The following comments have been submitted:
Comment #1Page Number: 3Paragraph / Figure / Table / Note: A-1.3.1Comment Intent: ObjectionComment Type: TechnicalComment: This heading seems too limited. It should be broadened so that it encompasses both insulated sheathing and rigid foam board insulation since the latter is otherwise not addressed anywhere in the Appendix. Proposed Change: A-1.3.1 Insulated Sheathing and Rigid Foam Board Insulation
This heading seems too limited. It should be broadened so that it encompasses both insulated sheathing and rigid foam board insulation since the latter is otherwise not addressed anywhere in the Appendix.
A-1.3.1 Insulated Sheathing and Rigid Foam Board Insulation
Comment #2Page Number: 3Paragraph / Figure / Table / Note: A-1.3.1Comment Intent: ObjectionComment Type: TechnicalComment: This heading seems too limited. It should be broadened so that it encompasses both insulated sheathing and rigid foam board insulation since the latter is otherwise not addressed anywhere in the Appendix. Proposed Change: A-1.3.1 Insulated Sheathing and Rigid Foam Board Insulation
Comment #3Page Number: 1-2Paragraph / Figure / Table / Note: 4.2.2.2 and 4.2.2.2.1 and A-1.Comment Intent: ObjectionComment Type: TechnicalComment: In the above sections, the language is not explicit about whether inspections of insulation using thermographic/IR are permitted for Grade I or Grade II or if those are "not inspected" and are therefore limited to Grade III only. Some Raters use their discretion and use IR cameras to "assess" insulation grading, and others do not feel that is the intent of this section. In the absence of a standard for these kinds of inspections, RESNET needs to be explicit that they can only count as Grade III until such a standard is available. Proposed Change: Please add a sentence to one fo the section making it explicit that IR can only count as Grade III
In the above sections, the language is not explicit about whether inspections of insulation using thermographic/IR are permitted for Grade I or Grade II or if those are "not inspected" and are therefore limited to Grade III only. Some Raters use their discretion and use IR cameras to "assess" insulation grading, and others do not feel that is the intent of this section. In the absence of a standard for these kinds of inspections, RESNET needs to be explicit that they can only count as Grade III until such a standard is available.
Please add a sentence to one fo the section making it explicit that IR can only count as Grade III
Comment #4Page Number: 4Paragraph / Figure / Table / Note: A-1.3.2Comment Intent: ObjectionComment Type: TechnicalComment: Inset or side stapling of batt insulation shall not be permitted for Grade I installations. I believe that this is unreasonable. I have seen many installs with paper flanges stapled that were excellent. Since the only difference between friction fit and regular faced batt insulation is the paper tab, why not allow a Grade 1 installation? R-value is the same and the friction fit over the paper tab makes no difference. Also, just how much diffference is there in contact with back of drywall between stapled and unstapled? I believe it's not enough to justify. Thanks for the opportunity to comment.
Inset or side stapling of batt insulation shall not be permitted for Grade I installations.
I believe that this is unreasonable. I have seen many installs with paper flanges stapled that were excellent. Since the only difference between friction fit and regular faced batt insulation is the paper tab, why not allow a Grade 1 installation? R-value is the same and the friction fit over the paper tab makes no difference.
Also, just how much diffference is there in contact with back of drywall between stapled and unstapled? I believe it's not enough to justify.
Thanks for the opportunity to comment.
Comment #5Page Number: not numberedParagraph / Figure / Table / Note: A-1.2.1.Comment Intent: ObjectionComment Type: TechnicalComment: I don't think the version of the referenced IECC should be mentioned, if possible. Or, it should be whichever code is in effect in the jurisdiction where the inspection is taking place. Or it could be the 2006 IECC to align with the rest of the intent for ERIs. Proposed Change: 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 402.1.1 of the 2006 International Energy Conservation Code (IECC) and that extends from the bottom to the top of all perimeter floor framing members. The cavity insulation between floor joists, beams or other horizontal floor supports that create cavities under the subfloor shall be permitted to be in direct contact with any additional continuous insulation attached to the underside of the horizontal supports. The combination of both cavity and continuous insulation shall meet or exceed the minimum required floor R value in Ttable 402.1.2 of the 2015 402.1.1 of the 2006 International Energy Conservation Code, (IECC). Instances of reflective insulation system installed beneath hydronic floors are not required to meet this standard.
I don't think the version of the referenced IECC should be mentioned, if possible. Or, it should be whichever code is in effect in the jurisdiction where the inspection is taking place. Or it could be the 2006 IECC to align with the rest of the intent for ERIs.
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 402.1.1 of the 2006 International Energy Conservation Code (IECC) and that extends from the bottom to the top of all perimeter floor framing members.
The cavity insulation between floor joists, beams or other horizontal floor supports that create cavities under the subfloor shall be permitted to be in direct contact with any additional continuous insulation attached to the underside of the horizontal supports. The combination of both cavity and continuous insulation shall meet or exceed the minimum required floor R value in Ttable 402.1.2 of the 2015 402.1.1 of the 2006 International Energy Conservation Code, (IECC). Instances of reflective insulation system installed beneath hydronic floors are not required to meet this standard.
Comment #6Page Number: 4Paragraph / Figure / Table / Note: A-1.3.2Comment Intent: ObjectionComment Type: TechnicalComment: I disagree with the correction,"inset or side stapling of batt insulation shall not be permitted for Grade I installations." Fiberglass batt manufacturers instructions allow for inset stapling in their guidelines. I have seen it done properly, where there aren't substantial voids. I don't think you can mandate face stapling only for Grade I. Furthermore, I often see face stapled batts incorrectly 'pinched' which leaves significant voids on the back of the insulation. Sure it looks great from the face, but you can't see all the voids hiding behind the face stapled batts. I think you should address 'pinched batts' as a concern to face stapling in your Normative. Proposed Change: 3. Faced batts shall be stapled to the face of the studs or side stapled to the studs with no buckling of the stapling tabs or the tabs shall be permitted to be left unstapled. Inset or side stapling of batt insulation shall not be permitted for Grade I installations. Faced batt products without tabs and friction fit products shall not be required to be stapled when installed in vertical walls. When batts are face stapled, verify batts are not pinched, hiding the compression.
I disagree with the correction,"inset or side stapling of batt insulation shall not be permitted for Grade I installations." Fiberglass batt manufacturers instructions allow for inset stapling in their guidelines. I have seen it done properly, where there aren't substantial voids. I don't think you can mandate face stapling only for Grade I.
Furthermore, I often see face stapled batts incorrectly 'pinched' which leaves significant voids on the back of the insulation. Sure it looks great from the face, but you can't see all the voids hiding behind the face stapled batts. I think you should address 'pinched batts' as a concern to face stapling in your Normative.
3. Faced batts shall be stapled to the face of the studs or side stapled to the studs with no buckling of the stapling tabs or the tabs shall be permitted to be left unstapled. Inset or side stapling of batt insulation shall not be permitted for Grade I installations. Faced batt products without tabs and friction fit products shall not be required to be stapled when installed in vertical walls. When batts are face stapled, verify batts are not pinched, hiding the compression.
