|November 8, 1999
Office of the Secretary
Re:ANPR Comment, R-Value Rule, 16 CFR Part 460
These comments are being provided on the Federal Trade Commission 16 CFR Part 460 Trade Regulation Rule: Labeling and Advertising of Home Insulation; Proposed Rule as published Wednesday September 1, 1999 in the Federal Register.
AFM Corporation represents the interest of 15 manufacturers of Expanded Polystyrene (EPS) rigid board insulation geographicaly located throughout the United States. EPS insulation is used extensively in both residential and commercial construction. We have extensive experience with promoting the energy effeciency of our insulation to both home users and the commerical markets. The R-Value Rule has been instrumental in helping to provide a valuable basis for comparison for all insulation products. Manufacturers and consumers benefit from this single basis for comparision, but are not restricted from providing additional information above and beyond the requirements of the R-Value Rule.
We wish to supply comments on two items as discussed in the ANPR.
Non-Residential Insulations (Section IV.A.2)
The commision does not propose extending the Rule to cover sales to the commerical market. The discussion on this item states that in many instances the thermal insulation purchasing decisions for commerical building applications are made by architects or engineers. In addition, manufacturers often prepare detailed technical data for building industry professionals, who should already be informed concerning thermal insulation performance.
We suggest that the comments of the commision are accurate but do not extend completely to all engineers and architects. Many architect and engineers excel at their professions, but have not fully investigated the various technical issues regarding R-Values and the impact on their structures.
For this reason, we suggest that the commission extend the R-Value Rule to commercial applications under the same basis as given for the use in home insulation. A uniform approach to disclosure of R-value is necessary to provide accurate and understandable information to individual architects/engineers (i.e. commercial consumers) to compare competing products and make purchasing decisions. This would not in any way hamper manufacturers from providing full technical publications on performance based upon different circumstances when warranted.
Disclosing R-Values that Account for Factors Affecting R-value. 1. Aging a. Cellular Plastic Insulations (Section IV.C.1.a)
The commission recognizes that R-value tests be performed on specimens that "fully reflect the effect of aging on the products R-value." The current rule accepts "accelerated aging procedures. The insulation industry accepts that 90 day or 180 day accelerated aging does account for some R-value aging but also that these values do not fully reflect the effect of long term aging on the products R-value.
The use of accelerated aging which do not reflect the long term R-value does not meet with the intent of providing accurate information to insulation purchasers.
We urge the commission to fully investigate the use of limited aging procedures and adopt aging procedures which can predict long term R-values or consider adding language to the rule which requires disclosure on the use of accelerated aging procedures which do not necessarily reflect the long term R-value of the products.
We appreciate the opportunity to provide comments during the commissions review of the R-value rule. As discussed in our comments, we urge the commission to extend the R-value rule to commercial insulation applications and also provide for accurate determination of long term R-value through appropriate testing or disclosure.
Todd Bergstrom, Ph.D.
AFMâ Corporation Box
246 Excelsior,MN 55331 Phone 800 255 0176
Fax 612 474 2074