The following comments have been submitted:
Comment #1Page Number: 2Paragraph / Figure / Table / Note: A-1.1 Minimum General Installation Requirements:Comment Intent: ObjectionComment Type: GeneralComment: Why would you remove the requirement for the insulaiton to be with the air barrier? In other places the insulation is required to be enclosed on all 6 sides by the air barrier. It has been a mainstay that insulation works better when associatied with an air barrier. Proposed Change: Leave A-1.1 (2) in place
Why would you remove the requirement for the insulaiton to be with the air barrier? In other places the insulation is required to be enclosed on all 6 sides by the air barrier. It has been a mainstay that insulation works better when associatied with an air barrier.
Leave A-1.1 (2) in place
Comment #2Page Number: 3Paragraph / Figure / Table / Note: A-1.3.2 Fibrous Batt InsulationComment Intent: ObjectionComment Type: GeneralComment: A-1.3.2 (3) At what point was it determined that inset stapling was as effectiive as being a grade one? I do not see any ratioanl for the change and unless you can prove side stapling is not a detriment you have no right to change the test. Proposed Change: A-1.3.2 (3) Do not remove ...Inset or side stapling of batt insulation shall not be permmitted for grade I insulaiton.
A-1.3.2 (3)
At what point was it determined that inset stapling was as effectiive as being a grade one? I do not see any ratioanl for the change and unless you can prove side stapling is not a detriment you have no right to change the test.
Do not remove ...Inset or side stapling of batt insulation shall not be permmitted for grade I insulaiton.
Comment #3Page Number: 5Paragraph / Figure / Table / Note: A-1.3.6 Closed-cell spray polyurethane foam (SPF) insulation:Comment Intent: ObjectionComment Type: GeneralComment: I'm not sure what is meant by "primary" air barrier but the IECC looks for a continous air barrier and this in no way would qualify. The exterir sheathing would serve better as it is at least covering the entire surface. Proposed Change: Leave section A-1.3.6 (2) as is.
I'm not sure what is meant by "primary" air barrier but the IECC looks for a continous air barrier and this in no way would qualify. The exterir sheathing would serve better as it is at least covering the entire surface.
Leave section A-1.3.6 (2) as is.
Comment #4Page Number: 5Paragraph / Figure / Table / Note: A-1.3.6 Closed-cell spray polyurethane foam (SPF) insulation:Comment Intent: ObjectionComment Type: GeneralComment: The requiremnt for the ASTM E2178 report be prepared by a ISO certified organization is excesive. Some labs are NVLAP accredited which carries a higher degree of confidence in the actual test procedure than a ISO certification would. Proposed Change: Leave A-1.3.6 Exception as is.
The requiremnt for the ASTM E2178 report be prepared by a ISO certified organization is excesive. Some labs are NVLAP accredited which carries a higher degree of confidence in the actual test procedure than a ISO certification would.
Leave A-1.3.6 Exception as is.
Comment #5Page Number: 5Paragraph / Figure / Table / Note: A-1.3.6 Closed-cell spray polyurethane foam (SPF) insulation: Item 1Comment Intent: ObjectionComment Type: GeneralComment: Why would this "Shall Meet' traing requirement for installer be included the grading criteria for insulation. Would the rater need ask for proof of this before giving a Grade 1 value? 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. Proposed Change: Strike the 1 entirely.
Why would this "Shall Meet' traing requirement for installer be included the grading criteria for insulation. Would the rater need ask for proof of this before giving a Grade 1 value?
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.
Strike the 1 entirely.
Comment #6Page Number: 1Paragraph / Figure / Table / Note: 4.2.2.2.1Comment Intent: ObjectionComment Type: EditorialComment: In this or another similar section it would make sense to reference how insulation should be graded for compliance with the IECC. All the IECC really says about the installation of insulation is that is shall be installed in accordance with manufacture instructions. This would clearly be Grade 1 not two or three. Therefore, these standards should say Grade 1 shall be the only allowable grade used when assessing or modeling for IECC compliance. This is true as installation is a mandatory item in the IECC so although a home modeled with grade 2 or 3 may pass the code modeling it is still not compliance from the mandatory inspection perspective.Our currnet probelm is that Raters are mixing asset rating issues when doing a compliant pass fail code rating. Proposed Change: When assessing or modeling the installation of insulation for the purposes of IECC compliance the installation shall meet the intent of a grade 1 at install and shall be modeled as grade one to reflect the proper code installation.