Comment #7Page Number: 9Paragraph / Figure / Table / Note: A-2.3.2Comment Intent: ObjectionComment Type: TechnicalComment: "4. The radiant barrier shall be installed on gable ends". Most builders in my region of Climate Zone 3 use a radiant barrier roof sheathing and a different type of wall sheathing, including for the gable end of the attic. Siding doesn't get anywhere near the amount of solar heat gain that an asphalt roof shingle does, so I don't think it makes sense to require that to take credit for having a radiant barrier. Proposed Change: A-2.3.2 Attic Radiant Barriers Minimum Requirements: 1. Attic radiant barriers shall be installed with an airspace adjacent to the low emittance (metallic) surface(s); 2. When the radiant barrier only has one low emittance surface, it shall be on the bottom side (in the direction of the ceiling ); 3. Attic and/or roof ventilation shall be maintained. Roof, gable and soffit vents shall not be covered. 4. The radiant barrier shall be installed on gable ends. 5.4. The radiant barrier shall be firmly secured.
"4. The radiant barrier shall be installed on gable ends". Most builders in my region of Climate Zone 3 use a radiant barrier roof sheathing and a different type of wall sheathing, including for the gable end of the attic. Siding doesn't get anywhere near the amount of solar heat gain that an asphalt roof shingle does, so I don't think it makes sense to require that to take credit for having a radiant barrier.
Comment #8Page Number: 2Paragraph / Figure / Table / Note: Minimum General Installation RequirementsComment Intent: ObjectionComment Type: EditorialComment: A-1.1 I think both item #1 and item #5 as minimum requirements without any specified tolerances suggests that the areas must be met everywhere, i.e 100%, which contradicts the grading tolerance levels outlined later in the normative. To suggest that both statements, "Insulation shall be installed to manufacturers' recommendations" and "Insulation shall fill around obstructions including, but not limited to framing, blocking, wiring, pipes, etc. without substantial gaps or voids." are minimum requirements is objectionable. That is the point of specifying threshold amounts, whether its 2% or 15%. For example, the manufacturers' recommendations may not be met in all obstructed cavities, but the compression or misalignment may be less than 15% of the total surface area. The point of having tolerances, whether it be 2% or 15%, was that those areas may not meet the manufacturer's recommendations but as long as it was under the stated threshold of 2% or 15%, then you could achieve that corresponding insulation grade. Thus in other words, if 2% of the area or less doesn't meet the manufacturer's recommendations, then Grade I can be given. Or if no more than 15% of the total insulated area doesn't meet the manufacturer's recommendations or doesn't fill obstructed cavities then Grade II can be given. Afterall, Grade II is a penalty, isn't it? The proposed change below obviously needs work, but here is a first attempt. Proposed Change: A-1.1 Minimum General Installation Requirements: 1. Insulation shall be installed to manufacturers’ recommendations and industry standards and shall not exceed stated tolerances outlined in A-2.1.1.1 or A-2.1.2.1. 2. Insulation shall be integral to or on the interior to or exterior side and in substantial and permanent contact with the primary air barrier. 3. No air spaces shall be allowed between different insulation types or systems. Exception: When claiming the R-value of an enclosed reflective air space in accordance with the ASHRAE Handbook of Fundamentals90.1-2016 Section A9-4 (or addendum ac to the 2013 edition) or ASTM C 1224. 4. Insulation shall be installed to the required density and thickness necessary to achieve the labeled R-value. 5. Insulation shall fill around obstructions including, but not limited to, framing, blocking, wiring, pipes, etc. without substantial gaps or voids and shall not exceed stated tolerances outlined in A-2.1.1.1 or A-2.1.2.1.
A-1.1 I think both item #1 and item #5 as minimum requirements without any specified tolerances suggests that the areas must be met everywhere, i.e 100%, which contradicts the grading tolerance levels outlined later in the normative.
To suggest that both statements, "Insulation shall be installed to manufacturers' recommendations" and "Insulation shall fill around obstructions including, but not limited to framing, blocking, wiring, pipes, etc. without substantial gaps or voids." are minimum requirements is objectionable. That is the point of specifying threshold amounts, whether its 2% or 15%.
For example, the manufacturers' recommendations may not be met in all obstructed cavities, but the compression or misalignment may be less than 15% of the total surface area.
The point of having tolerances, whether it be 2% or 15%, was that those areas may not meet the manufacturer's recommendations but as long as it was under the stated threshold of 2% or 15%, then you could achieve that corresponding insulation grade.
Thus in other words, if 2% of the area or less doesn't meet the manufacturer's recommendations, then Grade I can be given.
Or if no more than 15% of the total insulated area doesn't meet the manufacturer's recommendations or doesn't fill obstructed cavities then Grade II can be given.
Afterall, Grade II is a penalty, isn't it?
The proposed change below obviously needs work, but here is a first attempt.
Comment #9Page Number: 6Paragraph / Figure / Table / Note: A-2.1.1.4Comment Intent: ObjectionComment Type: TechnicalComment: Same concept as comment #1. Include "and rigid foam board insulation" with all instances of "insulated sheathing." Proposed Change: Insulated Sheating and Rigid Foam Board Insulation
Same concept as comment #1. Include "and rigid foam board insulation" with all instances of "insulated sheathing."
Insulated Sheating and Rigid Foam Board Insulation
Comment #10Page Number: 3 and 4Paragraph / Figure / Table / Note: A-1.3.2, 2. and A-1.3.3, 5.Comment Intent: ObjectionComment Type: TechnicalComment: Specify the material that shall enclose the insulation. It's implied but not stated that the material shall be an air barrier. Proposed Change: Insulation shall be enclosed on all six sides with an air barrier.
Specify the material that shall enclose the insulation. It's implied but not stated that the material shall be an air barrier.
Insulation shall be enclosed on all six sides with an air barrier.
Comment #11Page Number: 3Paragraph / Figure / Table / Note: A-1.3.2, 2., c.Comment Intent: ObjectionComment Type: TechnicalComment: The phrase "located in conditioned space" is unnecessary and adds ambiguity. If the rim is entirely in conditioned space (between two bedrooms), insulation is never required. If it's an exterior rim, then it's not fully located in conditioned space because one side is exterior. Proposed Change: Insulation installed in rim or band joists located in conditioned space shall not require an air barrier on the interior side.
The phrase "located in conditioned space" is unnecessary and adds ambiguity. If the rim is entirely in conditioned space (between two bedrooms), insulation is never required. If it's an exterior rim, then it's not fully located in conditioned space because one side is exterior.
Insulation installed in rim or band joists located in conditioned space shall not require an air barrier on the interior side.
Comment #12Page Number: 4Paragraph / Figure / Table / Note: A-1.3.2, 3.Comment Intent: ObjectionComment Type: TechnicalComment: The modifier "vertical" is unnecessary and adds ambiguity. Proposed Change: Faced batt products without tabs and friction fit products shall not be required to be stapled when installed in vertical walls.
The modifier "vertical" is unnecessary and adds ambiguity.
