The following comments have been submitted:
Comment #1Page Number: 3Paragraph / Figure / Table / Note: A-1.3.2(3)Comment Intent: ObjectionComment Type: TechnicalComment: Should read "inset or side stapling of batts shall not be permitted for grade I installations". Permitting Inset stapling as proposed is not consistent with the less than 2% void requirement of the standard. Everyone knows this yet we continue to see this type of stapling being permitted. In my opinion it makes a mockery of the standard.
Should read "inset or side stapling of batts shall not be permitted for grade I installations". Permitting Inset stapling as proposed is not consistent with the less than 2% void requirement of the standard. Everyone knows this yet we continue to see this type of stapling being permitted. In my opinion it makes a mockery of the standard.
Comment #2Page Number: 4Paragraph / Figure / Table / Note: A-1.3.3(4)Comment Intent: Not an ObjectionComment Type: EditorialComment: "Insulation shall be installed at a density sufficient to prevent settling over time" Suggest you add "according to Manufacturer's installation procedures" or similar verbiage. As written there is nothing to compare as installed density to the density required to prevent settlement. There needs to be some criteria for the field verification.
"Insulation shall be installed at a density sufficient to prevent settling over time" Suggest you add "according to Manufacturer's installation procedures" or similar verbiage. As written there is nothing to compare as installed density to the density required to prevent settlement. There needs to be some criteria for the field verification.
Comment #3Page Number: 6Paragraph / Figure / Table / Note: A-2.1.2.1Comment Intent: ObjectionComment Type: EditorialComment: Grade I requires less than 2% gaps or voides while grade II allows up to 15%? That seems an absurd allowance.
Grade I requires less than 2% gaps or voides while grade II allows up to 15%? That seems an absurd allowance.
Comment #4Page Number: No Page NumberParagraph / Figure / Table / Note: A-1.1Comment Intent: ObjectionComment Type: TechnicalComment: The proposed document states: Insulation shall be integral to or interior to and in substantial and permanent contact with the primary air barrier. No air spaces shall be allowed between different insulation types or systems. How does this jive with external insulation such as when rigid insulation is installed on the exterior of sheathing on a building? Would that insulation be considered 'integral to' to the primary air barrier. If the structural sheating was the primary air barrier, that insulation would certainly not be 'interior to' the primary air barrier. What about, for example if there was a double-framed wall system with the exterior sheating acting as the primary air barrier and, for example the top and bottom plates were 2x10 and the double stud framing was 2x4s. If 3-1/2" of batt insulation was installed in the cavities of the framing next to the exterior sheathing and 3-1/2" batt insulation was installed in the cavities between the interior sets of studs, the interior batt insulation would not 'be integral to or interior to and in substantial and permanent contact with the primary air barrier'. There would also be ~2" air space with no insulation between the outer and interior studs. This does not satisfy the requirement that 'no air spaces shall be allowed between different insulation'. How would one have to treat the insulation per this standard? Would we have to ignore the insulation between the inner set of double-frame studs -- only recognizing the 3-1/2" that is interior to and in contact with the air barrier?
The proposed document states:
Insulation shall be integral to or interior to and in substantial and permanent contact with the primary air barrier.
No air spaces shall be allowed between different insulation types or systems.
How does this jive with external insulation such as when rigid insulation is installed on the exterior of sheathing on a building? Would that insulation be considered 'integral to' to the primary air barrier. If the structural sheating was the primary air barrier, that insulation would certainly not be 'interior to' the primary air barrier.
What about, for example if there was a double-framed wall system with the exterior sheating acting as the primary air barrier and, for example the top and bottom plates were 2x10 and the double stud framing was 2x4s. If 3-1/2" of batt insulation was installed in the cavities of the framing next to the exterior sheathing and 3-1/2" batt insulation was installed in the cavities between the interior sets of studs, the interior batt insulation would not 'be integral to or interior to and in substantial and permanent contact with the primary air barrier'. There would also be ~2" air space with no insulation between the outer and interior studs. This does not satisfy the requirement that 'no air spaces shall be allowed between different insulation'.
How would one have to treat the insulation per this standard? Would we have to ignore the insulation between the inner set of double-frame studs -- only recognizing the 3-1/2" that is interior to and in contact with the air barrier?
Comment #5Page Number: No Page NumberParagraph / Figure / Table / Note: A-1.2 1.Comment Intent: ObjectionComment Type: TechnicalComment: The proposed standard currently states: A-1.2 Minimum Specific Application Requirements: Insulation installed in framed floor assemblies shall be in substantial and permanent contact with the subfloor. Exception: The floor framing-cavity insulation shall be permitted to be in contact with the topside of sheathing or continuous insulation installed on the bottom side of floor framing where combined with insulation that meets or exceeds the minimum wood frame wall R-value in Table 402.1.2 and that extends from the bottom to the top of all perimeter floor framing members. I have been involved with projects which have framed floor systems with hydronic radiant heat distribution piping embedded in a 1-1/2" thick layer of gypcrete (or whatever) above the framed floor rough sheating. The architect specified a radiant reflector under the subfloor with a small air space (1/2" to 1") to redirect heat that has been radiated downward back up into the conditioned space. In this case the floor insulation is not and can not be in substantial and permanent contact with the subfloor or the radiant heat reflector would not be effective.
The proposed standard currently states:
A-1.2 Minimum Specific Application Requirements:
Insulation installed in framed floor assemblies shall be in substantial and permanent contact with the subfloor.
Exception: The floor framing-cavity insulation shall be permitted to be in contact with the topside of sheathing or continuous insulation installed on the bottom side of floor framing where combined with insulation that meets or exceeds the minimum wood frame wall R-value in Table 402.1.2 and that extends from the bottom to the top of all perimeter floor framing members.
I have been involved with projects which have framed floor systems with hydronic radiant heat distribution piping embedded in a 1-1/2" thick layer of gypcrete (or whatever) above the framed floor rough sheating. The architect specified a radiant reflector under the subfloor with a small air space (1/2" to 1") to redirect heat that has been radiated downward back up into the conditioned space. In this case the floor insulation is not and can not be in substantial and permanent contact with the subfloor or the radiant heat reflector would not be effective.
Comment #6Page Number: multipleParagraph / Figure / Table / Note: sections listedComment Intent: ObjectionComment Type: TechnicalComment: The following are sections I see as confusing the issue and/or needing more clarifying descriptions: By Sections: A-1.3.3 Blown or Sprayed Fibrous Loose Fill Insulation Exceptions: a. Insulation installed in attics and ceilings shall not require an air barrier on the exterior or interior side. *This sentence refers to two different applications and offers no clear guidance as to what the standards is detailing. Not having an air barrier in the thermal boundary conflicts with all ICC Codes. There needs to be either more information given or this sentence needs to be reworded. A-2.1.1.4 Insulated Sheathing *This section skirts around what they mean by saying “ Voids through interior to exterior of the intended insulation areas shall not be permitted.” What this section really means is the use of shiplap foam will be required to meet this minimum standard. One could argue that there is always a void between abutting sheet goods. This needs clarification or define shiplap or “overlay” is acceptable. A-2.1.2.1 Batt or Loose-fill Insulation “…no more than 15% of the total insulated area (cavity) shall be compressed or contain gaps or voids in the insulation.” A-2.1.2.2 Open-Cell Polyurethane Spray Foam Insulation (cavity not filled and not trimmed) “No more than 15% of the insulated area shall contain voids or be more than 1 inch below the specified thickness.” A-2.1.2.3 Closed-Cell Polyurethane Spray Foam “No more than 15% of the insulated area shall contain voids or be greater than ½ inch below the specified thickness.” * This is where there is a lot of confusion and where this needs a lot of clarification and inserting the diagrams as we are used to seeing in the RESNET Standards. The current RESNET Standard says “No more than 2% of surface area insulated missing is acceptable for ‘Grade 2’.” It goes on to say “No more than 10% of the surface area of insulation compressed or incomplete fill, by up to 30% (70% or more of intended thickness) is acceptable for ‘Grade 2’.” *We need definitions defined or specifically used for “insulated area” vs. “surface area” vs. “cavity” along with some diagrams (as we see in the RESNET Standards) to help clarify what they are going after here. My thought is the 15% is one number the standard can be held by measurement. Over all, references in this document need to be inline with manufacturers specification if they are going to refer to what the manufcturers requirements or recommendations. There are inconsistencies with the grading system vs. manufacturers specifications.
The following are sections I see as confusing the issue and/or needing more clarifying descriptions:
By Sections:
*This sentence refers to two different applications and offers no clear guidance as to what the standards is detailing. Not having an air barrier in the thermal boundary conflicts with all ICC Codes. There needs to be either more information given or this sentence needs to be reworded.
*This section skirts around what they mean by saying “ Voids through interior to exterior of the intended insulation areas shall not be permitted.” What this section really means is the use of shiplap foam will be required to meet this minimum standard. One could argue that there is always a void between abutting sheet goods. This needs clarification or define shiplap or “overlay” is acceptable.
