We have been asked to express ourselves relative to a mandatory third party follow-up program and our general feeling is that if a mandatory follow-up program, well thought out, was implemented by the Federal government, NCIMA would support that position.

It is hoped that if a national standard is implemented, that this industry will be able to get on with the job of building itself and to be disassociated from the harassment from all sectors raising innuendoes and questions about the creditability of cellulosic loose fill insulation. I trust that you gentlemen are all aware that competitive interests are having a field day wtih the dilemma confronting the cellulosic insulation industry today. I believe that the American business climate was built upon competitive aspects and I think it is to the well being of our national insulation programs that we do have a strong cellulosic industry competing with other forms of thermal insulation for the market.

I previously mentioned to you the thought that there should be a single agency involved in this entire insulation dialogue to endeavor to harmonize the regulations. I would remind you gentlemen, that Public Law 93-383 passed by the Ninety-third Congress on August 22, 1974, established the National Institute of Building Sciences to adjudicate such a problem as we now confront. I would suggest to you gentlemen, that this institution which is now beginnnig to move, might be drawn into this dialogue in the hope that they, with their particular expertise in construction related problems, might be given the opportunity to harmonize the regulations being considered in the Federal sector.

And finally, to reiterate again, gentlemen, as to the feelings of NCIMA towards Federal mandated standards, against the backdrop that it is inevitable that a Federally mandated standard will be imposed upon the insulation industry that NCIMA would support such a program with third party follow-up services for inspection provided that it was well thought out and administered to all sectors. By that I mean, at the present time, the Federal standard covering cellulosic insulation, is as you know, HH-I-515C. I would feel that any agency in the Federal sector purchasing cellulosic insulation would have to buy against that standard. It is my understanding that there is product purchased by the Community Action Programs under the jurisdiction of the Department of Energy that does not conform to the present HH-I-515C. Therefore, it's all well and good to have specifications and to endeavor to improve an industry by the mandatory imposition of such standards, but I would say to the Federal sector, if you do implement such standards, insist that they be applied impartially to the entire country and above all to your own Federal agencies.

Thank you.

Mr. METCALFE. Thank you very much, Mr. Barron.

I prefer that we hear all the members of the panel and then we will ask the questions.

Mr. Mesigh, would you care to make a statement at this point?

STATEMENT OF CHARLES D. MESIGH, PRESIDENT, SOCIETY OF INTERNATIONAL CELLULOSE INSULATION MANUFACTURERS

Mr. MESIGH. Mr. Chairman, for the purpose of the record I would like to point out that SICIM which is the Society of International Cellulose Insulation Manufacturers does not necessarily take part in the same position of that of NCIMA which is proposed to be ĈIMA. We are a separate trade organization with different views.

I would like also for the record, if possible, to be held open for further comments regarding specificities arising as a result of this hearing.

Mr. METCALFE. The record will remain open for any additional information you wish to submit.

Mr. MESIGH. Thank you, Mr. Chairman.

Mr. METCALFE. Without objection, so ordered.

Mr. MESIGH. Mr. Chairman, members of the Subcommittee on Consumer Protection and Finance, I am Charles D. Mesigh, president of SICIM, the Society of International Cellulose Insulation Manufac

turers, an established trade association concerned with the production and utilization of cellulosic insulation materials.

At the time ERDA published its now well known report, the SICIM group of manufacturers, aware of the growing energy crisis, and the many problems connected with other forms of insulation, decided to join together as a functioning body (early 1977) with primary interest in the following:

Nationwide manufacture of quality cellulose insulation products; Establishment of governmental standards to provide unmistakable demands for safe, reliable, stable cellulose insulation products; Consumer education concerning energy conservation in such areas as insulation and R-values, weatherization and products available; Assistance to code bodies in their responsibilities concerning insulating materials and building practices;

Advising on the national need to train insulation installers, and license if need be, to eliminate the hazard of misapplication;

And last, but not least, promoting education of our own members as to public responsibility and product performance.

Our original concerns, as well as our present determinations, remain the same; that is, education, quality control, consumer protection and continuing professionalization of our own manufacturing membership. We realize that the rapid growth of the industry has brought with it many problems-primarily too many inexperienced people led to believe that the cellulose insulation industry is a profitable business in which to engage.

The results were predictable-faulty materials produced by some because of a lack of nationally mandated standard; overdemand on limited manufacturing materials-newsprint, borax/boric acid, other chemical additives-produced serious escalation of raw materials costs; violation of installation practices created unnecessary hazards for certain owners/consumers; and of greatest importance the erosion of credibility that cellulose insulation has unfairly suffered because of the confusing and/or overlapping actions of various Federal agencies-CPSC, GSA, DOE, DOC, FHA and FMHA. The consumer reaction to these recent Government actions has been a catastrophic drop in purchasing-and all of this coming at a time when the United States has experienced its worst two winters in living memory.