Faced batt products without tabs and friction fit products shall not be required to be stapled when installed in vertical walls.
Comment #13Page Number: 3 and 4Paragraph / Figure / Table / Note: A-1.3.2, 1. and A-1.3.3, 3.Comment Intent: ObjectionComment Type: TechnicalComment: This statement is crazy when considered in context of a conventional vented attic (layer the batts or blow the insulation to the peak!). It is also contradictory to the Minimum Specific Application Requriements for framed floors. It should either be modified or stricken entirely. The insulation grading guidelines cover this aspect of insulation installation. Proposed Change: When installed in a closed cavity, iInsulation shall fill the cavity being insulatedfrom side to side, and from top to bottom. OR Insulation shall cover the areafill the cavity being insulated, from side to side in all cases, and from top to bottom in walls and rim or band joists. OR Insulation shall fill the cavity being insulated, side to side, and top to bottom.
This statement is crazy when considered in context of a conventional vented attic (layer the batts or blow the insulation to the peak!). It is also contradictory to the Minimum Specific Application Requriements for framed floors. It should either be modified or stricken entirely. The insulation grading guidelines cover this aspect of insulation installation.
When installed in a closed cavity, iInsulation shall fill the cavity being insulatedfrom side to side, and from top to bottom.
OR
Insulation shall cover the areafill the cavity being insulated, from side to side in all cases, and from top to bottom in walls and rim or band joists.
Insulation shall fill the cavity being insulated, side to side, and top to bottom.
Comment #14Page Number: 3 and 4Paragraph / Figure / Table / Note: A-1.3.2, 1. and A-1.3.3, 3.Comment Intent: ObjectionComment Type: TechnicalComment: This statement is crazy when considered in context of a conventional vented attic (layer the batts or blow the insulation to the peak!). It is also contradictory to the Minimum Specific Application Requriements for framed floors. It should either be modified or stricken entirely. The insulation grading guidelines cover this aspect of insulation installation. Proposed Change: When installed in a closed cavity, iInsulation shall fill the cavity being insulatedfrom side to side, and from top to bottom. OR Insulation shall cover the areafill the cavity being insulated, from side to side in all cases, and from top to bottom in walls and rim or band joists. OR Insulation shall fill the cavity being insulated, side to side, and top to bottom.
Comment #15Page Number: 5Paragraph / Figure / Table / Note: A-1.3.4, 5.Comment Intent: ObjectionComment Type: TechnicalComment: This sentence is unclear and could be read with a reverse intent: "it shall fill the cavity to within no more than 1/2 inch from the face of the studs". It shall not be fully filled, but be at least 1/2 inch recessed from the face of the studs. Proposed Change: Insulation shall fill the cavity to at least within no more than ½ inch from the interior face of the studs. OR Insulation shall fill the cavity to within no more than ½ inch from the face of the studs A cavity shall be considered filled when the face of the insulation is less than 1/2 inch from the face of the studs.
This sentence is unclear and could be read with a reverse intent: "it shall fill the cavity to within no more than 1/2 inch from the face of the studs". It shall not be fully filled, but be at least 1/2 inch recessed from the face of the studs.
Insulation shall fill the cavity to at least within no more than ½ inch from the interior face of the studs.
Insulation shall fill the cavity to within no more than ½ inch from the face of the studs A cavity shall be considered filled when the face of the insulation is less than 1/2 inch from the face of the studs.
Comment #16Page Number: 5Paragraph / Figure / Table / Note: A-1.3.4, 5. ExceptionComment Intent: ObjectionComment Type: EditorialComment: Add text to make this exception a full sentence. Proposed Change: Exception: Cavities shall not be required to be filled with insulation wWhen the required R-value is met using a thickness that is less than the cavity depth.
Add text to make this exception a full sentence.
Exception: Cavities shall not be required to be filled with insulation wWhen the required R-value is met using a thickness that is less than the cavity depth.
Comment #17Page Number: 5, 6, and 7Paragraph / Figure / Table / Note: A-2.1.1, A-2.1.2, A-2.1.3Comment Intent: ObjectionComment Type: TechnicalComment: Strike "cavity fill" because these requriements also apply to continuous insulation. No other section addresses the grading criteria for these materials when installed continuously. Batts may be blankets, loose-fill insulation may be installed continuously over bottom chords of roof trusses, open or closed cell spray foam may be installed continuously over masonry, insulated sheathing is typically installed continuously, etc. Proposed Change: Shall meet ASTM-specified installation requirements in the applicable standards C1015 and C1320, and shall also meet the following cavity fill requirements: AND Installations not complying with the minimum installation requirements in ASTM standards C1015 and C1320, and Grade I or Grade II cavity fill requirements shall be considered a Grade III installation.
Strike "cavity fill" because these requriements also apply to continuous insulation. No other section addresses the grading criteria for these materials when installed continuously. Batts may be blankets, loose-fill insulation may be installed continuously over bottom chords of roof trusses, open or closed cell spray foam may be installed continuously over masonry, insulated sheathing is typically installed continuously, etc.
Shall meet ASTM-specified installation requirements in the applicable standards C1015 and C1320, and shall also meet the following cavity fill requirements:
AND
Installations not complying with the minimum installation requirements in ASTM standards C1015 and C1320, and Grade I or Grade II cavity fill requirements shall be considered a Grade III installation.
Comment #18Page Number: 5Paragraph / Figure / Table / Note: A-2.1.1.1Comment Intent: ObjectionComment Type: TechnicalComment: Strike "cavity" because these requriements also apply to continuous insulation. No other section addresses the grading criteria for these materials when installed continuously. Batts may be blankets, loose-fill insulation may be installed continuously over bottom chords of roof trusses, open or closed cell spray foam may be installed continuously over masonry, insulated sheathing is typically installed continuously, etc. Strike "missing or" because the last sentence covers that sentiment, or clarify some other way that "missing" is the same concept as "voids." Proposed Change: 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 3/4 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. OR 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 3/4 inch of the specified insulation thickness in any given location. Voids or gaps extending from the interior to exterior of the intended insulation areas shall not be permitted.
Strike "cavity" because these requriements also apply to continuous insulation. No other section addresses the grading criteria for these materials when installed continuously. Batts may be blankets, loose-fill insulation may be installed continuously over bottom chords of roof trusses, open or closed cell spray foam may be installed continuously over masonry, insulated sheathing is typically installed continuously, etc.
Strike "missing or" because the last sentence covers that sentiment, or clarify some other way that "missing" is the same concept as "voids."
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 3/4 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.
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 3/4 inch of the specified insulation thickness in any given location. Voids or gaps extending from the interior to exterior of the intended insulation areas shall not be permitted.
Comment #19Page Number: 6Paragraph / Figure / Table / Note: A-2.1.1.2Comment Intent: ObjectionComment Type: TechnicalComment: This section says that "no more than 2% of the insulated area shall contain voids..." and also that "voids extending to the exterior of the intended insulation areas shall not be permitted." These concepts seem o be contradictory. One of those two sentences should be modified. Proposed Change: No more than 2% of the insulated area shall be compressedcontain voids or be more than ¾ inch below the specified thickness. The minimum installed thickness shall not be less than 1 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.
