Health and Safety FAQs
DOE issued revised Health and Safety Guidance WPN 11-6
in response to concerns with clarity and consistency in how health and safety issues are approached by grantees. To update the guidance, DOE reconvened its Health and Safety Committee to review trends and practices of the WAP network. The result was a compilation of past guidance, with minor changes and clarifications, into a comprehensive user-friendly table. However, since addressing health and safety measures is not always straight forward, as seen in several examples below, and sometimes leaves much interpretation to the grantee, DOE decided to respond to several direct questions from the Weatherization network and offer additional clarification on WPN 11-6 in this collection of frequently asked questions.
The answers below may vary for subgrantees due to requirements set by the grantee’s Health and Safety Plan. Be sure to consult your DOE-approved Health and Safety Plan for specific direction that is applicable for your state, territory, or tribe. DOE will continue this dialogue and add questions and answers that come up. Grantees should contact their respective Project Officer if a question is not answered below or if additional clarification around health and safety is needed.
“Grantee” refers to the state, tribe, or territory who directly receives WAP funds.
“Program” refers to all of the activity being conducted under the grantee for the DOE WAP.
Q: Why is a health and safety measure allowed in WPN 11-6 but my grantee doesn’t allow me to do it?
A: Just because it is allowed in WPN 11-6 does not mean that the grantee will extend that to their program. Each grantee has a different budget with different needs and limitations. It is also up to the grantee to establish any metrics or details around specific health and safety measures. The grantee must include details on implementation in their Health and Safety Plan. While the Plan must be consistent with WPN 11-6, there is a lot of flexibility for the grantee. Grantees must build their Plans within the framework of WPN 11-6 and funding is limited to addressing those measures as defined by the guidance. Only those components of WPN 11-6 that are required or not allowed must be carried over to grantee Health and Safety Plans, which become the guiding document for local programs once approved by DOE.
Q: What if, as a grantee, I would rather perform certain health and safety repairs as incidental repairs?
A: While it is recommended in most cases that grantees perform those categories identified in WPN 11-6 as health and safety repairs; the grantee could decide to remove specific repairs from the health and safety budget category. In order to remove a health and safety repair from the health and safety budget category, the repair must meet the definition of incidental repair and be identified as such in the grantee’s Grantee Plan. Issues such as minor electrical repair (including knob-tube-wiring) and minor roofing repair could potentially be identified in the Grantee Plan as incidental repairs. Once identified as an incidental repair, its application must be applied consistently across the program and be cost-justified as part of an efficiency measure or possibly a set of measures. For example, grantees could remove all roofing repairs from the health and safety category so they would always be considered incidental repairs and be cost justified. Once the incidental repair measures are defined, the definitions must be applied consistently across the program. So if the roof repair cannot be cost-justified with the package of measures on a given dwelling, the repair would not be allowed, as it is defined as incidental repair and could not be paid for with WAP health and safety funds. The only time a decision can be made in the field between conducting a measure as an efficiency or health and safety measures, is when the entire measure could be cost justified – such as a furnace replacement. If a measure has the potential to save energy, it must be ruled out as an energy efficiency measure through the audit or priority list prior to using health and safety funds for installation.
Q: What if a health and safety measure can be cost justified as an efficiency measure?
A: It is recommended that grantees perform those categories identified in WPN 11-6 as health and safety repairs, except where the measure as a whole has the potential to be energy efficient, in which case an attempt should always be made to cost justify the measure prior to considering it for health and safety costs. There are some instances where a measure can be considered either a health and safety measure OR an energy conservation measure. Most replacement measures such as furnaces, air conditioning, or water heaters could potentially save energy. In those instances where the measure has a cost-effective savings-to-investment ratio of one or greater, the measure must be treated as an efficiency measure. For example, if the audit or the priority list justifies the replacement of a furnace, the grantee cannot pay for the replacement out of health and safety funds. Any potential energy efficiency measures must be considered through the audit or priority list before installation, to determine whether it is an energy efficiency measure or a health and safety measure. If the measure cannot achieve an SIR of 1 or greater, only then can it be installed as a health and safety measure.
Q: What if code compliance triggers the installation of a health and safety measure?
A: An example of a code compliance health and safety measure would be if when insulating a wall, local code requires that the outlets be upgraded to GFCI along the wall being insulated. The measure will ensure the occupant’s safety, but does it relate to the efficiency measure, i.e. insulation? - The answer is no. Since the outlet upgrade is not a component of the insulation, it should be considered a health and safety measure.
