Now as I have indicated to the panel in previous testimony, there are 17 tunnels at the present time. Some of them are operated by manufacturers of thermal insulation but at the present time it is my understanding that there are only five laboratories that have the flooring panel test and they are largely in carpet country. Mr. ECKHARDT. To what extent would the placing into effect of 515C result in contractors purchasing tunnels with the costs passed on to a certain extent in their charges to the insulation purchasers? To what extent would that ultimately afford a burden on the cost of the material? Mr. BARRON. I would not necessarily think that there would be any new tunnel facilities established, Mr. Chairman, because there are, as I say, 17 tunnels in place across the country at the present time. Factory Mutual up in the Boston area has one, U. S. Testing in Hoboken has one, Underwriters has one, Southwest Research has one. What should be done is that they should all be told that thou shalt perform your flame spread testing on cellulosic insulation in accordance with 739 C77. That would clear up the matter tremendously. Mr. ECKHARDT. So you are saying that we could put into effect the 515C standard and then provide that the 515D standard would become effective without putting an undue burden on industry from the standpoint of waste in complying with the first requirement. Mr. BARRON. If and when that point in time comes, Mr. Chairman, I think it would be a normal extension because what we are trying to determine, Mr. Chairman, is the credibility of the data base. As I explained earlier there are only 11 tests at the present time that are the data base for the flooring radiant panel test and the 11 tests for the smoldering test. We think that there should be a much broader data base of affirming that the test method is indeed reproducible. Mr. MESIGH. Mr. Chairman, I would like to make the comment that SICIM has submitted to a laboratory which happens to be Certified Testing Laboratories in Dalton, Ga. At the time of sampling we had 16 manufacturers and 10 of these were submitted to Mr. Fitzgerald, our executive director, of which then 7 were submitted to the laboratory. Of the seven, six passed both the radiant panel and the smolder test and one failed very marginally; at a cost of $300 a test. If this is to be concurred as so expensive where we might bankrupt any company; I would suggest that they should not be in business. Mr. ANDERSON. If I may add to that that our company has submitted material for the radiant panel testing to two separate laboratories to see what the reproducibility might be on the test results. The results came back by a difference factor of two. I do not consider that to be consistent and I think this is why it is very necessary that the current work being performed by the Bureau of Standards be completed on checking out the reproducibility of the respective testing facilities. Unless there is reproducibility and correlation between the respective testing facilities, we have no idea as to which data are valid. Likewise, the Government would have no idea as to the validity of the data base. Mr. ECKHARDT. What are those two laboratories? Mr. ANDERSON. U.S. Testing and Southwest Research. Mr. MESIGH. If I may make one other comment that these same materials have also been submitted to the Van Ness Laboratories of NBS from the same samplings. MS. KINNEY. And those tests? Mr. MESIGH. Those test results are not vailable yet. Mr. ECKHARDT. Thank you, gentlemen, for your testimony. Mr. BARRON. Thank you, Mr. Chairman. Mr. ECKHARDT. Mr. John T. Miller, Chief, Hardware and Mechnical Branch, Mechanical and Electrical Division, Standards and Quality Control, Federal Supply Service, General Services Administration. Can you identify yourself for the record, Mr. Miller. STATEMENT OF JOHN T. MILLER, CHIEF, HARDWARE AND MECHANICAL BRANCH, MECHANICAL AND ELECTRICAL DIVISION, STANDARDS AND QUALITY CONTROL, FEDERAL SUPPLY SERVICE, GENERAL SERVICES ADMINISTRATION, ACCOMPANIED BY ERNEST FREEMAN, SPECIFICATION MANAGER, BUILDING MATERIALS Mr. MILLER. Yes. Mr. Chairman and members of the committee, my name is John T. Miller, Chief, Hardware and Mechanical Branch, Mechanical and Electrical Division, Federal Supply Service, General Services Administration. To my right is Mr. Ernie Freeman, Specification Manager for Building Materials. On behalf of the Administrator of General Services, I am very pleased to be with you today to discuss our technical programs in support of establishing the level of Federal requirements for thermal insulation material. The Federal Supply Service of the General Services Administration is responsible for the administration of the Federal Government's Federal specifications and standards program. This program encompasses 4,500 Federal specifications and 1,500 Federal standards. Federal specifications are technical descriptions of materials, products or services. These descriptions objectively specify necessary characteristics and performance in such a manner as to support competition for Government business through the formal advertised bid