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Grantee Health and Safety Plan - Instructions

The grantee Health and Safety (H&S) Plan will be used by DOE to monitor the health and safety

costs, activities, and implementation protocols by subgrantees as well as the enforcement of

these practices by the grantee. Weatherization Program Notice (WPN) 11-6 entitled Health and

Safety Guidance, issued on January 12, 2011, must be used as a guide for the development of

policies, procedures, and field standards governing this important feature of the Weatherization

Assistance Program (WAP) service delivery. The submission of the grantee’s annual Health and

Safety Plan must meet the following minimum requirements:

The grantee must show how they will budget their health and safety costs. These costs

can either be included in a separate health and safety budget category or as part of the

regular program operations. The grantee is encouraged to budget health and safety

costs as a separate category, thereby excluding these costs from the average cost per

unit calculation. Creating a separate budget category also allows these costs to be

isolated from energy efficiency costs during program evaluations. The grantee is also

reminded that, if health and safety costs are budgeted and reported under the program

operations category rather than a separate health and safety category, the costs must

be included in the calculation of the average cost per unit and cost-justified through the

energy audit.

The grantee must identify in their Plan which measures will be installed under health

and safety and which measures will be installed as incidental repairs. As a note,

Incidental Repairs means “those repairs necessary for the effective performance or

preservation of weatherization materials.” These repairs are usually different than

those measures identified in the grantee’s Health and Safety Plan. It is the Project

Officer’s responsibility to approve the delineation in the grantee’s Plan between health

and safety and incidental repair costs.

The grantee will set health and safety expenditure limits, providing justification for the

basis of these limits. These limits must be expressed as a percentage of the average

cost per dwelling unit. For example, if the average cost per dwelling is $5,000, then an

average expenditure of $500 per dwelling in Health and Safety costs would be

acceptable in the Plan. While it has been a common practice to accept 10 percent as a

benchmark in health and safety allowance, the grantee should establish a percentage

that best reflects both the history of these applications and the complication of the H&S

protocols in the Plan. The higher percentage identified for H&S requires more stringent

documentation to support the costs. 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.

The grantee must create a 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

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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.

The grantee must develop procedures on how information is solicited from clients to

reveal known or suspected occupant health concerns as part of the initial application for

Weatherization. During the energy audit, the auditor should perform additional

screening to determine what steps will be taken to ensure that Weatherization work will

not worsen the health concern.

The grantee must develop documentation forms that should 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 conditions under which weatherization could continue, the

responsibility of all parties involved, and the client(s) signature(s) indicating that they

understand and have been informed of their rights and options.

The grantee must identify the hazards to be remedied and anticipated approaches

including testing, training, client education, and conditions that require referral to other

agencies. The Health and Safety Plan should comply with WPN 11-6 and address

each issue identified in the Guidance as well as any additional health and safety issues

the grantee wishes to address. This should also include guidelines for determining and

documenting if the potential health and safety issue should be remedied, referred to

other agencies, result in partial weatherization, or lead to deferral. Subgrantees are

expected to pursue reasonable options on behalf of the client, including referrals, and

to use good judgment in dealing with difficult situations.

The grantee must develop procedures that include a method used to determine when

DOE monies will be used to remedy the health and safety issue, and how the grantee

will treat problems that cannot be remedied with DOE monies after discovery.

The grantee must specify how training will be provided for each of the health and safety

issues included in the grantee’s H&S Plan.

The grantee must specify how testing will occur to determine the presence of any

health and safety problem that requires action by the subgrantee, including, at a

minimum, those tests required in WPN 11-6.

The grantee must provide a detailed explanation on implementation of ASHRAE 62.2,

which will be required for the 2012 program year. Grantees must provide justification if

making changes to ASHRAE 62.2 specific to their housing stock and local

considerations.

The grantee must provide a detailed explanation on implementation of smoke and/or

carbon monoxide detector installation parameters and procedures.

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The grantee must provide an explanation of protocols for the repair and replacement of

both heating and cooling equipment, including justification for allowance within the

scope of service delivery, climate justification with degree days and how the grantee

defines “at-risk occupants” for cooling allowance.

The grantee must provide an explanation of procedures to be followed when problems

are discovered during testing of combustion gases.

The grantee must provide an explanation on 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 being used to determine if crews are

using safe work practices according to all requirements.

The grantee must provide an explanation on the protocols being used to identify any

mold or moisture related issues in the client’s home. The protocol should include how

these issues are discovered during the initial audit or assessment, notification to the

client, and crew training on how to alleviate limited mold and moisture conditions in the

home.

