ATTACHMENT No. 2

APPENDIX C-STANDARD METHOD OF TEST FOR SMOLDERING COMBUSTION CHARACTERISTICS OF MATERIALS USED FOR THERMAL INSULATION

1. SCOPE

1.1 This method evaluates the tendency of thermal insulation in the form of loose fill, batts or blankets to support smoldering combustion. It is applicable to any insulation that is capable of being installed in the specimen holder at the density and in the physical state of the material in its intended use.

1.2 The purpose of this test is to determine the tendency of the material under test to support and propagate smoldering combustion subsequent to exposure to a standard ignition source.

2. SUMMARY OF METHOD

2.1 This method measures the extent and progression of smoldering from a lighted cigarette inserted vertically, with the lit end upward, into the center of an insulation material sample.

2.2 The extent of damage to the test specimen, as indicated by percent of specimen weight loss and by the extent of charring, are recorded in this test, as well as any other observable combustion behavior, such as progression to flaming combustion.

3. SIGNIFICANCE

3.1 This method of test is designed to provide a basis for evaluating the tendency of insulation to support smoldering combustion when subjected to a small ignition source. The lighted cigarette represents a typical ignition source which may make contact with insulation installed in residential buildings.

4.1 Specimen holder.

4. APPARATUS

4.1.1 The specimen holder shall be an open-top 20 ± 0.2 cm square box, 10±0.2 cm in height, fabricated from a single piece of 0.61 ± 0.08 mm thick (24 U.S. Standard gauge) stainless steel sheet with the vertical edges of the box overlapped, not to exceed to 7 mm in seam width, and soldered so as to be watertight.

4.1.2 The specimen holder during test use shall rest upon a pad of inert insulation, such as of glass or ceramic fibers, of at least 1.5 cm in thickness and approximating the dimensions of the bottom of the specimen holder. The density of the insulation shall be 50 ± 15 Kg/m3.

4.2 Ignition source.

4.2.1 The ignition source shall be a cigarette without filter tip made from natural tobacco, 85 ± 2 mm long with a tobacco packing density of 0.270 ± 0.020 g/cm3 and a total weight of 1.1 ± 0.1 gm.

4.3 Balance.

4.3.1 A balance of 1 kg capacity, accurate at least to 0.1 g, and provided with a suitable pan is required.

4.4 Test area.

4.4.1 The test area shall be draft-protected and equipped with a suitable system for exhausting smoke and/or noxious gases produced by testing. Air velocities as measured by a hot wire anemometor in the vicinity of the surface of the sample shall not exceed 0.5 m/sec.

4.4.2 The test area shall be maintained at 23±5 °C and 50±5 percent relative humidity.

4.3 Sampling.

4.3.1 At least three samples shall be prepared of any material undergoing test. Samples shall be taken in a manner to encompass possible variations in material composition (for example, from the top, middle, and bottom of bagged insulation).

4.3.2 Samples of material to be tested shall be selected, prepared, and handled in a manner to avoid differences in the composition and condition of the sample from that of the sampled material in its intended use.

5. TEST PROCEDURE

5.1 Samples and cigarettes shall be conditioned in air at a temperature of 23±5 °C and a relative humidity of 50 percent for at least 12 hours piror to test. Samples and cigarettes shall be removed from any packaging and exposed in a

suitable manner to permit free movement of air around them during conditioning.

5.2 Sample material shall be loaded into specimen holders to uniformly and homogeneously fill the holders level and flush to the top edges of the holders. Specimen weight shall be measured, at least to the nearest 0.2 g, by weighing the holder before and after filling. The density of the specimen contained in a holder (volume 4 1, 0.14 ft3) shall be calculated and shall be not less than the density recommended for the material in its intended use.

5.3 With the sample in the holder and placed on the insulated pad, a rod of 8 mm diameter with a pointed end shall be inserted vertically into the center of the material being tested and withdrawn to form an appropriate cavity for the ignition source. A well lit cigarette, burned not more than 8 mm (0.3 in), shall be inserted in the formed cavity, with the lit end upward and flush with the sample surface.

5.4 Burning of the cigarette and specimen shall be allowed to proceed undisturbed in the test area for at least 2 hours or until the smoldering is no longer progressing.

5.5 After completion of burning and after the holder has cooled down to 25 °C, the specimen holder with its material residue shall be weighed, at least to the nearest 0.2 g, and the percent weight loss of the original specimen calculated.1 5.6 After completion of burning, the minimum distance of charring or smoldering of the material from the edge of the holder shall be measured. In cases where the material tested has smoldered to some extent, the material residue shall be carefully removed by layers and the closest proximity of charred material to the vertical sides of the specimen holder determined to the nearest 0.5

cm.

6. CRITERIA

6.1 Materials tested by this method shall be judged in terms of the following criteria:

6.1.1 Weight loss of each specimen expressed as a percent of its initial weight. 6.1.2 Charring of specimen in terms of progression to within 4 cm of the sides of the specimen holder.

6.1.3 Evidence of flaming combusion of the specimen during testing.

7. REPORT

7.1 The report shall include the following:

7.1.1 Identification and/or description of the material being tested.

7.1.2 The original weight of specimens tested and their calculated density.

7.1.3 The final weight of specimens tested and the percent weight loss they have experienced during testing.

7.1.4 The closest distance that charring in specimens tested has approached the sides of the specimen holder during testing, when appreciable charring of a specimen has occurred.

7.1.5 Any observations of the burning characteristics of the specimens that could be pertinent to the material's performance in its intended use.

Mr. ECKHARDT. The GSA specification HH-I-515C states when applications are made requiring higher flame spread resistance it is recommended that class 25 loose fill thermal installation be used. Do you think that that application requiring higher flame spread resistancedo you think that that term would be applicable to residential attics? Mr. MILLER. I would think so, yes, sir.