In this or another similar section it would make sense to reference how insulation should be graded for compliance with the IECC. All the IECC really says about the installation of insulation is that is shall be installed in accordance with manufacture instructions. This would clearly be Grade 1 not two or three. Therefore, these standards should say Grade 1 shall be the only allowable grade used when assessing or modeling for IECC compliance. This is true as installation is a mandatory item in the IECC so although a home modeled with grade 2 or 3 may pass the code modeling it is still not compliance from the mandatory inspection perspective.Our currnet probelm is that Raters are mixing asset rating issues when doing a compliant pass fail code rating.
When assessing or modeling the installation of insulation for the purposes of IECC compliance the installation shall meet the intent of a grade 1 at install and shall be modeled as grade one to reflect the proper code installation.
Comment #7Page Number: 2Paragraph / Figure / Table / Note: A-1.1Comment Intent: ObjectionComment Type: TechnicalComment: There are several places where this language from 1-5 is used and compression is never talked about. Compression is equally as bad for the performance of the insulation at gaps and voids. Proposed Change: Insulation shall fill around obstructions including, but not limited to, framing, blocking, wiring, pipes, etc. without substantial gaps, voids, or compression.
There are several places where this language from 1-5 is used and compression is never talked about. Compression is equally as bad for the performance of the insulation at gaps and voids.
Insulation shall fill around obstructions including, but not limited to, framing, blocking, wiring, pipes, etc. without substantial gaps, voids, or compression.
Comment #8Page Number: 3Paragraph / Figure / Table / Note: A-1.2 #3Comment Intent: ObjectionComment Type: EditorialComment: This session is talking about the importance of soffit baffles. It is requiring soffit baffles in every cavity or bay. I agree that this is important to ensure that continuous or skip soffit ventilation does not bypass the baffle and migrate into the insulation. This is not a code requirement and therefore some clarification is needed. Proposed Change: Air permeable insulation installed in ventilated attics and vented sloped roofs shall have an effective air barrier (wind block, air chute, or eave baffle) securely fastened and installed at the eave or soffit edge vent of every cavity of bay so as to ensure that attic ventilation air will not bypass the baffle.
This session is talking about the importance of soffit baffles. It is requiring soffit baffles in every cavity or bay. I agree that this is important to ensure that continuous or skip soffit ventilation does not bypass the baffle and migrate into the insulation. This is not a code requirement and therefore some clarification is needed.
Air permeable insulation installed in ventilated attics and vented sloped roofs shall have an effective air barrier (wind block, air chute, or eave baffle) securely fastened and installed at the eave or soffit edge vent of every cavity of bay so as to ensure that attic ventilation air will not bypass the baffle.
Comment #9Page Number: 3Paragraph / Figure / Table / Note: A-1.3.2 #2Comment Intent: ObjectionComment Type: TechnicalComment: This language is used often in the proposed standard revision, “Insulation shall be enclosed on all six sides with an air barrier”. Although I like it the insulation industry has an issue with it and therefore it is more difficult to get their by in. Either an explanation of how air tight the cavity needs to be needs to be addressed or better language is needed to ensure that cavity insulation installation is enclosed on all six sides. Proposed Change: Cavity Insulation, walls and floor, shall be enclosed on all six sides. OR Cavity Insulation, walls and floor, shall be enclosed on all six sides with air impermeable framing and interior and exterior sheathing?
This language is used often in the proposed standard revision, “Insulation shall be enclosed on all six sides with an air barrier”. Although I like it the insulation industry has an issue with it and therefore it is more difficult to get their by in. Either an explanation of how air tight the cavity needs to be needs to be addressed or better language is needed to ensure that cavity insulation installation is enclosed on all six sides.
Cavity Insulation, walls and floor, shall be enclosed on all six sides.
OR
Cavity Insulation, walls and floor, shall be enclosed on all six sides with air impermeable framing and interior and exterior sheathing?
Comment #10Page Number: 3Paragraph / Figure / Table / Note: A-1.3.2 #2 a,cComment Intent: ObjectionComment Type: TechnicalComment: creating language that is understandable and acceptable by the majority will help our standards be more widely used. Proposed Change: A . Insulation installed in attics above ceilings shall not require attic side sheathing. B. Insulation installed in rim or band joists located in conditioned space shall not require interior sheathing.
creating language that is understandable and acceptable by the majority will help our standards be more widely used.
