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Home My WebLink About0218.092i > f--". I I ! - .April 15, 1992 HONORABLE CITY COUNCIL Palo Alto, California ~el1ulQse Insulation £in~-.l-R~ Members of the Council: Report in Brie! 2 The purpose o! this report 1s to summarize the concerns raised, the follo~-up research performed, and the actions taken follo~ing the discovery that samples of cellulose insulation installed during the City's Home Weatherization Program did not pass specific fire retardance tests. This report is the last in a series of reports to council regarding the cellulose insulation issue. The previous two progress reports (CMR.543:8 and CMR: 286: 8) ...... ere ~resented in 1988, and described the research efforts still underway. Staff was awaiting the results of these efforts before returning to council with a final recommendation. Based upon the information gathered, the completion of a comprehensive ~inspect and correctft program~ and the absence of any historical evidence of cellulose-related fire incidents, staff is recommending to Council that no further remedial action be tak2n in regar~ to the homes insulated through the City's ~eatherization pr09ram~ General Backgro\1nd From 1978 through 1386 the City of Pale Alta operated a Home Weatherization Program '~'P), ~hich included cOotractinq with interested residents to install blown-in rockW'ool, fibergla::s.s and cellulose attic insulation. The City performed these installations using insulation co'tlpanies ...... ho 'WerE nired tnrough an annual competitive bid process and who were required to use insulation materials ~hich met city specifications. Those specifications included compliance ~ith all relevant state and federal standards, plus the requirement that the manufacturer of the insulation used in the HWP participate in the ongoing follow ~p t~sting programs offered by Underwriters Laboratories. During the a-year program, 866 of tr.e approximately 1400 participating homes were insulated with cellulose~ CXR: 218: 92 L " ~; .. ~..,~. --- p~pment of Copcerns The Fire Depart:men.t providE!s home s3.fe,tl~ inspecti~ns upon rec;:ue&t and during one such inspection in 1986, the investigator informally checked the dttic insulation's fire retardar.ce. From this incident it 'Was discovered that a few samples of National Fiberfill insulation (taken :!ro11'l attics insulated through t,he City's ~P} could net pass the t~o fed~ral tests established to evaluate tire retardance characteristics." Al't-hoU9h these federal tests were designed to evaluate insulation characteristics at the tine of manufacture and not after inst'lllation (an issue discussed at length later in this report) ~ staff 'Was sufficiently concerned "\I,rith these results to embark upon a 15 pe~cent sampling program to test all brands of cellu20se installed tbrough the City's ~WP (CMR:603:5). The results of this testing demonstrated that over 90 percent of the samples of all brands of cellulose insulation installed through the City's R~P failed one or both of the fire retardance tests (CMR:294:7). Since staff h~d been planning to phase out the program anywaYr these test results pro~pteo the decision to not continue the ~'p after the expiration of the 1986 cont~acts~ Meanwhile, during the five month testing period, staff discovered that concerns about cellulose ~ere not localized. Other utilities in California had submitted installed insul"tion samples for testing ~nd had similar test failures~ A state~ide task force formed by the California PUblic Utilities Commission (CPUC) was investigating the connection bet-"",e.en blo'Wn-in attic insulation and fire incidents. Staff also learned fro~ people involved in developing the federal test procedures that the original federal standards, adopted in 1979, were put together quicltly and .. ere therefore "interim'" standards; ho .... ever, the standards have not since been reviewed, nodified or finalized. Add~~ssing the Concerns As time passed, inve5~igation into actual fire risk from installed cellulose insulation resulted in more questions tha'1'\ answers. .From staff's perspective, the roost ir.portant questions for Falo Alto ~ere: * The tlriO fire retardance tests 2IIre called critical radiaJJ __ 'f;. ___ JJ_\1~ and M9J--<:lering COr.lbi..l9tion~ The critical radiant flux test evaluates how far fla-rncs (generated else ... ·here in the home.