This section says that "no more than 2% of the insulated area shall contain voids..." and also that "voids extending to the exterior of the intended insulation areas shall not be permitted." These concepts seem o be contradictory. One of those two sentences should be modified.
No more than 2% of the insulated area shall be compressedcontain voids or be more than ¾ inch below the specified thickness. The minimum installed thickness shall not be less than 1 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.
Comment #20Page Number: 7Paragraph / Figure / Table / Note: A-2.2, 1.Comment Intent: ObjectionComment Type: TechnicalComment: This is normative text, right? Can we delete "regarding the use of mastics and/or expanding foam"? If not, I'd add "tape, caulk, or other manufacturer-approved sealant." The second two sentences should be informative footnotes. Also, this whole section reads like I'm the one doing the installing. Isn't this Addendum intended to cover inspection procedures? "Any damaged area shall be repaired" is outside of the scoe of Raters. We can try to enforce it, but, for HERS Ratings, all we're supposed to be doing is inspecting and evaluating what's present, right? As a Rater, I could say, "in order to achieve Grade I or Grade II, any damaged area shall be repaired," but I can't or shouldn't have to say "in order to receive an ERI as calculated via 301, any damaged area shall be repaired." How could I ever produce a HERS Rating on an existing building? This same sentiment carries through to many of the other sections as well. However, under the Grade I heading for SIPS, there's a provision for unrepaired panels. Isn't this contradictory with the minimum requirements for SIPs? Or, maybe most of these grading criteria need to be moved to the Grade I description. Editorial: Are we using "SIPs" or "SIPS"? I think SIPs is more accurate. Proposed Change: 1. Sealing of panel joints shall meet the manufacturer's recommended requirements regarding the use of mastics and/or expanding foam. # (Informative Footnote) If the manufacturer does not have specific joint sealing details use SIPA's typical joint sealing details. SIPA details are available at www.sips.org. 2. Use spray foam to seal penetrations through the SIP panels. 3. Any damaged area shall be repaired. 4. All gaps and penetrations through SIPs including windows, doors, and foundation or roof connections shall be air-sealed with expanding foam compatible with the SIP materials.
This is normative text, right? Can we delete "regarding the use of mastics and/or expanding foam"? If not, I'd add "tape, caulk, or other manufacturer-approved sealant." The second two sentences should be informative footnotes.
Also, this whole section reads like I'm the one doing the installing. Isn't this Addendum intended to cover inspection procedures? "Any damaged area shall be repaired" is outside of the scoe of Raters. We can try to enforce it, but, for HERS Ratings, all we're supposed to be doing is inspecting and evaluating what's present, right? As a Rater, I could say, "in order to achieve Grade I or Grade II, any damaged area shall be repaired," but I can't or shouldn't have to say "in order to receive an ERI as calculated via 301, any damaged area shall be repaired." How could I ever produce a HERS Rating on an existing building? This same sentiment carries through to many of the other sections as well. However, under the Grade I heading for SIPS, there's a provision for unrepaired panels. Isn't this contradictory with the minimum requirements for SIPs? Or, maybe most of these grading criteria need to be moved to the Grade I description.
Editorial: Are we using "SIPs" or "SIPS"? I think SIPs is more accurate.
Comment #21Page Number: throughoutParagraph / Figure / Table / Note: throughoutComment Intent: ObjectionComment Type: GeneralComment: Overall, what happens when requirements aren't met? Much of the basic installation guidance given for each material reads like minimum requirements before insulation grading can even be applied. As verifiers of somebody else's installation, it's our job to observe and evaluate and train, but not install. What if we don't observe these things? What if we're evaluating existing conditions, where the insulator was off the jobsite 40 years ago? I think that the amount of detail provided in this Addendum is very valuable, but the presentation is somewhat confusing.
Overall, what happens when requirements aren't met? Much of the basic installation guidance given for each material reads like minimum requirements before insulation grading can even be applied. As verifiers of somebody else's installation, it's our job to observe and evaluate and train, but not install. What if we don't observe these things? What if we're evaluating existing conditions, where the insulator was off the jobsite 40 years ago?
I think that the amount of detail provided in this Addendum is very valuable, but the presentation is somewhat confusing.
Comment #22Page Number: throughoutParagraph / Figure / Table / Note: throughoutComment Intent: ObjectionComment Type: TechnicalComment: The concept of "uninsulated" is completely absent. In MINHERS, Grade III was defined as having substantial gaps and voids, with gaps limited to 3-5% of the total insulated area. Uninsulated was defined as having substantial defects, air barrier misalignment, gaps ranging from 6-100%, and/or compression ranging from 11-100% and to any depth. This grouping limits Grade III to a sloppy attempt at a good quality installation and considers pretty awful installations to be completely uninsulated. I disagree that the concept of uninsulated should be removed from the insulation grading criteria and that Grade III can be anything that doesn't comply with Grade I or Grade II installations (including really crummy installations). In otherwords, anything that isn't nearly perfect is all the same and can be modeled as having a decent insulative effect (modeled as having 5% of the area not insulated per 301-201(9) 4.2.2.2.2). The MINHERS grading used a very narrow band of evaluation to assess the grades and then called everything else uninsulated. Addendum F is applying a very narrow band of evaluation to Grades I and II and calling everything else Grade III (whether the uninsulated area is 5%, 50%, or 75%+). Unfortunately, it's probably too late to make this change since it would require adjustments to many sections throughout the document. Maybe it could be mentioned in the beginning sections as a blanket statement. Proposed Change: 4.2.2.2. Insulation Inspections: All enclosure elements for the Rated Home shall have their insulation assessed in accordance with this Standard. Installed cavity insulation shall be rated as Grade I, II, or III, or uninsulated in accordance with the on-site inspection procedures equivalent to Normative Appendix A. 4.2.2.2.1. The insulation of the Energy Rating Reference Home enclosure elements shall be modeled as Grade I. The insulation of the Rated Home shall either be inspected according to procedures equivalent to Normative Appendix A or, if confirmed to be present but not fully inspected, shall be modeled as Grade III and shall be recorded as “not inspected” in the rating. A-1. Insulation In order to meet the requirements of a Grade I or Grade II insulation rating, the insulation material shall be installed in accordance with the minimum installation requirements of this Appendix and the requirements specified by ASTM standards C727, C1015, C1743, C1320, and C1321 as described below in the Insulation Grading section. Installations not complying with the minimum installation requirements of this Appendix, and the relevant ASTM standard for the type insulation, or not 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.
The concept of "uninsulated" is completely absent.
In MINHERS, Grade III was defined as having substantial gaps and voids, with gaps limited to 3-5% of the total insulated area. Uninsulated was defined as having substantial defects, air barrier misalignment, gaps ranging from 6-100%, and/or compression ranging from 11-100% and to any depth. This grouping limits Grade III to a sloppy attempt at a good quality installation and considers pretty awful installations to be completely uninsulated.
