The National Retrofit Workforce Guidelines: Round 2 (Section 8 aka Crawl Spaces & Basements)

As listed in the first article in this series, many industry experts were asked to perform a technical review of the updated Workforce Guidelines and we are combining both the review & a Clif Notes version of the standards together.

HTRC Series: Combustion Safety, Ventilation, Air Sealing, Heating & Cooling, Insulation, Crawl Space & Basements, Base-Load aka Appliances & Lighting.

Topic: Health and Safety (8.1 – 8.11)

Wow, what was once just a single item for Safe Work Practices has now expanded into 3 sub topics; Safe Work Practices, Separation of Basements and Crawl Spaces, followed up by Occupant Health. Amazingly one item I do not see in here is any mention of enclosed space health risks.

• 8.1: Worker Safety – this is the typical see the Global Work Safety section
• 8.2: Combustion Safety – this has mostly been covered in Section 3, with the following exception “If replacing appliances, a sealed-combustion, direct-vent appliance will be installed” – Amen, now can we please make that part of the guideline for all items unless they are located completely outside the house?
• 8.3: Material selection, Labeling & MSDS sheets
  • 8.3.1: Materials that do not create long-term health risks for occupants and workers will be used – and this is not a global item / only applies here? Unfortunately the issue with this is that means that nothing can be used, because every item could create said problems if not installed properly, California or the EU slaps a label on it, etc…
  • 8.3.2: Material Labels = Manufacturer specifications will be followed – you might want to change the title as not all labels carry specs
  • 8.3.3: MSDSs will be provided onsite and available during all work – this should also be under the global worker safety as it is required by OSHA
• 8.4: Separation of Basements & Crawl Space – first I have to ask what this has to do with health & Safety (as you have it written).
  • 8.4.1 – Cond. Basement & Vented Crawl, Crawl will be separated with cont. air barrier, ground moisture barrier, & thermal boundary (no specs listed on how far it extends but they point to a later section)
  • 8.4.2 – Cond. Basement & Closed Crawl – same as above minus thermal boundary
  • 8.4.3 – Unconditioned Basement & Vented crawl – same as 8.4.2
  • 8.4.4 – Unconditioned Basement & Closed crawl – Unconditioned Basement must be treated as an extension of the Closed Crawl Space
• 8.5 – Radon they simply punt & say one needs to see the EPA’s Healthy Indoor Envir. Protocols which basically call for a test-in & test-out protocol be followed. (if you get results above the 4 pCi/L result – well then life gets interesting)
• 8.6 – Okay the Detail name just says “Access” but the outcome only applies to Closed Crawl Spaces where you are required to create a lockable access if one doesn’t exist that doesn’t damage the thermal & air barrier – nothing mentioned on being insulated? How about a vented crawl?
• 8.7 – Crawl Space Signage, wow – a durable 8.5 x 11” sign that is easily seen must be installed at each access that tells one that if you do damage you must fix it immediately, the installers contact information & that storage of hazardous or flammable materials is prohibited… Yeah, moving on
• 8.8 – Occupant Education- I rarely cuss in an article but this one truly deserves a “WHAT THE FUCK WERE YOU SMOKING?” when you put this together? Seriously, every other occupant education mentions the federal regulation on the R Level sticker that must be on the electrical panel, explain or leave documentation on how to do XY or Z…, explain the importance of… & the list goes on. Now we get to this one, where the first part starts off fine; “occupants will be given written…” followed up by “information will be provided in simple terms” which I can understand. Then we hit this “Text & pictures will be used” (still not too bad, but unique to this document) and then the clincher “Literacy levels and language of occupants will be considered in selecting appropriate materials” – wow folks, just wow.
• 8.9 – Return & Supply Plenum, in short you may not use the Crawl space as a plenum (even conditioned crawl spaces)
• 8.10 – Warranty & Service Agreement, ok now this is stretching the H&S aspects past the breaking point. Also why does this only apply here & nowhere else. Truly this needs to go, or it should become a global suggestion as many localities already having something similar or more stringent.
• 8.11 – Knob & Tube Wiring, seriously this has already been covered before & instead of repeating it all the time – put it in the global area

Topic: Crawl Spaces (8.12 – 8.30)