} ,",'ill spread once they reach the insulation. The smoldering co~~ustion test evaluates vhether the insulation itself ...... ill catch fire from contact with a heat svurce (e.g. recessed light fixture, chimney, etc. ) CMR: 218: 92 L • "- I ~." t ~. l : 1) Is it valid to apply the feder~l fire retardance tests to insulation after it has been installed in order t~ assess degree of fire hazard? 2} Do the fir~ retardant capabilities of cellulose insulation decrease over time? 3) Is there any correlation bet~een ho~es insulated ~ith cellulose and fire inci~ents in Palo Alto: 4) What are the appropriate steps for the City to take te· protect the interests of homeo~ners ~hose attics ~ere insulated through the City's HWP? To address these issues, staff took a variety of actions. First and foremost, a program of inspection and co~rection was implemented to ensure that every ho~e insulated vith cellulose through the city I s program had proper barriers installed betw"een the attic insulati~n and a~l possible heat sources. (CMR:294:i) These barriers are considered key to minimizing fire risk. (In fact, several federal and state agency representatives advised staff that having proper barriers installed ~as a far more critical factor in a safe installation than the tiLe retardant treatment of the insulation itself.) During these inspections I even in attics where the original contractor had neglected to install the proper barriers, staff found only three or four places where heat sources had affected the inSUlation and that effect was only minor charring. Staff also conducted regUlar comprehensive .::;earches of all Palo Alto Fire Department records from 1978 through the present time to determine any connections het~een residential files and attics with cellulose insulation installed~ Out of all the residential fire incidents occurring in this period, only one involved a c~llulose-insulatEd attic and, in that case, the fire investigator determined the cellulose had no effect l.lpon the initiation cr the severity of the fire. In addition to gathering local information, staff ~anted to take advantage of any state and national research tnat ICight provide insight into ~hat action was appropriate. staff began closely monitoring the activities of the CPUC Task Force investigating insulation and fires on a statewide basis. Staff participated in the development of a study by the federal Depart'mcnt of £nergy (DOE) und6rtaken in response to Palo Alto's test results~ the DOE study ai:rned to evaluate the effects of installation en the fire retardant capability of cellulose insulation. Also responding to Palo Alto's sample test results, the California Bureau of Hom~ Furnishings and Thermal Insulation began a multi-year study to evaluate the effects of long-term aging on cellulose inSUlation; staff monitored this study's progress as well. Staff also CHR:21S:92 r o •• _._ ....... _ ........... - L ! -......• " .. ~c 1 - tracked various studies unde:rt.'ay c.n the performance of various fire retardant ~hemicals used in cellulo$e manufacture. Of particular importance to staff ~as corresponden~e ~ith the federal Consumer Product Safety co~ission ,CPSC), ~hich is the enforcement agency for the fede~al insulation fla~~ability standards. The CPSC is charged with monitoring the insulation industry for standards compliance a~d determining when corrective or disciplinary action is' \liar-ranted. 'I'r.e objective was to ascertain the CPSC position on the issue of assessing fire risk~ ~ased on results of applying th9 fede~al fire retardance te$ts after insulation is instal!ed. Finally, in coordination ~ith other utilities and inter~sted parties, staff pursued the possibility of an independ~nt national-scale risk analysis being performed by th~ Federal Center for Fire Research in the National Bureau of Standards. (It was there that the original fire retardant test standards _ere developed.) However, this option proved to be very expensive and since there ~ere not enough agencies sufficiently cc.