Hello. My name is Derek Schroeder, lead policy advisor for technical operations and technical project officer for the Department of Energy's Weatherization Assistance Program. Today I'm going to talk about the Weatherization Assistance Program's update to the health and safety guidance known as WPN 22-7 weatherization health and safety. The purpose of this presentation is to review WPN 22-7, the weatherization health and safety, highlight updates in WPN 22-7 compared to 17-7, highlight where grantee health and safety plans can be updated and review support materials associated with 22-7.
An overview of WPN 22-7. This was drafted, reviewed and approved during 2021. It describes the most common issues encountered during weatherization, describes required, allowable and prohibited actions with Department of Energy funding and outlines minimum plan requirements for grantees where more guidance may be needed at the local level.
WPN 22-7 organization comes in three parts. There's the Guidance Narrative, the Table of Issues and supporting documents and additional resources. Similar to the quality work plan update the supporting documents and additional resources are completely separate from the official WPN itself. This will allow the Department of Energy to keep these up to date. The main documents is the Guidance Narrative and the Table of Issues. The Guidance Narrative describes the universal requirements, project considerations, required forms and use of Table of Issues. The Table of Issues describes action allowability, testing, client education and now incorporates what was previously attachment one to WPN 17-7.
The next few slides I'm going to go through piece by piece each aspect of WPN 22-7. The first aspect is the Guidance Narrative. New in 22-7 it consolidates and clarifies all previous health and safety guidance into more specific topics, reinforces health and safety expenditure documentation requirements and clarifies required contents of hazard notification and screening requirements. It clarifies required allowable and prohibited health and safety activities with Department of Energy funding and clarifies terms that must be defined. Examples of that are minor and major.
Additional updates to the Guidance Narrative is it incorporates references to the building assessment, the radon reduction interventions with energy retrofits expansion study also known as the BEX study and its recommendations for associated radon precautionary measure installations. It clarifies that the requirement that all required testing/ inspection related items must be documented in each client file and it identifies required health and safety forms needed in client files. The next item is piece by piece the Table of Issues. New for 22-7 is it categorizes health and safety actions as requires, allowable or prohibited. Reduces redundancy for training requirements and keeps training and technical assistance T&TA only in the T&TA plan. Client education is reduced only to required activities. It removes redundancy and consolidates items and as previously mentioned incorporates former Attachment A into the new Table of Issues.
The first item of the update to the Table of Issues is that we have better clarified the required, allowable and prohibited. As a reminder required as items that must be explicitly detailed in the health and safety plan regardless of funding source. Allowable indicates that they must be addressed in the health and safety plan only if Department of Energy WAP funds are being used to implement. And prohibited are not allowed to be implemented with Department of Energy health and safety WAP funds and do not need to be addressed in the health and safety plan but may be addressed using alternative funding that does not follow DOE rules. This does not require that the health and safety plan detail how you will be covering those prohibited items with alternative funding.
Walking through each individual issue in 22-7 the updates to air conditioning, heating systems and combustion appliances. It now clearly defines primary and secondary heat sources. It adds unvented space heater and combustion gasses to this section, requires documentation that demonstrates all heating and cooling system replacements were first cross tested as an ECM prior to using health and safety funds for installation. And it also requires that all homes must have a safe, operable primary heating system for the entire dwelling unit after weatherization is complete.
For asbestos previously this was multiple sections in the Table of Issues. It has now been combined all of those previous asbestos related activities into a single category and consolidated guidance requirements. For biologicals and unsanitary conditions it adds allowance for limited cleaning of the workspace to protect the health and safety of workers and occupants as defined in the grantees health and safety plan. For fuel leaks it better clarifies the allowable and prohibited activities relating to bulk fuel tank leakage.
For hazardous materials it now combines the formaldehyde, volatile organic compounds, flammable liquids and other air pollutants from the 17-7 Table of Issues within this section. It clarifies that limited removal of hazardous material for the protection of workers is not required but is an allowable item for protection of occupants. For injury prevention of occupants it removes the injury prevention of workers from this section and moves those requirements to an overarching worker safety section within the Table of Issues. For lead based surface coverings it clarifies that lead can exist in other forms than just paint. And it clarifies that DOE WAP health and safety funds may not be used for lead abatement or for the purchase of resourcing or maintenance of x-ray fluorescence device.
For mold and moisture it now incorporates the window and door replacement, window guards section previously from 17-7 Table of Issues. It clarifies that window and door repairs are allowable health and safety expenses to resolve a bulk water intrusion issue that is the cause of visible biological growth known as mold and in compliance with the most current program notice, WPN 19-5 at the time of this reporting. It also clarifies that DOE WAP health and safety funds for window replacements and/or mold cleanup is prohibited.
