At the 2012 RESNET conference in Austin, most of the HERS trainers in attendance at the trainers roundtable wanted combustion safety testing added to the list of skills required to be a certified home energy (HERS) rater. Really, what we wanted was not to have two separate certification tracks for HERS raters. Two years later, it’s clear that RESNET staff, Board of Directors, and the Training & Education committee blew it.
Requirements that aren’t required
In the middle of 2013, RESNET staff began telling all trainers that we would have to take two new combustion safety exams: a 25 question multiple choice exam and an online simulation exam of combustion safety testing and work scope development. To get recertified as a HERS trainer for 2014, all trainers had to pass those two exams.
Trainers had to pass the new exams first, and, according to RESNET staff, all new HERS raters would have to pass the exams to get certified beginning in 2014. All raters certified before 2014 would have to pass the exams before 2015.
The only problem with those requirements is that the Training & Education committee forgot to add them to the HERS Standards. When I questioned RESNET staff on this in January, I was told at first that I was “misreading the standard.” I wrote back with more detail and got another response that the “RESNET Board is currently voting on a series of amendments to address this and other concerns.”
A “Clean Up Amendment” that doesn’t clean up
The amendments came out in February, shortly before the annual RESNET conference. One of them was called a “clean up amendment” and went out for public comment on the new requirements. (The comment period ended yesterday.) The justification section stated, “Clean up language is needed to have the Standards reflect the Board policy.” Unfortunately, this amendment only makes more of a mess.
Here are a few of the problems I’ve discovered therein:
- The 25 question multiple choice exam still seems to be AWOL.
- A new “Simulated Practical Examination” will be required in 2016, but there’s no definition of it and no protocol for trainers to use in conducting such an exam.
- A recent interpretation approved by the Board mentions a “RESNET CAZ field training requirement” in, but I can’t find anything about it in the HERS Standards or clean-up amendment or anywhere else. What is it? As a trainer, how am I supposed to enforce it if there’s no definition?
- The “Combustion Appliance Simulation Test and the Work Scope Development Test” are, I believe, the same exam. You wouldn’t know it from this language.
- The exams have different names in different parts of the standard; e.g., National Rating Practical Simulation Test and RESNET Rater Simulation Practical Examination.
- In some places the word test is used, in others, examination.
Is RESNET breaking its own rules?
Another problem with this process, as pointed out in more than one of the public comments (e.g., see #18), is that RESNET has rushed out these amendments to enact a policy they’ve already been trying to enforce. RESNET policies, however, require that new policies cannot go into effect until a minimum of 30 days after the public comment period ends. Here’s what it says in RESNET Policy 024, adopted in 2011:
The period of the time before an amendment or interpretation becomes effective is likely to vary with the nature of the interpretation or amendment. In no case, however, will the period of time be less than thirty (30) days from official approval of the interpretation or amendment.
Yet, the clean-up amendment states: “The effective date for item 184.108.40.206.9 is Jan 1, 2014.” This is what can happen when you get in a big rush.
RESNET would be wise to delay the process
Not only does this amendment not clean up the standards, but also the changes proposed in this amendment go beyond mere clean-up. As one of the commenters wrote in the public review (see comment #42), “This is not clean up language. Clean up language is when you make editorial changes.”
In addition, a large number of certified HERS raters are also certified BPI Building Analysts. Many of them have done a lot of combustion safety testing and are not happy that RESNET now wants them to pay $249 for test fees and most likely additional proctoring fees to take tests they feel they don’t need to take. And that was a concession as the RESNET Board hurriedly passed an interpretation that allows raters who are certified BPI Building Analysts not to have to undergo field training.
But wait. Is field training even required? It’s not in the standards, unless maybe that’s what the Simulated Practical Examination is supposed to be. Of course, with no definition for either term, we just don’t know.
It’s hard to know which party—RESNET staff, the Board, or the Training & Education committee—is most guilty of creating the mess we have now, but I think the Training & Education committee has to shoulder most of the blame. They were responsible for writing clear language laying out the requirements, and they failed to do so.
RESNET should step back, take a deep breath, and start over with this whole process. It’s one thing to have a clear policy that people disagree over. It’s another to have RESNET staff going out and trying to enforce policies that don’t exist and then put out a clean-up amendment that makes things worse.
Take a mulligan on this one, RESNET. If we’re going to do this, let’s do it right.
Afterword, 8/9/14. RESNET did not delay the requirements but did make some changes. For the latest details on the requirements, see our CAZ training page, which includes a Frequently Asked Questions section.
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