16 CFR Part 460: Labeling and Advertising Of Home Insulation: Trade Regulation Rule; Comment Request; R-value Rule (Project No. R811001) #00015

Submission Number:
00015
Commenter:
Charles Clark
Organization:
Brick Industry Association
State:
Virginia
Initiative Name:
16 CFR Part 460: Labeling and Advertising Of Home Insulation: Trade Regulation Rule; Comment Request; R-value Rule (Project No. R811001)
R-value Rule (No. R811001) §460.22 -- R-Value Claims for Non-Insulation Products The Brick Industry Association (BIA) prepares technical documents regarding the use of brick masonry. Some of these documents include discussions of the energy efficiency of homes with brick cladding and provide an estimated R-value for a wall assembly that includes brick veneer. Because of this, §460.22 appears to apply to these documents. To obtain this estimated R-value, a modified version of ASTM C1363 -- "Standard Test Method for the Thermal Performance of Building Assemblies by Means of a Hot Box Apparatus" is conducted. The test specimen is a full-thickness wall assembly and the test procedure is modified to extract additional data during steady-state measurements and to include dynamic temperature cycling. The modifications are necessary to accurately evaluate the thermal performance of a wall assembly with brick veneer. The modified test procedure does not deviate from the intent of the test standard incorporated within the proposed rule and therefore should comply. BIA requests that the language in §460.22 be clarified to incorporate cases such as this.