EPA Water Sense Response to Public Comments Received on Draft WaterSense® Professional Certification Program Labeling System and Revised Specifications for Professional Certification Programs July 24, 2014 ------- EPA Response to Public Comments Received on Draft WaterSense® Professional Certification Program Labeling System and Revised Specifications for Professional Certification Programs WaterSense Background This document provides WaterSense's responses to public comments received on the draft WaterSense Professional Certification Program Labeling System and Revised Specifications for Professional Certification Programs. For purposes of this document, the comments are summarized. The verbatim comments can be viewed in their entirety at www.epa.gov/watersense/partners/programspecs.html. 2 July 24, 2014 ------- Response to Public Comments Received on Draft WaterSense Professional Certification Program Labeling System and Revised Specifications CT jCUSC for Professional Certification Programs Table of Contents I. Comments on Section 1.0: Introduction 4 II. Comments on Section 2.0: Effective Date 4 III. Comments on Section 3.0: Scope 4 IV. Comments on Section 4.0: References and Definitions 4 V. Comments on Section 5.0: Eligibility Requirements for Professional Certifying Organizations (PCOs) 4 VI. Comments on Section 6.0: Application 6 VII. Comments on Section 7.0: Authorization to Use the Label 6 VIII. Comments on Section 8.0: PCO Roles and Responsibilities 7 IX. Comments on Section 9.0: EPA Roles and Responsibilities 8 X. Comments on Section 10.0: Misuse, Suspension, or Withdrawal of the WaterSense Label From a PCO 9 XI. Comments on Section 11.0: Amendments, Modifications, and Revisions 9 XII. Comments on Section 12.0: More Information 9 XIII. General Comments on the Professional Certification Program Labeling System. 9 XIV. Comments on the Revised Specifications 10 3 July 24, 2014 ------- EPA Response to Public Comments Received on Draft WaterSense® Professional Certification Program Labeling System and Revised Specifications for Professional Certification Programs WaterSense I. Comments on Section 1.0: Introduction WaterSense received no comments on the labeling system's introduction. II. Comments on Section 2.0: Effective Date Effective Date a. One commenter responded in support of the one-year compliance requirement. Response: WaterSense appreciates the comment. III. Comments on Section 3.0: Scope WaterSense received no comments on the labeling system's scope. IV. Comments on Section 4.0: References and Definitions WaterSense received no comments on the labeling system's references and definitions. V. Comments on Section 5.0: Eligibility Requirements for Professional Certifying Organizations (PCOs) Accreditation Path a. Two commenters suggested eliminating the accreditation path and allowing one path for organizational approval. Both commenters felt that the non-accreditation path has sufficient rigor to uphold the quality of the WaterSense label. One commenter was not aware of any PCOs that currently meet the accreditation path requirements and stated that, while inclusion of an accreditation path might elevate the WaterSense program on paper, it does not increase professionalism of irrigation practitioners. The commenter was also concerned that including the accreditation path was a signal that WaterSense might eventually require accreditation, which would put additional burden on PCOs. b. Another commenter noted their support for the inclusion of the accreditation path for PCOs. The commenter suggested that WaterSense use third-party accreditation as a minimum standard for the program, perhaps after a three-year period. Response: WaterSense has revised the terminology used in the labeling system to better describe the accreditation options. Both paths involve accreditation so the labeling system differentiates between accreditation provided by WaterSense and accreditation provided by a third party. To reflect this distinction, the final 4 July 24, 2014 ------- EPA Response to Public Comments Received on Draft WaterSense® Professional Certification Program Labeling System and Revised Specifications for Professional Certification Programs WaterSense labeling system references the "third-party accreditation path" and the "WaterSense accreditation path." WaterSense does not intend to require third-party accreditation in the future. WaterSense provided for a third-party accreditation path in the labeling system only to streamline the approval process for organizations that are already accredited by a third party or choose to pursue it in the future. To date, at least one WaterSense PCO partner has been accredited by a third party. Security of Assessment Instruments c. One commenter requested that WaterSense add clarifying language regarding whom is allowed to administer the exam. The commenter stated that allowing the same person to serve as both a trainer and test proctor is contrary to best practices for certification. The commenter added that PCOs are judged on their effectiveness by the percentage of students who pass the exam. Where the PCO, and specifically the trainer, is also proctoring the exam, there is a private or personal interest sufficient to influence or appear to influence the objective exercise of the proctor's official duties. The commenter suggested the following change to Section 5.2.2.6: "The PCO shall have procedures in place to ensure that exams are administered proctored by an independent academic institute, a professional testing organization, professional test administrator, or a professional certified in the subject matter not involved in the training." Response: WaterSense appreciates this suggestion but has concluded that adopting it would place an undue burden on some PCOs. PCOs that offer certification programs at many locations do so by using a single practitioner. Offering training programs at multiple locations expands the program's geographic reach and affords more opportunities for irrigation professionals to earn certifications. Requiring PCOs to enlist a separate exam proctor would discourage this practice and could restrict opportunities. Therefore, WaterSense has made the following changes to clarify the roles outlined in Section 5.2.2.6: • The PCO shall have procedures in place to ensure that exams are administered proctored by an independent academic institution, a professional testing organization, professional test administrator, or a professional certified in the subject matter. Requirements for Adopting PCOs d. One commenter suggested delaying implementation of the Adopting PCOs portion of the program (with the exception of existing adopting PCOs) to free up WaterSense resources for the short term. The commenter suggested that this would allow new Parent PCOs to apply and become established, while building the appropriate framework for adding Adopting PCOs in the future. 