I disagree that the concept of uninsulated should be removed from the insulation grading criteria and that Grade III can be anything that doesn't comply with Grade I or Grade II installations (including really crummy installations). In otherwords, anything that isn't nearly perfect is all the same and can be modeled as having a decent insulative effect (modeled as having 5% of the area not insulated per 301-201(9) 4.2.2.2.2).
The MINHERS grading used a very narrow band of evaluation to assess the grades and then called everything else uninsulated. Addendum F is applying a very narrow band of evaluation to Grades I and II and calling everything else Grade III (whether the uninsulated area is 5%, 50%, or 75%+).
Unfortunately, it's probably too late to make this change since it would require adjustments to many sections throughout the document. Maybe it could be mentioned in the beginning sections as a blanket statement.
Comment #23Page Number: 1, 5, 7, 8 and 12Paragraph / Figure / Table / Note: Sections A.1, A-2.1.1, A-2.1.2, A-2.1.3, A-3.0Comment Intent: Not an ObjectionComment Type: GeneralComment: ASTM 41440 is the designation for an ASTM Workgroup to develop a SPF Insulation Installation Standard Practice, That standard, ASTM C1848 is now published and is entitled: "Standard Practice for Installation of High-Pressure Spray Polyurethane Foam Insulation for the Building Enclosure". M Proposed Change: Section A-1: ....minimum installation requirements of this Appendix and the requirements specified by ASTM standards C727, C1015, C1743, C1320, , C1321 and WK41440 ASTM C1848 as described below in the Insulation Grading section Section A-2.1.1: Shall meet ASTM-specified installation requirements in the applicable standards C1015, C1320, and ASTM WK41440 and ASTM C1848 and shall also meet the following cavity fill requirements: Section A-2.1.2: Shall meet ASTM-specified installation requirements in ASTM standards C1015, C1320, and ASTM WK41440 and ASTM C1848 and shall also meet the following cavity fill requirements: Section A-2.1.3: Installations not complying with the minimum installation requirements in ASTM standards C1015, C1320, and ASTM WK41440 and ASTM C1848 and Grade I or Grade II cavity fill requirements shall be considered a Grade III installation. Section 3.0 Normative References ASTM WK41440: New Guide for Installation of Spray Polyurethane Foam Insulation in the Building Envelope ASTM C1848: 17a Standard Practice for Installation of High-Pressure Spray Polyurethane Foam Insulation for the Building Enclosure
ASTM 41440 is the designation for an ASTM Workgroup to develop a SPF Insulation Installation Standard Practice, That standard, ASTM C1848 is now published and is entitled: "Standard Practice for Installation of High-Pressure Spray Polyurethane Foam Insulation for the Building Enclosure".
M
Section A-1:
....minimum installation requirements of this Appendix and the requirements specified by ASTM standards C727, C1015, C1743, C1320, , C1321 and WK41440 ASTM C1848 as described below in the Insulation Grading section
Section A-2.1.1:
Shall meet ASTM-specified installation requirements in the applicable standards C1015, C1320, and ASTM WK41440 and ASTM C1848 and shall also meet the following cavity fill requirements:
Section A-2.1.2:
Shall meet ASTM-specified installation requirements in ASTM standards C1015, C1320, and ASTM WK41440 and ASTM C1848 and shall also meet the following cavity fill requirements:
Section A-2.1.3:
Installations not complying with the minimum installation requirements in ASTM standards C1015, C1320, and ASTM WK41440 and ASTM C1848 and Grade I or Grade II cavity fill requirements shall be considered a Grade III installation.
Section 3.0 Normative References
ASTM WK41440: New Guide for Installation of Spray Polyurethane Foam Insulation in the Building Envelope
ASTM C1848: 17a Standard Practice for Installation of High-Pressure Spray Polyurethane Foam Insulation for the Building Enclosure
Comment #24Page Number: 2Paragraph / Figure / Table / Note: Section A.1.1Comment Intent: ObjectionComment Type: EditorialComment: When an insulation is in substantial contact with the air barrier, by definition it will be on the interior or exterior side of the air barrier. Describing interior or exterior seems redundant. Proposed Change: A-1.1 Minimum General Installation Requirements: Insulation shall be installed to manufacturers’ recommendations and industry standards. Insulation shall be integral to or on the interior to or exterior side and in substantial and permanent contact with the primary air barrier. No air spaces shall be allowed between different insulation types or systems.
When an insulation is in substantial contact with the air barrier, by definition it will be on the interior or exterior side of the air barrier. Describing interior or exterior seems redundant.
A-1.1 Minimum General Installation Requirements:
Comment #25Page Number: 2-3Paragraph / Figure / Table / Note: A-1.2Comment Intent: ObjectionComment Type: TechnicalComment: 1. Not all jurisdictions will use the 2015 version of the IECC. This should be changed to applicable versions of the IECC. 2. Specific R-values are not the only means to meet insulation requirements. A provision to meet the alternate assembly U-factors should be included. Proposed Change: 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 or U-factors of Table 402.1.4 of the applicable 2015 International Energy Conservation Code (IECC) and that extends from the bottom to the top of all perimeter floor framing members. The cavity insulation between floor joists, beams or other horizontal floor supports that create cavities under the subfloor shall be permitted to be in direct contact with any additional continuous insulation attached to the underside of the horizontal supports. The combination of both cavity and continuous insulation shall meet or exceed the minimum required floor R value in tTable 402.1.2 or U-factors of Table 402.1.4 of the applicable 2015 International Energy Conservation Code, (IECC). Instances of reflective insulation system installed beneath hydronic floors are not required to meet this standard.
1. Not all jurisdictions will use the 2015 version of the IECC. This should be changed to applicable versions of the IECC.
2. Specific R-values are not the only means to meet insulation requirements. A provision to meet the alternate assembly U-factors should be included.
A-1.2 Minimum Specific Application Requirements:
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 or U-factors of Table 402.1.4 of the applicable 2015 International Energy Conservation Code (IECC) and that extends from the bottom to the top of all perimeter floor framing members.
The cavity insulation between floor joists, beams or other horizontal floor supports that create cavities under the subfloor shall be permitted to be in direct contact with any additional continuous insulation attached to the underside of the horizontal supports. The combination of both cavity and continuous insulation shall meet or exceed the minimum required floor R value in tTable 402.1.2 or U-factors of Table 402.1.4 of the applicable 2015 International Energy Conservation Code, (IECC). Instances of reflective insulation system installed beneath hydronic floors are not required to meet this standard.
Comment #26Page Number: 3Paragraph / Figure / Table / Note: A-1.2Comment Intent: ObjectionComment Type: TechnicalComment: A substantial number of residential buildings are now constructed with wood I-joists and those should be included. Proposed Change: A-1.2 Minimum Specific Application Requirements: 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 wood i-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.
A substantial number of residential buildings are now constructed with wood I-joists and those should be included.
