Issues with Codes and Steiner Tunnel ratings for

insulation foams

Don Lucas, Ph.D.Lawrence Berkeley National Laboratory

UC Berkeley

Green Science Policy Institute

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Flammability characteristics of foam plastics first regulated in 1961

Flame spread and smoke developed by the Steiner Tunnel test (ASTM E 84)

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The Steiner Tunnel test results for flame spread of foam plastics are not meaningful

WOOD

How fire travels on material determines the flame spread index

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The Steiner Tunnel test results for flame spread of foam plastics are not meaningful

POLYSTYRENE

Result = low flame spread

4Excessive smoke, intumescence, etc. also problematic for other types of foam plastic

Why is ASTM E84 used for Foam?

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Research during the 1970s

• Important, full-scale fire test projects.

• Realistic test rooms with bare foams mounted on walls and ceiling.

• Flame Spread Index (FSI) did not correlate to a meaningful improvement.

6 Williamson and Baron, 1973; Castino et al., 1975; Rose, 1975.

Lower flame spread does not mean longer time to flashover

Castino, 1975; Lee 1985; Rose 19758

Research during the 1970s

• Code bodies concluded:

• Bare foam cannot be safely used inside a habitable space.

• Thermal barrier requirement added to Uniform Building Code in 1976.

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Thermal barrier provides fire safety

• No exposed foam can safely be used

• Protects foams for at least 15 minutes after flashover

@Moosicorn

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Steiner Tunnel requirements retained without a demonstrated benefit.

Babrauskas 2003; Babrauskas 2012

Fire spread in a cavity

Exterior Interior

Fire spread determined by size of gap

Flame spread rating of insulation not a determining factor

Choi and Taylor, 198411

Potential spread in cavities

• Steiner Tunnel rating has no proven correlation to practical benefits.

• Flame spread in cavity determined by size of gap between insulation and walls

• Firestopping is essential, and is included in all the modern codes.

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Primary item contributing to flame spread in home structure fires

Ahrens, 2011Str

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97% of XPS/EPS in Sweden, Norway is non-flame retarded

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• Codes changed to allow for use of non-flame retarded insulations

• No observed increase in fire incidence, injuries, or deaths

Blomqvist et al., 2011; Lassen et al., 2011; POPRC 2011

Conclusions

• Flame retardants in foam plastic insulation have no practical benefit in many applications• Needed to pass the Steiner Tunnel requirement • Does not improve safety or limit spread of flames

in wall cavities

• Thermal barrier and firestopping requirements are sufficient in many applications

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California AB 127 (Skinner)

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Our Goals for California AB 127

• Maintain fire safety• Remove Steiner Tunnel requirements for

• Insulation protected by a 15-minute thermal barrier

OR• Insulation used below grade of building

• Allow for use of insulation without added flame retardants where they do not improve safety

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RIGID INSULATIONS

Flame Retardants in Building Insulation:

Changing the Status Quo

Suzanne DrakePerkins + Will

San Francisco, CA19

RIGID INSULATIONSFlame Retardants in Building Insulation:

Should Building Codes be Re-Evaluated?

Insulation below grade will not burn.

Wall insulation behind 15-minute thermal barrier.

Steiner Tunnel Test not effective for plastic insulations

Can the standards bechanged so retardants aren’t required where there is no benefit?

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Why Change the I-Codes?

Plastic foam insulation is increasingly being used to increase energy efficiency.

We need to address the presence of toxic flame retardants without undermining energy efficiency.

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Work with the system

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The International Code Council

• main U.S. organization of building code officials

• publishes a full set of building codes

• updated on three year cycles

• staggered code development cycles

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2012 I-Codes…2015…2018…

• 2015 Group A Codes development process completed in October 2012

• 2015 Group B codes, including the International Residential Code (IRC), concluded in October 2013

• Initial SIS code change effort started with the 2015 IRC, and continues with the IgCC in the 2015 Group C codes

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2015 IRC code change proposal

No flame spread or smoke development requirements as measured by Steiner Tunnel test/ ASTM E 84 when foam plastics are:

– protected by a 15-minute minimum thermal barrier, such as ½” gypsum board

OR– protected by concrete or used below grade

on the exterior of a building

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2015 IRC code change proposal

• Defeated during Final Action Hearings• Arguments against:

– Exterior fire safety concern– Complications from different product lines– “Minimal chemical risk” due to “low exposure”– Issues for code inspectors (where to use FR

versus non-FR insulation?)– Would not reduce toxicity of fires (other materials

produce toxic combustion products)– Outside the scope of the I-codes – EPA issue

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2015 IgCC code change proposalsAdd new text as follows:

508 Insulation

Section 508.x Surface-burning characteristics. Foam plastic insulation shall meet IBC Section 2603.3 or IRC Section 316.3.

Exception: Rigid foam plastic insulation board shall not be subject to flame spread or smoke developed requirements when installed below a concrete slab on grade that provides continuous separation from the interior of the building, or installed as below-grade exterior foundation insulation, or is installed in accordance with IBC Section 1809.5 Frost protection. This foam plastic insulation shall be clearly labeled as such in addition to the requirements of IBC Section 2603.2 Labeling and identification.

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2015 IgCC code change proposals508 Insulation

Section 508.x Disclosure. All insulation must use one of the following programs to disclose contents of the product to at least 0.1% (1000 ppm).• Manufacturer Inventory. The manufacturer has published complete content inventory

for the product following these guidelines:

◦ A publicly available inventory of all ingredients identified by name and Chemical

Abstract Service Registration Number (CASRN)

◦ Materials defined as trade secret or intellectual property may withhold the name

and/or CASRN but must disclose role, amount and GreenScreen benchmark, as

defined in GreenScreen v1.2.

• Health Product Declaration - The end use product has a published, complete Health

Product Declaration with full disclosure of known hazards in compliance with the

Health Product Declaration Open Standard.

• Cradle to Cradle- The end product has been certified at the Cradle to Cradle v2

Basic Level or Cradle to Cradle v3 Bronze Level.

• Declare- The end use product has a valid Declare label.

• Pharos Project- The end use product is fully disclosed in the Pharos Project Building

Product Library.

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2015 IgCC code change proposalsRevise as follows:

806.6 Insulation.806.6.1 A minimum of 85 percent of insulation shall comply with

the requirements of Table 806.6(1) or Table 808.6(2). The test methodology used to determine compliance shall be from CDPH/EHLB/Standard Method V.1.1, Standard Method for Testing VOC Emissions From Indoor Sources, dated February 2010. The emissions testing shall be performed by a laboratory that has the CDPH/EHLB/Standard Method V1.1 test methodology in the

scope of its ISO 17025 Accreditation.

806.6.2 A minimum of 50 percent by volume of insulation shall not contain halogenated flame retardants.

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2015 IgCC code change process

2014 ICC Group C code development cycle:

- Code Change Deadline: January 10, 2014- Deadline to make proposal changes February 10- Posting of Proposed Changes: March 10- Code Development Hearings: April 27 – May 4

Memphis, TN

- Report of Hearings (results): June 6

- Public Comments Due: July 15- Public Comment Hearings: Oct. 1 – 7

Ft. Lauderdale, FL

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With better flammability standards

We can have fire safety and a healthier world.

Google: Green Science Policywww.greensciencepolicy.org

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