>nvinced of its value to help pay for it, such a study jr,'as never undertaken. Out90me of Investigations After several years, most of the above-described studies have been completed. The California PUC Task force found that there was a statisticallr insignificant numb~r of fires in California where cellulose insulation was cited as the first mate~ial to ignite. The Task Force findings are undermined, however, by quest_ions about the accuracy of the state's fit:'e incident report database and the adequacy of fire investigators' training in detecting the possible role of insulation in a fire. Nevertheless, the task force findings are consistent ~ith the results of investigation into Palo Alto's fire records. The DOE study found t~at fire retardance test results from samples of cellulose insulation taken before and after installation 'Were sir..ilar~ The inplication is that if ir,sulation fails the fire retardance tests aft~ __ :t it is installed, it presumably would have failed before installation} and vice-versa. However~ the -after" tests 'Were performed immediately following installation and again 30 days later, leaving open the question of whether fire retardance ability deteriorates over greater lengths of time. The ~~estion of long-term aging effects on cellulose insulation fire retardance is being addl.-essed by the ongoing state Bureau .of Thermal Insulation study. The Bureau has found that thus far, over two years of aging, samples of cellulose in$ulation (purchased in the open market) deteriorated in terms of their CMR!218t92 L .J:""" .' ... ,. ---. . r ", I - ability to pass the critical radiant flux test.. ~ loss of fire retardant chemical over time was obsel..-ved in this study, but the reason 'Why or hoW' is unknO .... "l1. (Other studies of cl'lemict!l permanence have demonstrated that evaporation and ~ettling are unlike11 explanations.} A complicating f~ctor in ~pplying these stuay results to the "real world" is that cellulose manufacturers ll~,e a variety of chemicals: and net necessarily the standard borates use~ in the various st~dies. A signific.ant factor in st~ff's ultimate reco~~endaticn that further remedial action is not needed is a letter received from the CPSC stating its position on the key iss~es ,Attachment One). The key elements of the CPSC·s letter are summari~ed pelo~~ 1) The CPSC does not consider it valid to apply the fire retardance tests to installed insul~tion and GOes not do so under its standards enforcement program. In other ~ords, they do not consider post-installation test results as grounds for enforcement action against an insulati·::m manufacturer. 2) Assuming the insulation is prcperly installed ~ith adequate barriers around heat sources, and given the absence of fire-related incidents related to cellulose insulation, the CPSC believes that "an after installation product ~hich does not ~eet the standard does not represent an unreasonable risk of fire.- 3) Because of the limited risk associatea ~ith properly installed cellulose iT1$ulation, the CPSC does not feel further risk analysis is ,,"'arran ted on their part. CPsc's staff stated during telephone conversations that there had been discussions about making the standards voluntary rather than mandatory. According to CPSC staff, this change has not peen pursued aggressively, no' ... evf>,r, because: tbe ,,"'hole issu~ is such a 10'" pr'iority for the CPSC. Cpnclusion Staff research efforts to date have yielded a vast and often conflicting array of data that includes the City's own sample test results; various state ana federal study results; expert opinions from industry representatives, regulatory agency staff, and fire inspectors; Palo Alto fire incident reports; descriptions of the variety of different oethods used to perform the "standard" federal fire retardance tests: and anecdotal evidence of the confUsion and disagreement anong experts over the • This test is considered less important in evaluating fire hazard than the smoldering cOtr.bustion test, .... nich the sa~.Jples continued to pass over time. CMR:21B:92 ·' .. " , .. ,-~~-,;?