Q: What happens if code compliance requires the replacement of operable smoke/CO alarms or the correction of other health and safety issues that are not allowed in WPN 11-6?
A: Code corrections are allowable health and safety costs when they are required by the local code authority in order for weatherization work to be performed. Use the previous questions to determine if these costs must be considered incidental repair or health and safety. You must note the specific code requirement with reference to the efficiency measure(s) that triggered the code activity. If the code correction cannot be related to weatherization work, then WAP funds cannot be used to make the code correction. An example of this would be bringing hand rails up to code, since it is not related to the installation of the efficiency measures.
Q: Can doors and windows be repaired or replaced as health and safety measures?
A: Door and window replacement, repair, and/or installation are not eligible WAP health and safety expenses. They must be considered efficiency measures or incidental repairs, and cost justified, when being replaced, air sealed, or repaired.
Q: Can I include incidental repairs when working from a priority list?
A: Unless the costs are minimal and can be attributed to relatively high SIR measures where the additional costs are unlikely to lower the SIR to below 1, or the priority list was developed from the audit with specific incidental repair costs included, a full audit would be required in order to cost justify incidental repairs. Combining a partial audit and the priority list is not allowed and a complete audit for all weatherization measures on the home is necessary to cost-justify incidental repairs.
Q: What does “case by case” mean?
A: “Case by case” indicates that the grantee would not be able to create a catchall policy for repair/replacement around these issues, but must instead provide guidance for the decision-making process. An example would be requiring a cost comparison between repair and replacement for water heaters. Where “case by case” is used in WPN 11-6, it should be seen by the grantee as an opportunity to shape their Health and Safety plan in a way that benefits from sound judgment based on program regulations and knowledge of local conditions. The grantee may require additional review or analysis of a situation to ensure that cost-effective guidelines are considered. The grantee could create a system where they are contacted for approval of certain measures in pre-determined situations, or draft additional guidance the crews must follow when assessing certain issues. “Case by case” leaves flexibility to the grantee while highlighting the importance of providing strong oversight on the issue.
Q: What do “major”, “minor”, or “limited” repairs mean?
A: This should be defined further by the grantee to avoid allowing overspending of their specific average expenditure limits. It is a factor of the grantee’s health and safety budget and the cumulative expenses that the grantee expects to spend on health and safety measures. The grantee is responsible for setting the average per unit cost limitations. Each grantee has a different budget with different needs and limitations. The grantee must set their own limitations around “minor/major” so that they are assured their subgrantee’s spending stays within their allocated per unit average for health and safety expenditures.
“Limited” could refer to the costs associated with the repair or the size of the problem, but this needs to be defined by the grantee in their Health and Safety Plan. Some grantees set a maximum limit for health and safety measures before a waiver-process kicks in. The grantee then works in conjunction with the subgrantee to conduct an analysis of the situation and may or may not allow the cost limit to be exceeded.
Q: Can appliances be replaced as a health and safety measure?
A: Appliances including ranges, cook stoves, rangetops, etc. are not allowed to be replaced or installed as health and safety measures. Water heater replacement is allowed on a case-by-case basis. Repair and cleaning of appliances that create a health and safety problem such as carbon monoxide, are allowable health and safety expenses. Appliances, such as refrigerators, can be replaced as energy efficiency measures if they can be cost justified.
Q: Can light fixtures be replaced as a health and safety measure?
A: No. Since the activity is a direct component of an energy efficiency measure, installing energy efficient lighting (the bulbs do not function without the fixture), the activity must be included in the SIR for the lighting or as part of the package of measures. Each individual fixture must be assessed for replacement. One fixture being broken does not justify replacing them all. Replacement of fixtures is not allowed unless related weatherization work is taking place.
Q: Why can’t I install stairs, porches, or safety lights as a health and safety measure under injury prevention?
A: The WAP is not a rehab program. Porches, stairs, and exterior lights are not allowed as health and safety costs. WPN 11-6 states “Minor repairs and installation may be conducted only when necessary to effectively weatherize the home; otherwise these measures are not allowed.” There may be rare cases where safe entry for workers is impossible without some “minor” repair, but most workers are capable of using ladders, portable lighting, and other tools to allow for safe weatherization without correction of structural issues or other installation.
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