sion is preparing a de facto specification in terms of their requirements. Likewise, the Department of Commerce is preparing a de facto specification in terms of its labeling requirements. In addition, many of the states are preparing their own standards because of the lack of a national standard. The industry, and the consumer, do not need 50 additional standards to be lived with. That only creates confusion. Therefore, we urgently support and request that the interim standard be implemented as soon as possible and that the new standards be properly evaluated, and, at such time as they are properly evalnated, that these be implemented. Thank you, Mr. Chairman. Mr. METCALFE. Thank you very much, Mr. Anderson. I think the panel for their very expert testimony. Certainly you gentlemen appear to be in unison with your request for standards. I would like to ask Mr. Barron and Mr. Mesigh a couple of questions here. How many manufacturers belong to the association that you represent and what percentage of the total U.S. production of cellulose insulation do they produce? In other words, how many of these manufacturers? Mr. BARRON. Yes; NCIMA, the National Cellulose Insulation Manufacturers Association, has at the present time 12 member companies. It is our best estimate, based on advice from the Department of Commerce, that those companies probably put into place about 30 percent in their general area of the cellulose sold in these United States. Now the new association that I have revealed to you, CIMA, it is our best estimate, Mr. Chairman, that that association and the members subscribing to it will represent about 70 percent of the tonnage of cellulose sold in the United States. We think that there will be about 150 companies supporting that activity. Mr. METCALFE. What is CIMA? Mr. BARRON. CIMA has just been organized, Mr. Chairman. Just in the last week representatives from the boards of directors of the four associations that I have named have agreed to coalesce their viewpoints into one voice so instead of five voices clamoring with our colleagues in SICIM at least four of the associations are amalgamating into one association to be called Cellulosic Insulation Manufacturers Association. Mr. METCALFE. Mr. Mesigh, how many organizations that produce the cellulose insulation do you represent? Mr. MESIGH. We represent 20 companies. Mr. METCALFE. What percentage is that generally? Mr. MESIGH. It is 35 percent of the industry. Mr. METCALFE. There has been a great deal of adverse publicity recently about the safety of cellulose home insulations. Have you or your members noticed any lessening or demand for cellulose installations as a result of that adverse publicity? Mr. BARRON. Yes. Mr. MESIGH. That is correct. Mr. METCALFE. Appreciably? Mr. MESIGH. Appreciably. Mr. METCALFE. Could you be specific as to how much of this loss have you had? What percentage of your business has it affected? Mr. BARRON. That is day to day, Mr. Chairman. We don't monitor company statistics that closely but it is a seat of pants if you will excuse the phrase. It is a seat of pants that there was a downturn just about coincident with the end of January, first of February. I believe just about the time the consumer's report that Mr. Anderson referred to hit the marketplace. Mr. METCALFE. Could you be a little more definitive and give us some idea as to a ball park figure as to what that loss has been in terms of your own industry? Mr. BARRON. No, Mr. Chairman, I cannot speak to that except to paraphrase comments that my colleagues have made to me that they have noticed a softening of the marketplace. Mr. METCALFE. May I further point out the softening could be 1 percent, it could be 2 percent, it could be 35 percent. I would like to get a little more definitive answer if you could. We are asking for ball park figures, we are not holding you strictly to your answer. Mr. BARRON. Mr. Chairman, with all respect to the Chair, and I appreciate your pressing for an answer, I cannot answer that in all honesty. All we can say is that there has been a softening and I would rather imagine that might be rather significant. Mr. METCALFE. Mr. Mesigh. Mr. MESIGH. It is the opinion of SICIM after polling our members which are spread from the east coast to the west coast that production is off 45 to 55 percent and as much as 80 percent in certain areas. Mr. METCALFE. Give me some other ideas about it. Does the testing method specified by the existing GSA 515C standards in any way stimulate the home use conditions? If so, why then would the mandating compliance with the 515 provide any assurance of safety to consumers? I further go on by asking might it not simply lull consumers into a false security thinking that their product