The grantee must provide an explanation on how it plans to implement and verify

compliance with RRP and LSW. The explanation should clearly show an

understanding that LSW and RRP are separate requirements and both protocols are

required to be met.

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Grantee Health and Safety Plan - Template

(Fill in the white boxes below the category heading.)

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

Contained in Program Operations

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.

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.

4

Per-Unit Average Percent: _______%

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.

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.

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

No

Completing the General Issue Tables below, or something similar, for each health and safety category will help explain to DOE how the WPN 11-6 requirements will be addressed.

Air Conditioning and Heating Systems

5

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

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.

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.

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

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

6

Appliances and Water Heaters








Concur with WPN11-6

Alternative Guidance

Funding: State that DOE funds are being used or indicate that alternate funding sources will be



DOE WAP.




safety category.









Asbestos - in siding, walls, ceilings, etc.






7



Concur with WPN11-6





DOE WAP.




safety category.









Asbestos - in vermiculite








Concur with WPN11-6


8




DOE WAP.




safety category.









Asbestos - on pipes, furnaces, other small covered surfaces








Concur with WPN11-6





DOE WAP.

9




safety category.









Biologicals and Unsanitary Conditions - odors, mustiness, bacteria, viruses, raw sewage, rotting wood, etc.








Concur with WPN11-6





DOE WAP.




10

safety category.









Building Structure and Roofing








Concur with WPN11-6





DOE WAP.




safety category.




11






Code Compliance








Concur with WPN11-6





DOE WAP.




safety category.







12



Combustion Gases








Concur with WPN11-6





DOE WAP.




safety category.









Combustion Gas Problem Discovery: Provide a narrative describing the process to be

followed when combustion gas testing reveals health and safety concerns.

13

Drainage - gutters, down spouts, extensions, flashing, sump pumps, landscape, etc.








Concur with WPN11-6





DOE WAP.




safety category.









Electrical, other than Knob-and-Tube Wiring




14





Concur with WPN11-6





DOE WAP.




safety category.









Electrical, Knob-and-Tube Wiring








Concur with WPN11-6

15





DOE WAP.




safety category.









Fire Hazards








Concur with WPN11-6





16

DOE WAP.




safety category.









Formaldehyde, Volatile Organic Compounds (VOCs),and other Air Pollutants








Concur with WPN11-6





DOE WAP.



17


safety category.









Injury Prevention of Occupants and WeatherizationWorkers – Measures such as repairing stairs and replacing handrails.








Concur with WPN11-6





DOE WAP.




safety category.


18








Lead Based Paint








Concur with WPN11-6





DOE WAP.




safety category.






19




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.

Mold and Moisture








Concur with WPN11-6





DOE WAP.




safety category.






specific health and safety category if this is not explained elsewhere in the State Plan. Note:

20

Some health and safety categories, like mold and moisture, require client education.



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.

Occupant Preexisting or Potential Health Conditions








Concur with WPN11-6





DOE WAP.




safety category.







21



Occupational Safety and Health Administration (OSHA) and Crew Safety








Concur with WPN11-6





DOE WAP.




safety category.









OSHA and MSDS Compliance: Provide a narrative describing procedures for implementation of

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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.).

Pests








Concur with WPN11-6





DOE WAP.




safety category.









Radon

23








Concur with WPN11-6




DOE WAP.




safety category.









Refrigerant








Concur with WPN11-6

24





DOE WAP.




safety category.









Smoke, Carbon Monoxide Detectors, and Fire Extinguishers








Concur with WPN11-6





25

DOE WAP.




safety category.









Smoke/CO Detector Installation: Provide a narrative describing smoke/CO Detector installation

parameters and procedures.

Solid Fuel Heating (Wood Stoves, etc.)








Concur with WPN11-6





DOE WAP.


26



safety category.









Space Heaters, Stand Alone Electric








Concur with WPN11-6





DOE WAP.




safety category.

27









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


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.

28

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

Standards.

Space Heaters, Vented Combustion








Concur with WPN11-6





DOE WAP.




safety category.









Spray Polyurethane Foam (SPF)

29








Concur with WPN11-6




DOE WAP.




safety category.









Ventilation








Concur with WPN11-6

30





DOE WAP.




safety category.









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 AHRAE 62.2 specific to their housing stock and local considerations.

Window and Door Replacement, Window Guards








Concur with WPN11-6


31




DOE WAP.




safety category.









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.

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.

32

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.

33

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