November 10, 1999 Office of the Secretary Subject: ANPR Comment, R-value Rule, 16 CFR Part 460 Dear Secretary, Federal Trade Commission: The Celotex Corporation has reviewed the Trade Regulation Rule: Labeling and Advertising of Home Insulation; Proposed Rule dated September 1, 1999 and provides the following comments to the Commissions solicitation of comments. Reference: 48027, IV. 2. Non-residential Insulations Celotex supports the extension of the Rule to cover insulation products used in all buildings including residential and commercial applications. While no misrepresentations of thermal insulation performance of commercial insulations have been evident, the information overload present today places an increased burden on design professionals to rely solely on insulation manufacturers for technical information and training. This results in a significant responsibility for providing accurate and representative thermal insulation testing data on the manufacturer. Celotex did not support extending the Rule to commercial applications in comments submitted on June 5, 1995. However, Celotex resigned as a member of the Polyisocyanurate Insulation Manufacturers Association (PIMA) in December 1998. This resignation was prompted by several issues including the method of aging, testing and reporting the R-value of permeable faced polyiso insulation. Permeable faced polyiso is characterized by the use of organic felt or glass mat facers applied to the core foam. Secretary, Federal Trade Commission – continued November 10, 1999 Page 2 of 3 The application of the R-value Rule to commercial applications would also standardize the performance reporting method which simplifies the specification process for the architectural community. Reference: 48031, 1., a. Cellular Plastic Insulations Celotex Corporation supports the use of ASTM C 1303 as the most accurate method of determining the Design (Stabilized) R-value of permeable faced cellular plastic insulations blown with a non-air agent (for example: HCFC-141b, HCFC-142b, hydrocarbon). Testing programs have been conducted on permeable faced polyisocyanurate and extruded polystyrene insulations in accordance with the ASTM C 1303 method. These tests demonstrated the Design R-value for permeable faced polyisocyanurate of 5.6 to 6.3 per inch of thickness and for extruded polystyrene of 4.2 to 4.7 per inch of thickness. The R-value range is due to the insulation thickness and length of time (10 years, 20 years, etc.) for which the Design R-value is determined. It should be noted that the permeable faced polyiso R-value range is nearly identical to the range in the ASHRAE Fundamentals Handbook for this type of polyiso insulation. Celotex supports the use of the ASTM C 1303 test method for determining the Design-R-value for all permeable faced cellular plastic insulations (polyisocyanurate and polystyrene) blown with non-air agents. A schedule for implementation of 2 years would allow manufacturers sufficient time to conduct the necessary testing and revise published literature. Celotex has conducted numerous tests per ASTM C 236 and C 518 on impermeable faced (aluminum foil facers) free-rise polyisocyanurate insulation that has been aged using the 90 day/140 F accelerated aging method referenced in ASTM C 1289. The adhesion of impermeable facers to a core foam is critical to the effectiveness of the facer in providing long-term R-value retention. Polyisocyanurate insulation is manufactured using two distinct processes, free-rise and restrained-rise, and the testing of impermeable faced insulation using the 90 day/140 F aging method is the most accurate method in determining the Design R-value. The results of multiple R-value testing programs have demonstrated that this accelerated aging method provides an excellent correlation to the long-term aged R-value of impermeable faced polyiso insulation. Celotex supports the use of the 90 day/140 F accelerated aging method for determination of the Design R-value of impermeable faced cellular plastic insulation blown with non-air agents. Secretary, Federal Trade Commission – continued November 10, 1999 Page 3 of 3 Reference: 48037, 3. Tolerance Celotex supports the requirement that manufacturers design products to meet 100% of the claimed R-value. Manufacturing specifications must reflect the product performance for the published Design R-value for each thickness marketed. However, we believe that a specification regarding sampling requirements would be extremely burdensome to the manufacturers. A statement could be included such as, "The sampling technique used to determine the Design R-value for an insulation must determine the average Design R-value for a full-size board unit". This statement requires the manufacturer to accurately represent the Design R-value for the insulation without prescribing specific sampling requirements which may be different based on the type of insulation. If you require additional information or clarification, please contact the Technical Services Department at (800) 622-6075, ext. 4276. Sincerely, Douglas C. Gehring, P.E. cc: M. E. Londrigan, Celotex Technical Center |