Colorado Health And Safety Plan Summary

WPN 11-6a. This 2013 H & S plan will take effect July 1, 2013 at the start of Colorado’s Program Year 2013-2014 state plan, unless otherwise stated within this document. This plan is subject to revision and is not to be construed as final.

State of Colorado Weatherization Assistance Program Health & Safety Plan

Budgeting (Check one): The grantee is encouraged to budget health and safety costs as a separate category and, thereby, excludes such costs from the average per-unit cost calculation. This separate category also allows these costs to be isolated from energy efficiency costs in program evaluations. The grantee is reminded that, if health and safety costs are budgeted and reported under the program operations category rather than the health and safety category, the related health and safety costs must be included in the calculation of the average cost per home and cost-justified through the audit.

Separate Health & Safety Budget Colorado exercises the option to budget health and safety costs as a separate budget category.

Incidental Repairs (List repairs, if any, that will be removed as health and safety measures and implemented as incidental repairs.): If the grantee chooses to identify any health and safety measures as incidental repairs, they must be implemented as such under the grantee’s weatherization program in all cases – meaning, they can never be applied to the health and safety budget category. In order to be considered incidental repairs, the measure must fit the following definition and be cost justified along with the associated efficiency measure. Incidental Repairs means those repairs necessary for the effective performance or preservation of weatherization materials. Such repairs include, but are not limited to, framing or repairing windows and doors which could not otherwise be caulked or weather-stripped and providing protective materials, such as paint, used to seal materials installed under this program. Per Colorado Technical Standards, incidental repairs such as minor plumbing to repair a minor leak in a pipe, minor roof leak repair, and minor structural repairs may only be made when necessary to preserve weatherization materials such as insulation. Replacement of doors that are broken beyond repair is considered to be an incidental repair or prescriptive air sealing measure if cost effective under Colorado Technical Standards. In instances where repair or replacement of doors or windows is recommended because the door/window could not otherwise be caulked or weather-stripped effectively this measure should not be billed as a Health and Safety cost; it should be categorized as an incidental or air sealing repair. Providing protective materials such as primer or paint to seal and protect the weatherization materials installed shall be categorized as an incidental repair and shall be billed as such. Such materials shall only be allowed to protect weatherization materials installed. They shall not be allowable for cosmetic reasons alone.

Health and Safety Expenditure Limits (Provide a per-unit average percentage and justification relative to the amount. Low percentages should include a statement of what other funding is being used to support health and safety costs, while larger percentages will require greater justification and relevant historical support.): The grantee must set health and safety expenditure limits for their subgrantees, providing justification by explaining the basis for setting these limits and providing related historical experience. It is possible that these limits may vary depending upon conditions found in different geographical areas. These limits must be expressed as a percentage of the average cost per dwelling unit. For example, if the average cost per dwelling is $5000, then an expenditure of $500 per dwelling would equal 10 percent expenditures for health and safety. 10 percent is not a limit on H&S expenditures but exceeding this amount will require ample justification. These funds are to be expended by subgrantees in direct weatherization activities. While required as a percentage of the average unit cost, if budgeted separately, the health and safety costs are not calculated into the per- house limitation.

Statewide per unit average H/S is 10%.

Colorado exercises the option to budget health and safety costs separately. The above number is merely an average based on our historical data regarding the housing stock of eligible Colorado clients and the preponderance of health and safety issues found in the typical housing stock.

Deferral Policy (Provide a detailed narrative of the grantees overall deferral policy): Deferral may be necessary if health and safety issues cannot be adequately addressed according to WPN 11-6 guidance. The decision to defer work in a dwelling is difficult but necessary in some cases. This does not mean that assistance will never be available, but that work must be postponed until the problems can be resolved and/or alternative sources of help are found. In the judgment of the auditor, any conditions that exist, which may endanger the health and/or safety of the workers or occupants, should be deferred until the conditions are corrected. Deferral may also be necessary where occupants are uncooperative, abusive, or threatening. The grantee should be specific in their approach and provide the process for clients to be notified in writing of the deferral and what corrective actions are necessary for weatherization to continue. The grantee should also provide a process for the client to appeal to a higher level in the organization. Per Colorado’s Health & Safety Plan, a dwelling unit should not be weatherized where there is a major code violation or where there is a potentially harmful situation that may adversely affect the occupants or agency’s weatherization crew and/or other staff. When such issues are found to be present, the owner/occupant is notified verbally and in writing; and, only after the owner corrects the identified issues satisfactorily and to code shall any weatherization work begin. The audit form shall include the client’s name and address, dates of the audit/assessment, date the client was informed, a clear description of the issue(s), a clear description of the condition(s) under which weatherization work could begin/continue, a clear description of the responsibilities of all parties involved, client’s signature(s) indicating that they have been informed of their rights and options and that they understand the issues and their responsibilities.

Should a client request a second opinion on a deferral or walk-away, the weatherization agency is encouraged to contact their local county health, building, electrical, fire, or other city/county inspector to request an inspection of the site. Should the client refuse to have another inspector inspect the unit, the crew will note the refusal in the client file, and no work shall be performed on the unit. If, after an outside inspection, the inspector deems that the work pending deferral can and should be completed, crews and weatherization agencies are encouraged to work with the outside inspector’s suggestions to make the improvements. However, the outside inspector does not make the final determination on the amount, cost of work, or measures applied to the unit. Should the weatherization agency deem the suggestion(s) financially or programmatically beyond the scope of the weatherization assistance program, the weatherization may document their justifications and still defer weatherization work to the unit.

Crew members or other weatherization agency staff who choose to work on a unit that could or should be a deferral or walk-away, do so at his or her own risk. However, putting occupants at further risk as a result of doing the work is never allowable. The Colorado Energy Office Weatherization Assistance Program does not require, expect, or encourage weatherization crews to work in unsafe or unhealthy conditions. Deferral conditions may include, but are not limited to: 1. The client, or other household member, has known health conditions that prohibit the installation of insulation materials or other weatherization materials. 2. The building structure or its mechanical systems, including electrical and plumbing, are in such a state of disrepair that failure is imminent and the conditions cannot be resolved cost effectively or within the scope of the weatherization assistance program guidance. 3. The house has raw sewage, excessive animal feces, or other sanitation problems that would further endanger the client and weatherization crews if the weatherization work were performed. 4. The house has been condemned or electrical, heating, plumbing, or other equipment has been “red tagged” by local, county, or state building officials or utilities due to safety or code issues. 5. Moisture problems that are so severe they cannot be resolved under existing health and safety measures or as incidental minor repairs. 6. Dangerous conditions exist due to high carbon monoxide levels associated with combustion appliances which cannot be resolved under existing health and safety measures and guidance. 7. The client is uncooperative, abusive, hostile, or threatening to the crew, subcontractors, auditors, inspectors, or others who must work on or visit the home. 8. The extent and condition of lead-based paint in the house would potentially create increased health and safety hazards for both the occupants and crew members. 9. In the judgment of the energy auditor, any condition exists which may endanger the health and/or safety of the work crew or subcontractor, the work should not proceed until the identified condition is satisfactorily corrected. 10. If a mold condition is discovered during the initial audit of the home by an energy auditor and cannot be adequately addressed by the weatherization crew, the unit will be referred to the appropriate public or non-profit agency for remedial action. Colorado weatherization agencies shall defer work on the home until another funding source or the owner completes mold remediation. Colorado weatherization agencies shall distribute the pamphlet from the U.S. Environmental Protection Agency (EPA), Indoor Environment Division, (IED), “A Brief guide to Mold, Moisture, and Your Home” to clients whose homes have a moisture and/or mold problem. The pamphlet can be found at http://www.epa.gov/iaq/molds/images/moldguide.pdf 11. Client cannot be reached at telephone number on file due to the service being disconnected or due to client unavailability. 12. Client refuses to allow energy auditor(s) access to all areas of the home necessary to conduct the comprehensive energy audit. 13. Presence of animals which pose a risk to the weatherization workers. The work may be deferred until such animal threats have been secured adequately so that they no longer pose a threat. 14. Unable to gain access to the area to perform the work. The work may be deferred until the blocked access is cleared to allow the necessary access to perform the work. The Walk-Away Deferral policy is CEO Wx 311.

Procedure for Identifying Occupant Health Concerns: Procedures must be developed and explained on how information is solicited from clients to reveal known or suspected occupant health concerns as part of the initial application for weatherization, additional screening of occupants again during the audit, and what steps will be taken to ensure that weatherization work will not worsen the health concern. Weatherization agencies are required to gather occupant health information as part of the initial client application process. Information is then discussed with the client during the interview process which occurs before any work is done to the home by the agency auditor or subcontractor. Weatherization Documentation Form(s) have been developed (Check Yes or No): Documentation forms must be developed, include the client's name and address, dates of the audit/assessment and when the client was informed of a potential health and safety issue, a clear description of the problem, a statement indicating if, or when weatherization could continue, and the client(s) signature(s) indicating that they understand and have been informed of their rights and options

Yes -Colorado has a Chemical Sensitivity Statement form that is signed by both the client and auditor prior to beginning work.