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 wood i-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 #27Page Number: 4-5Paragraph / Figure / Table / Note: A-1.3.4 and A-1.3.6Comment Intent: Not an ObjectionComment Type: TechnicalComment: The Spray Polyurethane Foam Alliance has established an ISO 17024 compliant certification and accreditation program to help ensure that SPF insulation is installed safely and properly. This can be used in lieu of manufacturer's training and certification programs. http://www.sprayfoam.org/certification Proposed Change: A-1.3.4 Open cell spray polyurethane foam (SPF) insulation: Installers shall meet the SPFA Professional Certification Program requirements or manufacturer’s recommended training requirements and shall complete the online health and safety training for SPF provided by the Center for Polyurethanes Industry. A-1.3.6 Closed-cell spray polyurethane foam (SPF) insulation: Installers shall meet the SPFA Professional Certification Program requirements or manufacturer’s recommended training requirements and shall complete the online health and safety training for SPF provided by the Center for Polyurethanes Industry.
The Spray Polyurethane Foam Alliance has established an ISO 17024 compliant certification and accreditation program to help ensure that SPF insulation is installed safely and properly. This can be used in lieu of manufacturer's training and certification programs.
http://www.sprayfoam.org/certification
A-1.3.4 Open cell spray polyurethane foam (SPF) insulation:
A-1.3.6 Closed-cell spray polyurethane foam (SPF) insulation:
Comment #28Page Number: 5Paragraph / Figure / Table / Note: A-1.2.4Comment Intent: Not an ObjectionComment Type: TechnicalComment: Some open-cell SPF products are air-impermeable per ASTM E2178 at thicknesses less than 4.5 inches. Proposed Change: A-1.3.4 Open cell spray polyurethane foam (SPF) insulation: Open-cell Insulation, installed at a minimum thickness of not less than 4.5 inches to be air impermeable per ASTM E2178 (air permeance of less than 0.04 cfm/ft2)i and in-contact with the substrate shall be permitted to serve as the air barrier. Exception: Thicknesses less than 4.5 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 authority having jurisdiction or approved code compliance.
Some open-cell SPF products are air-impermeable per ASTM E2178 at thicknesses less than 4.5 inches.
Exception: Thicknesses less than 4.5 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 authority having jurisdiction or approved code compliance.
Comment #29Page Number: 3Paragraph / Figure / Table / Note: A-1.3.2Comment Intent: Not an ObjectionComment Type: EditorialComment: This is a typographical error that may have been overlooked in the original document. Unvented or conditioned crawl spaces typically have insulation on the stem walls. Vented crawl spaces typically have insulation under the floor. Proposed Change: A-1.3.2 Fibrous Batt Insulation: 1. Insulation shall fill the cavity being insulated side to side, top to bottom. 2.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. Insulation installed under floors directly above an unvented crawl space shall not require an air barrier on the exterior side. Insulation installed in rim or band joists located in conditioned space shall not require an air barrier on the interior side.
This is a typographical error that may have been overlooked in the original document. Unvented or conditioned crawl spaces typically have insulation on the stem walls. Vented crawl spaces typically have insulation under the floor.
A-1.3.2 Fibrous Batt Insulation:
1. Insulation shall fill the cavity being insulated side to side, top to bottom.
2.Insulation shall be enclosed on all six sides.
Exceptions:
Comment #30Page Number: 5Paragraph / Figure / Table / Note: A-1.3.6Comment Intent: ObjectionComment Type: TechnicalComment: 1. New proposed wording for open-cell minimum thickness for air impermeabilty should improve clarity. 2. ICC-ES Reports are not the only code compliance report in the marketplace. Other organizations compliant with ISO-17065, including but not limited to Intertek, IAPMO, NSF, UL and other publish code compliance reports for building products including SPF. Proposed Change: A-1.3.6 Closed-cell spray polyurethane foam (SPF) insulation: Installers shall meet the SPFA Professional Certification Program requirements or 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 a minimum thickness of 1.5 inches and in-contact with the substrate, shall be permitted to serve as the primary air barrier. 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 prepared by an organization accredited for product certification per ISO-17065. by tICC-ES Report.
1. New proposed wording for open-cell minimum thickness for air impermeabilty should improve clarity.
2. ICC-ES Reports are not the only code compliance report in the marketplace. Other organizations compliant with ISO-17065, including but not limited to Intertek, IAPMO, NSF, UL and other publish code compliance reports for building products including SPF.
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 prepared by an organization accredited for product certification per ISO-17065. by tICC-ES Report.
Comment #31Page Number: 4Paragraph / Figure / Table / Note: A-1.3.2 Fibrous Batt Insulation: #3Comment Intent: ObjectionComment Type: TechnicalComment: The National Association of Home Builders is in objection to section A-1.3.2 with addition of new language that prohibits the use of inset or side stapling for Grade 1 installation. Limiting the use of this method takes away acceptable installation options for builders. NAHB supports flexibility and options for builders and there is no justification to take this option away. Inset and side stapling is a manufacturer’s approved method of fibrous batt installation and a method that has been previously allowed as an acceptable installation practice for the grading of installation. The standard lacks the technical reasoning for prohibiting inset stapling as a Grade 1 installation practice. Given that there is no supporting documents or elaboration on why inset stapling is no longer allowed one can only assume it is due to the degrading of insulation when compressed. The North American Insulation Manufacturers Association (NAIMA) came out with a paper title The Facts About Compressing Fiber Glass Insulation. The example in the paper shows that a R-19 batt insulation goes to R-18 when compressed into a 2x6 wall cavity. I took the same calculation approach and found that if fibrous batt insulation is inset stapled at ¾ inch (the acceptable depth by the 301 standard) then the insulation would perform at R-17 in the areas where it is compressed. Given that the compression only occurs on the vertical studs you have 10% of the cavity performing at R-17 and 90% at R-18. In the standard it stats that Grade 1 installation is classified as minor defects. Having 10% or less of your all 1 R-value less than the remaining 90% should be classified as a minor defect and therefore considered as a Grade 1 installation practice. See calculations below. 2x6 wall 8 feet in height 6.25 (batt width) – 4.75 (inset stapling depth) = 1.5 1.5/6.25 = .24 (24% compression where stapled) R-values decrease by ½% of compression. Therefore it would be 12%. 19 (r-value of batt) x (.12) = 2.28 19 – 2.28 = 16.72 Rounded up to 17. R- Value of 17 in the small areas of compression for stapling. References: https://insulationinstitute.org/wp-content/uploads/2016/08/Compressed_R_values.pdf https://www2.owenscorning.com/literature/pdfs/10017858%20Install%20Guide%20Light%20Density%20Fiberglas%20Bldg%20Insul%20Tech%20Bulletin.pdf Proposed Change: 3. Faced batts shall be stapled to the face of the studs or side stapled to the studs with no buckling of the stapling tabs or the tabs shall be permitted to be left unstapled. Inset or side stapling of ball insulation shall not be permitted for Grade 1 Installations. Faced batt products without tabs and friction fit products shal lnot be required to be stapled when installed in verticle walls
The National Association of Home Builders is in objection to section A-1.3.2 with addition of new language that prohibits the use of inset or side stapling for Grade 1 installation. Limiting the use of this method takes away acceptable installation options for builders. NAHB supports flexibility and options for builders and there is no justification to take this option away. Inset and side stapling is a manufacturer’s approved method of fibrous batt installation and a method that has been previously allowed as an acceptable installation practice for the grading of installation. The standard lacks the technical reasoning for prohibiting inset stapling as a Grade 1 installation practice. Given that there is no supporting documents or elaboration on why inset stapling is no longer allowed one can only assume it is due to the degrading of insulation when compressed.