5 July 24, 2014 ------- EPA Response to Public Comments Received on Draft WaterSense® Professional Certification Program Labeling System and Revised Specifications for Professional Certification Programs WaterSense Response: WaterSense does not believe that delaying implementation would free up resources. WaterSense already accommodates the Adopting PCO and Parent PCO process on an informal basis. The labeling system formalizes a process that is developed and functioning efficiently. VI. Comments on Section 6.0: Application Application Requirements for Adopting PCOs a. One commenter expressed dissatisfaction with the application process for Adopting PCOs. The commenter felt that splitting responsibilities between the Parent PCO and WaterSense is confusing, and that the Parent PCO should assume all responsibility for the activities and performance of the Adopting PCO. The commenter questioned what would happen if the relationship between a Parent PCO and an Adopting PCO ended. The commenter added that, because the Adopting PCO is a WaterSense partner, the Parent PCO would have to rely on WaterSense to take independent action to end the relationship with the Adopting PCO. Response: Parent PCOs are required to assume responsibility for the activities and performance of the Adopting PCO. The application requirements outlined in Section 6.2 provide WaterSense with oversight over this process. WaterSense has revised Section 8.2.1 of the labeling system to clarify that a Parent PCO must notify WaterSense if it discontinues the relationship with an Adopting PCO. WaterSense will discontinue partnership with any PCO partner not offering a WaterSense labeled certification program in accordance with the terms of the WaterSense Partnership Agreement for Professional Certifying Organizations. VII. Comments on Section 7.0: Authorization to Use the Label Parent PCO Label Use a. One commenter requested that EPA provide label artwork to Parent PCOs that includes the name of the labeled program for use by the Adopting PCOs. The purpose would be to associate the adopted program with the Parent PCO, similar to the process used by WaterSense's labeled products program with the licensed certifying body. Response: It is not feasible for WaterSense to create and then monitor the use of program-specific labels. However, WaterSense encourages Parent PCOs to work with their Adopting PCOs to define and implement a format that depicts and/or articulates the relationship between the two parties as long as the format does not contradict the WaterSense Program Mark Guidelines. 6 July 24, 2014 ------- EPA Response to Public Comments Received on Draft WaterSense® Professional Certification Program Labeling System and Revised Specifications for Professional Certification Programs WaterSense WaterSense Program Mark Use by Irrigation Professionals b. One commenter expressed support for allowing individuals who hold labeled certifications to use the WaterSense promotional label in their marketing materials. While these marks will no longer state that that individual is a "WaterSense partner," many irrigation contractors use the WaterSense designation as a successful marketing tool. Response: WaterSense agrees and will allow certified professionals to use the WaterSense promotional label as referenced in Section 8.1.5. WaterSense Program Mark Guidelines a. One commenter noted that the change of partnership status for irrigation professionals and new program mark instructions are somewhat unclear. The commenter proposed that certified professionals be allowed to use a version of the WaterSense label with the PCO's name in place of the WaterSense partner logo. The commenter suggested that by replacing WaterSense partner logo with the WaterSense promotional label, the number of individuals completing the certification process could diminish. The commenter also suggested including program mark examples within the labeling system. • Response: The labeling system specifies that certified professionals can use the WaterSense promotional label artwork, which encourages consumers to "look for" the WaterSense label. Individual irrigation professionals are not permitted to use the WaterSense label because WaterSense labels certification programs, not individual professionals. Irrigation professionals should advertise that they have earned a WaterSense labeled certification by using the WaterSense promotional label. WaterSense will provide PCO partners with information for certified professionals, including examples of how to use the promotional label to market their certification. Responsibilities Regarding Adopted Programs b. One commenter noted appreciation for the clear language delineating the relationship between the Parent PCO and Adopting PCO in regard to WaterSense certification. The language assures that the quality of WaterSense label is retained without specifying other aspects of any agreement between a Parent PCO and Adopting PCO. Response: WaterSense appreciates the comment. VIII. Comments on Section 8.0: PCO Roles and Responsibilities 7 July 24, 2014 ------- EPA Response to Public Comments Received on Draft WaterSense® Professional Certification Program Labeling System and Revised Specifications for Professional Certification Programs WaterSense Maintain a Listing of Certified Professionals c. One commenter requested that WaterSense continue to maintain an online listing of certified professionals. The commenter