Colorado WAP Plan for implementing the guidance issued in WPN 11-6

Air Conditioning and Heating Systems Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 x “Red tagged”, inoperable, or nonexistent heating system replacement, Alternative Guidance repair, or installation is allowed where climate conditions warrant. In most cases, Colorado does not allow air conditioning system replacement, repair, or installation because Colorado is mostly a cold weather state for the majority of the year. Colorado does allow a waiver process to be used to allow for exceptions to elderly clients where health and safety would be at risk. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the heating system issue is determined to be beyond the scope of DOE WAP, weatherization agencies will defer the work and refer the client to other resource agencies who may be able to address the problem. Colorado’s deferral policy and protocols shall always be strictly adhered to when deferring weatherization work. If client is completely without heat and the weather warrants, the weatherization agencies shall make every attempt to provide client with temporary means of heat, such as safe space heaters. Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Minimal standards for remedy include, but are not limited to the following:

Ducts: Ducts must be assessed, cleaned and/or vacuumed to remove any objects that impede airflow.

Ductwork outside the thermal boundary must be re-connected, sealed, and if un-insulated, they must be insulated to at least an R-8.

Large duct leaks to unintentionally heated areas inside the thermal boundary must also be sealed.

Return air ducts within ten (10) feet of open combustion appliances, except gravity systems, must be sealed to eliminate the potential for back drafting.

Duct mastic, mesh tape, flashing and screws are approved materials for use on ductwork in the CEO Wx program.

Homes with ducts below the main living space, in basements, or in crawlspaces require dominate duct leakage test. Homes must have either a slightly positive or neutral pressure after weatherization.

Duct leakage assessment techniques and results must be documented in the client file. Use of the blower door and assessing air movement is allowed where the ducts are inside the thermal boundary.

Ducts that are outside the thermal boundary must have pre and post sealing leakage assessment with one of the following techniques:

 Pressure pan measurement.  Duct leakage measurement with a duct leakage assessment tool.  Duct leakage measurement using the subtraction technique.

Dryer ducts shall terminate outside of the building shell whenever feasible.

Duct material shall be metal and have a smooth interior finish (rigid duct). Flex ducting is allowed where physical constraints prohibit the use of rigid duct material.

Dryer ducts should not exceed 25’ in length.

A deduction of 5 feet shall be made for each 90 degree bend, and 2.5 feet for every 45 degree bend. No bend shall be made over 90 degrees whenever possible.

If the 25’ limit is not possible, the use of a power vent or lint trap is acceptable providing the lint trap is accessible to the client and instruction on cleaning the trap is provided to the client.

Duct must be supported every 8 feet or less by metal or plastic strapping and no penetrations through the vent pipe, i.e. screws, nails, etc. The male end of the duct at overlapped duct joints shall extend in the direction of airflow.

Joints must be sealed with silver metal tape.

Refer to CEO Wx Policy 822.

Combustion Appliances:

CEO-WX-820 is an all-inclusive policy that ensures the safety and efficiency of all combustion appliances.

The goal of all testing shall be to make sure heating systems are present, operable, and performing safely. Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Deferral should be exercised when existing code violations are present and correcting them would be beyond the scope of the DOE WAP, and/or when there are problems affecting the heat system/furnace that are beyond the scope of the DOE WAP, such as certain electrical problems. For additional deferral criteria, see deferral section above. Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral should be made when problems are identified that are beyond the scope of the DOE WAP, such as electrical or other code violations. Examples of referral agencies include, but are not limited to, local housing authority agencies, other CAA local agencies and landlords. Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis. Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Clients shall be given all pertinent information on the appropriate use and maintenance of heating units as well as information regarding the proper disposal of bulk fuel tanks when not removed, if applicable. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. Colorado will follow the manufacturer’s recommendations for proper disposal in addition to city/county regulations. Air Conditioning Installation (as specific to installation as a health and safety measure): Provide a narrative on implementation protocols of air conditioning repair, replacement, and installation including justification for allowability that includes climate justification with degree days and how to define at-risk occupants Air conditioning installation is not an allowable health and safety measure in Colorado. Colorado is not considered a cooling state and therefore, in most cases, does not consider air conditioning as an efficiency measure. By a waiver process, Colorado will allow for an exception to this for elderly at risk clients.

Heating System Installation (as specific to installation as a health and safety measure): Provide a narrative on implementation protocols of Heating System repair, replacement, and installation including justification for allowability that includes climate justification with degree days Colorado is primarily a heating climate with potentially severe cold weather conditions. Heat loss emergencies in Colorado can put clients at severe health and safety risk that could potentially be life- threatening. Thus, heating system installation as a health and safety measure is allowable. CEO-WX-820 is a policy that describes in detail the protocol for heating system replacement. Reasons include, but are not limited to cracked heat exchanges, un-repairable appliance, and a no heat situation.

Appliances and Water Heaters Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 x Replacement of water heaters is allowed on a case by case basis. Some reasons for replacement would be leaking tank or high CO emission that cannot be repaired. Colorado also allows testing and minor repair of cook stoves, but does not allow replacement. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the water heater or appliance issue is determined to be beyond the scope of DOE WAP, weatherization agencies will defer the work and refer the client to other resource agencies who may be able to address the problem. Colorado’s deferral policy and protocols shall always be strictly adhered to when deferring weatherization work. Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Domestic water pipes likely to freeze must be insulated. Electric water heaters outside the living space, including mobile home water heaters in exterior closets, must be insulated if the total existing tank insulation is less than R-11.

Gas water heaters outside the living space of the structure, including mobile home water heaters in exterior closets, must be insulated if the existing tank insulation is less than R-7.

Domestic hot water temperature must be measured. An auditor or technician may adjust the water temperature down to 125° F from a higher temperature with the client’s approval.

When installing a new water heater a pressure and temperature relief valve and safety discharge pipe must be included. The safety discharge pipe shall not terminate more than 6 inches above the floor or waste receptor.

Water heaters may be converted from electric to gas fired. If the water heater is replaced, heat trap check valves must be included. NEAT/MHEA must be used to evaluate the cost effectiveness of water heater conversions.

The rental property owner is required to contribute to the total cost of the water heater conversion.

Measure the water heater’s water temperature.

Talk to the client about the potential for scalding if the water temperature is above 130° F.

Show the client how to set the water temperature, if they want a lower temperature setting. They should set the temperature to that which feels most comfortable.

Water heaters outside of the living space must be wrapped with blanket insulation, unless:

The electric water heater is already insulated to R-11 or greater.

The gas water heater is already insulated to R-7 or greater.

The water heater label gives specific instructions not to insulate.

Don’t cover draft diverters, pressure relief valve, thermostats, high-limit switch, or access plates with the insulation blanket.

It is not necessary to insulate over the combustion chamber, below the water vessel.

When installing a new water heater you must include a pressure and temperature relief valve and a safety discharge pipe.

Hot water leaks must be repaired if found.

Landlords must be contacted to arrange for major plumbing repairs.

InsulateStandards the for first Deferral: 3 feet Describeof both hot when and deferral cold water should pipes. take place for the specific health and safety category. Deferral shall be exercised when existing code violations are beyond the scope of the DOE WAP, and when problems such as electrical are present and require repairs that go beyond the scope of the DOE WAP. For additional deferral criteria, see Deferral Section above. Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral should be made when problems are identified that are beyond the scope of the DOE WAP, such as electrical or other code violations. Examples of referral agencies include, but are not limited to, local housing authority agencies, other CAA local agencies and landlords. Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis. Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Clients shall be given all pertinent information on the appropriate use and maintenance of water heating units.

Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. Colorado will follow the manufacturer’s recommendations for proper disposal in addition to city/county regulations.

Asbestos - in siding, walls, ceilings, etc. Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 General asbestos removal is not approved as a health and safety x weatherization cost. Major asbestos problems should be referred to the Alternative Guidance appropriate state agency and/or EPA. However, where local WAP agencies work on heating and distribution systems, including related pipes, asbestos removal may be necessary. The temporary removal of siding is allowed to perform energy conservation measures. All precautions must be taken not to damage the siding. Asbestos siding should never be cut or drilled. Recommended, where possible, to insulate through home interior walls. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used.

Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols. Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Minimal standards for remedy include, but are not limited to the following:

Testing will be allowed, except for cases of vermiculite.

CEO-Wx 831 requires at least one agency person to hold an Asbestos Building Inspector certification. Blower door testing is not allowed (pressurization and depressurization) on homes with vermiculite attic insulation as to not disturb the product thereby bringing particles into the home.

It is difficult to tell whether a material contains asbestos simply by looking at it, unless it is labeled. If in doubt, treat the material as if it contains asbestos.