The North American Insulation Manufacturers Association (NAIMA) came out with a paper title The Facts About Compressing Fiber Glass Insulation. The example in the paper shows that a R-19 batt insulation goes to R-18 when compressed into a 2x6 wall cavity. I took the same calculation approach and found that if fibrous batt insulation is inset stapled at ¾ inch (the acceptable depth by the 301 standard) then the insulation would perform at R-17 in the areas where it is compressed. Given that the compression only occurs on the vertical studs you have 10% of the cavity performing at R-17 and 90% at R-18. In the standard it stats that Grade 1 installation is classified as minor defects. Having 10% or less of your all 1 R-value less than the remaining 90% should be classified as a minor defect and therefore considered as a Grade 1 installation practice.
See calculations below.
2x6 wall 8 feet in height
6.25 (batt width) – 4.75 (inset stapling depth) = 1.5
1.5/6.25 = .24 (24% compression where stapled)
R-values decrease by ½% of compression. Therefore it would be 12%.
19 (r-value of batt) x (.12) = 2.28
19 – 2.28 = 16.72
Rounded up to 17.
R- Value of 17 in the small areas of compression for stapling.
References:
https://insulationinstitute.org/wp-content/uploads/2016/08/Compressed_R_values.pdf
https://www2.owenscorning.com/literature/pdfs/10017858%20Install%20Guide%20Light%20Density%20Fiberglas%20Bldg%20Insul%20Tech%20Bulletin.pdf
3. Faced batts shall be stapled to the face of the studs or side stapled to the studs with no buckling of the stapling tabs or the tabs shall be permitted to be left unstapled. Inset or side stapling of ball insulation shall not be permitted for Grade 1 Installations. Faced batt products without tabs and friction fit products shal lnot be required to be stapled when installed in verticle walls
Comment #32Page Number: 6Paragraph / Figure / Table / Note: A-2.1Comment Intent: ObjectionComment Type: TechnicalComment: There appears to be an oversight within Section A-2.1 regarding the handling of Open-Cell Spray Polyurethane Foam Insulation where the cavity is filled and the insulation is trimmed to fit the cavity. For context, when most ocSPF is installed in a 2x4 cavity, in order to meet the code requirements and achieve R-13, it must fill the cavity completely and be shaved off. It looks as though an additional section where this practice is covered was meant to be included as “Section A-2.1.1.2 Open-Cell Spray Polyurethane Foam Insulation (cavity not filled and not trimmed)” specifically calls out in its section title that the ocSPF is not intended to fill the cavity. “Section A1.3.4 Open cell spray polyurethane foam (SPF) insulation:” also references the practice of trimming insulation that fills the cavity, furthering the thought that it was an oversight in not including guidance for cavities that are filled and trimmed: “When insulation extends beyond the wall cavity it shall be trimmed to allow insulation and contact with the interior sheathing or finish material.” And “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.” As there was an oversight regarding ocSPF applications that fill the cavity and are trimmed, this comment proposes that an additional section for this practice be included in the grading section for three reasons: To ensure that raters properly interpret this standard as it applies to ocSPF insulation used to fill the cavity. Clearly state the intent of the Minimum Specific Material Requirements for ocSPF with the grading requirements which state that ocSPF insulation that fills the cavity is no more than ½ inch from the face of the studs. Align with Grade I and II % area requirements associated with batt or loose fill insulation products. Proposed Change: A-2.1.1.X Open-Cell Polyurethane Spray Foam Insulation (Cavity filled and trimmed) When installing open-cell polyurethane spray foam, no more than 2% of the total insulated area (cavity) shall be below the thickness required to attain the specified thickness, or contain gaps or voids in the insulation. The minimum installed thickness shall not be less than 1/2 inch below the specified thickness at any point. Voids extending from the interior to exterior of the intended insulation areas shall not be permitted. A-2.1.2.X Open-Cell Polyurethane Spray Foam Insulation (Cavity filled and trimmed) When installing open-cell polyurethane spray foam, no more than 15% of the total insulated area (cavity) shall be below the thickness required to attain the specified thickness, or contain gaps or voids in the insulation. The minimum installed thickness shall not be less than 1/2 inch below the specified thickness at any point. Voids extending from the interior to exterior of the intended insulation areas shall not be permitted.
There appears to be an oversight within Section A-2.1 regarding the handling of Open-Cell Spray Polyurethane Foam Insulation where the cavity is filled and the insulation is trimmed to fit the cavity. For context, when most ocSPF is installed in a 2x4 cavity, in order to meet the code requirements and achieve R-13, it must fill the cavity completely and be shaved off.
It looks as though an additional section where this practice is covered was meant to be included as “Section A-2.1.1.2 Open-Cell Spray Polyurethane Foam Insulation (cavity not filled and not trimmed)” specifically calls out in its section title that the ocSPF is not intended to fill the cavity.
“Section A1.3.4 Open cell spray polyurethane foam (SPF) insulation:” also references the practice of trimming insulation that fills the cavity, furthering the thought that it was an oversight in not including guidance for cavities that are filled and trimmed: “When insulation extends beyond the wall cavity it shall be trimmed to allow insulation and contact with the interior sheathing or finish material.” And “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.”
As there was an oversight regarding ocSPF applications that fill the cavity and are trimmed, this comment proposes that an additional section for this practice be included in the grading section for three reasons:
A-2.1.1.X Open-Cell Polyurethane Spray Foam Insulation (Cavity filled and trimmed)
When installing open-cell polyurethane spray foam, no more than 2% of the total insulated area (cavity) shall be below the thickness required to attain the specified thickness, or contain gaps or voids in the insulation. The minimum installed thickness shall not be less than 1/2 inch below the specified thickness at any point. Voids extending from the interior to exterior of the intended insulation areas shall not be permitted.
A-2.1.2.X Open-Cell Polyurethane Spray Foam Insulation (Cavity filled and trimmed)
When installing open-cell polyurethane spray foam, no more than 15% of the total insulated area (cavity) shall be below the thickness required to attain the specified thickness, or contain gaps or voids in the insulation. The minimum installed thickness shall not be less than 1/2 inch below the specified thickness at any point. Voids extending from the interior to exterior of the intended insulation areas shall not be permitted.
Comment #33Page Number: 2Paragraph / Figure / Table / Note: A-1.1, 2Comment Intent: ObjectionComment Type: TechnicalComment: Even with the revisions to this section, I believe the statement is not consistent with some accepted building practices. Additionally it limits options available for design. There are currently reflective insulation assemblies specified on the exterior and interior side of the air barrier. Proposed Change: Insulation shall be integral to or on the interior to or exterior side and in substantial and permanent contact with the primary air barrier.
Even with the revisions to this section, I believe the statement is not consistent with some accepted building practices. Additionally it limits options available for design. There are currently reflective insulation assemblies specified on the exterior and interior side of the air barrier.