noted that transferring responsibility for listing of certified professionals to the PCO might increase costs for the PCO (e.g. for dedicated staff and technology to maintain a publicly accessible listing). These costs would have to be recouped by increasing fees for professionals to become certified, which could deter some professionals from seeking certification. Having professionals listed on one central EPA-supported website also provides a common listing for clientele, which is important where multiple PCOs offer certifications within a geographic area. Response: WaterSense does not anticipate that maintaining an online listing will be a burden to PCOs because the majority of PCO partners already have some type of online listing in place. However, WaterSense has revised the labeling system to provide for one centralized listing of all certified professionals on the WaterSense website. Specifically, in Section 9.0, EPA's roles and responsibilities have been expanded to include "host and maintain a consolidated list of all certified professionals on the WaterSense website." To implement this role, WaterSense also revised Section 8.1.4 to indicate that PCOs shall report quarterly to WaterSense basic contact and business information for each certified individual using a standardized format provided by WaterSense. Parent PCOs are responsible for reporting this information to WaterSense on behalf of their Adopting PCO(s). Reporting Requirements for Adopting PCOs d. One commenter suggested that Parent PCOs be responsible for submitting annual data to WaterSense for its Adopting PCOs. The commenter felt that allowing Adopting PCOs to manage and report on certifications locally—even if coordinated with the Parent PCO—could lead to unequal and inaccurate reporting platforms and possible duplication or missed information. Response: WaterSense believes that the annual data reporting process will be most efficient if all PCOs are required to report program activity, statistics, and feedback to WaterSense on an annual basis. WaterSense has updated the labeling system to clarify that all PCOs shall comply with the roles and responsibilities listed in Section 8.1, as opposed to only EPA Approved PCOs. All PCOs shall report annually activity and statistics pertaining only to professionals that their organization certified. IX. Comments on Section 9.0: EPA Roles and Responsibilities WaterSense received no comments on the labeling system's "EPA Roles and Responsibilities" section. 8 July 24, 2014 ------- EPA Response to Public Comments Received on Draft WaterSense® Professional Certification Program Labeling System and Revised Specifications for Professional Certification Programs WaterSense X. Comments on Section 10.0: Misuse, Suspension, or Withdrawal of the WaterSense Label From a PCO WaterSense received no comments on the labeling system's "Misuse, Suspension, or Withdrawal of the WaterSense Label From a PCO" section. XI. Comments on Section 11.0: Amendments, Modifications, and Revisions WaterSense received no comments on the labeling system's "Amendments, Modifications, and Revisions" section. XII. Comments on Section 12.0: More Information WaterSense received no comments on the labeling system's "More Information" section. XIII. General Comments on the Professional Certification Program Labeling System State Agencies and Academic Institutions Being Professional Certifying Organizations a. One commenter raised concerns that the labeling system does not adequately address a scenario where the PCO is a state agency or academic institution. The commenter requested an exemption for state agencies or academic institutions from the requirement that exams be reviewed by an independent academic institution or professional testing organization. The commenter stated that these types of organizations with experience offering testing services for other programs already exhibit institutional stability, and the requirement to seek additional review and services might result in increased costs to maintain partnership. Response: WaterSense's existing program specifications already allow for academic institutions to have a different department within the institution review the exam as long as the two departments are considered independent. To clarify that this exception will continue, WaterSense revised the program labeling system by adding a footnote (see Section 5.2.2.5) that states "If the PCO is an academic institution, then a different department within the institution may review the exam as long as the departments are autonomous and considered independent." 9 July 24, 2014 ------- EPA Response to Public Comments Received on Draft WaterSense® Professional Certification Program Labeling System and Revised Specifications for Professional Certification Programs WaterSense Expanding the Types of Certification Programs That Can Earn the WaterSense Label b. One commenter applauded WaterSense for taking the steps necessary to expand the types of certification programs that can earn the WaterSense label and extend the benefits of the WaterSense program to a larger number of certified individuals. The commenter noted that plumbing industry training organizations, plumbing contractors, and plumbers are eager to support and promote WaterSense. c. One commenter requested that WaterSense develop a specification for programs certifying landscape architects. The commenter felt that the U.S. Green Building Council's LEED® program requires too much paperwork, and that any WaterSense specification should use a performance-based system. Response: One of the primary reasons EPA created the Professional Certification Program Labeling System was to allow WaterSense to label a broader range of certification programs that can affect water use. WaterSense will develop additional program specifications as soon as time and resources allow. XIV. Comments on the Revised Specifications Experiential Requirement a. One commenter discussed expanding the installation and maintenance specification to also include irrigation technician programs. The commenter requested that WaterSense reduce the experiential requirement in the system installation and maintenance