A . Insulation installed in attics above ceilings shall not require attic side sheathing.
B. Insulation installed in rim or band joists located in conditioned space shall not require interior sheathing.
Comment #11Page Number: 3Paragraph / Figure / Table / Note: A-1.3.2 #2 b,dComment Intent: ObjectionComment Type: TechnicalComment: b. All floor systems are wall cavities laid down horizontally. The insulation in a cavity needs to be enclosed on all six sides. Proposed Change: b. Insulation installed under floors directly above a vented or unvented crawl space is required to be sheathed.
b. All floor systems are wall cavities laid down horizontally. The insulation in a cavity needs to be enclosed on all six sides.
b. Insulation installed under floors directly above a vented or unvented crawl space is required to be sheathed.
Comment #12Page Number: 5Paragraph / Figure / Table / Note: A-1.3.3 #3Comment Intent: ObjectionComment Type: TechnicalComment: air permiable insulation should fill the cavitly not only from side to side and top to bottom but from front to back. Otherwise convective air loops degrade the ability ofd the insulation to work. A 3.5" batt should not be allowed to be installed in a 5.5" cavity and achieve a grade 1. Proposed Change: Insulation shall fill the cavity being insulated, side to side, top to bottom, and front to back.
air permiable insulation should fill the cavitly not only from side to side and top to bottom but from front to back. Otherwise convective air loops degrade the ability ofd the insulation to work. A 3.5" batt should not be allowed to be installed in a 5.5" cavity and achieve a grade 1.
Insulation shall fill the cavity being insulated, side to side, top to bottom, and front to back.
Comment #13Page Number: 1Paragraph / Figure / Table / Note: 4.2.2.2Comment Intent: ObjectionComment Type: TechnicalComment: No where in the standard dose it call out how much the R-value of the installed insulation is being reduced if it is assessed and modeled as a grade 2 or 3. This would be very helpful information. I am also concerned that the grading system does not, in essence, penalize the installation by de-rating the R-value more. This could be a significant impetuous for changing behavior. Has the committee vetted the deration that is used for grade 2 and 3 insulation? Do you know where the data for these decisions came from, how it was created, and if it is still relevant. I believe the data could be over 10 or more years old or was not created in a scientific mannor. This all should be assessed while we have this opportunity to change the standard. Proposed Change: Insulation Inspections: All enclosure elements for the Rated Home shall have their insulation assessed in accordance with this Standard. Insulation installation shall be assessed and modeled for the purpose of generating a HERS Index score as Grade I, II, III, or uninsulated in accordance with the on-site inspection procedures equivalent to Normative Appendix A. Grade 1 insulation installation shall be modeled using the manufactures rated R-value. Grade 2 insulation installation shall be modeled with a X% reduction in the manufactures rated R-value and Grade 3 shall be modeled with a XX% reduction in the manufactures rated R-value.
No where in the standard dose it call out how much the R-value of the installed insulation is being reduced if it is assessed and modeled as a grade 2 or 3. This would be very helpful information. I am also concerned that the grading system does not, in essence, penalize the installation by de-rating the R-value more. This could be a significant impetuous for changing behavior. Has the committee vetted the deration that is used for grade 2 and 3 insulation? Do you know where the data for these decisions came from, how it was created, and if it is still relevant. I believe the data could be over 10 or more years old or was not created in a scientific mannor. This all should be assessed while we have this opportunity to change the standard.
Insulation Inspections: All enclosure elements for the Rated Home shall have their insulation assessed in accordance with this Standard. Insulation installation shall be assessed and modeled for the purpose of generating a HERS Index score as Grade I, II, III, or uninsulated in accordance with the on-site inspection procedures equivalent to Normative Appendix A. Grade 1 insulation installation shall be modeled using the manufactures rated R-value. Grade 2 insulation installation shall be modeled with a X% reduction in the manufactures rated R-value and Grade 3 shall be modeled with a XX% reduction in the manufactures rated R-value.