Comment #34Page Number: 2Paragraph / Figure / Table / Note: A-1.1, 3, ExceptionComment Intent: ObjectionComment Type: TechnicalComment: I agree with part of the revision. Where disagreement exists is in the elimination of the ASHRAE Handbook of Fundamentals which is recognized by the FTC. I propose including the handbook and additionally referencing the published date and the appropriate table. Proposed Change: Exception: When claiming the R-value of an enclosed reflective air space in accordance with the 2017 the ASHRAE Handbook of Fundamentals, Chapter 26, table 3 or the ASHRAE Handbook of Fundamentals90.1-2016 Section A9-4 (or addendum ac to the 2013 edition) or ASTM C 1224.
I agree with part of the revision. Where disagreement exists is in the elimination of the ASHRAE Handbook of Fundamentals which is recognized by the FTC. I propose including the handbook and additionally referencing the published date and the appropriate table.
Exception: When claiming the R-value of an enclosed reflective air space in accordance with the 2017 the ASHRAE Handbook of Fundamentals, Chapter 26, table 3 or the ASHRAE Handbook of Fundamentals90.1-2016 Section A9-4 (or addendum ac to the 2013 edition) or ASTM C 1224.
Comment #35Page Number: 8Paragraph / Figure / Table / Note: A-2.3, 2, 3Comment Intent: ObjectionComment Type: TechnicalComment: There are three key issues evident in this language: 1. The use of the word “sealed” can be interpreted as “special sealing” – this has been debated heavily in ASHRAE 90.1 and this term was never incorporated into any of the text – this term has implication of competitive industry potential undue restrictions 2. Also – there is significant redundancy in describing the “enclosed air space 3. This section should include the FTC Rule 460 requirements for reflective insulation R-values as a reference Please note: Subsection numbers did not copy and paste accurately Proposed Change: When utilizing R-values claims for the air space adjacent to a reflective insulation, product 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. the air space shall be an enclosed and unventilated cavity designed to minimize airflow into or out of in accordance with ASTM C727. 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 the enclosed airspace shall be based on ASTM C1224, the Standard Specification of Reflective Insulation or per the current FTC Rule 460 requirements. The assembly that is tested for thermal resistance shall be representative of the field assembly.
There are three key issues evident in this language:
1. The use of the word “sealed” can be interpreted as “special sealing” – this has been debated heavily in ASHRAE 90.1 and this term was never incorporated into any of the text – this term has implication of competitive industry potential undue restrictions
2. Also – there is significant redundancy in describing the “enclosed air space
3. This section should include the FTC Rule 460 requirements for reflective insulation R-values as a reference
Please note: Subsection numbers did not copy and paste accurately
Comment #36Page Number: 8Paragraph / Figure / Table / Note: A-2.3, 4Comment Intent: ObjectionComment Type: TechnicalComment: This sub-section contains language that inappropriately benefits competitive interests. This specific application is currently being addressed by an ASHRAE RTAR in TC 4.4. Additionally, reflective insulation installed behind brick with a 0.75 inch air space has R-value performance. Proposed Change: 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.
This sub-section contains language that inappropriately benefits competitive interests. This specific application is currently being addressed by an ASHRAE RTAR in TC 4.4. Additionally, reflective insulation installed behind brick with a 0.75 inch air space has R-value performance.
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 #37Page Number: 8Paragraph / Figure / Table / Note: A-2.3.1, 2Comment Intent: ObjectionComment Type: TechnicalComment: 1. This language is redundant and overly restrictive 2. The use of the word “sealed” can be interpreted as “special sealing” – this has been debated heavily in ASHRAE 90.1 and this term was not incorporated into any text – this term has implication of competitive industry potential undue restrictions 3. By definition – a reflective insulation with multiple enclosed air spaces will be designed and installed to prevent air-exchange between the enclosed air spaces Proposed Change: 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;
1. This language is redundant and overly restrictive
2. The use of the word “sealed” can be interpreted as “special sealing” – this has been debated heavily in ASHRAE 90.1 and this term was not incorporated into any text – this term has implication of competitive industry potential undue restrictions
3. By definition – a reflective insulation with multiple enclosed air spaces will be designed and installed to prevent air-exchange between the enclosed air spaces
Comment #38Page Number: 8Paragraph / Figure / Table / Note: A2.3.1, 8Comment Intent: ObjectionComment Type: TechnicalComment: This sub-section contains language that inappropriately benefits competitive interests. This specific application is currently being addressed by an ASHRAE RTAR in TC 4.4. Additionally, reflective insulation installed behind brick with a 0.75 inch air space has stated R-value performance. The brick application is on the exterior side of the air barrier, so the “interior” side of the air barrier is design restrictive. Proposed Change: 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.
This sub-section contains language that inappropriately benefits competitive interests. This specific application is currently being addressed by an ASHRAE RTAR in TC 4.4. Additionally, reflective insulation installed behind brick with a 0.75 inch air space has stated R-value performance. The brick application is on the exterior side of the air barrier, so the “interior” side of the air barrier is design restrictive.
Comment #39Page Number: 9Paragraph / Figure / Table / Note: A-2.3.1.1Comment Intent: ObjectionComment Type: TechnicalComment: This is a section on reflective insulation, not radiant barrier. The existing text addresses any issue that might be related to the proper installation of the product. The new text is vague and this issue is evaluated in the existing text Proposed Change: 2% or less of the area is not insulated such that the building envelope exterior sheathing (wall) is visible from the building’s interior and that air leakage is not evident between the sheathing and radiant barrier.
This is a section on reflective insulation, not radiant barrier. The existing text addresses any issue that might be related to the proper installation of the product. The new text is vague and this issue is evaluated in the existing text
2% or less of the area is not insulated such that the building envelope exterior sheathing (wall) is visible from the building’s interior and that air leakage is not evident between the sheathing and radiant barrier.
Comment #40Page Number: 9Paragraph / Figure / Table / Note: A-2.3.1.2Comment Intent: ObjectionComment Type: TechnicalComment: This is a section on reflective insulation, not radiant barrier. The existing text addresses any issue that might be related to the proper installation of the product. And the new text is vague and this specific issue is already evaluated in the existing text. Proposed Change: A-2.3.1.2 Grade II (Moderate to Frequent Defects) Shall meet the minimum installation requirements in ASTM standard C727 and shall also the following area coverage requirements: Greater than 2% and less than 10% of the area which is available for insulation is not insulated such that the building envelope exterior sheathing (wall) is visible from the building’s interior and that air leakage is not evident between the sheathing and radiant barrier.
This is a section on reflective insulation, not radiant barrier. The existing text addresses any issue that might be related to the proper installation of the product. And the new text is vague and this specific issue is already evaluated in the existing text.
Shall meet the minimum installation requirements in ASTM standard C727 and shall also the following area coverage requirements:
Greater than 2% and less than 10% of the area which is available for insulation is not insulated such that the building envelope exterior sheathing (wall) is visible from the building’s interior and that air leakage is not evident between the sheathing and radiant barrier.