| The
National Air Duct Cleaners Association (NADCA)
has released the much-anticipated public review
draft of the organization's new Standard for
Assessment, Cleaning and Restoration of HVAC
Systems for Hygiene, otherwise known as ACR-2000.
The document is available free of charge via the
NADCA website (www.nadca.com) during a
60-day comment period that began at the beginning
of this month.
This article provides an overview of the
standard's primary sections, including commentary
regarding new material added since the 1992
publication of ACR-2000's predecessor, NADCA
Standard 01, Mechanical Cleaning of Non-Porous
Air Conveyance System Components.
Standard 01-1992 limited its scope to fundamental
HVAC system cleaning project requirements and
methods to evaluate cleaning effectiveness.
ACR-2000 attempts to establish far more detailed
project requirements as well as strict criteria
for a whole new range of elements related to
system maintenance and construction. Like the
original NADCA standard, ACR-2000 defines methods
and procedures to measure system cleanliness. The
new standard also includes a unique system that
integrates building classification, debris
identification and applicable engineering
controls to produce project specifications and
criteria.
A Broad Scope
According to Section 1.1, Scope, ACR-2000
establishes requirements for cleaning contractors
and their clients, as well as for IAQ
professionals who investigate HVAC system
cleanliness and condition. These requirements
cover system assessment, cleaning methods and
equipment for both general hygiene and HVAC
system performance.
Going further, the requirements within ACR-2000
are categorized and systematized to "address
occupancy type, building use, contaminant type,
worker and occupant health and safety,
environmental engineering controls, project
monitoring, remediation; and environmental
considerations for removal and installation of
HVAC components." That's a tremendous scope,
and critics of the standard may argue that NADCA
has stepped outside its members' domain in
certain areas.
While Section 1 is titled "General,"
subpart 4 goes beyond general and probably could
stand as a section unto itself. Titled,
"When to Remediate," 1.4 provides
information consumers and contractors have
requested for years - a guide to determining when
HVAC system cleaning is really needed. According
to ACR-2000, if an assessment reveals any of four
adverse conditions, remediation is required. For
example, evidence of "significant quantity
of particulate or debris" within a system
"which may adversely affect the indoor
environment or HVAC system performance"
mandates cleaning. Unfortunately, however, the
standard fails to qualify key terms like
"significant quantity" and
"adversely affect."
When particulate is discharged from the HVAC
system into occupied spaces, ACR-2000 mandates
cleaning. The standard includes an appendix that
describes a procedure called "Aggressive
Particle Profiling" that compares
particulate levels in the return space (before
filtration) with levels distributed by supply
ducts. This procedure enables the standard's user
to determine of the HVAC system is releasing
contaminants into occupied spaces. The procedures
specified in the appendix are difficult to
follow, however, and should be rewritten and
explained with greater clarity.
Other times system remediation is required
include when system performance is compromised
due to debris blockages within mechanical
components, when contamination is left behind
after system installation or retrofit, and as
part of a proactive hygiene maintenance program.
Assessment
Section 2 of ACR-2000 breaks important ground. It
describes how procedures common to HVAC system
cleaning may negatively affect the indoor
environment, and it requires a complete
assessment of how cleaning processes will be
managed to prevent any additional contamination
of occupied spaces. A more detailed discussion of
specific procedures that might expose occupants
to contaminants would greatly enhance the
engineering controls to contain debris during
cleaning that are defined in section 5 of the
standard.
"HVAC Hygiene Assessment" is the third
section of the standard. It describes the areas
of a system that must be evaluated in order to
determine the need for cleaning. More importantly
to the overall construction of the standard,
however, is a unique set of building
classifications and associated assessment
criteria contained in this section. Buildings are
classified as follows: Class 1 - Industrial;
Class 2 - Residential; Class 3 - Light
Commercial; Class 4 - Commercial; Class 5 -
Health Care; Class 6 - Marine; and Class 7 -
Special Use Areas. The first part of Section 3
addresses cleanliness assessment criteria common
to all classes of buildings, such as HVAC
component condition, contamination levels and
system performance abnormalities. This is
followed by subparts for each building
classification that contain assessment criteria
that may be unique to a particular class.