* This is where there is a lot of confusion and where this needs a lot of clarification and inserting the diagrams as we are used to seeing in the RESNET Standards. The current RESNET Standard says “No more than 2% of surface area insulated missing is acceptable for ‘Grade 2’.” It goes on to say “No more than 10% of the surface area of insulation compressed or incomplete fill, by up to 30% (70% or more of intended thickness) is acceptable for ‘Grade 2’.”
*We need definitions defined or specifically used for “insulated area” vs. “surface area” vs. “cavity” along with some diagrams (as we see in the RESNET Standards) to help clarify what they are going after here. My thought is the 15% is one number the standard can be held by measurement.
Over all, references in this document need to be inline with manufacturers specification if they are going to refer to what the manufcturers requirements or recommendations. There are inconsistencies with the grading system vs. manufacturers specifications.
Comment #7Page Number: 2Paragraph / Figure / Table / Note: A-1Comment Intent: ObjectionComment Type: TechnicalComment: An ASTM work item is not an appropriate reference. The reference should be only for completed standards. The WK item draft should also be provided for public review since the content of the work item (or its current status) may not be available to all public reviewers.
An ASTM work item is not an appropriate reference. The reference should be only for completed standards. The WK item draft should also be provided for public review since the content of the work item (or its current status) may not be available to all public reviewers.
Comment #8Page Number: 2Paragraph / Figure / Table / Note: A-1.1Comment Intent: ObjectionComment Type: TechnicalComment: The exception statement is incomplete as the salient (and more complete) requirements and limitations for application of airspace R-values for code compliance are found in the ASHRAE 90.1-2016 provisions in Section A9.4 (or addendum AC to the 2013 edition). Furthermore, the 2018 IECC provisions will likely be revised to agree with the ASHRAE 90.1-2016 provisions regarding airspace R-values and their application. In addition, this applies to use of both reflective and non-reflective airspaces. A research report is also available on this subject for additional information: http://www.appliedbuildingtech.com/rr/1601-02 Proposed Change: Refer to ASHRAE 90.1-2016 Section A9-4 (or addendum ac to 2013 edition) for appropriate language needed to ensure appropriate use of reflective airspaces with regard to air-space conditions and enclosure to achieve the necessary air-tightness. ASTM C1224 does not adequately address this concern and the ASHRAE HOF includes only a footnote reference to "no air-leakage" that is often overlooked or not properly interpreted (particularly in regard to matters of installation). Perhaps this could be treated with a user note, so I have not specified exact language to address this concern but am willing to work with the committee to do so (and provide the necessary documentation in support).
The exception statement is incomplete as the salient (and more complete) requirements and limitations for application of airspace R-values for code compliance are found in the ASHRAE 90.1-2016 provisions in Section A9.4 (or addendum AC to the 2013 edition). Furthermore, the 2018 IECC provisions will likely be revised to agree with the ASHRAE 90.1-2016 provisions regarding airspace R-values and their application. In addition, this applies to use of both reflective and non-reflective airspaces. A research report is also available on this subject for additional information: http://www.appliedbuildingtech.com/rr/1601-02
Refer to ASHRAE 90.1-2016 Section A9-4 (or addendum ac to 2013 edition) for appropriate language needed to ensure appropriate use of reflective airspaces with regard to air-space conditions and enclosure to achieve the necessary air-tightness. ASTM C1224 does not adequately address this concern and the ASHRAE HOF includes only a footnote reference to "no air-leakage" that is often overlooked or not properly interpreted (particularly in regard to matters of installation). Perhaps this could be treated with a user note, so I have not specified exact language to address this concern but am willing to work with the committee to do so (and provide the necessary documentation in support).
Comment #9Page Number: 2Paragraph / Figure / Table / Note: A-1.2Comment Intent: ObjectionComment Type: TechnicalComment: The language is incomplete and does not address all conditions of use. Proposed Change: 2. For rim or band joist applications, insulation shall be in substantial and permanent contact with rim or band joist framing and tightly fitted to intersecting solid floor joists or extend continuously through open web floor trusses; interior sheathing or air barrier is not required provided there is an air barrier on the exterior side or the insulation material is installed as an air barrier material.
The language is incomplete and does not address all conditions of use.
2. For rim or band joist applications, insulation shall be in substantial and permanent contact with rim or band joist framing and tightly fitted to intersecting solid floor joists or extend continuously through open web floor trusses; interior sheathing or air barrier is not required provided there is an air barrier on the exterior side or the insulation material is installed as an air barrier material.
Comment #10Page Number: 2Paragraph / Figure / Table / Note: A-1.3.1Comment Intent: ObjectionComment Type: TechnicalComment: The language should be modified as shown below. Joint sealing of insulated sheathing should only be required where it is used as an air-barrier or water-resistive barrier. Otherwise, joint sealing is not required as other layers provide these functions. Also, the term “durably” is vague and instead the manufacturer’s recommended joint sealing treatments should be applied (as these are tested for durability as part of product approvals). Item 2 requiring tightly fitted sheathing joints without substantial gaps should be deleted or revised as it is vague and unenforceable. It will likely result in varied judgments by raters, sometimes onerously without any significant benefit. It would be better to simply state that the sheathing be installed in accordance with the manufacturer’s installation instructions. Items 3 and 4 should be revised for similar reasons stated above. Item 5 should be revised to correctly use current building code terminology (e.g., water-resistive barrier) and properly identify approved applications and related joint sealing requirements in the manufacturer’s installation instructions. Proposed Change: A-1.3.1 Insulated Sheathing: 1. If used as an air barrier, eEdges and joints shall be durably taped or otherwise air sealed in accordance with the manufacturer’s recommendations. 2. Edges not supported directly only sheathing or framing shall be tightly fitted to one another without substantial gaps or otherwise be taped or air sealed. 3. Sheathing shall be carefully fitted and durably taped or otherwise air sealed around obstructions in accordance with the manufacturer’s recommendations. 4. When two or more layers of insulation are installed the joints shall be staggered. Only the joints of one of the exterior layers shall be required to be durably taped or otherwise air sealed where that layer is designated to be an air-barrier. 5. Where used as an approved water-resistive barrier (WRB), sSheathing joints, fenestration, and service penetrations shall be durably taped or otherwise air sealed in accordance with the manufacturer’s installation instructions and have the proper approvals if used as a Weather Resistive Barrier (WRB).
The language should be modified as shown below. Joint sealing of insulated sheathing should only be required where it is used as an air-barrier or water-resistive barrier. Otherwise, joint sealing is not required as other layers provide these functions. Also, the term “durably” is vague and instead the manufacturer’s recommended joint sealing treatments should be applied (as these are tested for durability as part of product approvals). Item 2 requiring tightly fitted sheathing joints without substantial gaps should be deleted or revised as it is vague and unenforceable. It will likely result in varied judgments by raters, sometimes onerously without any significant benefit. It would be better to simply state that the sheathing be installed in accordance with the manufacturer’s installation instructions. Items 3 and 4 should be revised for similar reasons stated above. Item 5 should be revised to correctly use current building code terminology (e.g., water-resistive barrier) and properly identify approved applications and related joint sealing requirements in the manufacturer’s installation instructions.
A-1.3.1 Insulated Sheathing:
1. If used as an air barrier, eEdges and joints shall be durably taped or otherwise air sealed in accordance with the manufacturer’s recommendations.
2. Edges not supported directly only sheathing or framing shall be tightly fitted to one another without substantial gaps or otherwise be taped or air sealed.
3. Sheathing shall be carefully fitted and durably taped or otherwise air sealed around obstructions in accordance with the manufacturer’s recommendations.
4. When two or more layers of insulation are installed the joints shall be staggered. Only the joints of one of the exterior layers shall be required to be durably taped or otherwise air sealed where that layer is designated to be an air-barrier.
5. Where used as an approved water-resistive barrier (WRB), sSheathing joints, fenestration, and service penetrations shall be durably taped or otherwise air sealed in accordance with the manufacturer’s installation instructions and have the proper approvals if used as a Weather Resistive Barrier (WRB).
Comment #11Page Number: 4Paragraph / Figure / Table / Note: A-1.3.6Comment Intent: ObjectionComment Type: TechnicalComment: Referring to a proprietary, sole source for code evaluation of materials and methods (when there are many sources available) is not appropriate and would render RESNET 301 incapable of being used as a code-reference standard for legal reasons. Also, the section number should be A-1.3.5. Proposed Change: A-1.3.56 Closed-cell spray polyurethane foam (SPF) insulation: 1. Installers shall meet the manufacturer’s recommended training requirements and shall complete the online health and safety training for SPF provided by the Center for Polyurethanes Industry. 2. Spray foam shall be well-bonded to the substrate, including framing and sheathing. 3. Closed-cell Insulation, installed at thicknesses of 1.5 inches thick or more shall be permitted to be an air-impermeable insulation when in-contact with the substrate. Exception: Thicknesses less than 1.5 inches considered air-impermeable with appropriate ASTM E2178 data (air permeance less than 0.04 cfm/ft2) from manufacturer data sheet or code evaluation report by an approved agency or approved source ICC-ES Report.
Referring to a proprietary, sole source for code evaluation of materials and methods (when there are many sources available) is not appropriate and would render RESNET 301 incapable of being used as a code-reference standard for legal reasons. Also, the section number should be A-1.3.5.
