Dear RESNET staff and Training Committee members,

I believe that it is critical that RESNET delay the implementation of the Combustion Safety and Work Scope Training and Certification requirements until the the standards, software and communication regarding these changes are refined. We hope that this will help make this transition smoother and more successful for the entire industry.

By signing this petition, I am in substantial agreement with the statements presented by Building Efficiency Resources below, and am in agreement that the implementation of these requirements should be delayed per the terms listed below. Please see details below for full scope.

--------------------------------------------------------------------

1. Intent

a. In contrast to a lot of the criticism RESNET has been receiving regarding the decision to require Raters to be trained on combustion safety, BER supports that this is an important concept on which Raters should be trained and tested for the sake of increasing the professionalism of the industry.

2. Requirement for 2014

a. Although BER supports the idea that Raters and field inspectors should be trained on Combustion Safety and should potentially have to take a certification test on the subject, BER does not believe 2014 is the right time to enforce this requirement.

b. The reason we do not support this requirement being enforced in 2014 is due to the following reasons:

i. Training Standards

1. The requirement that Raters and Trainers be made to undergo this training and certification requirement has not been written and adopted into Chapter 2 of the RESNET standards, and thus never went through a public comment.

2. These requirements should be written into Chapter 2 of the Standards, undergo public comment, and be adopted prior to being enforced.

ii. Chapter 8 uncertainty

1. There is currently a public comment review on whether the current Chapter 8 standards are to be replaced with ACCA standards.

2. Due to this uncertainty, how are we as trainers supposed to be train raters when the standards to which they will be tested on are still unclear? We literally have a training scheduled for March 17th 2014. To what standard should I be teaching the students, and on which will they be tested on?

3. RESNET must decide on whether it will maintain its current Chapter 8 Combustion Safety and Work Scope standards, or adopt those of ACCA, prior to enforcing that people be trained and certified on this topic.

iii. CAZ simulation software

1. Although BER believes the current simulation software offers some value as a training tool, we do not believe it is a great or even valid testing tool currently.

2. During our preparation to complete the required trainer certification, we discovered several building science inconsistencies, as well as coding errors in the programming of the software scenarios.

a. We have related these inconsistencies to the software vendor, but have yet to hear back from them about solutions or if they have been fixed.

3. Although the software has some merit as a training tool, it does not always reflect the reality of how pressures work in homes, and therefore really turns into more of a “game” that has to be “beat” than an impartial and realistic scenario for how a rater would perform Combustion Safety testing in real life.

4. Additionally, some of the requirements of the software to “beat” the “game” do not reflect the requirements of the current RESNET Chapter 8 standards. It is unclear how closely they mirror the requirements of the ACCA standards that may replace the current RESNET Chapter 8 requirements.

5. Finally and perhaps most critically, BER does not believe that the scoring rubric for the exam is fairly weighted or apportioned.

a. There are critical requirements of the Chapter 8 standards that students are never evaluated on, while at the same time there are items not included at all in the standards (ex. putting on safety glasses) that the student is graded on.

b. Additionally, for certain sections of the exam grading, students are given points for not choosing the wrong answer, but if they choose the wrong answer, are given negative points for that item. Students should not receive points for not choosing wrong answers, and if they get something wrong they should be awarded 0 points, not negative points.

c. Furthermore, the scoring is set up in an absolutist standpoint - it is either all or nothing, whereas perhaps there would be a way to grade the student on partial credit for certain concepts (ex. worst-case depressurization)

6. BER believes that RESNET must address these inconsistencies in the simulation software prior to requiring that raters must pass the simulation exam, otherwise it will become nothing but a video game level that has to be passed that has little practical value in ensuring raters are properly trained to deal with combustion safety related issues.

7. Additionally, BER feels that as an alternate option to the simulation software, RESNET should define a proctored field training environment condition that is acceptable to conduct a Trainer-proctored field exam based on RESNET Combustion Safety and Work Scope standards.