Unfortunately, we in SICIM cannot regulate the industry or we would without hesitation or uncertainty. As we see it, the entire matter concerns the function of cellulose insulation which should be defined as follows:

1. The insulation should provide predictable and controlled thermal resistance of a permanent nature when installed per the manufacturer's recommended practice.

2. The insulation should not increase the hazard due to fire for the occupants, structure, or firefighting personnel beyond that of an uninsulated structure.

3. The insulation should not adversely affect the structure or decrease the useful life of the structure and utilities.

4. The insulation should not adversely affect the health or well being of the occupants.

With reference to HH-I-515C and 515D, any adequate specification for cellulose insulation should address these four functions in terms of defining measurable qualities that relate to these functions:

1. Fire hazard: combustibility, fire spread, and total fuel contribution during a fire determined under the use conditions.

2. Permanency of the fire retardant treatment.

3. Thermal resistance under the use conditions.

4. Moisture absorption.

5. Corrosiveness.

6. Odor.

7. Fungal growth suspectibility not exceeding that of standard building materials.

To keep our statement brief and to avoid an extremely technical dissertation at this point we will provide for the committee's consideration and use earlier comments to Consumer Product Safety Commission and General Services Administation:

SICIM letter dated June 14, 1977, addressed to Mr. Byington, Consumer Product Safety Commission.

SICIM memorandum dated August 22, 1977, addressed to Consumer Product Safety Commission.

SICIM letter dated December 2, 1977, addressed to General Services Administration.

We will also furnish for your careful study and use the letter just received from the American Home Lighting Institute dated January 19, 1978, and our letter to the National Cellulose Insulation Manufacturers Association dated February 9, 1978.

SICIM is more aware now than ever before there are many problems in this industry crying for solution. At our annual meeting in New Orleans, January 26-27-28, 1978, we presented to the 200 plus registrants attending a comprehensive updating of the marketplace, the hazards, the Federal/congressional interest, and the corrective actions which could be taken. Our speakers were among the most expert in the Federal Government on the subject of insulation, testing, standards development, and enforcement. [Copy of speakers appended.]

SICIM during the past week attended the hearings conducted by the Subcommittee on Oversight and Investigations under Chairman John E. Moss. We would be less than candid if we did not note our very real appreciation for the extensive, indepth, and factual revelations brought out by the chairman, members of the committee, and an obviously very capable staff. We in SICIM now have more reason than in times past to insist on improvement-and where necessary we will modify our procedures to achieve same. I am confident that through Chairman Moss' work that a great deal of order will evolve in this industry.

SICIM, as a consumer conscious, energy conscious, conservation conscious association, has certainly had its motivation strengthened by recent events. We know that the innocent consumer cannot identify good insulation from bad, whether by looking, or feeling, or smelling or, if you'll permit, me, by kicking the side of the bag. Our absolute need is for a Federal standard, and for an effective method of concurrent enforcement. Without these safeguards the ethical manufacturers will continue to suffer because of the damage being done by some incompetent, inexperienced, and unethical manufacturers or installers.

This industry has no answer of its own that would get rid of bad products. The quickest remedy is pre-emptive national legislation.

The Moffett-Ford proposal-H.R. 10637/S. 2401-is known to most of the industry and is an immediate first step we would recommend. While we would hope for, and would support, a fail-safe set of specifications, we cannot delay any longer or the economic chaos that now exists in this industry will be irretrievable. The continuing waste of energy would be staggering and indeed unconscionable.

We would therefore strongly recommend the passage of H.R. 10637/S. 2401. If energy conservation and consumer safety is as paramountly important as we proclaim, we have no other choice. And the time to act is now or congressional credibility suffers a serious blow as well.

Mr. Chairman, that concludes my statement and I would be very happy to answer any questions that you or any member of the committee would care to ask. In closing we would note the happy circumstance that this proposed bill offers an immediate acceptable remedy. We would also note that there are areas in the bill that could be improved or strengthened and we would be happy to explore them with the committee.

Thank you.

[Testimony resumes on p. 222.]

[The following material was received for the record:]

SOCIETY INTERNATIONAL CELLULOSE INSULATION MANUFACTURERS,
Washington, D.C. June 14, 1977.

Reference: Briefing paper on petition CP 77-1 on home insulation.

Mr. JOHN BYINGTON,

Chairman,

Consumer Product Safety Commission,
Washington, D.C.

DEAR MR. BYINGTON: We have inadvertently come across data on subject report which makes us feel very strongly that we should make a statement regarding our position on the subject.

First, the Society of International Cellulose Insulation Manufacturers represents numerous independent manufacturers of cellulose insulation materials. They are earnestly trying to forestall massive insulation shortages and are constantly striving to improve the quality and the overall performance of the material. This Association requires that its members produce material as designated by the appropriate federal specification, HH-I-515c, and recommends that all insulation materials under the proposed legislation relate to the applicable federal specification-as to manufacturing processes and quality control, thus, ensuring proper safety measures and effective thermal R-values in actual installations.