Inspect exterior wall surfaces and sub-surfaces for asbestos siding prior to drilling or cutting. Typically, asbestos appears as a whitish, fibrous material which may release fibers that range in texture from coarse to silky.

Do not dust, sweep, or vacuum debris that may contain asbestos, except with a HEPA vacuum.

Never saw, sand, scrape, or drill holes in asbestos materials.

Do not track material that could contain asbestos through the house.

All precautions must be taken not to damage the siding during removal. Asbestos siding should never be cut or drilled.

It is recommended that insulation be installed through interior wall surfaces if possible to completely avoid disturbing or removing the asbestos siding on the exterior of the home.

Follow EPA and OSHA regulations regarding the safe handling of asbestos to ensure worker and client safety. Follow State and Local codes pertaining to asbestos.

Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Deferral should be exercised when local and/or state code does not allow the removal of asbestos siding as part of general contracting work, or when the asbestos siding cannot be removed without disturbing the asbestos. Deferral and appropriate referral should also be exercised when the asbestos siding is already in such a damaged state that it is releasing asbestos fibers and insulation cannot be installed via interior wall surfaces. Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral shall be made to the Colorado Department of Public Health and Environment. There are also several testing and mitigation companies available in Colorado for referral services. Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis. CEO Wx 831 requires at least one agency person to hold an Asbestos Building Inspector certification.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. In every instance, clients shall be informed both verbally and in writing that suspected asbestos siding is present. Clients shall also be informed as to the precautions that will be taken. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. Per the Colorado Department of Public Health and Environment, a householder may dispose of nonfriable asbestos wastes at local landfills. Friable asbestos materials can easily release fibers when crushed. Nonfriable asbestos materials have a binder that holds the asbestos fibers within a solid matrix and will not allow asbestos fibers to release easily, unless mishandled, damaged, or badly worn. However, the householder must make prior arrangements with the landfill owner/operator before disposing of the waste. There are instances where the local landfill is not permitted to dispose of friable asbestos wastes and it may be necessary to hire a contractor to have this done at another disposal site. It is always necessary to contact the local landfill owner/operator for suggestions and guidance on the proper disposal of asbestos containing materials, both friable and non-friable. All WAP sub-grantees shall also follow the DEQ Hazardous Waste Division “Solid Waste Guideline #5: Identification of Friable and Nonfriable Asbestos” when providing clients (householders) with asbestos-related information. DOE guidance does not allow for the removal of asbestos, unless on small covered surfaces. This guidance must always be followed by sub-grantees.

Asbestos - in vermiculite Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 When vermiculite is present, blower door testing is not allowed x (pressurization and depressurization), and no weatherization work shall take Alternative Guidance place in the attic space. Removal shall not be allowed. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If determined to be beyond the scope of the DOE WAP, follow all appropriate Deferral and Referral policies and protocols. Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Minimal standards for remedy include, but are not limited to the following:

If a home contains vermiculite insulation, assume that this material is contaminated with asbestos and do not disturb it.

Asbestos Hazard Emergency Response Act of 1986 (AHERA) certified prescriptive sampling is allowed by a certified tester. However, it is recommended to assume that vermiculite insulation contains asbestos and proceed accordingly.

Do not open any walls to check for vermiculite. Only check for vermiculite in the attic, and if found, leave it undisturbed, when possible.

If it is absolutely necessary to go into the attic containing vermiculite insulation, limit the number of trips and the shorten the length of those trips in order to limit any potential exposure and to avoid disturbing the product as any disturbance could potentially release asbestos fibers into the air.

Wear protective equipment when entering an attic area that may contain vermiculite insulation.

Do not track vermiculite insulation or associated dust into the living spaces of the home.

Follow EPA and OSHA regulations regarding the safe handling of asbestos to ensure worker and client safety. Follow State and Local codes pertaining to asbestos.

Removal shall not be allowed. However, vermiculite may be removed at the clients expense by an appropriately trained asbestos control professional with prior approval from the State Program Manager. Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Deferral may be exercised if it is determined that the vermiculite insulation material and/or associated dust is seeping into the home living spaces to an extent that cannot be resolved with typical weatherization sealing measures. Deferral of attic portion of the work may be exercised if it is determined that the attic already contains vermiculite insulation and it would be best to leave it undisturbed. Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral shall be made to the Colorado Department of Health and Environment as well as several other private agencies that specialize in containment and mitigation. Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and will continue to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis. Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. In every instance, clients shall be informed both verbally and in writing that suspected asbestos is present. Clients shall also be informed as to the precautions that will be taken. Client written materials shall include information about the potential health risks associated with asbestos. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. Removal and/or disposal are not recommended for vermiculite insulation. Colorado will not allow weatherization agencies to remove vermiculite. DOE guidance does not allow for the removal of asbestos, unless on small covered surfaces. This guidance must always be followed.

Asbestos - on pipes, furnaces, other small covered surfaces Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Assume asbestos is present in covering materials. Encapsulation is allowed by x an AHERA asbestos control professional and should be conducted prior to any Alternative Guidance blower door testing. Removal may also be allowed by an AHERA asbestos control professional on a case by case basis with prior approval from the State Program manager. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If determined to be beyond the scope of the DOE WAP, follow all appropriate Deferral and Referral policies and protocols. Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Minimal standards for remedy include, but are not limited to the following:

It is difficult to tell whether a material contains asbestos simply by looking at it, unless it is labeled. If in doubt, treat the material as if it contains asbestos.

Inspect pipe and other coverings for asbestos. Typically, asbestos appears as a whitish, fibrous material which may release fibers that range in texture from coarse to silky.

Check state and local codes prior to removal and replacement of asbestos containing materials. It may only be allowable if local and state codes allow removal and replacement of asbestos containing materials.

Keep activities to a minimum in any areas having damaged material that may contain asbestos. Document and inform the client regarding the damaged material and suspected asbestos. Do not further disturb the material. If necessary, weatherization work to that area may have to be deferred.

Do not dust, sweep, or vacuum debris that may contain asbestos, except with a HEPA vacuum.

Never saw, sand, scrape, or drill holes in asbestos materials.

Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Deferral should be exercised when asbestos is present and in such a damaged state as to require handling by a trained asbestos abatement professional. For additional deferral criteria, see deferral section above.

Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral shall be made to the Colorado Department of Public Health and Environment as well as several local companies that specialize in testing and mitigation. Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. In every instance, clients shall be informed both verbally and in writing that suspected asbestos is present. Clients shall also be informed as to the precautions that will be taken. Client written materials shall include information about the potential health risks associated with asbestos. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. Colorado will not allow disposal. DOE guidance does not allow for the removal of asbestos, unless on small covered surfaces. This guidance must always be followed.

Biologicals and Unsanitary Conditions - odors, mustiness, bacteria, viruses, raw sewage, rotting wood, etc. Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Remediation of conditions that may lead to or promote biological concerns x and unsanitary conditions is allowed. However, addressing bacteria and Alternative Guidance viruses is not an allowable cost. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Minimal standards for remedy include, but are not limited to the following:

This health and safety category shall require sensory inspection for the purpose of detection.

Types of health and safety hazards that may be included under this category include, but are not limited to: · Odors; · Mustiness; · Bacteria; · Viruses; · Raw sewage; · Rotting wood; · Garbage; · Etc.

Addressing bacteria and viruses shall not be allowed. Deferral may be necessary in cases where a known agent is present in the home that may create a serious risk to occupants or weatherization crews.

The use of personal protective equipment shall be strictly enforced. Respirators, protective eyewear, and protective clothing will be worn when there is suspicion or knowledge that biological agents may be present in order to eliminate or minimize crew exposure.

In the past, remediation of conditions listed under this health and safety category was not allowed. It is allowable under WPN 11-6, except for the removal of known bacteria and viruses, and Colorado will train crews regarding specific remediation activities that may be allowable. Colorado will assess the cost-effectiveness and necessity of remediation of these conditions on a case by case basis with prior approval from the Governor’s Energy Office.

See Mold and Moisture guidance below for additional standards for remedy.

Refer to GEO Wx Policy 828.

Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Deferral may be necessary in cases where a known agent is present in the home that may create a serious risk to occupants or weatherization crews. For additional deferral criteria, see deferral section above. Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral should be made when problems are identified that are beyond the scope of the DOE WAP, such as the presence of raw sewage or other known agents. Examples of referral agencies include, but are not limited to, local housing authority agencies, other CAA local agencies and landlords.

Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Clients shall be given all pertinent information on the dangers of biological and unsanitary conditions, if applicable.

Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. All Federal, State, and local regulations shall be followed regarding the disposal procedures as they pertain to this health and safety category.

