Qualifications and Capabilities of Quality Assurance Providers (QAP) 1, 2
To be successful transforming the housing market to increased energy efficiency, ENERGY STAR depends on a self-sustaining, independent, industry-based verification process for assuring that factory-built homes (modular and manufactured homes) meet ENERGY STAR guidelines. To that end, EPA is making it a matter of policy to designate one or more organizations to serve as a Quality Assurance Provider (QAP) to provide independent, third-party quality control/quality assurance oversight of the verification process for factory-built homes earning the ENERGY STAR. QAPs are authorized to provide ENERGY STAR labels for certified factory-built homes. As such, QAPs are responsible for the oversight and enforcement of all quality assurance requirements related to designing, producing and installing these homes. QAPs are also responsible for reporting to EPA all homes qualifying for the ENERGY STAR label under the verification guidelines developed by the QAP and approved by EPA as well as any issues of non-compliance. QAPs must document its procedures for in-plant and on-site quality control oversight of ENERGY STAR certified homes and submit them to EPA for review and approval.
To be a QAP, an organization must demonstrate to EPA's satisfaction that they posses the qualifications and capabilities listed below:
Develop and administer all aspects of a national quality assurance/quality control program for the design, production, and construction of ENERGY STAR certified factory-built homes that includes the following four elements: (1) ENERGY STAR labeled home requirements; (2) plant certification; (3) builder qualification; and (4) compliance verification:
- Develop a comprehensive program guide that details the in-plant and on-site construction, inspection and verification procedures, including protocols for addressing non-compliance in the plant and at the site. This program guide must also establish qualifications and eligibility criteria for third-party consultants, plants, and builders.
- Establish a mechanism for reporting program activity including but not limited to certified plants, certified homes, non-compliance issues, approved third-party consultants and other program data to EPA on a regular basis.
Accredit and track third-party consultants who certify a plant's readiness to consistently produce ENERGY STAR certified homes and spot-check field installation of homes produced by certified plants:
- Provide and enforce a nationwide accreditation process that verifies the training, skills and knowledge of third-party consultants. This includes the use of detailed application forms, mandatory training, and on-going education and collaboration meetings required to maintain accreditation.
- Maintain a database of accredited third-party consultants who can assist plants with improving the energy efficiency of factory-built homes such that they meet ENERGY STAR guidelines, certify the plants as proficient in producing ENERGY STAR certified homes, and inspect field installations of these homes.
Develop and manage a national labeling process that ensures ENERGY STAR certified homes are produced in certified plants and visually inspected and labeled onsite by a third-party consultant:
- Provide and enforce a nationwide process that verifies the training, skills and knowledge of third-party consultants.
- Develop, produce, and distribute labels signifying that ENERGY STAR certified homes were built in plants certified by accredited third-party consultants.
- Demonstrate expertise in the processes required to upgrade factory-built housing plants to produce ENERGY STAR certified homes.
Oversee and enforce all in-plant and on-site quality control processes involved in building ENERGY STAR certified homes and be responsible for necessary corrective actions:
- Monitor field inspections of installed ENERGY STAR certified homes conducted by accredited third-party consultants, investigate failures impacting the energy performance of these homes as identified during field inspections, and facilitate corrective actions with third-party consultants, plant representatives, and builder representatives. Share information about non-compliance with ENERGY STAR program requirements with EPA in a timely manner for further action. This includes:
- When homes are found to have been improperly labeled as ENERGY STAR and confirmed by the QAP:
- EPA will be notified of the plant certifier, plant, builder, rater, and address(s) of the affected home(s).
- The QAP will provide a signed affidavit and sufficient documentation that the home(s) do not meet ENERGY STAR program minimum requirements.
- EPA will inform the plant and builder partners of the QAP's findings and provide the plant and builder 90 days to apply corrective action to the affected home(s) that results in compliance with the relevant standard.
- A plant certifier and rater not associated with the original labeling of the home(s) must confirm compliance to relevant standard in order for corrective action to be accepted.
- If the home(s) are not brought to program standards within 90 days, EPA will inform the affected homeowner(s), the plant, the builder, the plant certifier, and the rater. The partnership status of the plant and/or builder will be terminated and EPA will remove the affected home(s) from ENERGY STAR's database.
- In the event that EPA staff or its contractors conduct formal or informal reviews of ENERGY STAR certified homes and files, these reviews will also supplement the QAP's QA process. Discrepancies discovered by EPA staff or contractors will be forwarded to the QAP and will trigger an independent inquiry into the discrepancies in question.
- When ENERGY STAR program sponsors undertake quality assurance reviews of ENERGY STAR certified homes, the reviews will serve to supplement the QAP's QA process. In the event the program sponsor informs either EPA or the QAP of any significant discrepancies found, then that party receiving the information from the sponsor will notify the other party. An independent inquiry will be conducted by the QAP into the discrepancies in question.
- Collect, maintain, and distribute information about ENERGY STAR certified homes nationwide. This includes contact information on accredited third-party consultants, manufacturing plants that have been certified to produce ENERGY STAR certified homes, the number of ENERGY STAR certified homes produced by each certified manufacturing plant, and the remediation problems of homes found not to meet energy efficiency specifications during field spot checks.
- Review all third-party consultants' records for homes that have been field inspected to ensure compliance with ENERGY STAR energy efficiency guidelines, adherence to field testing procedures, and proper remediation of identified problems.
- Based on tracking data and spot-checking of third-party consultant records, provide random quality control inspections of field verified homes by third-party consultants.
Communicate important developments within the industry:
- Demonstrate leadership researching and analyzing factory-built housing issues related to energy efficiency for all climate zones.
- Demonstrate proven experience facilitating energy-efficiency programs and initiatives with factory-built industry stakeholders across the nation including manufacturing plants, retailers, HUD inspection agents, and industry associations.
- Serve as liaison between factory-built housing industry stakeholders (plants, builders, retailers/dealers, HUD inspection agents, industry associations) to assure an effective and timely interchange of information as it relates to the development, implementation, marketing, and maintenance of energy efficiency programs, initiatives, and innovations.
- Coordinate national/regional training and educational programs among factory-built housing plants, communities, builders, and retailers regarding building and selling ENERGY STAR certified homes. This includes maintaining a web site, publishing reports and brochures, conducting seminars, providing presentations, and supporting conferences/workshops related to ENERGY STAR certified homes.