Comment #14Page Number: 1Paragraph / Figure / Table / Note: 4.2.2.2Comment Intent: ObjectionComment Type: TechnicalComment: No where in the standard dose it call out how much the R-value of the installed insulation is being reduced if it is assessed and modeled as a grade 2 or 3. This would be very helpful information. I am also concerned that the grading system does not, in essence, penalize the installation by de-rating the R-value more. This could be a significant impetuous for changing behavior. Has the committee vetted the deration that is used for grade 2 and 3 insulation? Do you know where the data for these decisions came from, how it was created, and if it is still relevant. I believe the data could be over 10 or more years old or was not created in a scientific mannor. This all should be assessed while we have this opportunity to change the standard. Proposed Change: Insulation Inspections: All enclosure elements for the Rated Home shall have their insulation assessed in accordance with this Standard. Insulation installation shall be assessed and modeled for the purpose of generating a HERS Index score as Grade I, II, III, or uninsulated in accordance with the on-site inspection procedures equivalent to Normative Appendix A. Grade 1 insulation installation shall be modeled using the manufactures rated R-value. Grade 2 insulation installation shall be modeled with a X% reduction in the manufactures rated R-value and Grade 3 shall be modeled with a XX% reduction in the manufactures rated R-value.
Comment #15Page Number: 6Paragraph / Figure / Table / Note: A-2.1.1 and A-2.1.2Comment Intent: ObjectionComment Type: TechnicalComment: These sections further define the requirements for grade 1 and 2 installs. I believe that only grade 1 should say “Shall meet ASTM-specified installation requirements in the applicable standards C1015, C1320 and ASTM C1848, and shall meet the following appropriate material installation grading requirements.” Currently Grade 2 also say this, and it by definition should not meet the installation requirements because the insulation R-value will be de-rated based on poor installation. Grade 2 should be defined in the same way that grade 3 is being defined in section A-2.1.3 Installations not complying with the minimum installation requirements in ASTM standards C1015, C1320 and C1848, and the appropriate Grade I or Grade II material installation grading requirements shall be considered a Grade III installation. To appropriate word being NOT. Only Grade 1 should be able to meet the requirements of the standards and be able to be assessed and modeled as achieving the rated R-value of the material. Grade 1 does not mean that the installation has to be perfect but it has to be good and that is what grade 1 defines. Grade 2 can have moderate defects which means that it is NOT in compliance with the standards that grade 1 is being held to. Proposed Change: A2.1.2 Grade II (Moderate Defects) Installations not complying with the minimum installation requirements in ASTM standards C1015, C1320 and C1848, and the appropriate Grade I material installation grading requirements shall be considered a Grade II installation.
These sections further define the requirements for grade 1 and 2 installs. I believe that only grade 1 should say “Shall meet ASTM-specified installation requirements in the applicable standards C1015, C1320 and ASTM C1848, and shall meet the following appropriate material installation grading requirements.”
Currently Grade 2 also say this, and it by definition should not meet the installation requirements because the insulation R-value will be de-rated based on poor installation. Grade 2 should be defined in the same way that grade 3 is being defined in section A-2.1.3
Installations not complying with the minimum installation requirements in ASTM standards C1015, C1320 and C1848, and the appropriate Grade I or Grade II material installation grading requirements shall be considered a Grade III installation.
To appropriate word being NOT. Only Grade 1 should be able to meet the requirements of the standards and be able to be assessed and modeled as achieving the rated R-value of the material. Grade 1 does not mean that the installation has to be perfect but it has to be good and that is what grade 1 defines. Grade 2 can have moderate defects which means that it is NOT in compliance with the standards that grade 1 is being held to.
A2.1.2 Grade II (Moderate Defects)
Installations not complying with the minimum installation requirements in ASTM standards C1015, C1320 and C1848, and the appropriate Grade I material installation grading requirements shall be considered a Grade II installation.