Building Structure and Roofing using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Building rehabilitation is beyond the scope of the WAP. Homes with x conditions that require more than incidental repair should be deferred. More Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may not be used for building rehabilitation work that goes beyond the scope of the WAP and requires more than incidental repairs. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. Structurally compromised areas requiring more than incidental repairs shall be deemed beyond the scope of the WAP and shall be deferred. Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Minimal standards for remedy include, but are not limited to the following:

Visual inspection.

Ensure that access to areas necessary for weatherization is safe for entry and performance of assessment, work, and inspection.

Notify client of structurally compromised areas; defer weatherization work to those areas.

Basic guidance for WAP crews: While conducting the initial audit, the building structure shall be inspected for structural integrity. Minor repairs to protect the DOE materials installed may be performed to protect the energy saving investment. However, building rehabilitation is beyond the scope of the WAP. Dwellings whose structural integrity is in question should be referred to HUD or other appropriate local and state agencies. Weatherization services may need to be delayed or deferred until the dwelling can be made safe for crews and occupants. Incidental (minor) repairs necessary to effectively perform or preserve weatherization materials/measures are allowed. Examples of these include sealing minor roof leaks to preserve new attic insulation and repairing water-damaged flooring as part of replacing a water heater. Incidental structural repairs shall not include cosmetic applications, such as replacing a floor covering such as a carpet or linoleum. Only the structural part shall be replaced/repaired. Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Homes that require more than incidental (minor) repair should be deferred. Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Dwellings whose structural integrity is in question should be referred to HUD or other appropriate local and state agencies, such as local building departments. Examples of some other referral agencies include, but are not limited to, local housing authority agencies, other CAA local agencies and landlords. Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Clients shall be notified verbally and in writing regarding any structurally compromised areas. Appropriate referral resources shall also be provided to the client. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. See Mold and Moisture guidance below. All Federal, state and local regulations regarding disposal of construction waste shall be followed.

Code Compliance Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Correction of pre-existing code compliance issues is not an allowable cost x other than where weatherization measures are being conducted. State and Alternative Guidance local (or jurisdiction having authority) codes must be followed while installing weatherization measures. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. Doe funds may be used when weatherization measures are being conducted. They may not be used simply to correct pre-existing code compliance issues. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Visual inspection as well as local code enforcement inspections shall be necessary to comply with WPN 11-6 guidance.

Follow all State and Local codes when installing weatherization measures.

Acquire all required permits and licenses pertinent to installing weatherization measures. These vary by jurisdiction and it is the responsibility of each sub-grantee agency to know what the codes are in each of the areas they work in, as well as what permits and licenses are required in each of the areas they work in.

Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Condemned properties and properties where “red-tagged” health and safety conditions exist that cannot be corrected under this WPN 11-6 guidance should be deferred. Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Where code compliance issues are identified and cannot be corrected under WPN 11-6 guidance, appropriate referrals should be made. Examples of some potential referral agencies include, but are not limited to, local housing authority agencies, local building departments, other local agencies, and landlords. Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety training to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Inform client of observed code compliance issues. Make appropriate referrals as necessary. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. All Federal, state and local regulations regarding disposal of construction waste shall be followed.

Combustion Gases Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Proper venting to the outside for combustion appliances, including gas dryers, x is required. Correction of venting is allowed when testing indicates a Alternative Guidance problem. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used in accordance with guidance in WPN 11-6. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Combustion safety testing is required when combustion appliances are present. Combustion appliances include any appliance using combustible fuels, including gas water heaters, wood stoves, gas or oil fueled furnace/heat system (including free standing kerosene, natural gas, or propane space heaters), and gas clothes dryers. These requirements apply to all active combustion heating systems and appliances, whether they are primary or secondary systems. Combustion appliances must also be properly vented to the outside of the home. Diagnostic equipment should be calibrated per manufacturer’s instructions.

The combustion appliance safety inspection includes all of the following: carbon monoxide testing, draft measurement, spillage evaluation, and worst case depressurization of the combustion appliance zone (CAZ). Combustion safety test results must be acted upon appropriately according to the combustion safety tables. As applicable, every combustion appliance will be checked for a safe flue pipe, chimney or vent, adequate combustion air, and gas leakage. It is strongly recommended that all unvented gas and liquid-fueled space heaters be removed and replaced with vented, code-compliant heat systems as a pre-requisite to weatherization. This practice will reduce the risk of fire that could potentially destroy the weatherization materials installed.

A complete mechanical systems audit is required to be completed on every home. All relevant information must be recorded on the Heating System Worksheet. The procedure includes collecting general information; collecting and recording mechanical systems information; visual and diagnostic inspection of the venting and distribution system; and, combustion analysis and diagnostic testing of gas/propane fired equipment. A post-installation safety inspection is also required.

Inspect venting of combustion appliances and confirm adequate clearances.

Test naturally drafting appliances for draft and spillage under worst case conditions before and after air tightening.

CO detectors should be installed in all homes when fuel-fired (combustion) appliances exist. This includes: cook stoves, furnaces, water heaters, wood and coal burning stoves.

Gas Leaks: Detect gas leaks with a combustible gas detector and/or soap. Repair leaks.

Building Tightness Limits: Colorado requires weatherization agencies to comply with ASHRAE 62.2.

Smoke Detectors: Smoke detectors should be considered and added whenever possible. There should be at least one operational smoke detector per floor. Only very old and inoperable existing smoke alarms shall be replaced using DOE funds. The crew must educate the client about the operation and safety purpose of the smoke detector.

Combustion appliances must be installed by licensed contractors or under the guidance of a licensed contractor if allowed by local or state codes and regulations. Refer to GEO Wx policy 820. Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Deferral should be exercised when existing code violations are present and correcting them would be beyond the scope of the DOE WAP, and/or when there are problems affecting the combustion appliance that are beyond the scope of the DOE WAP, such as certain electrical problems. For additional deferral criteria, see deferral section above.

Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral should be made when problems are identified that are beyond the scope of the DOE WAP, such as electrical or other code violations. Examples of referral agencies include, but are not limited to, local housing authority agencies, other CAA local agencies and landlords. Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Clients shall be provided with combustion safety and hazards information, including the importance of using exhaust ventilation when cooking and the importance of keeping burners clean to limit the production of CO. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. All weatherization agencies and subcontractors must follow local and state regulations when disposing of old heating system components and /or fuels.

Combustion Gas Problem Discovery: Provide a narrative describing the process to be followed when combustion gas testing reveals health and safety concerns. GEO-WX-820 is a policy that describes in great detail the protocol for testing combustion appliances, and remedying unsafe conditions.

Drainage - gutters, down spouts, extensions, flashing, sump pumps, landscape, etc. Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Major drainage issues are beyond the scope of the WAP. Homes with x conditions that may create a serious health concern that requires more than Alternative Guidance incidental repairs should be deferred. See Mold and Moisture guidance below. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. Except for allowable incidental repairs, DOE funds may not be used to address major drainage issues which are beyond the scope of the DOE WAP. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Major drainage issues are beyond the scope of the WAP. Homes with conditions that may create a serious health concern that require more than incidental repair shall be deferred. Visual inspection and observation shall be the primary mechanism for detecting drainage issues. Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Deferral should be exercised when major drainage issues are present and could present a serious health risk and correcting them would be beyond the scope of the DOE WAP. For additional deferral criteria, see deferral section above.

Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral should be made when problems are identified that are beyond the scope of the DOE WAP, such as electrical or other code violations, and serious drainage issues. Examples of referral agencies include, but are not limited to, local housing authority agencies, other CAA local agencies and landlords.

Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Training on how to recognize drainage issues will be provided at statewide health and safety trainings. Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Client education shall include, but not be limited to, the importance of cleaning and maintaining drainage systems. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes and regulations shall always be adhered to for proper disposal procedures.

Electrical, other than Knob-and-Tube Wiring Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Minor electrical repairs are allowed where health or safety of the occupant(s) x may be at risk. Upgrades and repairs are allowed when necessary to perform Alternative Guidance specific weatherization measures. These costs are included in the measure cost or as incidental repair costs. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used.

Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Per Colorado field standards, all of the electrical circuits in any dwelling must be analyzed and tested and the findings must be documented on the audit form.

In most instances, Colorado codes require licensed electricians to perform most electrical repairs. When electrical repairs within the scope of the DOE WAP are required, the typical standard of remedy shall be to sub-contract the repair work to a licensed electrician. All appropriate procurement procedures shall Standardsbe followed for when Deferral: sub-contracting. Describe when deferral should take place for the specific health and safety category. Deferral should be exercised when existing code violations are present and correcting them would be beyond the scope of the DOE WAP, and/or when there are problems affecting the heat system/furnace that are beyond the scope of the DOE WAP, such as certain electrical problems which fall outside of the scope of the DOE WAP because they require more than incidental minor repair. For additional deferral criteria, see deferral section above. If electrical wiring and circuitry is found to be in such a condition as to be a serious safety risk, work should be deferred until the electrical safety issue has been satisfactorily corrected. Client and/or building owner must be informed of the safety risk.

Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral should be made when problems are identified that go beyond the scope of the DOE WAP, such as electrical or other code violations. Examples of referral agencies include, but are not limited to, local housing authority agencies, other CAA local agencies and landlords.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Provide information on overloading circuits and electrical safety and risks. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes and regulations shall always be adhered to for proper disposal procedures and protocols.

Electrical, Knob-and-Tube Wiring Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Minor upgrades and repairs necessary for weatherization measures and x where the health or safety of the occupant(s) is at risk may be allowed. Alternative Guidance Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds maybe used only for minor repairs and upgrades as stipulated above.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Crews shall inspect for the presence and condition of knob-and-tube wiring. Crews will also check for alterations that may create an electrical hazard.

In most instances, Colorado codes require licensed electricians to perform most electrical repairs. When electrical repairs within the scope of the DOE WAP are required, the typical standard of remedy shall be to sub-contract the repair work to a licensed electrician. All appropriate procurement procedures shall be followed when sub-contracting.

It is critical to conduct thorough inspections and testing to determine if knob-and-tube wiring is active.

If knob-and-tube wiring is found to be active, a free air space must be kept around the wiring.

Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Deferral should be exercised when existing code violations are present and correcting them would be beyond the scope of the DOE WAP, and/or when there are problems affecting the heat system/furnace that are beyond the scope of the DOE WAP, such as certain electrical problems. For additional deferral criteria, see deferral section above. In the specific instance where active knob-and-tube wiring is present and it presents a safety risk, weatherization work may have to be deferred until the electrical safety issue has been adequately addressed.

Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral should be made when problems are identified that are beyond the scope of the DOE WAP, such as electrical or other code violations. Examples of referral agencies include, but are not limited to, local housing authority agencies, other local agencies and landlords.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Provide information to client on over-current protection, overloading circuits, and basic electrical safety/risks. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes shall be adhered to for proper disposal procedures and protocols.

Fire Hazards Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Correction of fire hazards is allowed when necessary to safely perform x weatherization. Alternative Guidance Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. At all times, crews are to look for potential fire hazards.

Crews and auditors shall check for potential fire hazards in the home during the audit and while performing the weatherization work.

Fire hazards must be remedied. If the remedy falls within the scope of the DOE WAP, the crew shall remedy the situation to eliminate the fire hazard they identified.

If the remedy required to remove the fire hazard goes beyond the scope of the DOE WAP, weatherization work may have to be deferred until the fire hazard has been eliminated. Proper referral and deferral protocols shall be followed.

Clients must be notified of any identified fire hazards. Standards for Deferral: Describe when deferral should take place for the specific health and safety category. When the crew or a sub-contractor working within the scope of the DOE WAP are unable to rectify the fire hazard, deferral protocols should be exercised. Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral should be made when problems are identified that are beyond the scope of the DOE WAP, such as electrical or other code violations. Examples of referral agencies include, but are not limited to, local housing authority agencies, other CAA local agencies and landlords.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Clients, occupants, and building owners/landlords must always be notified of potential fire hazards. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes shall always be adhered to for proper disposal procedures and protocols.

Formaldehyde, Volatile Organic Compounds (VOCs), and other Air Pollutants Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Removal of pollutants is allowed and is required if they pose a risk to workers. x If pollutants pose a risk to workers and removal cannot be performed or is not Alternative Guidance allowed by the client, the unit must be deferred. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used.

Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the identified pollutants pose a risk to workers and removal cannot be performed because it goes beyond the scope of the DOE WAP, or if the client will not allow the removal of the pollutants, the unit will be deferred. Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Sensory inspection shall be the primary detection method.

All reasonable steps shall be taken to limit worker exposure to VOCs. When using products known to emit VOCs, increase ventilation. Meet or exceed any label precautions. Identify, and if possible, remove the source. If not possible to remove, reduce exposure by using a sealant on all exposed surfaces of paneling and other furnishings. Educate clients regarding the use of integrated pest management techniques to reduce the need for continued use of pesticides. Properly dispose of partially full containers of old or unneeded chemicals. Because gases can leak even from closed containers, this single step could help lower concentrations of organic chemicals in the home and/or workplace. Do not simply toss these unwanted products in the garbage can. State and local codes and regulations Standardsregarding disposal for Deferral: of toxic Describe household when wastes deferral must should be followed. take place for the specific health and safety category. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols. And, if the pollutant cannot be removed due to client unwilling to allow its removal and exposure cannot be safely and adequately minimized, weatherization work may have to be deferred to ensure the safety of the crew. Clients must always be informed of potential pollutant hazards.

Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral should be made when problems are identified that are beyond the scope of the DOE WAP, such as electrical or other code violations, or the presence of hazards that may pose a health risk to workers and occupants. Examples of referral agencies include, but are not limited to, local housing authority agencies, other CAA local agencies and landlords.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Always inform the client/occupant/building owner of observed condition and associated health risks. Provide written materials on safety and proper disposal of household pollutants. Such material is often located on the product label. There are additional written materials at the EPA website listed above. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes and regulations must always be adhered to when disposing of toxic household wastes.

Injury Prevention of Occupants and Weatherization Workers – Measures such as repairing stairs and replacing handrails. Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Workers must take all reasonable precautions against performing work on x homes that will subject workers or occupants to health and safety risks. Alternative Guidance Minor repairs and installation may be conducted only when necessary to effectively weatherize the home; otherwise, these measures are not allowed. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used with the above stipulations.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. If crews encounter a situation where a stair case is deemed unsafe, for example, and the stair case is necessary to reach the area where the crews need to perform the weatherization work, and repairing the staircase requires only minor repair work and installation measures, crews shall perform the minor repair work so that they may safely perform the weatherization work to the home.

If the repair work required is deemed to be beyond the scope of the DOE WAP (major repair is required such as rebuilding an entire staircase), the weatherization work to that area of the home shall be deferred until the home owner has satisfactorily installed the required repair(s). Standards for Deferral: Describe when deferral should take place for the specific health and safety category. See above. Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral should be made when problems are identified that are beyond the scope of the DOE WAP, such as electrical or other code violations, or safety issues requiring repairs that go beyond the scope of the DOE WAP. Examples of referral agencies include, but are not limited to, local housing authority agencies, other CAA local agencies and landlords.

Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Crews will complete all required OSHA training and will also receive training on the awareness of potential hazards that fall within this category. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as- needed basis.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Inform client/building owner of observed hazards and their associated risks. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes and regulations shall always be followed regarding the proper disposal procedures and protocols.

Lead Based Paint Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Follow EPA’s Lead; Renovation, Repair and Painting Program (RRP) rule which x was implemented April 21, 2010. In addition to RRP, Weatherization requires Alternative Guidance all weatherization crews working in pre-1978 housing to be trained in Lead Safe Weatherization (LSW). Deferral is required when the extent and condition of lead-based paint in the house would potentially create further health and safety hazards. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Colorado is currently in compliance with the DOE RRP rule with most crew members having achieved Certified Renovator status. Certifications under this rule shall be kept current.

Colorado recommends assuming that lead paint may be present in any house built prior to 1978 and to follow the proper DOE LSW protocols, OSHA regulations and EPA regulations in all pre-1978 homes. Unless they were remodeled and paint and varnish added to mobile homes prior to 1978, mobile homes are exempt because lead was not used in the original manufacture of mobile homes. However, crews must be alert to any remodels that could have contained lead-based paint or varnish when addressing mobile homes. Don’t just assume that all mobile homes are categorically exempt. Any home built before 1978, or any mobile home remodeled using paints and varnishes prior to 1978, may contain lead- based paint. These paints should considered “guilty until proven innocent” by way of testing.

Testing is allowed per RRP requirements. Job site set up and cleaning verification is required by a Certified Renovator.

As a minimum guideline, the following weatherization activities require lead-safe practices. (Note that this is not a complete list of weatherization activities that may create lead hazards, so it is important to train all workers to follow LSW measures whenever they disturb or could potentially disturb painted surfaces on buildings built prior to 1978.) · Drilling holes in interior walls · Drilling holes in and removing siding from exterior walls · Cutting attic access into ceilings · Removing caulk or window putty (interior) · Removing caulk or window putty (exterior) · Removing weatherstripping · Modifying doors · Planing doors in place · Installing door shoes · Replacing door jambs and thresholds · Replacing windows · Replacing thermostats · Replacing furnace filters · Replacing furnaces · Replacing HEPA filters and cleaning HEPA vacuums at a weatherization facility · Replacing HEPA filters and cleaning HEPA vacuums at the work site

Crews must follow all client notification requirements: · Distribution of the EPA pamphlet, dated April 2010 and titled “Lead-Safe Certified Guide to Renovate Right”. · The client file must include signed documentation that the client received the Renovate Right pamphlet. Refer to GEO Wx Policy 814. Standards for Deferral: Describe when deferral should take place for the specific health and safety category. When it is determined that the level of lead present in the home is so high that it presents a hazard to workers, the weatherization work should be deferred until a licensed lead abatement professional has eliminated the health hazard. Clients will always be notified regarding lead-based paint and its potential health hazards. If the lead dust is so wide spread in the home that it would be impossible to contain, the weatherization work should be deferred until a lead abatement professional has removed the health hazard. Deferral is required when the extent and condition of lead-based paint in the house would potentially create further health and safety hazards. Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral should be made when problems are identified that are beyond the scope of the DOE WAP, such as electrical or other code violations. Examples of referral agencies include, but are not limited to, local housing authority agencies, other local agencies and landlords. In severe lead contamination situations, it may be necessary to make a referral to a lead paint risk assessment and abatement professional.

Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis. Colorado is in compliance with the RRP stipulation that crews working on pre-1978 homes be accompanied by an EPA certified renovator.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Colorado WAP crews will follow all RRP requirements for client education. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. Colorado WAP crews will follow all EPA RRP requirements for disposal as well as state and local code requirements. Lead Based Paint Compliance: Provide a narrative describing how RRP and LSW implementation will be conducted and how the grantee will verify compliance. The explanation should clearly show an understanding that LSW and RRP are separate requirements and both are required to be met. All Colorado WAP sub-grantees shall be monitored for compliance with LSW Minimum Standards and EPA RRP requirements. When a sub-grantee is found to be out of compliance, the sub-grantee shall be given a corrective action plan that will require training crews to ensure that all requirements are being met and to ensure compliance.

Mold and Moisture Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Limited water damage repairs can be addressed by weatherization workers x and correction of moisture and mold creating conditions are allowed when Alternative Guidance necessary in order to weatherize the home and to ensure the long term stability and durability of the measures. Where severe mold and moisture issues cannot be addressed, deferral is required. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used as stipulated above. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Visual assessment is required and diagnostics such as moisture meters are recommended pre and prior to final inspection. However, mold testing is not an allowable cost.

Per Colorado Technical Standards, all units must be inspected for problems associated with excess moisture. Identification of potential moisture problems shall be documented n the client file. If possible, and within the scope of the DOE WAP, repair minor moisture problems that will diminish the effectiveness of weatherization measures.

Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Where severe mold and moisture issues cannot be addressed, deferral is required. Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral should be made when problems are identified that are beyond the scope of the DOE WAP, such as electrical or other code violations or severe health and safety issues such as severe mold which cannot be adequately addressed within the scope of the DOE WAP. Examples of referral agencies include, but are not limited to, local housing authority agencies, other CAA local agencies and landlords.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Provide client notification and disclaimer on mold and moisture awareness. Completed mold form in client files as verification of client education. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes and regulations must always be followed to ensure proper disposal procedures and protocols. Mold Protocols: Provide a narrative describing protocols for addressing mold found in the client’s homes. The protocol should include a method of identifying the presence of mold during the initial audit or assessment, notification to the client, and crew training on how to alleviate mold and moisture conditions in homes. The WAP is not a mold remediation program. DOE funds may not be used to test for mold. The primary method of detecting mold and moisture issues shall be visual assessment and diagnostics such as moisture meters, infrared imaging, etc. Assessment shall include a general examination of the building, to include: · Examine structure, maintenance activities, occupancy patterns · Visually look for mold and water staining · Look for evidence of standing water · Look for evidence of condensation · Check basement or crawl space and attic for proper venting and exhaust Outdoors: · Soil grade or drainage toward foundation · Standing water adjacent to foundation · Wall and roof damage allowing water intrusion · Missing or blocked rain gutters · No downspout extensions · Firewood stacked adjacent to house · Excessive shrubbery around foundation HVAC System: · Air intakes: debris (organic) vs. clean air · Filters: dirty, damp, poor type · Heat exchangers: dirty & damp coils, condensate pans, drainage, stagnant water · Ducts: contamination, moisture Occupied Space: · Plumbing leaks · Water stains on walls, ceilings and around windows · Musty odor · Surface Condensation (especially during mild weather) · Mold on carpeting · Humidifiers · Window air conditioners · Lack of bathroom, kitchen exhaust · Clothes dryer not vented to outside · Firewood stored indoors · Wet clothes drying indoors

Colorado crews are required to notify and inform clients using the Mold Form. This form is used regardless of the presence or absence of noticeable mold and is required to be documented in each client file.

Refer to GEO Wx Policy 809

Occupant Preexisting or Potential Health Conditions Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 When a person’s health may be at risk and/or the work activities could x constitute a health or safety hazard, the occupant at risk will be required to Alternative Guidance take appropriate action based on severity of risk. Temporary relocation or at- risk occupants may be allowed on a case-by-case basis. Failure or the inability to take appropriate actions must result in deferral. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used as stipulated above. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Occupant pre-existing or potential health conditions shall be documented in the client file. If warranted, at-risk occupants may be temporarily relocated while the work is being completed. Crews will advise client as to any actions required for any at-risk occupants before work shall begin. Any failure or inability to take the appropriate actions shall result in deferral of the weatherization work. Proper referral and deferral protocols shall be followed and documented. Standards for Deferral: Describe when deferral should take place for the specific health and safety category. The failure or inability of at-risk occupants to take appropriate actions must result in deferral.

Referral should be made when problems are identified that are beyond the scope of the DOE WAP, such as electrical or other code violations. Examples of referral agencies include, but are not limited to, local housing authority agencies, other local agencies and landlords.

Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis. This training will address how to assess occupant pre-existing conditions and how to determine necessary actions.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Provide client information of any known risks. Provide worker contact information so client can inform of any issues. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes and regulations shall be followed to ensure proper disposal procedures and protocols.

Occupational Safety and Health Administration (OSHA) and Crew Safety Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Workers must follow OSHA standards and Material Safety Data Sheets (MSDS) x and take precautions to ensure the health and safety of themselves and other Alternative Guidance workers. MSDS must be posted wherever workers may be exposed to hazardous materials. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. OSHA 10-hour training for all crew level WAP employees OSHA 30-hour training for all crew leaders and above. All OSHA training shall be updated as required and kept current All local WAP sub-grantee crews conduct regular health and safety training Consistent posting of MSDS wherever crews may be exposed to hazardous materials Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Weatherization work may be deferred if doing the work would put crews at undue health and safety risk. Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral should be made when problems are identified that are beyond the scope of the DOE WAP, such as electrical or other code violations, or conditions that pose a health or safety risk to crews and/or clients. Examples of referral agencies include, but are not limited to, local housing authority agencies, other CAA local agencies and landlords.

Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis. All required OSHA training; monthly health and safety trainings at local level.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. N/A Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. Follow MSDS guidelines and all state and local codes. OSHA and MSDS Compliance: Provide a narrative describing procedures for implementation of OSHA and MSDS requirements related to crew and worker safety, how the 10 and 30 hour training requirements will be met, and what the process is for determining if crews are utilizing good safe work practices according to all requirements (EPA, OSHA, etc.). OSHA 10-hour training for all crew level WAP employees OSHA 30-hour training for all crew leaders and above All OSHA training shall be updated as required and kept current All local WAP sub-grantee crews conduct regular health and safety training Consistent posting of MSDS wherever crews may be exposed to hazardous materials

Currently, local WAP agencies conduct crew level monthly health and safety trainings. This practice will continue as a best practice. The process for determining whether crews are utilizing good safe work practices relies on visual assessment when monitoring crews on the job site. Lack of injury and incident reports is also a valuable indicator that crews are following safe work practices. Ask to see MSDS when Pests Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Pest removal is allowed only where infestation would prevent weatherization. x Infestation of pests may be cause for deferral where it cannot be reasonably Alternative Guidance removed or poses health and safety concern for workers. Screening of windows and points of access is allowed to prevent intrusion. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used as stipulated above. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Initial assessment of presence and degree of infestation and risk to workers.

Determine whether the pest infestation would prevent or hamper the weatherization work. If yes, and removal is a viable and cost-effective option, take the necessary steps to remove the pest infestation problem so that the weatherization work can proceed. If yes, and removal is not a viable and cost- effective option or significant health and safety risks exist, defer the weatherization work and provide client with appropriate referral information. If no, proceed as usual.

Screening of windows and points of access is allowable to prevent intrusion and must be assessed on a case-by-case basis.

Inform client of observed pest condition and associated risks. Document in client file.

Refer to GEO Wx policy 828 Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Infestation of pests may be cause for deferral where it cannot be reasonably removed or poses health and safety risks for workers. Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral should be made when problems are identified that are beyond the scope of the DOE WAP, such as electrical or other code violations. Examples of referral agencies include, but are not limited to, local housing authority agencies, other CAA local agencies and landlords.

Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis. Training will address how to assess presence and degree of infestation, associated risks, and need for deferral.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Inform client of observed condition and associated risks. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes and regulations shall be followed to ensure proper disposal procedure and protocols.

