I was amused, and maybe a little surprised, to find a snail mail, printed letter from NAIMA, the North American Insulation Manufacturers Association, in my mailbox recently. This letter, signed by the executive vice president and general counsel, was in response to my earlier post regarding batt insulation. Here is the text of the letter. Please forgive any errors, as it was scanned and run through an OCR program.
January 17, 2011
Mr. Carl Seville
Advisor to Green Building Advisor
RE: Green Building Advisor Article “Should Batt Insulation Be Outlawed?”
Dear Mr. Seville:
Thank you for your article emphasizing the importance of proper installation of insulation. The North American Insulation Manufacturers Association (“NAIMA”) is aware of many qualified contractors who properly install a variety of insulation products, but NAIMA is an advocate of the importance of proper installation in order to achieve full thermal performance. Indeed. NAIMA’s published literature states: “Carefully read the manufacturer’s directions printed on packaging of batt or roll insulation to be sure the material is correctly installed.” In another NAIMA publication, it is stated that “[t]he performance of any insulation product is dependent not only on selecting the proper product but also on installing it correctly.” NAIMA also provides guidance and training materials to insulation contractors.
What is true of all insulation products is that when properly installed, insulation delivers significant energy savings. What is also true of all insulation products is that all can be improperly installed. All insulation products must be installed correctly in order to achieve the intended thermal performance. The National Association of Home Builders (“NAHB”) has stated that “you can choose the right insulation, but it will not do the job it’s supposed to do if it is not installed properly.” The NAHB’s statement is directed towards all types of insulation products: batt and blanket, loose-fill, rigid board insulation, spray foam insulation, and others. Therefore, to single out fiber glass batts is unfair and inaccurate. If there is a problem with batts, there is a problem with all batts, including cotton, plastic, denim, rock wool, slag wool, or any other type of batt. Moreover, the rate of improperly installed fiber glass batts must also be weighed in balance with the fact that fiber glass is the most widely used insulation product in North America. Put simply, more fiber glass batts are installed so more are likely to be improperly installed.
Many insulation products when incorrectly installed not only fail to deliver their optimum thermal performance, but may cause serious damage or destruction to the building too. Just consider a few of the following examples that effectively illustrate the need to apply equitably the phrase “when properly installed.”
In your article, you mention that blown-in products might have been a preferable alternative, though more expensive. As noted above, there is not an insulation product, or any other product for that matter, that is foolproof. Spray foam insulation, which must be installed by experts, can be over-sprayed or under-sprayed. For example, a Maryland inspector reported about an insulation contractor who completely foamed all the walls, roof sheathing, ridge vents, attic fan, and soffit vents. The fan and vents ceased to function. In addition, significant fire and explosion hazards exist during installation of spray foam products. The Occupational Safety and Health Administration (“OSHA”) has identified several fatalities and incidents due to severe asthmatic attacks and fire/explosions associated with the use of isocyanurate-containing materials (which is one of the chemical hazards in spray foam products).
Other examples of misapplication of spray foam include under-spraying that leaves gaps and holes similar to those described in your article on fiber glass batts. These gaps or voids will result in decreased R-value. If during a retrofit foam insulation is applied over a 48 inch space using only a two or three inch opening at one side, the foam will begin to expand and cure before it has reached the full depth of the cavity. This would block any more foam from filling the cavity, so random voids would result. Even proponents of foam insulation caution that “spray foam products must still be sprayed correctly.”
Most other blown-in products can also be under-sprayed, fluffed, or subject to settling. For example, cellulose insulation settles over time. Third party documentation estimates that settling of cellulose insulation shows an average settling value of 19 percent. Therefore, if cellulose insulation is improperly installed without accounting for settling, cellulose insulation will lose about 19 percent of its R-value when it settles. Therefore, proper installation of cellulose insulation is required in order to improve energy efficiency. The installer must take into account installed thickness and settled thickness, which means additional product must be added to compensate for that settling factor.