• 8.12 – Pre-Work Qualifications, everything listed here applies everywhere else (Fuel Leaks, Mold, Electrical, etc…) & should be listed in a global area
• 8.13 – Debris removal –no issues, you must rake the crawl space & dispose of anything larger than 1”, but I don’t see anything about vegetation removal
• 8.14 – Drainage, ok I understand that the ground should slope away from the house, it would be nice if the gutters displaced the water 6’ away & the exterior should have waterproofing on it, along with French drains / weeping tile (in many areas of the country) – but to require it as part of your guideline with no qualifications is questionable at best
• 8.15 – Preliminary Dehumidification, again no real qualifications & questionable depending on the work to be done, time of year
• 8.16 – Interesting that one must seal & create a negative pressure in the crawl space to prevent containments from getting into the house when you could be pulling them into the house from the attic with the steps listed.
• 8.17 – Sealing Floor Penetrations, here we go again- items must not move… While they do list a few items requiring non-combustible materials being used, there are more items than that to be concerned about
• 8.18 – Regional Considerations, amazingly none are listed like Marine climates or those in flood plains require flood vents (even in a closed crawl), closed crawls should be utilized in mixed-humid, etc…
• 8.19 – Vented Crawls Moisture Barrier, must be installed last, only cover 100% of the floor (what about lapping up the walls?),with no listing for mils but it must have a .1 or less perm rating, last 10 years & be tear resistant. The seams must be lapped by 12” (better than the 6” normally stated), not taped (?) but fastened to the ground (really?). How about 12” overlapped, seams taped & securely fastened to the wall 6 – 12” up?
• 8.20 – Vented Crawl Spaces Venting – if you are going to actually mention the 2009 IRC (finally) you might want to use the proper section as 1203 does not exist –might it be R408?
• 8.21 – Skirting Post & Pier Foundation, seriously I want to know what you have been smoking as the desired outcome is to retard damage from natural causes such as wind, water, and pests – if that is your ultimate desire you wouldn’t be installing any in most cases
• 8.22 – Closed Crawl Spaces Venting – Vent openings will be permanently closed & sealed to prevent air & moisture intrusion. While that is correct, you didn’t mention how you want that done or the special circumstances when they might need to pop open.
• 8.23 – Closed Crawl Air Sealing Exterior Wall, ok but this has already been covered & applies to all types of crawl spaces – by the way can you please name one pest-proof air-sealing material besides a cement based product or did you mean pest proof backing?
• 8.24 – Closed Crawl with Brick Curtain Walls & Piers – I have never seen anything like this in my life- sorry
• 8.25 – Closed Crawl Vapor Retarder, ok this is interesting as an air & vapor retarded needs to be installed at least 1’ above grade while leaving a 3” inspection gap for termite’s – seriously hasn’t anyone heard of termite shields?
• 8.26 – see 8.6 as basically it is the same
• 8.27 – Closed Crawl Wall Insulation (.1 – .3) is very nicely stated – non-absorbent, fire rated insulation (or with covering?) shall be installed either on the inside or outside that follows the IECC requirements. Here we go again (.4) mentions a termite inspection gap – at least make it removable or replaceable. (i.e. maybe landscape fabric on the wall that can be sprayed on, cut with the insulation & pulled out & placed back in – courtesy of Demilic) – I am not even going to bother talking about the stupidity of .6 & .7 (Band joists on a sealed crawl with wood framed foundation)
• 8.28 – Closed Crawl Ground Cover, SHOULD NOT be installed last as it needs to wrap up the wall at least 6” and should at least be under the insulation. Fortunately, you mention taping the seams, but you still have an issue with the fastening it to the ground to prevent movement.
• 8.29 – Closed Crawl Conditioning, maybe you should refer to the code books like R408.3
• 8.30 – Regional Considerations, while they did list some & not worth the space used – there is nothing in there about closing vents off in the winter in X Climates, etc…

Topic: Basements (8.31 – 8.33)

• 8.31 – Basement wall insulation with no ground water leakage, do I seriously need to mention that just because it isn’t visible doesn’t mean it isn’t there or won’t happen? Or installing an air barrier is probably the worst thing you can do in most places & is easily negated by building it right in the first place? Along those lines, if you use a vapor permeable insulation in the basement, just because it is permeable to the inside does not mean it will ever dry out? What I do find amazing is you don’t mention a drainage plane or air gap behind a vapor permeable material.
• 8.32 – Basement wall insulation with ground water leakage – Ahhh, here comes the drainage plane; first that only really needs to apply to said vapor permeable materials not Closed Cell Foam – with that said I still prefer to use a product like Delta-Drain behind it. Interestingly there is no mention that the issues should be corrected before insulation is installed? Also, why do you only cover termite protection, insulation attachment, Sealing & Finish wall requirements in this detail & not the prior one?
• 8.33 – Basement Dehumidification – what is up with this “A permanent, low-temperature, auto-restart, minimum ENERGY STAR® rated dehumidifier will be installed?” What if one isn’t required, or maybe fixing the issues causing the problem?

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