must be safe because it complies with the Federal standard? Mr. BARRON. May I speak to that, Mr. Chairman? Mr. METCALFE. Please. Mr. BARRON. In order to answer that I would like to pose to you the spectrum that exists across the country at the present time. The building codes of the United States who generally adjudicate problems associated with materials have established the use of the so-called Steiner tunnel. Furthermore, the building codes of the United States have established three categories of flame spread 0 to 25 being class 1, 26 to 75 being class 2, and 76 to 200 being class 3. Now against that backdrop you should remember that 0 in the tunnel is cement asbestos board and 100 is select dry red oak. Framing lumbers that we find in the welding markets are in the category of 150 in the category of flame spread. Plywood paneling is around 150 to 200. Cellulose insulation is required at the present time in my interpretation to be not in excess of 50 in the present standard HH-I-515C and we are advocating that the top end not be more than 40. You should remember I spoke to the mineral fiber vapor barrier which was that the vapor barrier so frequently found with that type of insulation in the same tunnel over 2,500. I think that the tunnel test has been in use since 1952. It is a well established test method. These are 1,700 tunnel operators across the country who have run all sorts of flame spread tests on all sorts of material that it is indeed a viable test method properly used. Mr. METCALFE. The tunnel method is presently a viable method? Mr. BARRON. Absolutely, sir. It is a viable test method. Mr. METCALFE. Mr. Mesigh. Mr. MESIGH. Since we are representing two associations, and I certainly don't mean "go to war," our association has an entirely different. approach to this. One, with respect to the Moffett-Ford bill we would recommend that the E-84 tunnel be mandated with this bill and that the E-84 or UL 723 with a flame spread not greater than 25. The particular purpose of that is we can test untreated newspaper and get a class 2 material in the E-84 tunnel. We are not proposing that the E-84 tunnel is in fact the answer to the question lessening the credibility of the radiant panel, critical flux test. We are suggesting this: That there is a problem at the grassroots level if one should happen to be in Yipswitch, Wyoming, or small area of our country. Just because legislation is enacted in Washington, it could be 25 years before they are aware of that change. They are accustomed to class 1, class 2 materials. They are accustomed to certain terminology, et cetera, and for a temporary period we would suggest that again the E-84 and the UL 723 be mandated along with the smolder test and the radiant panel. Mr. METCALFE. I yield to counsel. Mr. ANDERSON. I would like to amplify on that if I may, Mr. Chairman. Mr. METCALFE. Yes. Mr. ANDERSON. I think it is important to note that I agree with the position as stated by Mr. Barron. I think though that it is necessary to state that I do not object to the radiant panel testing or the test provisions within the new Federal specifications HH-I-515D. My concern is simply this: That they do have confusion with the use of the existing specifications at this time. The existing specifications are not perfect, they are being improved upon. The new ASTM specification, C-739-77-the new existing specification does improve upon the flame spread requirements as performed by the tunnel. This should go a long way to eliminate confusion about the test data now being developed in the industry. With respect to the radiant panel the test may very well turn out to be a marked improvement over the existing Steiner tunnel. This may very well be. The position that our company takes is that we would like to have this demonstrated and shown and we would also like to see that the industrial capability for the use of this test if it turned out to be an improved test procedure and be available within the marketplace. I would see tremendous confusion developing if the test were to be imposed at this time or within the near future without adequate testing facilities available throughout the country. This takes time. My position is simple: That if the new test procedures are viable, let's use them in a reasonable, timely manner. Thank you. Mr. METCALFE. Thank you. I am going to ask counsel, Ms. Kinney, if she has any questions. Mr. Barron, you mentioned-I think you said 17 testing facilities that are available that do the Steiner tunnel test right now. Mr. BARRON. That is my understanding. Ms. KINNEY. We have information from the National Bureau of Standards which shows considerably fewer. You may not have the information with you right now. Can you provide us for