process. Federal standards establish engineering or technical limitations and applications for materials, processes, methods, and designs. Standards are used primarily as references in specifications. Both Federal specifications and standards are mandatory only on Federal agencies. Included in this program are three Federal specifications for blanket and loose fill thermal insulation designed for application in walls and ceilings of residential buildings and other frame type structures. They are: HH-I-515-Insulation, thermal. (Loose fill for pneumatic or poured application) cellulosic or wood fiber [see p. 239]. HH-I-1030-Insulation, thermal (mineral fiber, for pneumatic or poured application) [see p. 262]. HH-I-521-Insulation blankets, thermal (mineral fiber for ambient temperatures) [see p. 285]. Federal specifications HH-I-515 and HH-I-1030 covering loose fill cellulose and mineral fiber insulation respectively are intended for use in housing and other framed building applications. They are adaptable to wood joist, rafters, and stud construction. The material can be pneumatically blown or poured into place. Federal specification HH-I-521 is also intended for use in housing and other framed building applications. This mineral fiber material is furnished in blanket form with or without vapor barriers. The material is supplied in various roll lengths. These specifications are essentially performance oriented documents which describe the requirements of Federal agencies for insulation. Based on information provided us by the Department of Energy and the National Bureau of Standards and other members of the Federal family it was determined that we should revise the three insulation specifications to specify the most current technical data for physical properties and testing methods. This revision effort is being accomplished in accordance with our normal procedures, as follows: (1) Pertinent technical data relative to the products is gathered. (2) A draft proposed specification is prepared. (3) Copies of the proposed specification are circulated for comments to interested parties including manufacturers, Federal Government activities, industry associations and testing laboratories. (4) Comments are received, reviewed and evaluated, meetings are held to resolve differences and appropriate changes are made to the proposed specification. (5) A final draft is prepared and forwarded for printing and promulgation. Mr. Chairman, with your permission we are submitting copies of the three draft specifications (HH-I-515D, HH-I-1030B, and HH-I521F) for the record. Mr. ECKHARDT. Without objection, the record will be held open for these materials [see p. 239]. Mr. MILLER. The specific areas in the specifications where major changes or new requirements appear are fire testing, density measurement, and resistance to fungal growths. The National Bureau of Standards accepted responsibility for reviewing the flame spread requirements and after examination and testing recommended the use of the radiant panel test chamber for the flame spread requirement. They also recommended that we include a smoldering combustion test. The major points considered in the decision to propose the radiant panel and smoldering combustion tests were as follows: 1. The E-84 tunnel test has been applied to cellulose insulation in ASTM C-739 only since 1973. Prior to this, the test was used for building material, including mineral fiber insulation for laboratory comparison. Mineral fiber insulation does not burn under this test; therefore, the use of E-84 for this material seems of little meaning. The use then in 1973 of the E-84 test for cellulose insulation seems to be based on previous acceptance with mineral fiber insulation. 2. The ignition source and ceiling mounting in the E-84 test have raised questions as to the relationship to real attic situations. In addition the ceiling mounting requires a wire screen for which a correction factor may or may not be applied. The ignition source in the tunnel test does not address a small open flame or a smoldering ignition source. 3. The flame spread classification may not be a reasonable comparison tool for all densities and material forms so that a classification of 100 means the same for a dense solid wood as for a low density cellulosic insulation. 4. The ASTM E-84 tunnel test has been shown to be invalid for some low density fire-retardant treated plastic foams in terms of measuring their contribution to fire growth. Its applicability to, and appropriateness for, other low density insulation materials may also be seriously questioned. 5. Fire data from the National Bureau of Standards has indicated that covered electrical-for heating-devices or a wiring hot spot may cause ignition of exposed insulation in the attic, basement, or crawl spaces. 6. The E-84 test does not simulate realistic exposure of the insulation to possible fire starting situations in the attic. 7. The attic floor radiant panel test simulates the configuration and radiant heat exposure which may be experienced by insulation laid between attic floor joists and subjected to a small open flame ignition. 