A-1.3.56 Closed-cell spray polyurethane foam (SPF) insulation:
1. Installers shall meet the manufacturer’s recommended training requirements and shall complete the online health and safety training for SPF provided by the Center for Polyurethanes Industry.
2. Spray foam shall be well-bonded to the substrate, including framing and sheathing.
3. Closed-cell Insulation, installed at thicknesses of 1.5 inches thick or more shall be permitted to be an air-impermeable insulation when in-contact with the substrate.
Exception: Thicknesses less than 1.5 inches considered air-impermeable with appropriate ASTM E2178 data (air permeance less than 0.04 cfm/ft2) from manufacturer data sheet or code evaluation report by an approved agency or approved source ICC-ES Report.
Comment #12Page Number: 5Paragraph / Figure / Table / Note: A-2.1.1Comment Intent: ObjectionComment Type: TechnicalComment: Referencing an ASTM work item is not appropriate (see prior comment). Also the term “cavity fill” is not appropriate as at least one of the materials addressed in the subsections (e.g., A-2.1.1.4 Insulated Sheathing) are not commonly used as “cavity fill” and are more commonly used as continuous insulation which necessarily must be placed outside of cavities in a continuous fashion. Also, the referenced ASTM C1015 and C1320 standards do not address non-cavity fill types of insulation applications (e.g., continuous insulation). They are for specific products that exclude spray foam and insulated sheathing. Thus, it is inappropriate to require that spray foam and insulated sheathing products be installed in accordance with standards that are meant for loose fill or fibrous insulation products. This charging language needs to be re-worked accordingly. Proposed Change: Not sure how to best fix this. Will work with committee as needed, if the comment reason statement is not clear enough.
Referencing an ASTM work item is not appropriate (see prior comment). Also the term “cavity fill” is not appropriate as at least one of the materials addressed in the subsections (e.g., A-2.1.1.4 Insulated Sheathing) are not commonly used as “cavity fill” and are more commonly used as continuous insulation which necessarily must be placed outside of cavities in a continuous fashion. Also, the referenced ASTM C1015 and C1320 standards do not address non-cavity fill types of insulation applications (e.g., continuous insulation). They are for specific products that exclude spray foam and insulated sheathing. Thus, it is inappropriate to require that spray foam and insulated sheathing products be installed in accordance with standards that are meant for loose fill or fibrous insulation products. This charging language needs to be re-worked accordingly.
Not sure how to best fix this. Will work with committee as needed, if the comment reason statement is not clear enough.
Comment #13Page Number: 5Paragraph / Figure / Table / Note: A-2.1.1.4Comment Intent: ObjectionComment Type: TechnicalComment:
Comment #14Page Number: 5Paragraph / Figure / Table / Note: A-2.1.1.4Comment Intent: ObjectionComment Type: TechnicalComment: This provision is awkwardly worded. Also, manufacturer installation instructions should be referenced. Proposed Change: A-2.1.1.4 Insulated Sheathing Insulated sheathing insulation installations meeting the minimum installation, application, and material requirements of Section A-1.3.1 and installed in accordance with the manufacturer’s installation instructions above. Voids through interior to exterior of the intended insulation areas shall not be permitted.
This provision is awkwardly worded. Also, manufacturer installation instructions should be referenced.
A-2.1.1.4 Insulated Sheathing
Insulated sheathing insulation installations meeting the minimum installation, application, and material requirements of Section A-1.3.1 and installed in accordance with the manufacturer’s installation instructions above. Voids through interior to exterior of the intended insulation areas shall not be permitted.
Comment #15Page Number: 5Paragraph / Figure / Table / Note: A-2.1.2Comment Intent: ObjectionComment Type: TechnicalComment: Same concern as prior comment on Section A-2.1.1 regarding referencing an ASTM work item and the list of items not all being "cavity insulation" as the charging language implies. Proposed Change: Not sure how to best fix this concern. Will work with the committee regarding appropriate standards or references and deletion of the "cavity fill" term in the charging language.
Same concern as prior comment on Section A-2.1.1 regarding referencing an ASTM work item and the list of items not all being "cavity insulation" as the charging language implies.
Not sure how to best fix this concern. Will work with the committee regarding appropriate standards or references and deletion of the "cavity fill" term in the charging language.
Comment #16Page Number: 5Paragraph / Figure / Table / Note: A-2.1.2 and A2.1.3Comment Intent: ObjectionComment Type: TechnicalComment: Sections A-2.1.2 and A2.1.3 for Grade II (moderate defects) and Grade III (substantial defects) should be disallowed (at least for new construction). Grade II allows substantial defects (not moderate) with allowance for 15% of the total insulated area to be voids. This could mean that up to 150 sqft of a 1000 sqft ceiling could be completely uninsulated! Or, it could mean the top 15-inches (for 8-foot walls) or more (for taller walls) could be completely uninsulated! Even if this were properly accounted for in the performance impact (e.g., ERI), it legitimizes very poor installation that should result in a call-back and repair. Instead, Grade II and III (which is permitted to be worse than Grade II by an unlimited amount) should be rejected as non-code compliant and non-compliant with manufacturer’s installation instructions. Alternatively, the Grade II allowance should be significantly tightened. Proposed Change: Not sure how to best fix this. The reason statement should provide adequate direction and I'm willing to work with the committee to adequately resolve my concern. Thank you.
Sections A-2.1.2 and A2.1.3 for Grade II (moderate defects) and Grade III (substantial defects) should be disallowed (at least for new construction). Grade II allows substantial defects (not moderate) with allowance for 15% of the total insulated area to be voids. This could mean that up to 150 sqft of a 1000 sqft ceiling could be completely uninsulated! Or, it could mean the top 15-inches (for 8-foot walls) or more (for taller walls) could be completely uninsulated! Even if this were properly accounted for in the performance impact (e.g., ERI), it legitimizes very poor installation that should result in a call-back and repair. Instead, Grade II and III (which is permitted to be worse than Grade II by an unlimited amount) should be rejected as non-code compliant and non-compliant with manufacturer’s installation instructions. Alternatively, the Grade II allowance should be significantly tightened.
Not sure how to best fix this. The reason statement should provide adequate direction and I'm willing to work with the committee to adequately resolve my concern. Thank you.
Comment #17Page Number: 7Paragraph / Figure / Table / Note: A-2.3Comment Intent: ObjectionComment Type: TechnicalComment: There are many errors and omissions in this section which the proposed edits attempt to fix; refer also to prior comment on the exception in Section A-1.1. These requirements (and those missing) should be made consistent with ASHRAE 90.1-2016 Section A9.4 (or Addendum AC for the 2013 edition). Similar provisions have been recently approved for inclusion in the 2018 IECC provisions. The proposed edits are intended to address some of the more significant errors and omissions in the current proposed language. Proposed Change: A-2.3 Reflective/Radiant Grading Criteria Regarding thermal performance claims or R-values: 1. R-value claims for the air space adjacent to a reflective insulation product shall be based on average cavity depth (where not less than ½”), heat flow direction which represents the application (wall, ceiling or floor), temperature of the airspace surfaces relative to the specific wall assembly, location of the airspace in the assembly, and design climate conditions. 2. When utilizing R-values from the ASHRAE Handbook of Fundamentals, the enclosed airspaces shall be sealed cavities which do not to allow air flow in or out of the cavity. 3. Where utilizing R-values based on testing in accordance with ASTM C1224, the air-space shall be enclosed on all 6 sides by building components installed in the field in a manner consistent with the materials and methods used in the tested assembly, including sealing of joints between the enclosing building components if used.All other R-value claims by the manufacturer for the assembly including an airspace shall be based on ASTM C1224, the Standard Specification of Reflective Insulation. The assembly that is tested for thermal resistance shall be representative of the field assembly. 4. Reflective airspaces behind cladding or otherwise located to the exterior side of the air barrier layer for the assembly shall not claim R-values based on having an airspace.
There are many errors and omissions in this section which the proposed edits attempt to fix; refer also to prior comment on the exception in Section A-1.1. These requirements (and those missing) should be made consistent with ASHRAE 90.1-2016 Section A9.4 (or Addendum AC for the 2013 edition). Similar provisions have been recently approved for inclusion in the 2018 IECC provisions. The proposed edits are intended to address some of the more significant errors and omissions in the current proposed language.
A-2.3 Reflective/Radiant Grading Criteria
Regarding thermal performance claims or R-values:
1. R-value claims for the air space adjacent to a reflective insulation product shall be based on average cavity depth (where not less than ½”), heat flow direction which represents the application (wall, ceiling or floor), temperature of the airspace surfaces relative to the specific wall assembly, location of the airspace in the assembly, and design climate conditions.
2. When utilizing R-values from the ASHRAE Handbook of Fundamentals, the enclosed airspaces shall be sealed cavities which do not to allow air flow in or out of the cavity.
3. Where utilizing R-values based on testing in accordance with ASTM C1224, the air-space shall be enclosed on all 6 sides by building components installed in the field in a manner consistent with the materials and methods used in the tested assembly, including sealing of joints between the enclosing building components if used.All other R-value claims by the manufacturer for the assembly including an airspace shall be based on ASTM C1224, the Standard Specification of Reflective Insulation. The assembly that is tested for thermal resistance shall be representative of the field assembly.