3. Requirement of RESNET certification vs other similar certifications

a. BER believes that there is a significant amount of resentment by the rating community that RESNET is requiring that they earn a RESNET-specific combustion safety standard, and not acknowledging/accepting other similar standards as being accepted as equivalent.

b. There are many raters who have worked as weatherization auditors, BPI certified professionals, or in other similar roles where they have been trained, certified and have performed a significant number of combustion safety assessments.

i. BER is concerned that RESNET is potentially alienating these professionals by dismissing the value of these experiences and certifications.

ii. BER believes this resentment will be compounded when/if these field seasoned professionals are forced to take a simulation exam that is not designed to appropriately reflect the reality of performing these tasks.

1. The frank matter of things is that ResCAZ – as of right now - is more of a video game than a realistic combustion safety testing simulator. It has potential to achieve the later, but it is not there currently.

2. There are many raters who are great in the field, but are horrible with using computers and who have never played video games. BER is very concerned these people will fail, will be very frustrated due to failing and have to pay additional money to retake the simulation exam.

iii. Ultimately, BER believes that RESNET should accept other equivalent certifications as being sufficient to show compliance with the intent of what RESNET is attempting to achieve with this Combustion Safety training requirement.

1. As a compromise, BER would support RESNET requiring that current/future raters must pass a specific written exam on whatever the chosen RESNET combustion safety standard is even if they have an equivalent certification.

2. BER would also support new Rater students / current raters that do not have an equivalent certification having to pass both the written exam and ResCAZ (or proctored field exam), so long as the software is improved to better reflect the reality of performing these tasks.

4. RESNET communication

a. As previously mentioned, BER is concerned that these training/certification requirements were never formally adopted into the RESNET Standards. BER believes this needs to happen first before any requirement is issued.

b. Furthermore, BER is concerned that there is no official page on the RESNET website that lists all of the requirements and details of this process.

c. Thus, we’ve been telling current raters and new rater students that these are the new requirements, but we have absolutely nowhere to point them to for information on this process; it is not in the standards nor is there a consistent and thorough website page that explains everything.

5. Conclusion

a. BER supports the intent of what RESNET is attempting to do in requiring Raters to be trained in Combustion Safety issues, as we believe that there is significant value in Raters being trained on combustion safety testing and concepts.

b. BER believes that aforementioned issues with the standards, software and communication need to be addressed prior to this becoming a requirement. Things are simply too unclear and inconsistent for BER to feel comfortable training students/existing raters on these requirements.

c. BER believes that RESNET should consider creating an option for an approved alternative to the simulation exam, such as a proctored field exam at a site that meets the appropriate criteria to test students on their knowledge the RESNET Combustion Safety and Work Scope standards.

d. For the sake of fairness and consideration to the various professionals operating under the RESNET standards as certified raters who currently have obtained an equivalent combustion safety testing certification, RESNET should acknowledge the value of this certification by waiving the requirement to take the simulation exam.

i. Existing raters should be required to take the CAZ written exam to display their knowledge of RESNET’s specific Combustion Safety and Work Scope requirements, once the Standard has been finalized.

ii. New rater trainees, or existing raters who do not have an equivalent certification, should have to complete both the simulation (or proctored field exam) and written exams, once the above issues have been addressed.

e. Due to all of the following scenarios, BER believes that RESNET should delay implementation of this process so that the issues with the standards, software and communication can be addressed prior to the requirements going into effect.

i. The requirement for new Rater/RFI trainees to pass the combustion safety written exam and simulation exam (or proctored field exam) should be delayed until January 1, 2015.

1. Trainees should be able to waive ResCAZ testing if they have BPI, DOE weatherization, or similar certifications that involve combustion safety concepts.

ii. The requirement for newly certified Raters/RFIs to pass the combustion safety written exam and simulation exam (or proctored field exam) should be delayed until January 1, 2015.

1. New Raters/RFIs should be able to waive ResCAZ testing if they have BPI, DOE weatherization, or similar certifications that involve combustion safety concepts.

iii. The requirement for existing certified Raters/RFIs to pass the combustion safety written exam and simulation exam (or proctored field exam) should be delayed until July 1, 2015.

1. Existing Raters/RFIs should be able to waive ResCAZ testing if they have BPI, DOE weatherization, or similar certifications that involve combustion safety concepts.