Mr. ECKHARDT. Then I gather from your statement that in your view 515C standards do not provide any measurable amount of safety to homeowners.

Mr. MILLER. 515C

Mr. ECKHARDT. Or would not.

Mr. MILLER. 515C does require some measure of fire retardation in the product. However, we don't know just from the flame spread classification specifically how much protection this is inasmuch as that procedure does not simulate the actual attic conditions.

1 The weight of the cigarette residue is ignored in this exercise and may, in some cases, result in a slight gain in sample weight.

Mr. ECKHARDT. At least with respect to the testing that provision was not reliable assurance of safety in a home?

Mr. MILLER. Inasmuch as it has not been correlated to what actually happens in the home.

Mr. ECKHARDT. Yes. When do you expect final 515D revision? Mr. MILLER. We expect 515D to be finalized within 60 to 90 days. Mr. ECKHARDT. You had earlier said it would be ready in March but there has been some slippage on that.

Mr. MILLER. There have been some additional requirements to come to conferences and things that have slipped it, yes.

Mr. ECKHARDT. Have any of the Federal agencies pressured GSA to delay the standard?

Mr. MILLER. When you say "pressured" I would say, no, we have not been pressured. They have made some requests that additional time be allowed.

Mr. ECKHARDT. Which ones and why?

Mr. MILLER. Specifically DOE had in their comments to us requested an extension of 6 months- this was back as of December, the first part of December-in order for, in their opinion, more data to be gathered or for more tests to be conducted, and more people become familiar with the procedures. I don't have the specific comments here with us but that is the only agency that specifically asked for an extension.

Mr. ECKHARDT. Why was the cigarette selected for use in the smoldering test?

Mr. MILLER. The idea of smoldering is that it is recognized that cellulose material under certain conditions is going to smolder. The point of the test is that the smoldering ignition does not propogate. The cigarette provides an ignition source. It is not specifically intended to simulate the fact that somebody drops a cigarette in the attic.

Mr. ECKHARDT. How many testing labs have the capacity of doing the Steiner tunnel test?

Mr. MILLER. How many testing labs? Are you talking about independent testing labs as opposed to those owned by companies?

Mr. ECKHARDT. Both.

Mr. MILLER. If you will wait a second, we might have that.
To our knowledge there are 14 tunnels in the country.

Mr. FREEMAN. The breakdown on that is there are eight independent and eight industry E-84 tunnels in the country that we know of today. Mr. ECKHARDT. How many have the capability to do the radiant panel test?

Mr. MILLER. Well, some of those labs that have tunnels would not necessarily have the capability to run the radiant panel test. You want them to have both capabilities or just those that have the capability to perform the radiant panel test.

Mr. ECKHARDT. Just those that have the capability of running the radiant panel test at the moment. I gather it would be some of those labs and some additional ones, right?

Mr. FREEMAN. Well, what I would like to comment on there, Mr. Chairman, is that the flooring radiant panel configuration is not by any means a new test method, it has been used extensively in the carpet industry for the last 5 or 6 years.

A lot of the data base that goes with the radiant panel testing has been generated through the carpet industry. With that in mind we are

aware of 35 radiant panels in the United States today, not necessarily meaning that they are geared up for the modifications to run insulation but there are 35 radiant panels in the country.

Mr. ECKHARDT. But there would be no very substantial problem in gearing up to do that I gather; the equipment is not expensive. Mr. MILLER. That is my understanding.

Mr. FREEMAN. Yes.

Mr. ECKHARDT. Earlier witnesses have criticized the 515D standard because of the inadequate substantiation of the test result. Do you think these criticisms are valid?

Mr. MILLER. We would say that in working with the Bureau of Standards, they have conducted tests showing that performance in the radiant panel does relate to performance on a full scale basis. To that extent we consider the radiant panel a more relevant procedure and one which correlates to actual attic conditions. This has not been shown for the tunnel, at least has not been shown to us.

Mr. ECKHARDT. Could you briefly describe the testing that has been done by you or the Bureau of Standards to validate the test methods required? I understand 515D

Mr. MILLER. Briefly describe the procedures or the amount or-I am not sure what you are after.

Mr. ECKHARDT. Well, how much testing and what have been the results?

Mr. MILLER. We don't have all that specifically available but if you would hold the record open we could obtain that material.

Mr. ECKHARDT. Without objection, the record will be held open for that purpose.

[The information requested was not available to the subcommittee at the time of printing.]

Mr. FREEMAN. One comment on the radiant panel testing involving cellulose insulation and mineral fiber insulation. Back on September 15, 1977, there was a meeting held at the Bureau of Standards in the Fire Research Center with industry representatives, association representatives, proposing to them the findings that NBS has come up with and recommending at that time or substitution for the E-84 tunnel test in the Federal specifications. That for the record has been roughly 5 to 6 months now.

Mr. ECKHARDT. Thank you very much for your testimony here today.

Mr. MILLER. Thank you.

Mr. ECKHARDT. Mr. Philip Stern, Boulder district attorney's office. STATEMENT OF PHILIP S. STERN, CONSULTING ENGINEER, METROPOLITAN DENVER DISTRICT ATTORNEY'S CONSUMER OFFICE

Mr. STERN. Mr. Chairman, members of the committee, I am Philip S. Stern, consulting engineer with the Metropolitan Denver District Attorney's Consumer Office where I serve as a consulting engineer under contract with the Boulder district attorney's office where I am directly employed. This statement today is delivered on behalf of the Metropolitan Denver Consumer Office, however.

I will just very briefly summarize the statement.

Basically our office has had 3 years worth of experience in dealing with consumer problems related to the home insulation industry. These

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