4. Reflective airspaces behind cladding or otherwise located to the exterior side of the air barrier layer for the assembly shall not claim R-values based on having an airspace.
Comment #18Page Number: 7Paragraph / Figure / Table / Note: A-2.3.1Comment Intent: ObjectionComment Type: TechnicalComment: Revise as indicated. Concern similar to those indicated in comments to Section A-2.3. Proposed Change: A-2.3.1 Reflective Insulation in Ceilings, Walls and Floors Reflective insulation products include types with multiple layers, reflective bubble, and reflective foam – refer to the manufacturer’s instructions for the product’s installation details. 1. The products shall be permitted to be either face or side (inset) stapled and shall be permanently attached to the framing member; 2. When side or inset stapled, reflective insulation shall be installed at the depth in the cavity to attain the required airspace(s). Refer to manufacturer’s installation details for the specific application, including required airspace dimensions. Where the cavity is partitioned to provide two or more airspaces that are each claimed for R-value contribution, the attachment of the reflective material separating the spaces shall be sealed to the framing to prevent air-exchange between the two or more airspaces; 3. When face-stapled, the material width shall match the framing width (e.g. 16” wide material is a. Exception: Nonstandard cavity widths. 4. When face-stapled, the staple tabs shall be aligned with the direction of the framing; 5. When reflective insulation is to serve as a vapor retarder, the tabs are over-lapped or taped when face-stapled. When inset stapled, the edges shall be attached to the sides, top and bottom of the framing. 6. Reflective insulation and radiant barriers (sheet type) materials shall not be laid directly on top of the attic floor or insulation materials installed above the ceiling. 7. Reflective insulation and radiant barriers installed under slabs shall not claim R-values based on having an airspace. 8. Reflective airspaces behind cladding or otherwise located to the exterior side of the air barrier layer for the assembly shall not claim R-values based on having an air-space.
Revise as indicated. Concern similar to those indicated in comments to Section A-2.3.
A-2.3.1 Reflective Insulation in Ceilings, Walls and Floors
Reflective insulation products include types with multiple layers, reflective bubble, and reflective foam – refer to the manufacturer’s instructions for the product’s installation details.
1. The products shall be permitted to be either face or side (inset) stapled and shall be permanently attached to the framing member;
2. When side or inset stapled, reflective insulation shall be installed at the depth in the cavity to attain the required airspace(s). Refer to manufacturer’s installation details for the specific application, including required airspace dimensions. Where the cavity is partitioned to provide two or more airspaces that are each claimed for R-value contribution, the attachment of the reflective material separating the spaces shall be sealed to the framing to prevent air-exchange between the two or more airspaces;
3. When face-stapled, the material width shall match the framing width (e.g. 16” wide material is
a. Exception: Nonstandard cavity widths.
4. When face-stapled, the staple tabs shall be aligned with the direction of the framing;
5. When reflective insulation is to serve as a vapor retarder, the tabs are over-lapped or taped when face-stapled. When inset stapled, the edges shall be attached to the sides, top and bottom of the framing.
6. Reflective insulation and radiant barriers (sheet type) materials shall not be laid directly on top of the attic floor or insulation materials installed above the ceiling.
7. Reflective insulation and radiant barriers installed under slabs shall not claim R-values based on having an airspace.
8. Reflective airspaces behind cladding or otherwise located to the exterior side of the air barrier layer for the assembly shall not claim R-values based on having an air-space.
Comment #19Page Number: 7Paragraph / Figure / Table / Note: A-2.3.1.1 thru A-2.3.1.3Comment Intent: ObjectionComment Type: TechnicalComment: The Grade I installation allowance of 2% void in area coverage is completely inadequate to attain the claims based on sealed and enclosed airspaces. This is especially true if the material is not tightly adhered to an air-barrier material such that air leakage to and from the airspace will not occur as a result of the void. A 2% void in a reflective airspace can result in a huge airflow pathway and should be considered a Grade III defect or disqualified from claiming any R-value based on having a reflective airspace. The Grade II allowance of 2% to 10% also should disqualify the installation as it would permit substantial air leakage two and from the airspace. The only way this might be acceptable is if the reflective material is adhered to an air-barrier material such that no air-leakage to and from the airspace occurs, but only the effective emissivity is affected (e.g., the reflective facer is fouled or torn away from the air barrier substrate to which it is adhered). For additional information on the effects of air-leakage on the performance of reflective airspace R-values, refer to: http://www.appliedbuildingtech.com/rr/1601-02 Proposed Change: Suggest deleting Grade II and Grade III, but there may be alternative solutions that can address the concern depending on how the impact of a Grade II or III installation of reflective air-spaces is addressed in the ERI rating.
The Grade I installation allowance of 2% void in area coverage is completely inadequate to attain the claims based on sealed and enclosed airspaces. This is especially true if the material is not tightly adhered to an air-barrier material such that air leakage to and from the airspace will not occur as a result of the void. A 2% void in a reflective airspace can result in a huge airflow pathway and should be considered a Grade III defect or disqualified from claiming any R-value based on having a reflective airspace. The Grade II allowance of 2% to 10% also should disqualify the installation as it would permit substantial air leakage two and from the airspace. The only way this might be acceptable is if the reflective material is adhered to an air-barrier material such that no air-leakage to and from the airspace occurs, but only the effective emissivity is affected (e.g., the reflective facer is fouled or torn away from the air barrier substrate to which it is adhered). For additional information on the effects of air-leakage on the performance of reflective airspace R-values, refer to: http://www.appliedbuildingtech.com/rr/1601-02
Suggest deleting Grade II and Grade III, but there may be alternative solutions that can address the concern depending on how the impact of a Grade II or III installation of reflective air-spaces is addressed in the ERI rating.
Comment #20Page Number: 8Paragraph / Figure / Table / Note: A-2.3.2Comment Intent: ObjectionComment Type: TechnicalComment: How is the effective or apparent R-value determined for this application (Attic Radiant Barriers)? How is the ERI determined? Please provided appropriate documentation in response to this comment as these should be directly related to installation grading or assessment for grading purposes). The effectiveness of attic radiant barriers varies by time of year and climate zone and also by amount of ceiling insulation or presence/absence of mechanical equipment and/or ductwork in the attic space and the amount of insulation on those systems. Its value is also affected by the effectiveness of the roof ventilation design. How is this inter-related effect evaluated? Again, please provide documentation to substantiate response to this comment. Please be aware that I’m not questioning that there are some benefits (perhaps more in some climates and less or none in others), but these benefits need to be properly associated with the important variables that affect the efficacy in terms of ERI calculation or effective R-value or some other tangible Proposed Change: Not sure how to best resolve this concern and appropriate corrections are dependent on responses to the questions and concerns posed in the comment.
How is the effective or apparent R-value determined for this application (Attic Radiant Barriers)? How is the ERI determined? Please provided appropriate documentation in response to this comment as these should be directly related to installation grading or assessment for grading purposes). The effectiveness of attic radiant barriers varies by time of year and climate zone and also by amount of ceiling insulation or presence/absence of mechanical equipment and/or ductwork in the attic space and the amount of insulation on those systems. Its value is also affected by the effectiveness of the roof ventilation design. How is this inter-related effect evaluated? Again, please provide documentation to substantiate response to this comment. Please be aware that I’m not questioning that there are some benefits (perhaps more in some climates and less or none in others), but these benefits need to be properly associated with the important variables that affect the efficacy in terms of ERI calculation or effective R-value or some other tangible
Not sure how to best resolve this concern and appropriate corrections are dependent on responses to the questions and concerns posed in the comment.
Comment #21Page Number: 9Paragraph / Figure / Table / Note: A-2.3.3Comment Intent: ObjectionComment Type: TechnicalComment: See prior comment on A-2.3.2. Same concerns apply to Interior Radiation Control Coatings. Also, it appears the intent of this section is to limit application to the attic space. If so, this should be reflected in the section title as it is in Section A-2.3.2. Proposed Change: See prior comment on A-2.3.2.
See prior comment on A-2.3.2. Same concerns apply to Interior Radiation Control Coatings. Also, it appears the intent of this section is to limit application to the attic space. If so, this should be reflected in the section title as it is in Section A-2.3.2.
See prior comment on A-2.3.2.
Comment #22Page Number: 9Paragraph / Figure / Table / Note: GeneralComment Intent: Not an ObjectionComment Type: GeneralComment: I had some difficult submitting multiple (14) comments and cutting-and-pasting to this screen. If the comments did not come through correctly or completely I and provide a PDF or Word file of all comments. Thank you.
I had some difficult submitting multiple (14) comments and cutting-and-pasting to this screen. If the comments did not come through correctly or completely I and provide a PDF or Word file of all comments. Thank you.
Comment #23Page Number: 2Paragraph / Figure / Table / Note: Section A-1.1, item 2Comment Intent: ObjectionComment Type: TechnicalComment: Comment 1 Section A-1.1, item 2. Recommend revising the section to read: Insulation shall be integral to or on the interior to on the interior or exterior side and in substantial and permanent contact with the primary air barrier. Reason: The air barrier does not have to be on the exterior side of the insulation to perform. Interior air barriers, including the “sealed gypsum board” approach have been demonstrated to be effective air barriers.