Comment #16Page Number: 1Paragraph / Figure / Table / Note: A-2.1.1.1Comment Intent: ObjectionComment Type: TechnicalComment: I asked one of the approved software providers the following questions: I was wondering if you know or were given guidance on how much to de-rate the R-value of insulation that is modeled as a grade 1,2,or 3. Is it based on a % less R-value? Do you think the R-value deration is accurate. Do you know of any data that supports how much grade 2 or 3 de-rates the R-value. Here is what I got back: Out software calculates composite R value analytically using the parallel path methodology. For Grade II and Grade III, we assume 2% and 5% of the insulation area is missing, respectively. For those areas of the wall with missing insulation, we calculate R value of the assembly with just an air gap in the cavity. I'm pretty sure at least one of the other softwares does it the same way, so we at least have consistency there. As far as experimental data to compare against our analytical approach - I have none. That doesn't mean it doesn't exist, though, I'll admit I haven't looked all that hard. The section that discuss grading do not discuss modeling and or modeling guidance and it is unclear if DATA is avaialbe to guide the modeling. Grade 1 for batts says, "no more than 2% of the total insulated area shall be compressed below the thickness required to attain the labeled R-value or contain gaps or voids in the insulation. So are we just assuming that 2% compression does not affect the R-value? I am actually OK with that assumption. Grade 2 and 3 however, uses much larger % such as 15% compression. Do we actually know what this means when translated into performance and modeling. The software is not taking into account compression why? Proposed Change: Use data driven direct R-value reduction from the rated r-value that is assessed for grade 1 installs. For example if the data says you loose 15% R-value for moderate defects (grade 2) the the R-value of an R-21 batt would be modeled as an R-17.85 if it were graded as a 2 when installed.
I asked one of the approved software providers the following questions:
I was wondering if you know or were given guidance on how much to de-rate the R-value of insulation that is modeled as a grade 1,2,or 3. Is it based on a % less R-value? Do you think the R-value deration is accurate. Do you know of any data that supports how much grade 2 or 3 de-rates the R-value.
Here is what I got back:
Out software calculates composite R value analytically using the parallel path methodology. For Grade II and Grade III, we assume 2% and 5% of the insulation area is missing, respectively. For those areas of the wall with missing insulation, we calculate R value of the assembly with just an air gap in the cavity.
I'm pretty sure at least one of the other softwares does it the same way, so we at least have consistency there. As far as experimental data to compare against our analytical approach - I have none. That doesn't mean it doesn't exist, though, I'll admit I haven't looked all that hard.
The section that discuss grading do not discuss modeling and or modeling guidance and it is unclear if DATA is avaialbe to guide the modeling. Grade 1 for batts says, "no more than 2% of the total insulated area shall be compressed below the thickness required to attain the labeled R-value or contain gaps or voids in the insulation. So are we just assuming that 2% compression does not affect the R-value? I am actually OK with that assumption. Grade 2 and 3 however, uses much larger % such as 15% compression. Do we actually know what this means when translated into performance and modeling. The software is not taking into account compression why?
Use data driven direct R-value reduction from the rated r-value that is assessed for grade 1 installs. For example if the data says you loose 15% R-value for moderate defects (grade 2) the the R-value of an R-21 batt would be modeled as an R-17.85 if it were graded as a 2 when installed.
Comment #17Page Number: 3Paragraph / Figure / Table / Note: A-1.3.2 Fibrous Batt Insulation - Item 2Comment Intent: ObjectionComment Type: TechnicalComment: In item 2 NAIMA proposes the new language, “with an air barrier” be deleted and the previous language, “Insulation shall be enclosed on all six sides.” be retained. Reason: Requiring fibrous batt insulation to be installed “with an air barrier” on all six sides is not required to achieve the label R-value. The requirement for an “air barrier” on all six sides could be interpreted as requiring all holes in the framing for wiring, plumbing etc. to be air sealed. This requirement could also be interpreted as requiring the exterior sheathing and interior finish to be sealed to the framing – otherwise the materials on the sides of the insulation would not qualify as barriers. This level of sealing would not be necessary to acheive the label R-value. Proposed Change: A-1.3.2 Fibrous Batt Insulation 2. Insulation shall be enclosed on all six sides with an air barrier.
In item 2 NAIMA proposes the new language, “with an air barrier” be deleted and the previous language, “Insulation shall be enclosed on all six sides.” be retained.
Reason: Requiring fibrous batt insulation to be installed “with an air barrier” on all six sides is not required to achieve the label R-value. The requirement for an “air barrier” on all six sides could be interpreted as requiring all holes in the framing for wiring, plumbing etc. to be air sealed. This requirement could also be interpreted as requiring the exterior sheathing and interior finish to be sealed to the framing – otherwise the materials on the sides of the insulation would not qualify as barriers. This level of sealing would not be necessary to acheive the label R-value.