specification to six months. The commenter also requested that WaterSense allow education in lieu of work experience, based on a minimum number of hours from an accredited institution. The commenter had seen increased interest from academic institutions that want their students to graduate with a valid certification. Response: WaterSense does not plan to change the installation and maintenance specification to accommodate these types of programs, because the existing specification is not intended to be an entry-level certification program. However, in the future, WaterSense will consider developing a separate specification for irrigation technician programs. Exam Content b. One commenter stated that, based on certification best management practices developed by third-party authorities, legally defensible exam programs should begin with a job analysis which clearly defines the knowledge, skills and abilities needed to complete a specific job. A job analysis is the basis for the exam content outline. The commenter suggested that if an organization has completed a valid job analysis, it should take precedence over the exam content 10 July 24, 2014 ------- EPA Response to Public Comments Received on Draft WaterSense® Professional Certification Program Labeling System and Revised Specifications for Professional Certification Programs WaterSense WaterSense has outlined. The job analysis could be submitted to WaterSense as proof of completion, while organizations that do not have a valid job analysis can follow the exam content guidelines set by WaterSense. Response: WaterSense agrees that there is potential for incorporating job task analysis into the specifications. However, WaterSense is not prepared to define requirements for job task analyses at this time. Furthermore, a job task analysis is based on proficiency, but WaterSense's specifications address both proficiency and water efficiency. A professional can be proficient without being water-efficient. c. One commenter requested that the bullet in Section 2.2.1 of the WaterSense Specification for Irrigation System Designer Certification Programs that reads "Preparation of site design reflecting site requirements" be removed and replaced with "Preparation of irrigation design reflecting site requirements." Response: WaterSense agrees with this recommendation and has updated the language in the specification. d. One commenter requested that the "equipment commissioning" bullet in Section 2.2.1 of the WaterSense Specification for Irrigation System Installation and Maintenance Certification Programs be removed. The commenter stated that equipment commissioning is not a core competency for the irrigation system installation and maintenance professional as defined in Section 4.0. Response: WaterSense has determined that equipment commissioning is a core competency for the irrigation system installation and maintenance professionals and therefore has kept this requirement. From an efficiency standpoint, WaterSense believes it is important that equipment is tested to verify that it functions properly. Maintained Proficiency a. One commenter requested that "water-efficient concepts" should be defined as any material or activity directly relating to irrigation concepts and principles. This can include, but is not limited to, irrigation scheduling, auditing, hydraulics, installation, maintenance, and backflow practices. The commenter proposed that water-efficient concepts should include any continuing education units (CEUs) that are directly related to irrigation, including those that are product-specific. Response: WaterSense has revised the three irrigation specifications to include a definition for "water-efficient concepts." As stated in the Application to Label a Professional Certification Program, PCOs will be required to provide the language used by the PCO to ensure that the set percentage of the proficiency requirements, as outlined in the specification, are related to water-efficient concepts. 11 July 24, 2014 ------- EPA Response to Public Comments Received on Draft WaterSense® Professional Certification Program Labeling System and Revised Specifications for Professional Certification Programs WaterSense b. One commenter stated that proposed maintained proficiency criteria does not take into consideration the impact on irrigation professionals with multiple certifications. The commenter stated that the new requirement to have 50 percent of CEUs in water efficiency for each category would significantly increase the number of CEUs required. The commenter suggested two possible changes. First, keep the 50 percent requirement but specify that it either applies to the total cumulative CEUs required by the PCO or to only one certification when an individual has more than one qualifying certification. Second, set a minimum number of CEUs dedicated to water efficiency, rather than a percentage. The commenter suggested a minimum number between four and 10 CEUs every two years. Response: WaterSense did not intend to require CEUs across all areas for multiple certifications. To address this concern, WaterSense has removed the words "auditing," "design," and "installation and maintenance" from the specifications. c. One commenter requested that WaterSense consider a mandate for a minimum number of CEUs required for a labeled certification. The commenter suggested that the minimum be set at 16 CEUs every two years, equivalent to a one-day class on irrigation per year. The commenter felt that this requirement provides a minimum amount of education necessary for an irrigation professional to practice water-efficient irrigation techniques, and demonstrates a firm commitment to water efficiency. Response: WaterSense does not strictly define CEUs. This allows programs flexibility in developing continuing education requirements but also makes it impractical for WaterSense to set a minimum number of CEUs when the type and rigor of various programs' CEUs might vary. For example, some PCOs do not require classes, but rather require their certified professionals to track and report landscape water use over time for a minimum number of landscapes. 12 July 24, 2014 ------- |