the record a listing of all of those facilities which you believe now exist to do the Steiner tunnel testing? Mr. BARRON. By all means, Ms. Kinney. I will ask the person who chairs the Tunnels Operators Committee to supply you with a list of these tunnels. I can think of a few. I can probably tell you five tunnels that I know of at the present time. Not all of those operators incorporate the influence of the galvanized steel screen that I discussed in my testimony and I believe that that is one of the big problems. Underwriters does incorporate the galvanized and as Mr. Mesigh paraphrased there UL 723 and so those two are in consonance. I will certainly see to it that you have a list of the tunnel occasions across the United States. MS. KINNEY. Would you please indicate which of those do make the correction for the wire mount? Mr. BARRON. I will so endeavor. [The following material was received for the record:] TUNNEL OPERATORS OF NORTH AMERICA Organization E-84 task group mailing list: Ambric Testing and Engineering Association 4041 Ridge Ave., Commercial Testing Co., Inc., P. O. Box 94, 407 Central Ave, Factory Mutual Engineering Division, 1151 Boston-Providence Hardwood Plywood Manufacturers Association, 2310 South Johns-Manville Products Corp., Greenwood Plaza, P. O. Box National Gypsym Co., 1650 Military Road, Kenmore, N.Y. National Research Council of Canada, Division of Building Owens Corning Fiberglas Corp., P. O. Box 415, Granville, Ohio Southwest Research Institute, 8500 Culebra Rd., San Antonio, Terralab Engineers, P. O. Box 7025, Salt Lake City, Utah Underwriters Laboratories of Canada, 7 Crouse Rd., Scarborough, Ontario, Canada, MIR-3A-9. Underwriters Laboratories Inc., 333 Pfingsten Rd., North- United States Testing Co., Inc., 5521 Telegraph Rd., Los United States Testing Co., Inc., 1415 Park Ave., Hoboken, Weyerhauser Co., Technical Center, Longview, Wash. 98632... Warnock Hersey, 125 East 4th Ave., Vancouver, 10, British For mailing purposes-not task group members: G. O. Atkinson, Staff Liaison E05, ASTM Headquarters, 1916 Dan Davies, Chairman ASTM E05.04, Koppers Co., Inc., 700 A. A. Briber, Underwriters Laboratories, 165 Scott Blvd., Organization ORGANIZATIONS THAT OPERATE A 25-FT TUNNEL 1. Ambric Testing and Engineering Association, Philadelphia, Pa. 2. Commercial Testing Co., Inc., Dalton, Ga 3. Factory Mutual, Engineering Division, Norwood, Mass. 4. Hardwood Plywood Manufacturers, Association, Arlington, Va.. 5. Johns Manville Products Corp., Denver, Colo.. 6. National Gypsum Co., Kenmore, N.Y. 7. National Research Council of Canada, Ottawa, Ontario, Canada. 8. Ownes Corning Fiberglas Corp., Granville, Ohio. 9. Southwest Research Institute, San Antonio, Tex. 10. Terralab Engineers, Salt Lake City, Utah. 11. Underwriters Laboratories of Canada,2 Scarborcugh, Ontario, Canada. 12. Underwriters Laboratories Inc., Northbrook, III. 13. Underwriters Laboratories Inc., Santa Clara, Calif. 1 Does not test loose fill. 2 Tests loose fill on floor of furnace. MS. KINNEY. Also, you commented upon what you believe is the justification for using 515C as a mandatory standard and you mentioned the fact that it has been used for a number of years. Are you aware of any tests that have been done and documented and published that show that the 515C standard is a reproducible test. Mr. BARRON. When you speak of the 515C, I assume you are focusing in on the tunnel test. MS. KINNEY. That is correct. Mr. BARRON. There is 25 years of accumulated data in that data. MS. KINNEY. What kind of accumulated data? Mr. BARRON. Oh, my dear. All sorts of round robins have been around under the committee E-5 which has the overview for the tunnel and I am certain that the data could be developed for your review. Ms. KINNEY. All right. We would like to see it and I will check with you later about getting that. Mr. BARRON. Splendid. MS. KINNEY. Earlier witnesses from the DOE indicated that they were not aware of any published literature showing the 515C testing method was a reproducible testing method, so I will check with you on getting that later. Mr. BARRON. Thank you. Ms. KINNEY. 515C does not in any way simulate the conditions in a home attic. It merely measures how quickly material will burn. Now the GSA 515D revision would provide some kind of correlation between what actually occurs in the home and the 515D tests are designed to measure whether or not the insulation would be expected to burn under home conditions. As I understand it, NBS is currently going through some round robin tests right now which they expect to be finished within the next couple of months to verify the valadity of the two testing speed methods that have been specified in 515D. If those tests show that the 31-737 - 78 - 16 |