16 CFR Part 460: Labeling and Advertising Of Home Insulation: Trade Regulation Rule; Comment Request; R-value Rule (Project No. R811001) #00006

Submission Number:
00006
Commenter:
Robert aresty
Organization:
State:
New Jersey
Initiative Name:
16 CFR Part 460: Labeling and Advertising Of Home Insulation: Trade Regulation Rule; Comment Request; R-value Rule (Project No. R811001)
The rule covers "all home insulation products". As such radiant barriers and IRCCS (Interior Radiation Control Coatings)are covered, even though these technologies cannot be rated according to "R" value. In fact, the test spec in the rule for the above types of insulation is ASTM E408 which measures emissivity. Shouldn't the rule reflect this different method of measuring heat flows so that radiant barrier and IRCC products can be presented to the public in an equally easy format (such as a "E" value) which might eliminate many of the falacious paint products that are presently being marketed as insulation products?