We have recently found that some Service Providers have not updated their retention policies to reflect the Weatherization contracts with Commerce. Please note the following which appears in all WAP contracts with the Minnesota Department of Commerce:
12.1 State Audits. Under Minn. Stat. §16C.05, subd. 5, the Grantee’s books, records, documents, and accounting procedures and practices relevant to this grant contract are subject to examination by the State and/or the State Auditor or Legislative Auditor, as appropriate, for a minimum of six years from the end of this grant contract.
Please check your retention policy to make sure you have updated it to meet this contract requirement.
If you have questions, please contact you fiscal monitor.
Scope of Work Change Reminder
If there is a change in costs or a scope of work changes by the adding of a measure (or materials and labor), the entire job must be revisited (rerun) to determine if the change affects the SIR requirements. This is Minnesota Department of Commerce and DOE policy.
If there is a change in price for a conservation measure or the contractor or crew finds a situation different than what was described on the work order, no work may continue until the audit is rerun to determine if the measure and job is still cost effective.
Other items such as smoke alarms that do not need an SIR would just need a change order.
OSHA requirements for Contractors
A check with DOE verified that Service Providers must confirm that contractors have the proper OSHA training. The OSHA law pertains to all contractors and not just to employees of Service Providers. Make sure that your contract language with contractors and subcontractors contains verification of the appropriate OSHA training. Refer to OSHA requirements and to WPN 11-6 for more information. Although WPA 11-6 refers to “workers,” this flows to contractors based on the OSHA law.
Certifications for WAP Auditors and Inspectors to begin July 1, 2014
Beginning July 1, 2014 auditors and inspectors must be certified to a newly developed DOE competency test. This information is according to information disseminated by DOE’s Bob Adams at the NASCSP September 2012 conference. Details regarding the testing and training opportunities for the test can be found here. Please take a look at this information.
This new requirement will be included in the 2013 Program Guidance (WPN 2013-1).
Lead Safe Weatherization
The Minnesota Department of Commerce has received a question regarding the need for Lead-Safe Weatherization training for workers. WPN 11 -6 clearly states that “all crews working on pre-1978 homes must receive LSW curriculum training and be accompanied by an EPA Certified Renovators.”
If crew members have a Renovators Certificate, they do not also need LSW training. However, the LSW training does cover some things that are not covered in the RRP training. The requirement for LSW (workers) and Renovators Certification (lead workers, auditors, and inspectors) does flow to all work on pre-1978 housing. All insulation subcontractors should be lead firms and should have lead workers with RRP certification. HVAC and electrical companies do not necessary need to be lead firms, but must be to work in houses where the square footage affected exceeds the minimum levels.
If you have questions on this, please contact your field monitor.
Crawlspace Insulation Options
If an auditor or installer is not able to access a crawlspace or treat the crawlspace properly (installing a vapor barrier over the dirt floor and sealed at the top of the foundation wall) then the house should be deferred until that work can be done. If the work can never be done, the home would be a declared a walk away.
The installation of a vapor barrier on the walls of a crawlspace may by avoided provided if the crawlspace walls are insulated with a material that has a PERM rating of 1.0 or less. This method would indicate installation of a two part foam product that requires prior approval from the Minnesota Department of Commerce.
If the walls are being insulated and the floor of the crawlspace is exposed dirt, the vapor barrier on the floor must be continuously sealed as part of the wall insulation. This creates a continuous vapor barrier in the crawlspace and keeps bulk water and water vapor from entering the dwelling though the soil and the crawlspace wall.
State monitors have noted a few audits where separate attics have either been modeled as one or one or more attics have not been modeled at all. This is a reminder that all attics must be modeled and modeled separately if they are not continuous. In addition, in some cases, slants are not being modeled. Please make sure that all components of attics are modeled correctly and individually.