While the assessment criteria make sense overall,
some appear unrealistic. For example, a
"commercial" building hygiene
assessment must include particulate profile
testing using the Aggressive Particle Profile
procedure described in Appendix C. Also required
is air testing and balancing "to determine
if deposits and/or contaminants are contributing
to a reduction in system performance." Given
the myriad of factors beyond cleanliness that may
affect system performance, not to mention cost
involved, the practicality of testing and
balancing as part of a hygiene assessment is
questionable.
Section 4, HVAC Hygiene Maintenance, defines
minimum inspection frequencies for the classes of
buildings defined in Section 3. Classes 1 to 4
require annual hygiene assessments of air
handling units and representative sections of
supply and return ductwork. In more sensitive
environments, frequency increases.
Specification
Development And Project Planning
A key component of ACR-2000 is Section 5. Here
NADCA attempts to provide a standard for the
development of project specifications and
requirements using a series of tables that build
upon one another. In the first table the building
classification is established. Within the second
table, the project type - A, B, or C - is
determined based on whether there is debris or
particulate contamination, and microbial
contamination, within the HVAC system. With the
project type known (although many projects could
fall into types B or C without a clear
distinction why), a third table maps out the
degree to which 13 different engineering controls
must be employed.
As an example, in a commercial building with dust
and mold in the HVAC system (type B or possibly
C) ambient air cleaning is required during and
after cleaning, "to provide ambient airborne
particle reduction." If the system were only
to contain dust and no mold, then it would be
classified type A and ambient air cleaning would
be recommended but not required. When carefully
studied, the overall system of tables does make
sense. It took this reviewer about an hour to
figure out how the system works. The failure to
clearly delineate when a project is type B versus
C, however, is a weakness that must be corrected.
The current ambiguity leaves too much room for
incongruity between projects of a similar size
and scope.
Ultimately, if NADCA expects the marketplace to
adopt its system for specification development
and project planning, the association will need
to conduct workshops for facility managers and
engineers to teach them how to apply the standard
to their buildings. For residential applications,
the system is impractical from a consumer's point
of view, since few homeowners would take the time
or have the wherewithal to figure it out.
Supplemented by NADCA's existing safety manuals
for contractors, Section 6 of ACR-2000 covers
health and safety issues for workers adequately.
Section 7 repeats the key provisions of NADCA
Standard 05, Requirements for the Installation of
Service Openings in HVAC Systems, along with a
few improvements to the 1997 access door
standard.
Cleaning
Section 8, Mechanical Cleaning of HVAC Systems,
reconfirms some of the principles that have
guided NADCA since its inception, such as the use
of Source Removal cleaning techniques and
prohibitions against the use of encapsulants to
trap debris in place. The necessity to include
some method of agitating or dislodging debris is
set forth; however, specific methods are not
listed. Requirements for use of tools like manual
brushes, compressed airwhips, cleaning robots and
mechanical brushes could help prevent system
damage from improper use but are not provided.
Subpart 8.2 covers Remote Vacuum Collection - the
use of a large vacuum to create sufficient air
movement within a section of an HVAC system to
entrain and remove particles of debris. A table
is provided that defines required air movement
velocity to collect a wide variety of dust types.
How Clean Is
Clean?
Answering the question, How Clean is Clean?, was
a primary goal when NADCA wrote Standard 01 in
1992. ACR-2000 also covers this territory,
although the precise details have yet to be
released for one cleanliness verification method
and the draft is therefore incomplete in this
section.
Three levels of cleanliness verification are set
apart. The first is visual inspection. If visual
inspection disputes that acceptable cleanliness
levels have been achieved, the next level come
into play - the NADCA Contact Vacuum Test. The
test defined in the standard is a hybrid of the
verification method contained in Standard
01-1992. Improvements to the method developed
three years ago during joint NADCA-EPA research
are included in the new standard.
The third level of cleanliness verification has
yet to be published. It is called the "NADCA
Quantitative Vacuum Test" and within the
draft version of ACR-2000 readers are informed
that this test method is under development.