We have read the complete brief and feel that there are numerous inconsistencies. We have read the statement that the National Cellulose Insulation Manufacturers presented on the subject and, as far as what they say in the text of their statement, we would like to go on record as supporting their views entirely. However, NCIMA restricts their approach to that of dealing with only cellulose fiber insulation products. We feel that as an international trade association, we should assume the broader issue. We feel that the problems in the insulation industry are many and diversified and that the briefing (CP 77-1) only speaks in specifics pertaining to a small, localized Denver, Colorado area and really does a great disservice to the entire cellulose insulation industry. The manufacturer who actually caused the Denver cellulose problem has been defunct for over a year and it appears the Denver situation has been completely rectified. In all fairness to the Denver manufacturers and applicators alike, the small fires that did occur could have occurred very easily with other types of insulation materials because there was a flagrant mis-application which involved insulation usage over recessed light fixtures. This is recommended against by the two trade associations and by all manufacturers of the material. The national electric code requires that all insulation be installed no less than six inches from a light fixture nor less than two feet above same. We hasten to add 31-737-78-15

that if a Kraft-faced mineral wool blanket of either type were installed in the same manner, that the situation would indeed be far more hazardous.

This Association also feels that there should be considerably more emphasis made in investigating the fire hazards of any type of kraft or foil-backed vapor barrier blankets, regardless of type. Contrary to views by some of the staff investigators, there have been numerous fires in many places throughout the country that involved flammable paper-faced blanket insulations. This material definitely should be included in any investigative process to determine its actual installed fire resistance. It is almost impossible to install a vapor barrier insulation of this type and leave the product in a safe condition within any open attic space. If actual inspections of blanket type applications are made within an attic space, serious safety violations will be found, which would be many times worse than any possibility of defective cellulose insulations. Any further investigation of this type will clarify that all insulation materials should be subjected to strenuous fire hazard tests. To this end, we would suggest that a review be made of antiquated building, testing, and electric codes which will speak to the subject of construction that now requires much higher R-values in the national interest in conserving energy.

Industry test data should be developed on other items than fire safety. Specifically, corrosion has become an issue in many areas which is alleged to affect the safety of a structure. various competitive insulation industries have downgraded cellulose materials because of this and have neglected to get their own house in order. Corrosion is a problem with mineral types of insulation, as well as cellulose. SICIM and NCIMA both subscribe to the federal specification HH-I-515c and actively urge and require its members to produce quality cellulose insulations.

Thermal efficiency is another questionable practice which was brought out within the petition. To this end, we must affirm that in re-insulation of buildings, it is extremely important to use the most economical, thermally efficient, loosefill type insulation material available, one that will flow easily into all cracks and crevices and will provide a monolithic, high thermal value in ceilings, walls, and other hard-to-get-at places. A blanket type insulation, of whatever composition, is almost impossible to properly install in the preponderance of attic type re-insulation jobs. We have found in the past that poorly executed blown-in insulation jobs are far superior to better executed blanket type jobs. Blanket type installations have to be very restrictive in application for many reasons. In many instances, adding blanket insulation over blanket insulation has no additional value whatsoever. The problem is only compounded.

This Association feels that there is far less potential for exploitation of the consumer by the use of a quality blown-in cellulose material, than with blankets of any type, whereas no degree of professionalism is required. The insulating values of cellulose fiber insulation materials have been found to be thermally efficient and safe after many years of installation-certainly, much more so than blankets with the high fire hazard vapor barriers and installation with the normal massive voids associated with ordinary building construction problems. We feel that the leaking of news releases pertaining to this briefing has done the insulation industry, and most specifically, the cellulose insulation industry, irrevocable harm, and it is a disservice to the national goal of "conservation of energy" through insulation. There has been a series of serious, harsh accusations and innuendos directed against small insulation manufacturers, because they are small. There have been other equally harsh accusations against the cellulose insulation industry because of the nature of the product itself. We call attention to the articles distributed by the Mineral Fiber Association (Denver press releases), which were also included within the report.

We call your specific attention to the fact that government agencies of all types should recognize the importance of a strong cellulose fiber re-insulation program, with priorities established within our goal of conserving our natural resources as mandated in the Federal Register, dated January 15, 1976, part B-1, Environmental Protection Agency, which sets forth guidelines for Federal agencies in procurement policies, that “recycled products should be used whenever possible", which have so emphatically been overlooked in governmental priorities. We need the government to tell the vast needs of the recycling story to the public. Ours is a first-rate, dynamic, and rapidly expanding insulation industry, and we resent implications of inferiority by self-serving, competitive groups or by government sectors that variously have imposed unwarranted constraints on the use of our products. It must be remembered that most of the allegations and complaints set forth within the context of the report were generated by selfserving, competitive industries, which are acknowledged to be very big business.