Radon Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Whenever site conditions permit, exposed dirt must be covered with a vapor x barrier except for mobile homes. In homes where radon may be present, Alternative Guidance precautions should be taken to reduce the likeliness of making radon issues worse. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Colorado is a high risk state for radon. Testing for Radon is not allowed by Colorado weatherization, except by waiver. Agencies are required to cover all exposed dirt in subspace areas with 6 mil plastic, whenever feasible. Agencies are required to air seal where possible and as much as feasible to prevent the infiltration of possible Radon into the living space from the subspace. Agencies are required to provide client education on Radon and supply the EPA Citizen’s Guide To Radon pamphlet to the client. Refer to GEO Wx policy 830. Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Deferral should be exercised when existing code violations are present and correcting them would be beyond the scope of the DOE WAP, and/or when there are problems affecting the heat system/furnace that are beyond the scope of the DOE WAP, such as certain electrical problems. For additional deferral criteria, see deferral section above.

Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Radon publications in print can be downloaded, most are in HTML and as PDF files. Go to www.epa.gov/radon/pubs Several companies are available for Radon testing and mitigation as well. Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis. Training will be provided that includes defining what radon is, how it occurs, and factors that may make radon worse. Training will also go over weatherization measures that may be helpful.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Provide client with EPA consumer’s guide to radon, at minimum. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes and regulations shall be followed to ensure proper disposal procedures and protocols.

Refrigerant Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Reclaim refrigerant per Clean Air Act of 1990, section 608, as amended by 40 x CFR 82, 5/14/93. Alternative Guidance Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Follow all EPA testing protocols.

Colorado WAP sub-grantees shall ensure that sub-contractors who would be charged with refrigerant reclamation (e.g. removal of old refrigerators or air conditioning units) follow all EPA testing protocols and are EPA-approved section 608 type I certified or universal certified. Colorado is mostly a cold weather state and in most cases, does not replace air conditioning systems, so sub-grantees do not typically have to deal with refrigerants except in refrigerator replacement.

StandardsClients should for Deferral:not disturb Describe refrigerant. when deferral should take place for the specific health and safety category. N/A Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. www.epa.gov Clean Air Act of 1990, section 608, as amended by 40 CFR 82. Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Clients should not disturb refrigerant. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. Follow all EPA, state and local regulations. Clean Air Act of 1990 section 608.

Smoke, Carbon Monoxide Detectors, and Fire Extinguishers Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Installation of smoke/CO detectors is allowed where detectors are not x present or are inoperable. Replacement of operable smoke/CO detectors is Alternative Guidance not an allowable cost. Providing fire extinguishers is allowed only when solid fuel (such as wood) is present. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used as stipulated above. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Check any existing smoke/CO detectors for functional/accurate operation.

Install smoke/CO detectors when accurately operating units do not already exist.

StandardsMust follow for all Deferral: local codes Describe when installing when deferral smoke/CO should detectors. take place for the specific health and safety category. Deferral should be exercised when existing code violations are present and correcting them would be beyond the scope of the DOE WAP, and/or when there are problems affecting the heat system/furnace that are beyond the scope of the DOE WAP, such as certain electrical problems. For additional deferral criteria, see deferral section above.

Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral should be made when problems are identified that are beyond the scope of the DOE WAP, such as electrical or other code violations. Examples of referral agencies include, but are not limited to, local housing authority agencies, other local agencies and landlords.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Provide client with verbal and written information on use of smoke/CO detectors and fire extinguishers where allowed. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes and regulations shall be followed to ensure proper disposal procedures and protocols. Smoke/CO Detector Installation: Provide a narrative describing smoke/CO Detector installation parameters and procedures. Check any existing smoke/CO detectors for functional/accurate operation.

Install smoke/CO detectors when accurately operating units do not already exist.

Must follow all local codes when installing smoke/CO detectors.

Provide client with verbal and written information on use of smoke/CO detectors and fire extinguishers where allowed.

Smoke detectors shall be added whenever possible per the stipulations listed above. There should be at least one smoke detector per floor. Crews are required to educate clients on how to properly operate the detector(s) per the manufacturer instructions.

CO detectors must be installed in all homes when fuel-fired equipment or an attached garage exists (if functional CO detectors do not already exist). This includes: cook stoves, furnaces, water heaters, wood and coal burning stoves. Crew members must demonstrate to the client how the CO detectors work and what actions to take if the CO detector alarm sounds. The CO detector must be installed per manufacturers recommendation and be compliant with local codes.

Solid Fuel Heating (Wood Stoves, etc.) Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Maintenance, repair, and replacement of primary indoor heating units is x allowed where occupant health and safety is a concern. Maintenance and Alternative Guidance repair of secondary heating units is allowed. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used as stipulated above. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Requires inspection of chimney and flue and combustion appliance zone (CAZ) depressurization.

Colorado WAP crews shall in most instances sub-contract such repair and replacement work to a qualified solid fuel heating system vendor. Crews may conduct minor maintenance activities where warranted as allowed.

All state and local codes must be followed.

Provide client with safety information, including how to recognize depressurization. Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Deferral should be exercised when existing code violations are present and correcting them would be beyond the scope of the DOE WAP, and/or when there are problems affecting the heat system/furnace that are beyond the scope of the DOE WAP, such as certain electrical problems. For additional deferral criteria, see deferral section above.

Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral should be made when problems are identified that are beyond the scope of the DOE WAP, such as electrical or other code violations. Examples of referral agencies include, but are not limited to, local housing authority agencies, other CAA local agencies and landlords.

Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis. Ongoing on the job training on how to perform CAZ depressurization test and proper inspection protocols.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Provide safety information including how to recognize depressurization. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes and regulations shall be followed to ensure proper disposal procedures and protocols.

Space Heaters, Stand Alone Electric Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Repair, replacement, or installation is not allowed. Removal is recommended. x Alternative Guidance Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may not be used for repair, replacement or installation of these types of space heaters. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Removal is strongly recommended. Inform client of hazards if removal is not allowed. Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Deferral should be exercised when existing code violations are present and correcting them would be beyond the scope of the DOE WAP, and/or when there are problems affecting the heat system/furnace that are beyond the scope of the DOE WAP, such as certain electrical problems. For additional deferral criteria, see deferral section above.

Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis. This training shall include awareness of the guidance regarding this category of space heater.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Inform client of hazards if removal is not allowed. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes and regulations shall be followed to ensure proper disposal procedures and protocols.

Space Heaters, Unvented Combustion Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Removal is required, except as secondary heat where the unit conforms to x ANSI Z21.11.2. Units that do not meet ANSI Z21.11.2 must be removed Alternative Guidance prior to weatherization but may remain until a replacement heating system is in place. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Test for air-free carbon monoxide (CO)

Inform client of dangers of unvented space heaters – CO, moisture, NO2, CO can be dangerous even if the CO detection alarm does not sound.

StandardsRemoval is forrequired Deferral: if unit Describe does not when meet deferral ANSI Z21.11.2. should take This place must for be the done specific prior healthto weatherization and safety category. If client will not allow removal, defer the weatherization work to the home. Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies. Referral should be made when problems are identified that are beyond the scope of the DOE WAP, such as electrical or other code violations. Examples of referral agencies include, but are not limited to, local housing authority agencies, other CAA local agencies and landlords.

Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis. On the job training regarding performance of air-free CO testing. Training shall encompass an understanding of the dangers of unvented space heaters.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Inform client of dangers of unvented space heaters. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes and regulations shall be followed to ensure proper disposal procedures and protocols.

Space Heaters, Vented Combustion using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Shall be treated as furnaces. x Funding:Alternative State Guidance that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Follow same protocols and procedures as for furnaces.

Venting should be tested consistent with furnaces. Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Deferral should be exercised when existing code violations are present and correcting them would be beyond the scope of the DOE WAP, and/or when there are problems affecting the heat system/furnace that are beyond the scope of the DOE WAP, such as certain electrical problems. For additional deferral criteria, see deferral section above.

Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis. On the job training re: proper testing methods for safe operation (draft and CO) just as with furnaces.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. N/A Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes and regulations shall be followed to ensure proper disposal procedures and protocols.

Spray Polyurethane Foam (SPF) Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Colorado has limited use of SPF. All DOE guidance will be incorporated should x Colorado choose to expand the use of SPF’s. Alternative Guidance Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. All DOE and OSHA guidelines regarding safe work practices will be incorporated should Colorado begin using this product.

Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Deferral should be exercised when existing code violations are present and correcting them would be beyond the scope of the DOE WAP, and/or when there are problems affecting the heat system/furnace that are beyond the scope of the DOE WAP, such as certain electrical problems. For additional deferral criteria, see deferral section above.

Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis. Training on the job regarding use of various products with specifications for each application type. MSDS sheets and temperature sensitivity. Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Provide notification to the client of plans to use two-part foam and the precautions that may be necessary. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes as well as manufacturer and EPA guidelines shall be followed.