According to the standard, cleanliness
verification must be performed before the system
or component is placed into operation. While this
make sense from a contractor perspective -
external factors might contaminate a just-cleaned
system - in reality it's not a very practical
requirement to follow. If followed to the letter,
a consumer would be required to have an inspector
on-site as each component was completed and
placed back on line. While some commercial
consumers may be willing to take such an
approach, many would find it cost prohibitive and
restrictive. The standard requires the client to
"assign a representative to act as an
assurance manager for verifying the HVAC
component post cleaning." It goes onto
specify that if no such manager is assigned,
"the contractor shall perform post-cleaning
assessments." This is likewise not the best
solution - the old fox watching the hen-house
scenario.
Section 10 of the standard addresses Remediation
of Biological Contamination. A significant
portion addresses porous materials (e.g.,
fiberglass), and recommends removal and
replacement when possible in most instances.
Other requirements call for the implementation of
management plans to locate and correct the system
deficiencies that allowed moisture and debris to
accumulate and foster microbial growth.
Restoration
The restoration section of ACR-2000, Section 11,
primarily covers restoration of damaged
fiberglass liner. First an assessment of HVAC
system component condition is specified.
Acoustical lining damaged by fire, smoke, flood
or water-damage must be evaluated for resurfacing
or replacement. Some criteria are also defined
for the use of encapsulating and coating
products.
While adequate in the area of fiberglass
assessment and refurbishment, the restoration
section lacks detail regarding fire and water
restoration decontamination procedures. For
instance, NADCA should consider adopting some of
the provisions from Institute of Inspection
Cleaning and Restoration Certification (IICRC)
Standard S500, Water Damage Restoration. An
understanding of the different categories of
water in water-damage situations should be
incorporated into the assessment of the HVAC
system when water damage is the primary
contamination source. Clean water decontamination
procedures would obviously require less stringent
controls and methods than decontamination after
damage from a sewer backup.
Extending Their
Domain
In Section 12, Maintaining the Indoor Environment
During HVAC Remediation and Commissioning,
ACR-2000 addresses subjects that go beyond the
scope of what people might think the NADCA
standard would include. It calls for an
environmental impact study before activities such
as HVAC system repair, retrofit, installation and
commissioning. In essence, the section attempts
to establish engineering controls to protect the
indoor environment from contamination by HVAC
system pollutants during all HVAC repair and
engineering activities. The goal is admirable,
but a separate environmental control standard for
these activities could easily stand on its own.
And it would seem logical for the creation of
such a standard to be initiated by professionals
in the fields most affected: HVAC contracting,
engineering and test and balance.
The final section of the standard is titled
Project Monitoring and it details steps to be
taken to monitor and evaluate the effectiveness
of engineering controls implemented to protect
the indoor environment.
Confusing Parts
While commendable for its ambitious scope,
ACR-2000 is difficult to follow in a few key
areas. This especially the case in Section 5,
where a series of charts are provided to assist
in classifying buildings, project types and
appropriate engineering controls. The charts are
helpful, but a more detailed explanation of how
to use them, as well their limitations, is needed
within the text of the section.
Perhaps as a result of their efforts to get a
draft standard on the street before NADCA's
annual convention next month in Phoenix, errors
in section numbering, spelling mistakes and other
typos make certain sections document particularly
confusing. An incorrectly numbered chart that
defines environmental engineering controls for
different types of facilities and contamination
levels left this reviewer frustrated and
perplexed until the error was recognized.
When NADCA Standard 01-1992 was drafted, it went
out for a 90-day review and the association
received a lot of feedback from industry experts
and trade groups. Key professionals from groups
such as ASHRAE Standard 62 subcommittee, ARI
technical staff, NAIMA and others gave positive
feedback enabling NADCA to produce a standard
that has been well respected for almost a decade.
With the comment period reduced by 30 days and
the scope of the standard increased dramatically,
one hopes that such professionals will still find
the time and energy to give meaningful comments.
For while ACR-2000 is certainly in need of
revisions, at its core it contains some valuable,
innovative information and requirements that
could help to improve the HVAC system cleaning
industry and protect its consumers.
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