Too much cellulose insulation above ceilings, however, can impact the ceiling structure of the home. Based on US Gypsum weight limit recommendations for backloaded standard drywall and the installed density of shredded newspaper insulations, there is potential for ceiling drywall to sag at R-values above R-30 for regular cellulose insulation when installed over 1/2 inch ceiling drywall with framing spaced 24 inches on centers. Cellulose insulation, if improperly installed, can cause fires when the insulation is placed near a heat source. In fact, the Consumer Product Safety Commission (“CPSC”) regulates cellulose insulation as a recognized fire threat. To protect against that fire threat, CPSC regulations mandate the proper installation of cellulose insulation: “Based on available fire incident information, engineering analysis of the probable fire scenarios, and laboratory tests, the Consumer Product Safety Commission has determined that fire may occur where cellulose insulation is improperly installed too close to the sides or over the top of recessed electrical light fixtures, or installed too close to the exhaust flues from heat producing devices or apparatus such as furnaces, water heaters, and space heaters. These fires may result in serious injuries or deaths. Presently available information indicates that fires may occur where cellulose insulation is improperly installed even though the cellulose insulation complies with the Commission’s amended interim standard for cellulose insulation.”‘
CPSC has actually issued regulations that mandate proper installation to avoid house fires, yet even a legal mandate cannot stop improper installation as attested to in the enclosed article, “Going Green May Make You See Red.” Improper installation of cellulose is so serious that this warning label must be affixed: Manufacturers of cellulose insulation shall label all containers of cellulose insulation with the following statement, using capital letters as indicated:
Potential Fire Hazard: Keep cellulose insulation at least three inches away from the sides of recessed light fixtures. Do not place insulation over such fixtures so as to entrap heat. Also keep this insulation away from exhaust flues of furnaces, water heaters, space heaters. or other heat-producing devices. To be sure that insulation is kept away from light fixtures and flues, use a barrier to permanently maintain clearance around these areas. Check with local building or fire officials for guidance on installation and barrier requirements. Request to Installer: Remove this label and give it to the consumer at completion of job.
Reflective insulation must be positioned adjacent to an air gap to be effective; otherwise heat will simply conduct through to the next solid layer that it touches. In other words, if the reflective insulation is positioned improperly, it will not deliver the intended thermal performance.
If you are so anxious to outlaw insulation products, would it not be prudent to start with those products clearly identified as threats to life and safety? Certainly outlawing fiberglass batts should be a low priority. Perhaps in future columns you can join with NAIMA and many other insulation producers in advocating proper installation for all insulation products. To single out fiber glass actually does a great disservice to your readers because it suggests that it is somehow a unique issue to fiber glass when, in reality, it is an issue for the entire insulation industry.
Executive Vice President, General Counsel
North American Insulation Manufacturers Association
So who is NAIMA anyway?
According to its website, “NAIMA is recognized as the voice of the insulation industry for architects and builders; design, process and maintenance engineers; contractors; code groups and standards organizations; government agencies; public interest, energy and environmental groups; and homeowners. NAIMA is an authoritative resource on energy-efficiency, sustainable performance, and the application and safety of fiberglass, rock wool and slag wool insulation products.”
OK, so we know they represent all insulation manufacturers, EXCEPT cellulose, foam, cotton, wool, and maybe a few others I am not aware of. So, it is not surprising that the letter focused on the dangers of spray foam and cellulose insulation while ignoring any potential problems with the products NAIMA represents. I do appreciate that they thanked me for emphasizing the importance of proper installation of insulation products, but I didn’t really need a lecture on how wonderful their products are and how evil the competition is. I suppose what I find the most interesting is that there was no acknowledgment that the title about outlawing batt insulation was tongue-in-cheek and meant only to get the reader’s attention, which it apparently did.
I suspect that NAIMA wishes I had never written the post, and that the whole issue would just go away—but somehow I think that since the letter has inspired me to write about this again, it will have the opposite effect and help promulgate this post even further.