Life Safety Comment Update - March 2021 | Standard Work Specifications

Any comments or inquiries that have a direct impact on life safety are considered through an expedited review process by the Standard Work Specifications (SWS) administrators to ensure any life safety issues are mitigated as soon as possible. Two life safety inquiries were received by the U.S. Department of Energy's (DOE's) Weatherization Assistance Program (WAP) during the field guide review process, which triggered the life safety process. The purpose of this letter is to inform the SWS network of the comments submitted, and the actions taken to address them.

The specifications and comments are as follows:

Life Safety Comment #1

Title	4.0401.1f – Rim and Band Joist – SPF Insulation - Ignition and thermal barriers
Specification	If foam is no more than 3 1/4" thick and the space is not permanently habitable no thermal barrier is required If foam is thicker than 3 1/4", does not meet the flame and smoke index, or is not between 0.5 and 2.0 lb./ft3 density, separate foam from the subspace with a suitable thermal barrier covering or coating as indicated in manufacturer's specifications and applicable building code If code requirements are unclear, consult local code officials for clarification
Comment	It contains the requirements that if the space is "permanently habitable" then the thermal barrier is required regardless of the foam's thickness, density, or fire rating. This is above the 2018 IRC (R316.5.11), which allows the foam to remain uncovered as long as it is no more than 3 ¼" thick, between 0.5 and 2.0 lb./ft3 density, and has a flame and smoke spread of 25/450 or less, regardless of the use of the space

Title

4.0401.1f – Rim and Band Joist – SPF Insulation - Ignition and thermal barriers

Specification

If foam is no more than 3 1/4" thick and the space is not permanently habitable no thermal barrier is required

If foam is thicker than 3 1/4", does not meet the flame and smoke index, or is not between 0.5 and 2.0 lb./ft3 density, separate foam from the subspace with a suitable thermal barrier covering or coating as indicated in manufacturer's specifications and applicable building code

If code requirements are unclear, consult local code officials for clarification

Comment

It contains the requirements that if the space is "permanently habitable" then the thermal barrier is required regardless of the foam's thickness, density, or fire rating. This is above the 2018 IRC (R316.5.11), which allows the foam to remain uncovered as long as it is no more than 3 ¼" thick, between 0.5 and 2.0 lb./ft3 density, and has a flame and smoke spread of 25/450 or less, regardless of the use of the space

Two proposed solutions were suggested:

Delete the language that requires a thermal barrier if the space is "permanently habitable" to align the specification with the current version of the 2018 IRC (R316.5.11); or
Keep the language that requires a thermal barrier in space defined as “habitable” (2018 IRC R202) defines habitable as: "a space for living, sleeping, eating, or cooking" and exempts "bathrooms, toilet rooms, closets, halls, storage or utility spaces and similar areas")

Life Safety Comment #2

Title	3.0102.2c Specific Air Sealing - Sealing High Temperature Devices - Clearance and Isolation
Specification	Maintain a minimum clearance of 3" between combustible materials or sealants and any portion of the high-temperature device (e.g., chimney, vent, flue), unless the venting material is listed and labeled for less clearance Install a rigid, fixed dam higher than the insulation that maintains the required clearance between high-temperature devices and combustible materials Do not allow combustible insulation between a high-temperature device and a dam unless insulation material is rated for contact with the device
Comment	A WAP Grantee has expressed concern that this may lead to incorrect clearances or treatment of some metal venting materials with a less than ideal clearance from combustibles (e.g., wood stove, fuel-oil, or gas vented through single wall venting). The specification does maintain that this is a "minimum clearance" so anything more than this is allowable if the installer should so choose, but it does not allow for less clearance if the manufactured vent material allows for less (e.g., "B-vent", or triple-walled "Z-vent").

Title

3.0102.2c Specific Air Sealing - Sealing High Temperature Devices - Clearance and Isolation

Specification

Maintain a minimum clearance of 3" between combustible materials or sealants and any portion of the high-temperature device (e.g., chimney, vent, flue), unless the venting material is listed and labeled for less clearance

Install a rigid, fixed dam higher than the insulation that maintains the required clearance between high-temperature devices and combustible materials

Do not allow combustible insulation between a high-temperature device and a dam unless insulation material is rated for contact with the device

Comment

A WAP Grantee has expressed concern that this may lead to incorrect clearances or treatment of some metal venting materials with a less than ideal clearance from combustibles (e.g., wood stove, fuel-oil, or gas vented through single wall venting). The specification does maintain that this is a "minimum clearance" so anything more than this is allowable if the installer should so choose, but it does not allow for less clearance if the manufactured vent material allows for less (e.g., "B-vent", or triple-walled "Z-vent").

One proposed solution was suggested:

Revise the minimum clearance 3" value to 6" while the rest of the language of the specification remains the same.