Ventilation Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Colorado weatherization agencies are required to meet 2010 (or most x current) ASHRAE 62.2 to the fullest extent possible, when performing Alternative Guidance weatherization. Implementing ASHRAE 62.2 is not required where acceptable indoor air quality already exists as defined by ASHRAE 62.2. Existing fans and blower systems should be updated if not adequate. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. ASHRAE = American Society of Heating, Refrigeration, and Air-Conditioning Engineers Section 62.2 pertains to acceptable indoor air quality and ventilation in low-rise residential buildings Must implement and comply with 2010 (or most current) ASHRAE 62.2 requirements/codes by 2012.

ANSI/ASHRAE Standard 62.2 – 2010, Ventilation and Acceptable Indoor Air Quality in Low-Rise Residential Buildings, is the only nationally recognized indoor air quality standard developed solely for residences. It defines the roles of and minimum requirements for mechanical and natural ventilation systems and the building envelope intended to provide acceptable indoor air quality in low-rise residential buildings.

The 2010 standard encourages home retrofits to improve indoor air quality through allowance of alternative methods for meeting the standard’s requirements regarding kitchen and bathroom exhaust fans. The standard currently requires fans in those rooms.

Installation of new equipment in some existing homes can be a barrier in terms of expense and practicality. Under the alternative compliance path, the overall whole-house ventilation rate can be increased to compensate for insufficient or non-existent bathroom exhaust.

The overall approach to residential ventilation in the standard has not changed since the 2007 version was published, such as whole house mechanical for most houses, local exhaust in baths and kitchens and some source control measures.

Additional improvements to the standard include more accurate factors for intermittent whole-house systems; changes to better limit unintended (potentially contaminated) air transfer from garages, leaky ducts, adjacent housing units, and other such spaces; and deletion of an exception for certain climates that had allowed the use of windows instead of fans given that studies have shown that windows are not used enough and are unreliable for ventilation.

CEO WX Policy 829: If the air infiltration rate of a unit is less than 5 ACH when tested with a blower door at 50 pa, the unit shall be provided with ventilation in accordance with ASHRAE 62.2.2010.

When calculating ACH, conditioned crawl spaces must be included in the volume. A conditioned crawl space is defined as one that is inside the thermal boundary, has a vapor barrier installed and includes a supply vent. Unconditioned and unintentionally conditioned crawl spaces do not need to be included in the calculation.

When a unit has 5ACH or greater, ASHRAE 62.2.2010 may be implemented if it is deemed to have an existing in-door air quality issue.

The CEO field sheet must be used to document ventilation requirements as prescribed by ASHRAE 62.2.2010. The approved field sheet is attached in Appendix A. The CEO field sheet must be included in the client file when ASHRAE is implemented.

Square footage, used for the ventilation calculation, includes any floor space within the thermal boundary including conditioned crawl spaces.

The formula method must be used in calculating ventilation needs.

Actual occupants or the number of bedrooms may be used when calculating ventilation requirements. The CEO recommends using the number of occupants instead of bedrooms when occupants exceed the number of bedrooms (+1).

The closest geographical N-Value must be used in ventilation calculations. Agencies need to determine how each of these N-Values will be used in their territories.

Mechanical ventilation installed under CEO Wx must be vented outside of the building shell. Existing mechanical ventilation must be vented outside the building if there are any signs of moisture problems associated with the ventilation. Insulation is required on mechanical venting ducts that are outside the thermal boundary on all newly installed systems, insulation should be installed on existing mechanical venting ducts if the condition of the attic will be changed with the weatherization work, i.e. adding insulation to an attic with zero insulation. Units with a final ventilation requirement of 15 CFM or less will not require additional ventilation.

Exhaust locations may not be located within 3 feet of eave vents.

Fan flow rates must be tested post-weatherization to determine if the required ventilation is achieved.

The client education form attached must be completed and provided to the client with a copy in the client file when ASHRAE 62.2.2010 is implemented.

An exhaust fan brings air into the house by creating a negative pressure. However, the low exhaust rates required by 62.2 should virtually never create enough negative pressure to cause a combustion device to backdraft.

High flow fans, such as large range hoods and clothes dryers, can create enough negative pressure to create a backdraft if natural draft combustion devices are used in a tight house. ASHRAE 62.2 sets a limit on how much total exhaust can be tolerated.

ASHRAE 62.2 allows the designer/contractor to choose the method that fits the project, climate, or budget the best. It only sets the continuous rate and provides guidance on how to increase the flow to allow for intermittent operation. Essentially, the higher rate is the reciprocal of the run time. If it operates one-third of the time, it must be increased to three times the continuous rate in the table.

Manufacturers do offer continuous flow fans that are designed specifically to meet ASHRAE 62.2. Fan vendors will be used during Colorado’s ASHRAE training.

Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Deferral should be exercised when existing code violations are present and correcting them would be beyond the scope of the DOE WAP, and/or when there are problems affecting the heat system/furnace that are beyond the scope of the DOE WAP, such as certain electrical problems. For additional deferral criteria, see deferral section above.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Provide client with information on function, use, and maintenance of ventilation system and components. Include disclaimer that ASHRAE 62.2 does not account for high polluting sources or guarantee indoor air quality. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes and regulations shall be followed to ensure proper disposal procedures and protocols. ASHRAE 62.2 Compliance: Provide a narrative describing implementation of ASHRAE 62.2, which will be required during the 2012 program year. Grantees must provide justification if making changes to ASHRAE 62.2 specific to their housing stock and local considerations. Implementation is complete.

Window and Door Replacement, Window Guards Concurrence or Alteration: Check if you concur with existing guidance from WPN 11-6 or if you are using an alternative action/allowability. Include the guidance action/allowability from WPN 11-6 or alternative guidance in the space provided. Alternatives must be explained and comply with DOE guidance. Note: Where an Action/Allowability or Testing is “required” or “not allowed” through WPN 11-6, the grantee must concur or choose to defer all units where the specific issue is encountered. Allowable items under WPN 11-6 leave room for determining if the issue or testing will be addressed and in what circumstances. Concur with WPN11-6 Replacement, repair, or installation is not an allowable health and safety cost x but may be allowed as an incidental repair or an efficiency measure if cost Alternative Guidance justified. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category. DOE funds may be used per the above stipulations. Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP. If the issue is determined to be beyond the scope of DOE WAP, crews shall follow all Colorado Referral and Deferral policies and protocols.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing. Follow Colorado WAP Technical Standards/Field Manual.

Broken or missing windows may be replaced or repaired if cost effective guidelines are met. Those merely cracked should receive minimal treatment.

Seals around entry doors may be improved, using lock sets, hinges, sweeps, thresholds, etc.

Replace only those doors that are broken beyond repair or sealed up.

Storm window decisions should be blower door driven or address specific comfort problems. Document reason for installing storm windows on audit form. Include cost justification documentation.

Any other measures must be cost effective.

Must follow LSW requirements for pre-1978 homes.

Refer to GEO Wx policy 819. Standards for Deferral: Describe when deferral should take place for the specific health and safety category. Deferral should be exercised when existing code violations are present and correcting them would be beyond the scope of the DOE WAP, and/or when there are problems affecting the heat system/furnace that are beyond the scope of the DOE WAP, such as certain electrical problems. For additional deferral criteria, see deferral section above.

Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training. Colorado has conducted and continues to conduct statewide weatherization assistance program health and safety trainings to ensure that all agencies and crews are aware of the guidance in WPN 11-6. Additional training will be handled on an ongoing and as-needed basis. On-the-job training.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education. Provide information on lead risks. Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards. State and local codes and regulations shall be followed to ensure proper disposal procedures and protocols.

Other (copy and paste as needed) Health and Safety Issue: Describe the health and safety category below. Methods for addressing additional energy related health and safety issues must be consistent with DOE guidance. None listed. Funding: State that DOE funds are being used or indicate that alternate funding sources will be used to address this particular health and safety category.

Beyond Scope of DOE WAP: Describe how the issue will be treated if beyond the scope of DOE WAP.

Standards for Remedy: Describe the standards for remedy of the health and safety category, including testing protocols. Also include when partial weatherization would be appropriate. Note: Some health and safety categories, like combustion gases, require testing.

Standards for Deferral: Describe when deferral should take place for the specific health and safety category.

Standards for Referral: Describe when referral should take place for the specific health and safety category. If possible, include associated referral agencies.

Training Provision: Discuss how training will be provided for the specific health and safety category. Note: Some health and safety categories, like OSHA, require training.

Client Education: Discuss what specific steps will be taken to educate the client, if any, on the specific health and safety category if this is not explained elsewhere in the State Plan. Note: Some health and safety categories, like mold and moisture, require client education.

Disposal Procedures: Provide disposal procedures or indicate where these procedures can be found in the Plan or Field Standards.