Comment 1
Section A-1.1, item 2. Recommend revising the section to read:
Insulation shall be integral to or on the interior to on the interior or exterior side and in substantial and permanent contact with the primary air barrier.
Reason: The air barrier does not have to be on the exterior side of the insulation to perform. Interior air barriers, including the “sealed gypsum board” approach have been demonstrated to be effective air barriers.
Comment #24Page Number: 2Paragraph / Figure / Table / Note: Section A-1.1, item 5.Comment Intent: ObjectionComment Type: TechnicalComment: Comment 2 Section A-1.1, item 5. Recommend revising the section to read: Insulation shall fill around obstructions including, but not limited to, framing, blocking, wiring, pipes, etc. without substantial gaps or voids greater than 1/8" in width. Reason: This will give specific guidance to the user and sets a reasonable minimum dimension for gaps and voids.
Comment 2
Section A-1.1, item 5. Recommend revising the section to read:
Insulation shall fill around obstructions including, but not limited to, framing, blocking, wiring, pipes, etc. without substantial gaps or voids greater than 1/8" in width.
Reason: This will give specific guidance to the user and sets a reasonable minimum dimension for gaps and voids.
Comment #25Page Number: 2Paragraph / Figure / Table / Note: Section A-1.2 item 1.Comment Intent: Not an ObjectionComment Type: GeneralComment: Comment 3 Section A-1.2 item 1. Recommend revising the section to read: Exception: The floor framing-cavity insulation shall be permitted to be in contact with the topside of sheathing or continuous insulation installed on the bottom side of floor framing where combined with insulation that meets or exceeds the minimum wood frame wall R-value in Table 402.1.2 of the 2015 International Energy Conservation Code (IECC) and that extends from the bottom to the top of all perimeter floor framing members. Reason: This table requires a specific reference.
Comment 3
Section A-1.2 item 1. Recommend revising the section to read:
Exception: The floor framing-cavity insulation shall be permitted to be in contact with the topside of sheathing or continuous insulation installed on the bottom side of floor framing where combined with insulation that meets or exceeds the minimum wood frame wall R-value in Table 402.1.2 of the 2015 International Energy Conservation Code (IECC) and that extends from the bottom to the top of all perimeter floor framing members.
Reason: This table requires a specific reference.
Comment #26Page Number: 4Paragraph / Figure / Table / Note: Section A-1.2 item 3.Comment Intent: Not an ObjectionComment Type: GeneralComment: Comment 4 Section A-1.2 item 3. Consider revising the section to read: Air permeable insulation installed in ventilated attics and sloped roofs shall have an effective air barrier (wind block, air chute, or eave baffle) installed at the eave or soffit edge that extends up and beyond the surface of the insulation or to the ridge vent to prevent air movement through the insulation. Reason: Consider striking the highlighted language. Although it provides good guidance, this is commentary language and not appropriate for language in a standard. If RESNET develops a commentary document for the insulation grading standards this would be the proper location for this language.
Comment 4
Section A-1.2 item 3. Consider revising the section to read:
Air permeable insulation installed in ventilated attics and sloped roofs shall have an effective air barrier (wind block, air chute, or eave baffle) installed at the eave or soffit edge that extends up and beyond the surface of the insulation or to the ridge vent to prevent air movement through the insulation.
Reason: Consider striking the highlighted language. Although it provides good guidance, this is commentary language and not appropriate for language in a standard. If RESNET develops a commentary document for the insulation grading standards this would be the proper location for this language.
Comment #27Page Number: 4Paragraph / Figure / Table / Note: Section A-1.3.3 item 1.Comment Intent: Not an ObjectionComment Type: EditorialComment: Comment 5 Section A-1.3.3 item 1. Consider revising the section to read: Insulation containment fabric or system that is side stapled shall not be stapled more than ½ inch back from the face of the stud. Reason: This clarifies the staples can be placed ½” into the cavity.
Comment 5
Section A-1.3.3 item 1. Consider revising the section to read:
Insulation containment fabric or system that is side stapled shall not be stapled more than ½ inch back from the face of the stud.
Reason: This clarifies the staples can be placed ½” into the cavity.
Comment #28Page Number: 4Paragraph / Figure / Table / Note: Section A-1.3.3 item 4.Comment Intent: ObjectionComment Type: GeneralComment: Comment 6 Section A-1.3.3 item 4. Recommend revising the section to read: Insulation shall be installed at a density sufficient to prevent settling over time according to manufacturer’s installation procedures. Reason: As written there is nothing to compare as installed density to the density required to prevent settlement. There needs to be some criteria for the field verification.
Comment 6
Section A-1.3.3 item 4. Recommend revising the section to read:
Insulation shall be installed at a density sufficient to prevent settling over time according to manufacturer’s installation procedures.
Reason: As written there is nothing to compare as installed density to the density required to prevent settlement. There needs to be some criteria for the field verification.
Comment #29Page Number: 4Paragraph / Figure / Table / Note: Section A-1.3.3 exception a.Comment Intent: ObjectionComment Type: TechnicalComment: Comment 7 Section A-1.3.3 exception a. Recommend clarification to exception a. below: a. Air permeable insulation installed in attics and ceilings on the top side of the ceiling in unconditioned attics shall not require an air barrier on the exterior or interior side. Reason: This sentence could refer to 3 different applications, insulation installed on an attic floor, insulation installed under a roof deck, and insulation installed in a cathedral ceiling. The standard needs to be expanded to provide clear guidance as to the requirements for these different applications. Not having an air barrier in the thermal boundary conflicts with the energy codes. There needs to be either more information given or this sentence needs to be reworded.
Comment 7
Section A-1.3.3 exception a. Recommend clarification to exception a. below:
a. Air permeable insulation installed in attics and ceilings on the top side of the ceiling in unconditioned attics shall not require an air barrier on the exterior or interior side.
Reason: This sentence could refer to 3 different applications, insulation installed on an attic floor, insulation installed under a roof deck, and insulation installed in a cathedral ceiling. The standard needs to be expanded to provide clear guidance as to the requirements for these different applications. Not having an air barrier in the thermal boundary conflicts with the energy codes. There needs to be either more information given or this sentence needs to be reworded.
Comment #30Page Number: 5Paragraph / Figure / Table / Note: Section A-2.1.2.1, A-2.1.2.2, A-2.1.2.3Comment Intent: ObjectionComment Type: GeneralComment: Comment 8 Section A-2.1.2.1 Batt or Loose-fill Insulation states: “…no more than 15% of the total insulated area (cavity) shall be compressed or contain gaps or voids in the insulation.” Section A-2.1.2.2 Open-Cell Polyurethane Spray Foam Insulation (cavity not filled and not trimmed) states: “No more than 15% of the insulated area shall contain voids or be more than 1 inch below the specified thickness.” Section A-2.1.2.3 Closed-Cell Polyurethane Spray Foam states: “No more than 15% of the insulated area shall contain voids or be greater than ½ inch below the specified thickness.” NAIMA believes there needs to be clear definitions for “insulated area” vs. “surface area” vs. “cavity” along with diagrams, like those currently in the RESNET standard. This may require further work by the industry partners and RESNET raters to clarify this issue.
Comment 8
Section A-2.1.2.1 Batt or Loose-fill Insulation states:
“…no more than 15% of the total insulated area (cavity) shall be compressed or contain gaps or voids in the insulation.”
Section A-2.1.2.2 Open-Cell Polyurethane Spray Foam Insulation (cavity not filled and not trimmed) states:
“No more than 15% of the insulated area shall contain voids or be more than 1 inch below the specified thickness.”
Section A-2.1.2.3 Closed-Cell Polyurethane Spray Foam states:
“No more than 15% of the insulated area shall contain voids or be greater than ½ inch below the specified thickness.”
NAIMA believes there needs to be clear definitions for “insulated area” vs. “surface area” vs. “cavity” along with diagrams, like those currently in the RESNET standard. This may require further work by the industry partners and RESNET raters to clarify this issue.
Comment #31Page Number: 5Paragraph / Figure / Table / Note: Section A-2.1.1 Grade I (Minor Defects).Comment Intent: Not an ObjectionComment Type: EditorialComment: Comment 9 Section A-2.1.1 Grade I (Minor Defects). Consider revising the section to read: Shall meet ASTM-specified installation requirements in the applicable standards C1015, C1320, and ASTM WK41440 and shall also meet the following cavity fill requirements: Reason: There are several products in this section and this clarifies only the standards that apply to those materials apply.
Comment 9
Section A-2.1.1 Grade I (Minor Defects). Consider revising the section to read:
Shall meet ASTM-specified installation requirements in the applicable standards C1015, C1320, and ASTM WK41440 and shall also meet the following cavity fill requirements:
Reason: There are several products in this section and this clarifies only the standards that apply to those materials apply.