8. It appears from the fire statistics and from tests with recessed lighting fixtures that smoldering ignition of insulation in the attic may be the most important potential hazard. In a review of density requirements we found that all blown fibrous insulations can be assumed to settle after application. Therefore, the requirement for density in HH-I-515C and HH-I-1030A is applied to newly installed insulation. Settling is not considered in this requirement. The density as determined in the proposed HH-I-515D and HH-I1030B is the density of the product that would be expected to be found in the field some time after installation and is considered the settled density. Finally, with respect to fungal growth of cellulosic insulation it is possible that this condition could cause the degrading of the thermal properties of the insulation by destroying the structure of the fibers; could provide a source of fungal spores which might penetrate the living area and cause health problems; could increase the corrosive action of the insulation material through the accumulation of metabolic products. Recently we have had a number of meetings with various insulation trade associations to discuss the requirements in our proposed revisions of the insulation specifications. These associations include: Society of International Cellulose Insulation Manufacturers; Society of American Cellulose Insulation Manufacturers; Manufacturing Association of Cellulose Insulation International; National Cellulose Insulation Manufacturers Association; and National Mineral Wool Insulation Association. After we have completed our evaluation of the comments we have received, we plan to issue a second draft on each of three specifications. These will be circulated again to industry and Federal agencies for final comment before a final determination is made. Again, Mr. Chairman, it is important to reiterate that Federal specifications are developed to describe Federal agency requirements and are mandatory only on Federal agencies. These comments conclude our prepared statement. I would be pleased to answer any questions. [Testimony resumes on p. 307.] [The following information was received for the record:] HH-I-515D (TO SUPERSEDE) PROPOSED FEDERAL SPECIFICATION-INSULATION THERMAL (LOOSE FILL FOR PNEUMATIC OR POURED APPLICATION): CELLULOSIC OR WOOD FIBER This proposed Federal Specification draft, dated November 4, 1977 prepared by the General Services Administration, Federal Supply Service, Washington, D.C. 20406, has not been approved for promulgation and is subject to modification. Do not use for procurement purposes. 1. SCOPE AND CLASSIFICATION 1.1 Scope: This specification covers chemically treated cellulosic or wood fiber loose fill thermal insulation for use in housing, and other framed building at ambient temperatures, by pneumatic or pouring application. While products that comply with this specification may be used in various constructions they are adaptable primarily, but not exclusively, to wood joist, rafters, and stud construction. 1.2. CLASSIFICATION 1.2.1 Types: Loose fill thermal insulation shall be of the following types, as specified (See 6.2). Type I-Pneumatic application. Type II-Poured application. 2. APPLICABLE DOCUMENTS 2.1 The following documents, of the issues in effect on date of invitation for bids or request for proposal, form a part of this specification to the extent specified herein. Federal specification US-S-48-Sacks, Shipping, Paper. Federal standard Fed. Std. No. 123—Marking for Shipment (Civil Agencies). (Activities outside the Federal Government may obtain copies of Federal Specifications, Standards, and Handbooks as outlined under General Information in the Index of Federal Specifications and Standards and at the prices indicated in the Index. The Index, which includes cumulative monthly supplements as issued, is for sale on a subscription basis by the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402. (Single copies of this specification and other Federal Specifications required by activities outside the Federal Government for bidding purposes are available without charge from Business Service Centers at the General Services Administration Regional Offices in Boston, New York, Philadelphia, Washington, D.C., Atlanta, Chicago, Kansas City, MO., Fort Worth, Houston, Denver, San Francisco, Los Angeles, and Seattle, WA. (Federal Government activities may obtain copies of Federal Specifications, Standards, and Handbooks and the Index of Federal Specifications and Standards from establishing distribution points in their agencies.) Military standards MIL-STD-105-Sampling Procedures and Tables for Inspection by Attributes. (Copies of Military Specifications and Standards required by contractors in connection with specific procurement functions should be obtained from the procuring activity or as directed by the contracting officer.) 2.2 Other publications: The following documents form a part of this specification to the extent specified herein. Unless a specific issue is identified, the issue in effect on date of invitation for bids or request for proposal shall apply. |