2. Insulation shall be enclosed on all six sides with an air barrier.
Comment #18Page Number: 4Paragraph / Figure / Table / Note: A-1.3.3 Blown or Sprayed Fibrous Loose Fill Insulation – Item 5Comment Intent: ObjectionComment Type: TechnicalComment: In item 5 NAIMA recommends requests the new language, “with an air barrier” be deleted and the previous language, “Insulation shall be enclosed on all six sides.” be retained. Reason: Requiring blown or sprayed fibrous loose-fill insulation to be installed “with an air barrier” on all six sides is not required to achieve the label R-value. The requirement for an “air barrier” on all six sides could be interpreted as requiring all holes in the framing for wiring, plumbing etc. to be air sealed. This requirement could also be interpreted as requiring the exterior sheathing and interior finish to be sealed to the framing – otherwise the materials on the sides of the insulation would not qualify as barriers. This level of sealing would not be necessary to achieve the label R-value. Proposed Change: A-1.3.3 Blown or Sprayed Fibrous Loose Fill Insulation 5. Insulation shall be enclosed on all six sides with an air barrier.
In item 5 NAIMA recommends requests the new language, “with an air barrier” be deleted and the previous language, “Insulation shall be enclosed on all six sides.” be retained.
Reason: Requiring blown or sprayed fibrous loose-fill insulation to be installed “with an air barrier” on all six sides is not required to achieve the label R-value. The requirement for an “air barrier” on all six sides could be interpreted as requiring all holes in the framing for wiring, plumbing etc. to be air sealed. This requirement could also be interpreted as requiring the exterior sheathing and interior finish to be sealed to the framing – otherwise the materials on the sides of the insulation would not qualify as barriers. This level of sealing would not be necessary to achieve the label R-value.
5. Insulation shall be enclosed on all six sides with an air barrier.
Comment #19Page Number: 3Paragraph / Figure / Table / Note: A-1.3.2 Fibrous Batt Insulation - item 3Comment Intent: ObjectionComment Type: TechnicalComment: A-1.3.2 Fibrous Batt Insulation - item 3 NAIMA recommends deleting the last sentence in item 5 which reads, When batts are face stapled, verify batts are not pinched, hiding the compression. And replacing it with this sentence, Compression of face stapled batts shall be graded in accordance with the criteria outlined in sections A-2.1.1.1, A-2.1.2.1 or A-2.1.3. Reason: The statement, “When batts are face stapled, verify batts are not pinched, hiding the compression.” is primarily commentary language that instructs the rater to check that face stapled batts are not “pinched, hiding the compression.” This language could be interpreted as not allowing any compression when the proposed standard allows varying amounts of compression in the grading sections. The issue of verifying batts are not “pinched” should be addressed in training and commentary for the standard. NAIMA believes replacing the proposed language with, “Compression of face stapled batts shall be graded in accordance with the criteria outlined in sections A-2.1.1.1, A-2.1.2.1 or A-2.1.3.” will clarify that compression in face stapled applications needs to be considered and provides the sections of the standard that address any compression. Proposed Change: A-1.3.2 Fibrous Batt Insulation - item 3 NAIMA recommends deleting the last sentence in item 5 which reads, When batts are face stapled, verify batts are not pinched, hiding the compression. And replacing it with this sentence, Compression of face stapled batts shall be graded in accordance with the criteria outlined in sections A-2.1.1.1, A-2.1.2.1 or A-2.1.3.
NAIMA recommends deleting the last sentence in item 5 which reads, When batts are face stapled, verify batts are not pinched, hiding the compression. And replacing it with this sentence, Compression of face stapled batts shall be graded in accordance with the criteria outlined in sections A-2.1.1.1, A-2.1.2.1 or A-2.1.3.
Reason: The statement, “When batts are face stapled, verify batts are not pinched, hiding the compression.” is primarily commentary language that instructs the rater to check that face stapled batts are not “pinched, hiding the compression.” This language could be interpreted as not allowing any compression when the proposed standard allows varying amounts of compression in the grading sections. The issue of verifying batts are not “pinched” should be addressed in training and commentary for the standard. NAIMA believes replacing the proposed language with, “Compression of face stapled batts shall be graded in accordance with the criteria outlined in sections A-2.1.1.1, A-2.1.2.1 or A-2.1.3.” will clarify that compression in face stapled applications needs to be considered and provides the sections of the standard that address any compression.