Comment #32Page Number: 5Paragraph / Figure / Table / Note: Section A-2.1.1.1 Batt or Loose-fill Insulation.Comment Intent: ObjectionComment Type: TechnicalComment: Comment 10 Section A-2.1.1.1 Batt or Loose-fill Insulation. Strongly recommend revising the section to read: When installing batt, or loose-fill insulation, no more than 2% of the total insulated area (cavity) shall be compressed below the thickness required to attain the labeled R-value or contain gaps or voids in the insulation. These areas shall not be missing or compressed more than ½ inch ¾ inch of the specified insulation thickness in any given location. Voids extending from the interior to exterior of the intended insulation areas shall not be permitted. Reason: Requiring a more stringent standard of compression (1/2” vs. ¾” maximum) for batt or loose-fill compared to SPF insulation is not technically justified. Especially considering the fact having ¾” less of CCSPF would decrease the overall R-value of the system more, because CCSPF has a greater R-value per inch. In other words, ¾” of CCSPF has more R-value than 1/2” of batt or loose-fill insulation. All materials should be treated equally under the standard.
Comment 10
Section A-2.1.1.1 Batt or Loose-fill Insulation. Strongly recommend revising the section to read:
When installing batt, or loose-fill insulation, no more than 2% of the total insulated area (cavity) shall be compressed below the thickness required to attain the labeled R-value or contain gaps or voids in the insulation. These areas shall not be missing or compressed more than ½ inch ¾ inch of the specified insulation thickness in any given location. Voids extending from the interior to exterior of the intended insulation areas shall not be permitted.
Reason: Requiring a more stringent standard of compression (1/2” vs. ¾” maximum) for batt or loose-fill compared to SPF insulation is not technically justified. Especially considering the fact having ¾” less of CCSPF would decrease the overall R-value of the system more, because CCSPF has a greater R-value per inch. In other words, ¾” of CCSPF has more R-value than 1/2” of batt or loose-fill insulation. All materials should be treated equally under the standard.
Comment #33Page Number: 5Paragraph / Figure / Table / Note: Section A-2.1.2.2 Open-Cell Polyurethane Spray Foam InsulationComment Intent: ObjectionComment Type: TechnicalComment: Comment 11 Section A-2.1.2.2 Open-Cell Polyurethane Spray Foam Insulation (cavity not filled and not trimmed). Strongly recommend revising the section to read: When installing open-cell polyurethane spray foam the average of all thickness measurements shall be greater than the specified thickness required to obtain the specified R-value. No more than 15% of the insulated area shall contain voids or be more than 1 inch ¾ inch below the specified thickness. Reason: Similar to Comment 10, requiring a more stringent standard of compression (3/4” vs. 1” maximum) for batt or loose-fill compared to SPF insulation is not technically justified. Considering the fact having 1” less of CCSPF would decrease the overall R-value of the system more than having ¾” less of batt or loose-fill insulation. In other words, 1” of OCSPF has more R-value than 3/4” of batt or loose-fill insulation because OCSF and batt and loose-fill insulation materials have a similar R-value per inch. All materials should be treated equally under the standard.
Comment 11
Section A-2.1.2.2 Open-Cell Polyurethane Spray Foam Insulation (cavity not filled and not trimmed). Strongly recommend revising the section to read:
When installing open-cell polyurethane spray foam the average of all thickness measurements shall be greater than the specified thickness required to obtain the specified R-value. No more than 15% of the insulated area shall contain voids or be more than 1 inch ¾ inch below the specified thickness.
Reason: Similar to Comment 10, requiring a more stringent standard of compression (3/4” vs. 1” maximum) for batt or loose-fill compared to SPF insulation is not technically justified. Considering the fact having 1” less of CCSPF would decrease the overall R-value of the system more than having ¾” less of batt or loose-fill insulation. In other words, 1” of OCSPF has more R-value than 3/4” of batt or loose-fill insulation because OCSF and batt and loose-fill insulation materials have a similar R-value per inch. All materials should be treated equally under the standard.
Comment #34Page Number: 5Paragraph / Figure / Table / Note: Section A-2.1.2.2 Open-Cell Polyurethane Spray Foam InsulationComment Intent: ObjectionComment Type: TechnicalComment: Comment 12 Section A-2.1.2.2 Open-Cell Polyurethane Spray Foam Insulation (cavity not filled and not trimmed). Strongly recommend revising the section to read: (Previous language addressed in Comment 11) The minimum thickness shall not be less than 1.5 inches ¾ inch below the specified thickness at any point. Voids extending from the interior to the exterior of the intended insulation areas shall not be permitted. Reason: Similar to Comments 10 and 11, requiring a more stringent standard of compression or missing insulation (1.5” vs. 3/4” maximum) for batt or loose-fill compared to OCSPF insulation is not technically justified. Considering the effect of having 1.5” less of OCSPF would decrease the overall R-value of the system more, than having ¾” less of batt or loose-fill insulation because OCSPF and batt and loose-fill insulations have a similar R-value per inch. In other words, 1” of OCSPF has more R-value than 3/4” of batt or loose-fill insulation. All materials should be treated equally under the standard.
Comment 12
(Previous language addressed in Comment 11) The minimum thickness shall not be less than 1.5 inches ¾ inch below the specified thickness at any point. Voids extending from the interior to the exterior of the intended insulation areas shall not be permitted.
Reason: Similar to Comments 10 and 11, requiring a more stringent standard of compression or missing insulation (1.5” vs. 3/4” maximum) for batt or loose-fill compared to OCSPF insulation is not technically justified. Considering the effect of having 1.5” less of OCSPF would decrease the overall R-value of the system more, than having ¾” less of batt or loose-fill insulation because OCSPF and batt and loose-fill insulations have a similar R-value per inch. In other words, 1” of OCSPF has more R-value than 3/4” of batt or loose-fill insulation. All materials should be treated equally under the standard.
Comment #35Page Number: 5Paragraph / Figure / Table / Note: Section A-2.1.2.3 Closed-Cell Polyurethane Spray FoamComment Intent: ObjectionComment Type: TechnicalComment: Comment 13 Section A-2.1.2.3 Closed-Cell Polyurethane Spray Foam. Strongly recommend revising the section to read: When installing closed-cell polyurethane spray foam the average of all thickness measurements shall be greater than the specified thickness required to obtain the specified R-value. No more than 15% of the insulated area shall contain voids or be greater than ½ inch ¾ inch below the specified thickness. (Remainder to remain unchanged) Reason: Related to previous comments on maximum compression or missing thickness. Requiring a more stringent standard of compression or missing insulation 1/2” for CCSPF vs. 1.5” for OCSPF and 3/4” for batt or loose-fill is not technically justified. All materials should be treated equally under the standard.
Comment 13
Section A-2.1.2.3 Closed-Cell Polyurethane Spray Foam. Strongly recommend revising the section to read:
When installing closed-cell polyurethane spray foam the average of all thickness measurements shall be greater than the specified thickness required to obtain the specified R-value. No more than 15% of the insulated area shall contain voids or be greater than ½ inch ¾ inch below the specified thickness. (Remainder to remain unchanged)
Reason: Related to previous comments on maximum compression or missing thickness. Requiring a more stringent standard of compression or missing insulation 1/2” for CCSPF vs. 1.5” for OCSPF and 3/4” for batt or loose-fill is not technically justified. All materials should be treated equally under the standard.
Comment #36Page Number: 6Paragraph / Figure / Table / Note: Section A-2.1.2.1 Batt or Loose-fill Insulation.Comment Intent: Not an ObjectionComment Type: TechnicalComment: Comment 14 Section A-2.1.2.1 Batt or Loose-fill Insulation. NAIMA Strongly supports the following revision for Grade II installations: recommend revising the section to read: When installing batt, or loose-fill insulation, no more than 15% of the total insulated area (cavity) shall be compressed or contain gaps or voids in the insulation. Reason: When neatly inset stapling insulation in a wall framed on 16 inch centers, this will result in a void that is approximately 1” from the edge of the stud to where the insulation bows out and touches the gypsum board. Therefore a 1” void on each side (2” total) divided by the 14.5” wide cavity results in a 13.7% (2/14.5) area of compression. Testing has shown that neatly inset stapled insulation batts perform as well as face stapled batts. Inset stapled batts should be permitted for Grade II applications.
Comment 14
Section A-2.1.2.1 Batt or Loose-fill Insulation. NAIMA Strongly supports the following revision for Grade II installations: recommend revising the section to read:
When installing batt, or loose-fill insulation, no more than 15% of the total insulated area (cavity) shall be compressed or contain gaps or voids in the insulation.
Reason: When neatly inset stapling insulation in a wall framed on 16 inch centers, this will result in a void that is approximately 1” from the edge of the stud to where the insulation bows out and touches the gypsum board. Therefore a 1” void on each side (2” total) divided by the 14.5” wide cavity results in a 13.7% (2/14.5) area of compression. Testing has shown that neatly inset stapled insulation batts perform as well as face stapled batts. Inset stapled batts should be permitted for Grade II applications.