Next, recommendations for these two life safety comments were brought to the SWS Air Sealing and Insulation Committee for review.

Life Safety Comment #1

SWS Air Sealing and Insulation Committee accepted the first proposed solution and added additional language to this specification (4.0401.1f) and 4.0401.1g (Insulation-onsite documentation)

Title	4.0401.1f Ignition and thermal barriers
Old Specification	If foam is no more than 3 1/4" thick and the space is not permanently habitable no thermal barrier is required If foam is thicker than 3 1/4", doesn’t meet the flame and smoke index, or is of less than 0.5 lb./ft3 density, separate foam from the subspace with a suitable thermal barrier covering or coating as indicated in manufacturer's specifications and applicable building code If code requirements are unclear, consult local code officials for clarification
Revised Specification	If foam is no more than 3 1/4" thick, is between 0.5 and 2.0 lb./ft3 in density, and has a flame spread/smoke development index of 25/450 or less when tested in accordance with ASTM E84 or UL 723, no thermal barrier is required If foam is thicker than 3 1/4", does not meet the flame and smoke index, or is not between 0.5 and 2.0 lb./ft3 density, separate foam from the subspace with a suitable thermal barrier covering or coating as indicated in manufacturer's specifications and applicable building code If code requirements are unclear, consult local code officials for clarification

Title

4.0401.1f Ignition and thermal barriers

Old Specification

If foam is no more than 3 1/4" thick and the space is not permanently habitable no thermal barrier is required

If foam is thicker than 3 1/4", doesn’t meet the flame and smoke index, or is of less than 0.5 lb./ft3 density, separate foam from the subspace with a suitable thermal barrier covering or coating as indicated in manufacturer's specifications and applicable building code

If code requirements are unclear, consult local code officials for clarification

Revised Specification

If foam is no more than 3 1/4" thick, is between 0.5 and 2.0 lb./ft3 in density, and has a flame spread/smoke development index of 25/450 or less when tested in accordance with ASTM E84 or UL 723, no thermal barrier is required

If foam is thicker than 3 1/4", does not meet the flame and smoke index, or is not between 0.5 and 2.0 lb./ft3 density, separate foam from the subspace with a suitable thermal barrier covering or coating as indicated in manufacturer's specifications and applicable building code

If code requirements are unclear, consult local code officials for clarification

Title	4.0401.1g Insulation-onsite documentation
Old Specification	Post a dated receipt signed by the installer that minimally includes: Installed insulation type, coverage area, installed thickness, and installed R-value
Revised Specification	Post a dated receipt signed by the installer that minimally includes: Installed insulation type, coverage area, installed thickness, installed R-value, manufacturer product name, manufacturer supplied material density, and flame spread and smoke development index as tested per ASTM E84 or UL 723

Life Safety Comment #2

SWS Air Sealing and Insulation Committee did not accept the proposed recommendation but updated the language in the specification.

Title	3.0102.2c – Clearance and isolation
Old Specification	Maintain a minimum clearance of 3" between combustible materials or sealants and any portion of the high-temperature device (e.g., chimney, vent, flue). Install a rigid, fixed dam higher than the insulation while that maintains a minimum 3" clearance between high-temperature devices and combustible materials Do not allow combustible insulation between a high-temperature device and a dam unless insulation material is rated for contact with the device
Revised Specification	Maintain a minimum clearance of 3" between combustible materials or sealants and any portion of the high-temperature device (e.g., chimney, vent, flue), unless the venting material is listed and labeled for less clearance Install a rigid, fixed dam higher than the insulation that maintains the required clearance between high-temperature devices and combustible materials Do not allow combustible insulation between a high-temperature device and a dam unless insulation material is rated for contact with the device

Title

3.0102.2c – Clearance and isolation

Old Specification

Maintain a minimum clearance of 3" between combustible materials or sealants and any portion of the high-temperature device (e.g., chimney, vent, flue).

Install a rigid, fixed dam higher than the insulation while that maintains a minimum 3" clearance between high-temperature devices and combustible materials

Do not allow combustible insulation between a high-temperature device and a dam unless insulation material is rated for contact with the device

Revised Specification

Maintain a minimum clearance of 3" between combustible materials or sealants and any portion of the high-temperature device (e.g., chimney, vent, flue), unless the venting material is listed and labeled for less clearance

Install a rigid, fixed dam higher than the insulation that maintains the required clearance between high-temperature devices and combustible materials

Do not allow combustible insulation between a high-temperature device and a dam unless insulation material is rated for contact with the device

SWS Air Sealing and Insulation Committee approved the revised language of 4.0401.1f (Ignition and thermal barriers), 4.0401.1g (Insulation-onsite documentation), and 3.0102.2c (Clearance and isolation) specifications.

The SWS was updated on March 23, 2021, to address the above comments. Users are encouraged to either submit a comment through the SWS site or submit messages through the Contact Us link.