For occupant pre-existing or potential health conditions it allows for occupant temporary relocation costs by a case-by-case basis. Grantees are required to define the allowable cost, relocation options and procedures for this within their health and safety plans. Case-by-case determination and WAP documentation is also required from the client if the Department of Energy WAP funds are to be used for this purpose. Clarifies that the screening of occupant health conditions is documented using the occupant pre-existing or potential health condition screening form required by 22-7.
For radon this is the item that has probably the largest change for the update to the health and safety guidance. Based on the results from the BEX report it requires that every dwelling receive the following package of measures if applicable regardless of radon zone or where located. Cover exposed dirt floors within the pressure and thermal boundary with a sealed soil gas retardant. Cover sump well/pits with airtight covers and implement ventilation as required by ASHRAE 62.2-16. This is a new requirement but one thing that I would like to point out is that two of the three of these have always prevalently been part of the Weatherization Assistance Program for several years now.
The covering of exposed dirt floors and the implementation of ventilation as required by ASHRAE 62.2-16 have been very much a part of the weatherization assistance program for several years. The one item that has historically been allowed but not be completed as prevalently is covering of sump well/pits with airtight covers. The SWS has been updated to include the precautionary package of radon measures. I encourage grantees to go to the SWS to look at those specifications when incorporating this precautionary package of radon measures into their health and safety plans. It also provides an updated sample template for the occupants consent which includes the required information and updated references.
Safety devices, smoke and carbon monoxide alarms and fire extinguishers. It clarifies the requirements for the installation of CO alarms in every home regardless of location or fuel sources. It also allows for replacement of functional smoke and CO alarms that have passed the manufacturers stated lifetime, typically ten years or the batteries that are operational or need replacement.
Ventilation and indoor air quality, reinforces the requirement for deferral if a client refuses ventilation installation as required in ASHRAE 62.2-16 has been properly calculated. Water heaters, this is a new section. It does refer you back to combustion safety. However water heaters was added to this section specifically to address the health and safety issues frequently reported by Weatherization Assistance Program grantees.
Worker safety. Worker safety has been updated to reinforce the requirements to adhere to all federal, state and local worker safety regulations. Examples of that is OSHA which would be fall protection in confined space, the HASCOM update, EPA which would be for radon and lead which may include the following also allowable expenses, minor repairs and installations, examples being repairing stairs, replacing handrails as defined by the grantees' health and safety plan are allowable when necessary to safely weatherize the dwelling. Equipment purchased to protect the health and safety of the worker, examples of that would be personal protective equipment or job site cleaning supplies and environment and surveillance testing required by OSHA. Also for worker safety it does move training requirements from the health and safety plan over to the grantee T&TA plan.
Next for piece by piece I'm going to cover the support documents. As I indicated earlier these are separate from the official WPN and the official Table of Issues which will allow the Department of Energy to keep these up to date. Those will be the FAQs and other. There's the guidance crosswalk, PY 22 health and safety template and optional radon disclosure form.
The first item is additional resources and references. Previously in 17-7 this was included within the FAQs. DOE determined that it would be more valuable to pull all of these additional resources and links into a single document. So as you can see we have done so and an example would be for combustion gases. There is multiple links where you can find useful information and additional resources about combustion gases, safety devices, electrical and any and all of the other health and safety issues that have been identified in WPN 22-7. The FAQs have been updated to reflect questions that have been received since the issuance of 17-7 as well as with the updates to 22-7.
Other resources would be the guidance crosswalk. Similar to the quality work plan update we have completed a guidance crosswalk to determine or to better visualize the differences between 17-7 and 22-7. DOE encourages you when you're working with your grantee, when you're working with your network to go over these changes as they better detail all of the changes that have happened. The optional health and safety plan template for grantees when submitting their health and safety plans has also been updated to incorporate the changes from 17-7 to 22-7. Again this is an optional template but we do encourage grantees to utilize this as it does help to streamline the review process of health and safety plans.
Then we've also updated the optional radon exposure disclosure. While this form is a required element this is an optional form our grantees can use when developing their form. This has been updated to incorporate language from the BEX report as well as to incorporate that the BEX report has indicated that through the precautionary package of measures that there is no significant, there's no statistically significant increase in indoor radon levels within the lowest living level when the precautionary package of measures is installed.
I want to thank everybody for taking the time today to listen to the update to 22-7. If you have additional questions please contact your respective project officer so that we can work with you to help better clarify any questions that you may have and try to answer them. Thank you and have a good day.
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