Comment #37Page Number: 5Paragraph / Figure / Table / Note: Section A-2.1.1.4 Insulated SheathingComment Intent: ObjectionComment Type: TechnicalComment: Comment 15 Section A-2.1.1.4 Insulated Sheathing. Recommend revising the section to read: Insulated sheathing insulation installations meeting the minimum installation, application, and material requirements above. Voids exceeding 1/8” through interior to exterior of the intended insulation areas shall not be permitted. Reason: Stating “Voids through interior to exterior of the intended insulation areas shall not be permitted.” This could be interpreted to mean the use of shiplap foam will be required to meet this minimum standard. One could argue that there is always a void between abutting sheet goods. Adding a minimum tolerance for a gap would help clarify this.
Comment 15
Section A-2.1.1.4 Insulated Sheathing. Recommend revising the section to read:
Insulated sheathing insulation installations meeting the minimum installation, application, and material requirements above. Voids exceeding 1/8” through interior to exterior of the intended insulation areas shall not be permitted.
Reason: Stating “Voids through interior to exterior of the intended insulation areas shall not be permitted.” This could be interpreted to mean the use of shiplap foam will be required to meet this minimum standard. One could argue that there is always a void between abutting sheet goods. Adding a minimum tolerance for a gap would help clarify this.
Comment #38Page Number: 4Paragraph / Figure / Table / Note: A-1.3.4; A-1.3.6Comment Intent: Not an ObjectionComment Type: TechnicalComment: Upon comparison of the proposed standard for insulation installation grading and the current requirements for the State of California contained in Title 24 document CF2R-ENV-23-H, it appears that there are multiple minor differences that could be resolved. RESNET has stated that one of its goals is to better align with California ratings, where possible, and this proposal outlines a simple change in the differences in minimum thickness to be considered an air barrier to align with California requirements. Proposed Change: A-1.3.4 Open cell spray polyurethane foam (SPF) insulation: Installers shall meet the manufacturer’s recommended training requirements and shall complete the online health and safety training for SPF provided by the Center for Polyurethanes Industry. Spray foam shall be well-bonded to the substrate, including framing and sheathing. Insulation, installed at thicknesses of 5.5 inches or more a minimum thickness to be air impermeable per E2178 (air permeance less than 0.04 cfm/ft2) and in-contact with the substrate shall be permitted to serve as the air barrier. Exception: Thicknesses less than 5.5 inches shall be considered air-impermeable with appropriate ASTM E2178 data (air permeance less than 0.04 cfm/ft2) from manufacturer data sheet or ICC-ES Report. When insulation extends beyond the wall cavity it shall be trimmed to allow installation and contact with interior sheathing or finish material. Insulation shall fill the cavity to within no more than ½ inch from the face of the studs. Exception: When the required R-value is met using a thickness that is less than the cavity depth. A-1.3.6 Closed-cell spray polyurethane foam (SPF) insulation: Installers shall meet the manufacturer’s recommended training requirements and shall complete the online health and safety training for SPF provided by the Center for Polyurethanes Industry. Spray foam shall be well-bonded to the substrate, including framing and sheathing. Closed-cell Insulation, installed at thicknesses of 1.52.0 inches thick or more shall be permitted to be an air-impermeable insulation when in-contact with the substrate. Exception: Thicknesses less than 1.52.0 inches shall be considered air-impermeable with appropriate ASTM E2178 data (air permeance less than 0.04 cfm/ft2) from manufacturer data sheet or ICC-ES Report.
Upon comparison of the proposed standard for insulation installation grading and the current requirements for the State of California contained in Title 24 document CF2R-ENV-23-H, it appears that there are multiple minor differences that could be resolved. RESNET has stated that one of its goals is to better align with California ratings, where possible, and this proposal outlines a simple change in the differences in minimum thickness to be considered an air barrier to align with California requirements.
A-1.3.4 Open cell spray polyurethane foam (SPF) insulation:
Exception: Thicknesses less than 5.5 inches shall be considered air-impermeable with appropriate ASTM E2178 data (air permeance less than 0.04 cfm/ft2) from manufacturer data sheet or ICC-ES Report.
Exception: When the required R-value is met using a thickness that is less than the cavity depth.
A-1.3.6 Closed-cell spray polyurethane foam (SPF) insulation:
Exception: Thicknesses less than 1.52.0 inches shall be considered air-impermeable with appropriate ASTM E2178 data (air permeance less than 0.04 cfm/ft2) from manufacturer data sheet or ICC-ES Report.
Comment #39Page Number: 7Paragraph / Figure / Table / Note: A-2.3Comment Intent: Not an ObjectionComment Type: GeneralComment: The criteria related to reflective and radiant insulation products is a welcomed addition to this standard. However, requirements related to air sealing for these products need to be clarified. Any airspace for which an R-value is claimed must be air-sealed for the products to perform as expected. This is because the lack of sealing: (1) introduces dust into the space, degrading the reflective insulation over time, and (2) changes the thermal profile of the space due to infiltration – reducing the rated insulation value. The proposed modification, below, includes language that reduces confusion on the requirement for this important feature by referencing all R-value claims rather than only those listed in the ASHRAE Handbook of Fundamentals. Proposed Change: A-2.3 Reflective/Radiant Grading Criteria Regarding thermal performance claims or R-values: R-value claims for the air space adjacent to a reflective insulation product shall be based on average cavity depth, heat flow direction which represents the application (wall, ceiling or floor), temperature of the airspace surfaces relative to the specific wall assembly, location of the airspace in the assembly, and design climate conditions. When utilizing R-value claims for the air space adjacent to a reflective insulation product s from the ASHRAE Handbook of Fundamentals, the enclosed airspaces shall be sealed cavities which do not to allow air flow in or out of the cavity. All other R-value claims by the manufacturer for the assembly including the airspace shall be based on ASTM C1224, the Standard Specification of Reflective Insulation. The assembly that is tested for thermal resistance shall be representative of the field assembly.
The criteria related to reflective and radiant insulation products is a welcomed addition to this standard.
However, requirements related to air sealing for these products need to be clarified. Any airspace for which an R-value is claimed must be air-sealed for the products to perform as expected. This is because the lack of sealing: (1) introduces dust into the space, degrading the reflective insulation over time, and (2) changes the thermal profile of the space due to infiltration – reducing the rated insulation value.
The proposed modification, below, includes language that reduces confusion on the requirement for this important feature by referencing all R-value claims rather than only those listed in the ASHRAE Handbook of Fundamentals.
Comment #40Page Number: n/aParagraph / Figure / Table / Note: All sectionsComment Intent: Not an ObjectionComment Type: GeneralComment: The revision of the insulation installation requirements represents an opportunity to align with the California CEC-developed Quality Insulation Installation (QII) protocol. RESNET has stated that one of its goals is to better align with California ratings, where possible. The California document CF2R-ENV-23-H outlines the insulation installation requirements for the State of California. Many of these items overlap with the verification levels outlined in the draft changes to standard 301 and a wholesale look/alignment would be advantageous to both RESNET and California.
The revision of the insulation installation requirements represents an opportunity to align with the California CEC-developed Quality Insulation Installation (QII) protocol. RESNET has stated that one of its goals is to better align with California ratings, where possible.
The California document CF2R-ENV-23-H outlines the insulation installation requirements for the State of California. Many of these items overlap with the verification levels outlined in the draft changes to standard 301 and a wholesale look/alignment would be advantageous to both RESNET and California.
Comment #41Page Number: page 2Paragraph / Figure / Table / Note: A-1.1Comment Intent: ObjectionComment Type: TechnicalComment: The term "industry standards" is not defined and is vague. It should be removed. Proposed Change: A-1.1 Minimum General Installation Requirements: Insulation shall be installed to manufacturers’ recommendations and industry standards.
The term "industry standards" is not defined and is vague. It should be removed.
A-1.1 Minimum General Installation Requirements:
Insulation shall be installed to manufacturers’ recommendations and industry standards.
Comment #42Page Number: page 3Paragraph / Figure / Table / Note: A-1.3.2Comment Intent: ObjectionComment Type: TechnicalComment: The general requirement is for an air barrier exterior to the insulation (Section A-1.1 item #2). The exception for attics removes the air barrier on the exterior and would leave no air barrier requirement. Fibrous batt insulation should have an air barrier. Proposed Change: A-1.3.2 Fibrous Batt Insulation: Insulation shall fill the cavity being insulated side to side, top to bottom. Insulation shall be enclosed on all six sides. Exceptions: Insulation installed in attics above ceilings shall not require an air barrier on the exterior side, provided there is an air barrier in substaintial and permanent contact with the insulation to the interior of the attic insulation.
The general requirement is for an air barrier exterior to the insulation (Section A-1.1 item #2). The exception for attics removes the air barrier on the exterior and would leave no air barrier requirement. Fibrous batt insulation should have an air barrier.
A-1.3.2 Fibrous Batt Insulation:
Insulation shall fill the cavity being insulated side to side, top to bottom.
Insulation shall be enclosed on all six sides.
Exceptions:
Insulation installed in attics above ceilings shall not require an air barrier on the exterior side, provided there is an air barrier in substaintial and permanent contact with the insulation to the interior of the attic insulation.
