Code Change Resolution

A Resolution on the Use of Halogenated Flame Retardants in Building Insulation

The following resolution represents a consensus statement of architects, builders, scientists, fire safety experts, and health and environmental advocates. This resolution emerged from research by the Green Science Policy Institute and a group of experts that has been meeting throughout 2012.

WHEREAS, virtually all foam-plastic insulation materials in the U.S. today (extruded and expanded polystyrene, polyisocyanurate, and spray polyurethane foam) are treated with halogenated flame retardants;

WHEREAS, many flame retardants are known to pose serious health and environmental hazards and are actively being banned or eliminated from use in many parts of the world;

WHEREAS, comprehensive investigations by fire-safety experts cast into doubt the contention that the addition of flame retardants—at the concentrations typically used in foam insulation—measurably improves fire performance;

WHEREAS, the presence of flame retardants does not prevent foam plastic from burning and upon combustion can significantly increase hazardous combustion by-products including smoke, soot, carbon monoxide, potentially carcinogenic dioxins, and other toxic chemicals;

WHEREAS, thermal barriers, such as drywall, provide far greater protection against fire and fire-spread than flame retardants;

WHEREAS, the most common test procedure used to determine flammability (flame spread and smoke developed), the Steiner Tunnel Test (ASTM E-84), produces misleading results when applied to foam plastic insulation; and

WHEREAS, flame retardants add to the cost of foam insulation materials while not appreciably enhancing fire safety.

THEREFORE, the signatories below propose the following:

1. Flammability requirements for flame spread or smoke development for foam plastic insulation should be waived when materials are protected by a 15-minute minimum thermal barrier, such as ½” gypsum board or an equivalent. This can be achieved by exceptions to ICC International Residential Code (IRC) Section R316.3 as defined below:

Exception: Foam plastic insulation shall not be subject to this requirement where installed with a thermal barrier in accordance with Section R316.4.

Exception: Foam plastic insulation shall not be subject to this requirement when used in a wall, floor, foundation or roof assembly where the foam plastic insulation is separated from the interior of the building by a minimum 1-inch (25 mm) thickness of masonry or concrete.

2. Halogenated flame retardants should not be used in building materials or furnishings unless or until they can be proven to be safe to human health and the environment.

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The following resolution represents a consensus statement of architects, builders, scientists, fire safety experts, and health and environmental advocates. This resolution emerged from research by the Green Science Policy Institute and a group of experts that has been meeting throughout 2012.

WHEREAS, virtually all foam-plastic insulation materials in the U.S. today (extruded and expanded polystyrene, polyisocyanurate, and spray polyurethane foam) are treated with halogenated flame retardants;

WHEREAS, many flame retardants are known to pose serious health and environmental hazards and are actively being banned or eliminated from use in many parts of the world;

WHEREAS, comprehensive investigations by fire-safety experts cast into doubt the contention that the addition of flame retardants—at the concentrations typically used in foam insulation—measurably improves fire performance;

WHEREAS, the presence of flame retardants does not prevent foam plastic from burning and upon combustion can significantly increase hazardous combustion by-products including smoke, soot, carbon monoxide, potentially carcinogenic dioxins, and other toxic chemicals;

WHEREAS, thermal barriers, such as drywall, provide far greater protection against fire and fire-spread than flame retardants;

WHEREAS, the most common test procedure used to determine flammability (flame spread and smoke developed), the Steiner Tunnel Test (ASTM E-84), produces misleading results when applied to foam plastic insulation; and

WHEREAS, flame retardants add to the cost of foam insulation materials while not appreciably enhancing fire safety.

THEREFORE, the signatories below propose the following:

1. Flammability requirements for flame spread or smoke development for foam plastic insulation should be waived when materials are protected by a 15-minute minimum thermal barrier, such as ½” gypsum board or an equivalent. This can be achieved by exceptions to ICC International Residential Code (IRC) Section R316.3 as defined below:

Exception: Foam plastic insulation shall not be subject to this requirement where installed with a thermal barrier in accordance with Section R316.4.

Exception: Foam plastic insulation shall not be subject to this requirement when used in a wall, floor, foundation or roof assembly where the foam plastic insulation is separated from the interior of the building by a minimum 1-inch (25 mm) thickness of masonry or concrete.

2. Halogenated flame retardants should not be used in building materials or furnishings unless or until they can be proven to be safe to human health and the environment.

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