806.1 If there is a noticeable odor indicating gas buildup within the home, the occupants and Auditor shall leave the house and the appropriate authorities and utility providers shall be notified from outside the home.

806.2 The Auditor should use a gas detector upon entry into the home to detect the presence of natural gas. If gas is suspected or confirmed, ensure that switches are not operated while exiting and no ignition concerns are present. The audit shall not proceed until the proper authorities have deemed it safe to re-enter the home. If there is no noticeable odor indicating gas buildup within the home, the Auditor shall determine if there are gas leaks in the fittings and connections of natural gas appliances within the home and natural gas/liquid propane supply lines following these protocols.

806.3 Inspect all fittings and joints in supply lines and appliance connectors and confirm sus-pected leaks with leak-detection fluid. Identify for repair or replacement any kinked, corroded or visibly worn flexible gas lines and any flexible connectors manufactured prior to 1974.

806.4 Equipment needed
• Combustible gas detector capable of measuring 20 ppm
• Leak detection fluid (non-corrosive)

Comment #88

Amendment: Proposed Amendment to Update RESNET CAZ Testing Standard
Page Number: 8-20
Paragraph / Figure / Table / Note: 806
Comment Type: Technical

Comment:

Proposed Change:

I am supportive of the proposed amendment but offer an alternative.

Delete Section 806.3 of the existing text in its entirety and replace with the following:

806.3 Inspect all gas lines in accordance with procedures found in Section 3.2.2 of ACCA Standard 12 QH - 2015.

Actual text from ACCA Standard 12 QH - 2015 could be substituted for the references provided in the Section 806 text above.

Response:
Reject

We believe that this modification meets the intent of the commenter:

805.1 The protocols contained in ANSI/ACCA 12 QH-2014, Appendix A Sections A3 (CarbonMonoxide Test) and A4 (Depressurization Test for the Combustion Appliance Zone (CAZ)) shall be followed by RESNET-accredited Raters and Auditors (hereinafter referred to collectively as “Auditors”) performing combustion appliance testing or writing work scopes for repairs. In addition, the protocols contained in ANSI/ACCA 12 QH-2014, section 3.2.2 (Gas/Oil Leakage Test-ing) shall be followed by Auditors performing combustible gas and oil line testing.

~~806 Gas Leakage Test~~

806.1 If there is a noticeable odor indicating gas buildup within the home, the occupants and Auditor shall leave the house and the appropriate authorities and utility providers shall be notified from outside the home.

806.2 The Auditor should use a gas detector upon entry into the home to detect the presence of natural gas. If gas is suspected or confirmed, ensure that switches are not operated while exiting and no ignition concerns are present. The audit shall not proceed until the proper authorities have deemed it safe to re-enter the home. If there is no noticeable odor indicating gas buildup within the home, the Auditor shall determine if there are gas leaks in the fittings and connections of natural gas appliances within the home and natural gas/liquid propane supply lines following these protocols.

806.3 Inspect all fittings and joints in supply lines and appliance connectors and confirm sus-pected leaks with leak-detection fluid. Identify for repair or replacement any kinked, corroded or visibly worn flexible gas lines and any flexible connectors manufactured prior to 1974.

806.4 Equipment needed
• Combustible gas detector capable of measuring 20 ppm
• Leak detection fluid (non-corrosive)

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