Comment #20Page Number: 3Paragraph / Figure / Table / Note: A-1.3.2 Fibrous Batt Insulation: Item 2 and other similar areasComment Intent: ObjectionComment Type: TechnicalComment: The intent of six sided encapsulation for insulation is to reduce infiltration and convective loss out of the cavity. The language needs to express that the air barriers need to be installed effectively to accomplish this goal. Air barriers can be present but ineffective and language should exist that defines an acceptable level of air barrier instillation and subsequent air tightness of the cavity any time "insulation shall be enclosed on all sides" is mentioned in the standard. Proposed Change: A-1.3.2 Fibrous Batt Insulation: 2. Insulation shall be enclosed on all six sides with an air barriers that are sealed tight to all adjacent framing members or visually verified to be compression fastened tight to adjacent framing members to be free of gaps, cracks and penetrations into the insulated cavity.
The intent of six sided encapsulation for insulation is to reduce infiltration and convective loss out of the cavity. The language needs to express that the air barriers need to be installed effectively to accomplish this goal. Air barriers can be present but ineffective and language should exist that defines an acceptable level of air barrier instillation and subsequent air tightness of the cavity any time "insulation shall be enclosed on all sides" is mentioned in the standard.
2. Insulation shall be enclosed on all six sides with an air barriers that are sealed tight to all adjacent framing members or visually verified to be compression fastened tight to adjacent framing members to be free of gaps, cracks and penetrations into the insulated cavity.
Comment #21Page Number: 1Paragraph / Figure / Table / Note: Proposed Addendum BSR/RESNET/ICC 301-2014 Addendum F-201x, Normative Appendix AComment Intent: ObjectionComment Type: TechnicalComment: The standard relies on air barriers to enclose insulation on six sides but does not define grading to include the installation of the air barrier system. Insulation installation is not the only component of the installation that affects the R-value of the insulation. Air barriers also need to be better defined and installed well. Proposed Change: Air barrier materials that define the enclosure of insulation on one or all sides of the material shall be continuous, impermeable, strong, durable, and stiff. Continuity: The most important element in 3D structures with so many different components to ensure alignment between insulation and the Air Barrier System. Impermeability: The Air Barrier System must be impermeable to Air after installation. Strength: The Air Barrier System must be designed to transfer the designed wind load, stop external or internal air movement into the assembly, and continue to be impermeable. Durability: The Air Barrier System must continue to be impermeable throughout its service life or as the IECC says, “over the useful life of the building.” Stiffness: The Air Barrier System must be stiff enough so that irregularities in the building found at installation of the Air Barrier System do not change its permeance.
The standard relies on air barriers to enclose insulation on six sides but does not define grading to include the installation of the air barrier system. Insulation installation is not the only component of the installation that affects the R-value of the insulation. Air barriers also need to be better defined and installed well.
Air barrier materials that define the enclosure of insulation on one or all sides of the material shall be continuous, impermeable, strong, durable, and stiff.
Comment #22Page Number: 1Paragraph / Figure / Table / Note: definition to Standard ANSI/RESNET/ICC 301-2014:Comment Intent: ObjectionComment Type: TechnicalComment: Air barriers and subsequent air sealing are referenced in the standard and appendix but no definition exists for air sealing or "sealing". The two terms should be seen as synonamous to one another. Proposed Change: Definition to Standard ANSI/RESNET/ICC 301-2014: Air Sealing (sealed) - the process of joining two or more building materials using fasteners, gaskets, caulks, foams, construction adhesives or other approved materials to eliminate cracks, gaps, penetrations and other pathways for air flow into and out of building assemblies.
Air barriers and subsequent air sealing are referenced in the standard and appendix but no definition exists for air sealing or "sealing". The two terms should be seen as synonamous to one another.
Definition to Standard ANSI/RESNET/ICC 301-2014:
Air Sealing (sealed) - the process of joining two or more building materials using fasteners, gaskets, caulks, foams, construction adhesives or other approved materials to eliminate cracks, gaps, penetrations and other pathways for air flow into and out of building assemblies.
Comment #23Page Number: 8Paragraph / Figure / Table / Note: A-2.3 #4Comment Intent: ObjectionComment Type: EditorialComment: For consistency, align the phrasing in item #4 with that in item #2. 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 airspace except where the cladding and the perimeter of the air space creates a totally enclosed air space and unventilated cavity.
For consistency, align the phrasing in item #4 with that in item #2.
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 except where the cladding and the perimeter of the air space creates a totally enclosed air space and unventilated cavity.