INSULATION CONTRACTORS ASSOCIATION OF AMERICA
November 9, 1999
Re: ANPR Comment, R-value Rule, 16 CFR Part 460
The Insulation Contractors Association of America herein comments (original plus four copies enclosed) on the Federal Trade Commission's advance notice of proposed rulemaking on its trade regulation rule governing the labeling and advertising of home insulation under 16 CFR Part 460 appearing in 64 Fed. Reg. 48,024 (September 1, 1999).
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Comment Submitted by the
Comment on Advance Notice of Proposed Rulemaking
"R-value Rule, 16 CFR Part 460
November 9, 1999
Introduction. The Insulation Contractors Association of America ("ICAA") presents the following comment related to FTC's advance notice of proposed rulemaking proposing amendments to its trade regulation rule governing the labeling and advertising of home insulation under 16 CFR Part 460 appearing in 64 Fed. Reg. 48,024 (September 1, 1999).
What is ICAA? ICAA, formed in 1977, is a member-based trade association of North American insulation contractors and suppliers primarily working in residential and commercial new construction and retrofit markets. ICAA is the only national trade association representing residential and commercial thermal insulation contractors.
Basis for Comment. ICAA developed its comment after conducting a thorough member-based review of the Rule and the ANPR. ICAA believes its proposals, which focus on improved pre-purchase disclosure to consumers, do not incur additional net economic burdens to insulation manufacturers.
Comment Related to FTC 460.12 (b)(3). ICAA previously proposed that this subsection require that manufacturers of loose-fill cellulose insulations disclose "minimum initially installed thickness" in addition to minimum thickness on cellulose insulations package labels. ICAA contends that this additional information will serve as a prepurchase guide to consumers who may be incorrectly installing cellulose insulation at "minimum thickness" levels, which then settles to a lower thickness.
ASTM, the standards-setting body, adopted in 1997 ASTM C-1374 Standard Test Method for Determination of Installed Thickness of Pneumatically Applied Loose-Fill Building Insulation. This new test method offers a reliable and uniform procedure to determine initial installed thickness levels ("minimum initially installed thickness") for each total R-value claimed on coverage charts for all loose-fill insulations including dry-applied loose-fill mineral fiber insulations.
Cellulose Insulation Manufacturers Association ("CIMA") concurs with ICAA that the additional information represents a marked improvement in consumer protection, offering consumers clear, conspicuous communications on cellulose insulations packaging labels. In fact, in 1991, CIMA's predecessor CISEP asked that cellulose insulation manufacturers include a "minimum installed thickness" column.
Cellulose manufacturers that choose to include an additional "minimum installed thickness" column on their product packaging must compete, albeit not on a level playing field, with manufacturers that do not print this data.
ICAA believes that addition of a "minimum initially installed thickness" column provides prepurchase disclosures enabling consumers to fairly compare competing brands as well as competing insulation products, thus improving the purchasing decision.
Canada Mortgage & Housing Corporation, Canada's national housing agency, requires cellulose insulation manufacturers to disclose "minimum initially installed thickness" levels on product packages.(1)