Comment #1Amendment: Proposed MINHERS Addendum 60, Combustion Safety Field Training, Draft PDS-01Page Number: 7Paragraph / Figure / Table / Note: 206.2.3.4Comment Intent: ObjectionComment Type: GeneralComment: 206.2.3.4 A minimum of two (2) hours of Combustion Safety field training using required combustion testing tools per ANSI/RESNET/ICC 380 in an in-field environment is required to be completed and overseen by a RESNET certified Candidate Field Assessor or Quality Assurance Designee during a HERS Rater Candidate’s probationary rating period. This field training shall include performance of CAZ, spillage, and CO testing in accordance with Carbon Monoxide (CO) Test and Depressurization Test for the Combustion Appliance Zone (CAZ) protocols contained in ANSI/ACCA 12 QH, Appendix A, Sections A4 and A5. Comments: The creation of the HERS Modeler designation and the Rating Field Inspector are driving rating companies to use fewer raters in the field. As the current system works, a modeler can build the rating in the software, the RFI can do all necessary field inspections and tests, send the results back to the modeler for software updates and the Rater of Record simply needs to review and sign. The above section seems unnecessary given that fewer Raters will actually be in the field performing inspections because of this direction taken by RESNET. Further, combustion safety testing is a very rare occurrence in the industry. The majority of HERS ratings are done on new construction. The direction of building codes and the industry at large is eliminating atmospherically vented appliances in new construction homes, thus eliminating the need for combustion safety testing. There is currently a requirement for a virtual combustion safety test which should suffice for a position that is spending less time in the field than any other RESNET certified position. Proposed Change: RECCOMENDATION: Strike this field test from the requirements for Home Energy Rater certification as it is increasingly unnecessary for the position and increasingly less frequent in the Energy Rating industry. 206.2.3.4 A minimum of two (2) hours of Combustion Safety field training using required combustion testing tools per ANSI/RESNET/ICC 380 in an in-field environment is required to be completed and overseen by a RESNET certified Candidate Field Assessor or Quality Assurance Designee during a HERS Rater Candidate’s probationary rating period. This field training shall include performance of CAZ, spillage, and CO testing in accordance with Carbon Monoxide (CO) Test and Depressurization Test for the Combustion Appliance Zone (CAZ) protocols contained in ANSI/ACCA 12 QH, Appendix A, Sections A4 and A5.
206.2.3.4 A minimum of two (2) hours of Combustion Safety field training using required combustion testing tools per ANSI/RESNET/ICC 380 in an in-field environment is required to be completed and overseen by a RESNET certified Candidate Field Assessor or Quality Assurance Designee during a HERS Rater Candidate’s probationary rating period. This field training shall include performance of CAZ, spillage, and CO testing in accordance with Carbon Monoxide (CO) Test and Depressurization Test for the Combustion Appliance Zone (CAZ) protocols contained in ANSI/ACCA 12 QH, Appendix A, Sections A4 and A5.
Comments: The creation of the HERS Modeler designation and the Rating Field Inspector are driving rating companies to use fewer raters in the field. As the current system works, a modeler can build the rating in the software, the RFI can do all necessary field inspections and tests, send the results back to the modeler for software updates and the Rater of Record simply needs to review and sign. The above section seems unnecessary given that fewer Raters will actually be in the field performing inspections because of this direction taken by RESNET. Further, combustion safety testing is a very rare occurrence in the industry. The majority of HERS ratings are done on new construction. The direction of building codes and the industry at large is eliminating atmospherically vented appliances in new construction homes, thus eliminating the need for combustion safety testing. There is currently a requirement for a virtual combustion safety test which should suffice for a position that is spending less time in the field than any other RESNET certified position.
RECCOMENDATION: Strike this field test from the requirements for Home Energy Rater certification as it is increasingly unnecessary for the position and increasingly less frequent in the Energy Rating industry.
Comment #2Amendment: Proposed MINHERS Addendum 60, Combustion Safety Field Training, Draft PDS-01Page Number: 7Paragraph / Figure / Table / Note: 206.2.3.3Comment Intent: Not an ObjectionComment Type: TechnicalComment: With the current language, our interpretation is that raters would be required to perform all of the tasks included in 206.2.1.2 in each of their three mentored probationary ratings. Due to the limited availability of atmospherically vented equipment, we propose adding the language below to require the CAZ testing in only one of the three to satisfy the requirement in 206.2.1.2.8. Section 206.2.1.2.6 requires ductwork for testing; in many markets, finding homes with ductwork can be difficult. We propose requiring duct testing in two of the three mentored probationary ratings. Proposed Change: After passing the all of the RESNET tests, but prior to being certified, the candidate shall complete five probationary ratings with a Rating Quality Assurance Provider overseen by a RESNET certified Candidate Field Assessor or Quality Assurance Designee. At least three of the five probationary ratings shall be accomplished using field verification of all rated features of the home in accordance with ANSI/RESNET/ICC 380-2016 and shall include the tasks as listed in 206.2.1.2. Task 206.2.1.2.6 to be completed on a minimum of two of the three mentored probationary ratings. Task 206.2.1.2.8 to be completed on a minimum of one of the three mentored probationary ratings per 206.2.3.4. and All field verification shall be completed in the presence of a RESNET Certified Field Assessor, or Quality Assurance Designee. a At least one of which field verified probationary rating shall be completed one-on-one. Probationary ratings shall not be considered Confirmed Ratings.
With the current language, our interpretation is that raters would be required to perform all of the tasks included in 206.2.1.2 in each of their three mentored probationary ratings. Due to the limited availability of atmospherically vented equipment, we propose adding the language below to require the CAZ testing in only one of the three to satisfy the requirement in 206.2.1.2.8. Section 206.2.1.2.6 requires ductwork for testing; in many markets, finding homes with ductwork can be difficult. We propose requiring duct testing in two of the three mentored probationary ratings.
After passing the all of the RESNET tests, but prior to being certified, the candidate shall complete five probationary ratings with a Rating Quality Assurance Provider overseen by a RESNET certified Candidate Field Assessor or Quality Assurance Designee. At least three of the five probationary ratings shall be accomplished using field verification of all rated features of the home in accordance with ANSI/RESNET/ICC 380-2016 and shall include the tasks as listed in 206.2.1.2. Task 206.2.1.2.6 to be completed on a minimum of two of the three mentored probationary ratings. Task 206.2.1.2.8 to be completed on a minimum of one of the three mentored probationary ratings per 206.2.3.4. and All field verification shall be completed in the presence of a RESNET Certified Field Assessor, or Quality Assurance Designee. a At least one of which field verified probationary rating shall be completed one-on-one. Probationary ratings shall not be considered Confirmed Ratings.
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