Comment #43Page Number: page 10Paragraph / Figure / Table / Note: A-3.0Comment Intent: ObjectionComment Type: GeneralComment: Standards which are not final should not be referenced. Replace the standard below with a final version and give time to examine that version and make a public comment. Or remove the reference. If any of the other standards are not final, treat them the same way. Proposed Change: ASTM WK41440: New Guide for Installation of Spray Polyurethane Foam Insulation in the Building Envelope
Standards which are not final should not be referenced. Replace the standard below with a final version and give time to examine that version and make a public comment. Or remove the reference.
If any of the other standards are not final, treat them the same way.
ASTM WK41440: New Guide for Installation of Spray Polyurethane Foam Insulation in the Building Envelope
Comment #44Page Number: page 2Paragraph / Figure / Table / Note: A-1.1Comment Intent: ObjectionComment Type: EditorialComment: Straighten out the "ands". As worded I think it literally says insulation does not get Grade III unless it fails all three tests. I think you mean to say if it fails any test it gets grade III. Proposed Change: Installations not complying with the minimum installation requirements of this Appendix and , the relevant ASTM standard for the type insulation and , or not complying with the Grade I or Grade II coverage requirements shall be considered Grade III installations. Grade III installations shall be recorded and shall be modeled as specified by Section 4.2.2.2.2 of this Standard.
Straighten out the "ands". As worded I think it literally says insulation does not get Grade III unless it fails all three tests. I think you mean to say if it fails any test it gets grade III.
Installations not complying with the minimum installation requirements of this Appendix and , the relevant ASTM standard for the type insulation and , or not complying with the Grade I or Grade II coverage requirements shall be considered Grade III installations. Grade III installations shall be recorded and shall be modeled as specified by Section 4.2.2.2.2 of this Standard.
Comment #45Page Number: page 1Paragraph / Figure / Table / Note: Table 4.2.2(1) Notes, def Approved TesterComment Intent: ObjectionComment Type: GeneralComment: The November 8th RESNET email announcing this public review does not mention duct tightness testing or envelop tightness testing. Rather the topic is"insulation installation grading". A reasonable person would conclude the proposed draft relates to the stated topic "insulation installation grading". It is inappropriate for RESNET to include unannounced topics in the draft. Section 2.1 of the ANSI Essential Requirements states in part: "2.1 Openness Timely and adequate notice of any action to create, revise, reaffirm, or withdraw a standard, and the establishment of a new consensus body shall be provided to all known directly and materially affected interests. Notice should include a clear and meaningful description of the purpose of the proposed activity and shall identify a readily available source for further information. ..." Incorrectly identifying the topic of the proposed change by leaving topics out is not adequate notice of an action to revise the standard. Incorrectly stating the topics of the proposed change impedes affected interests, including those who are on the RESNET mailing list, from getting a clear and meaningful description of the proposed revision simply because they don't know about it. Remove the "Table 4.2.2(1) Notes" change from the proposed draft. Remove "Approved Tester" definition change from the proposed draft. Announce a seperate review for these parts again. Proposed Change: Approved Tester – An individual who, by virtue of training and examination, has demonstrated competence in the performance of on-site testing in accordance with requirements equivalent to ANSI/RESNET/ICC 380-2016 and who has been approved by an Approved Rating Provider to conduct such tests. Table 4.2.2(1) Notes (e) Tested envelope leakage shall be determined and documented using the on-site inspection protocol as specified by requirements equivalent to ANSI/RESNET/ICC 380-2016 by an Approved Tester. (o) Tested duct leakage shall be determined and documented by an Approved Tester using the protocols equivalent to those specified in ANSI/RESNET/ICC 380-2016.
The November 8th RESNET email announcing this public review does not mention duct tightness testing or envelop tightness testing. Rather the topic is"insulation installation grading". A reasonable person would conclude the proposed draft relates to the stated topic "insulation installation grading".
It is inappropriate for RESNET to include unannounced topics in the draft.
Section 2.1 of the ANSI Essential Requirements states in part:
"2.1 Openness
Timely and adequate notice of any action to create, revise, reaffirm, or withdraw a standard, and the
establishment of a new consensus body shall be provided to all known directly and materially affected interests. Notice should include a clear and meaningful description of the purpose of the proposed activity and shall identify a readily available source for further information. ..."
Incorrectly identifying the topic of the proposed change by leaving topics out is not adequate notice of an action to revise the standard. Incorrectly stating the topics of the proposed change impedes affected interests, including those who are on the RESNET mailing list, from getting a clear and meaningful description of the proposed revision simply because they don't know about it.
Remove the "Table 4.2.2(1) Notes" change from the proposed draft. Remove "Approved Tester" definition change from the proposed draft. Announce a seperate review for these parts again.
Approved Tester – An individual who, by virtue of training and examination, has demonstrated competence in the performance of on-site testing in accordance with requirements equivalent to ANSI/RESNET/ICC 380-2016 and who has been approved by an Approved Rating Provider to conduct such tests.
Table 4.2.2(1) Notes
(e) Tested envelope leakage shall be determined and documented using the on-site inspection protocol as specified by requirements equivalent to ANSI/RESNET/ICC 380-2016 by an Approved Tester.
(o) Tested duct leakage shall be determined and documented by an Approved Tester using the protocols equivalent to those specified in ANSI/RESNET/ICC 380-2016.
Comment #46Page Number: page 1Paragraph / Figure / Table / Note: Table 4.2.2(1) Notes, def Approved TesterComment Intent: ObjectionComment Type: GeneralComment: The ANSI Essential Standards state "The appearance that a standard endorses any particular products, services or companies must be avoided." Note the goal is to avoid even the "appearance". ANSI states " Provisions involving business relations between buyer and seller ... shall not be included in an American National Standard." I'd contend that RESNET's Approved Providers and Raters do have a business relationship with the users of the envelop and duct testing standard. In suggesting how to reference a single source, ANSI says "Where a sole source exists .. it is permissible to supply the name ... in a footnote or informative annex ... " with the words “or the equivalent” added to the footnote or annex. Note it says "informative annex" not "normative annex". Any such RESNET Standard should be named in a footnote or informative annex in ANSI/ICC/RESNET' 301, as suggest by ANSI. If RESNET believes there are other equivalent standard(s), please name them in the response to this comment. Proposed Change: Approved Tester – An individual who, by virtue of training and examination, has demonstrated competence in the performance of on-site testing in accordance with requirements equivalent to Sections 802 and 803 of the Mortgage Industry National Home Energy Rating Systems Standards ANSI/RESNET/ICC 380-2016 and who has been approved by an Approved Rating Provider to conduct such tests. Table 4.2.2(1) Notes (e) Tested envelope leakage shall be determined and documented using the on-site inspection protocol as specified by requirements equivalent to Section 802 of the Mortgage Industry National Home Energy Rating Systems Standards ANSI/RESNET/ICC 380-2016 by an Approved Tester. (o) Tested duct leakage shall be determined and documented by an Approved Tester using the protocols equivalent to those specified in Section 803 of the Mortgage Industry National Home Energy Rating Systems Standards ANSI/RESNET/ICC 380-2016.
The ANSI Essential Standards state "The appearance that a standard endorses any particular products, services or companies must be avoided." Note the goal is to avoid even the "appearance".
ANSI states " Provisions involving business relations between buyer and seller ... shall not be included in an American National Standard." I'd contend that RESNET's Approved Providers and Raters do have a business relationship with the users of the envelop and duct testing standard.
In suggesting how to reference a single source, ANSI says "Where a sole source exists .. it is permissible to supply the name ... in a footnote or informative annex ... " with the words “or the equivalent” added to the footnote or annex. Note it says "informative annex" not "normative annex".
Any such RESNET Standard should be named in a footnote or informative annex in ANSI/ICC/RESNET' 301, as suggest by ANSI.
If RESNET believes there are other equivalent standard(s), please name them in the response to this comment.
Approved Tester – An individual who, by virtue of training and examination, has demonstrated competence in the performance of on-site testing in accordance with requirements equivalent to Sections 802 and 803 of the Mortgage Industry National Home Energy Rating Systems Standards ANSI/RESNET/ICC 380-2016 and who has been approved by an Approved Rating Provider to conduct such tests.
(e) Tested envelope leakage shall be determined and documented using the on-site inspection protocol as specified by requirements equivalent to Section 802 of the Mortgage Industry National Home Energy Rating Systems Standards ANSI/RESNET/ICC 380-2016 by an Approved Tester.
(o) Tested duct leakage shall be determined and documented by an Approved Tester using the protocols equivalent to those specified in Section 803 of the Mortgage Industry National Home Energy Rating Systems Standards ANSI/RESNET/ICC 380-2016.
Comment #47Page Number: allComment Intent: Not an ObjectionComment Type: GeneralComment: I strongly appreciate RESNET's leadership in describing what it means to install insulation correctly, to try to make the judgment on quality practical, and to specifying a consequence for installing insulation poorly. Multiple sources, including many raters, observe that insulation is very often installed incorrectly. The energy penalty, especially for new energy efficient homes, is substantial. Please keep it up.
I strongly appreciate RESNET's leadership in describing what it means to install insulation correctly, to try to make the judgment on quality practical, and to specifying a consequence for installing insulation poorly. Multiple sources, including many raters, observe that insulation is very often installed incorrectly. The energy penalty, especially for new energy efficient homes, is substantial. Please keep it up.