/;< - '-"--:~" -""OJ validity a~d application of the federal insulation standards. The only point upon which staff has fOlmd general consenSus is that the critical factcr in guaranteeing a safe installation of any cellulose insulation, regardless of its chemi~al treatment, is the use of proper barriers aroun-:l attic heat sources. From the available informati~n, staff can conclude that some l!Ianufacturers of cellulose insul.ation did a better job t.han others of usi~q an effective fire retardant chemical mix in producinq their product. Ho~ever, applying the federal fire ret3rdance test to insulation after it has been installed does not see~ to be a valid way to evaluate its fire retardance ability. Therefore, it is impossible to determine the signific~nce, if any, of Palo Alto's sample test results. Since the city has alreaQY taken steps to ensure that all cellulose insulation installations carried out thro'.lgh the C~tyPs ~'p incluoe appropriate barriers around heat sources, and, g~ven that over the past 14 years there has been no causal connection between cellulose ins~lated homes and fire incidents i~ Palo Alto r sta~f is satisfied ~~at the interests of the City's nWP participants have been adequately addressed. Re C 0 mme I}_.j_a t i on In light of actions already taken and the position held by t.he CPSC, staff recommends that no further remedial action be t~ken in regard to homes insulated through the city 1 s Home Weatherization Program. 'I'his recommendation includes permanent suspension of insulation removal activities (CMR:128:7). Respectfully submitted, 7) /----CZe! ('c /~ ~ y- DEBRA !<ATZ ~- Manager, Enc:--gy Services /..:... ... <-<4..-....... / i." -(,~;-;...~_...J; RICHARD L. YOUNG ~ .... / Director of utilities Aill'~Ll\'M~ JUN E FLEMING Assistant city Manager CMR: 218: 92 L • .\. I I - CMR:571:6 =.:503:6 =:5)2:7 CMR: 128:7 CMR: 382: 7 C>m:285:8 =:543:8 Attachment Rej ection of Thermal Insul~tion Bids (11/26/96) Authorization of Insulation Testing Expenditure (12/18/86) Thermal Insulation Installation Inspection (11/19/27J Thel~al Insulation Testing Update and Recommendations (1/29/87 ) Thermal Insulation Fin~l 'lest Results and Recommendations (6/18/87) Referral of CMR:294:7 to Fin~nce and Public Works co~~ittee (7/28/87) Progress Report on Thermal Insulation Issue (5/19/88) Proqress R~port on ·rhenna! Insulation Issue (11/23/88) U.S. Consumer Product safety Commission Letter (5/22/90) =:218:92 L'ebra S. Katz progra:ll1 C'?ordinator, Energy Serv ices city of Palo Alto P.O. Bo)! 10250 palo Alto. California 94303 Dear Ms. Katz: This is 'w"ritten in response to your correspondence dated April 3, 1990 regazding TJEstions that you raised reg2reing cellulose insulation installed by the City of Palo Alto Utilities Department between 1978 and 1906. We have re.viewed the study of post-installation testing of cellulose insulaticn according to ASTM C 739 conducted by the Department of Energy which determined that after 30 days of attic expos\..:.re there 'Were no significant differences in the s~olderin'3 combustion test and radiant panel tests. The position outlined in our August 18, 1987 letter has not changed and the staff of the co~~ission has not taken action regarding enforcement actions after cellulose insulation has beerl installed. I will answer your questions as outlined in your letter by repeating the questions. 1. \t,"hetr,er CPSC Interim Standa:-d HIH-515-D is appropriately ~pplied to installed i~sulaticn. The staff of the Commission has not conducted any enforc;;pent actions based or, sar.pl es of cellulose insulation collected after the insulation has been installed. All previous enforcehlent action .. ,;ere based on testing condu.cted prior to installation. Given the facts set forth in YO'J.r letter, the Commis$ion staff would not test cellulose inSUlation for cozr.pli3nce ",'ith the standard several years after installation in houses. 2. \o.'he~her any CPSC enforcement action is no .... warranted against the t'.am.lfacturers whoae product failed the CPSC sta ndards" - From the facts set forth in your lette~ ~e ~cu!d not take enforce~ent aGtions against the firms in que~tion, The Clepart:cent of Energy study that you enclosed described the results ()f tests c,·:mducted on samples of insulation ccllecte.:l (1) during installation; (2) im.1"Iled iately after installation; a:1d (3) 30 days after installation. The cellulose ir.sulation .... .-hi;:l"~ is t"!1e subj.gct of your correspondence \r,.'as installed in houses several years ago. The staff migbt consider action against a tailing product sa::::pled shortly after installation. H~·",,·-ever, the staff had not cond'.J.cted any such sa-rnpling ire the past an~ restricteo its enforcement actio~ based on sa~p~es of cellulosE insulation c~llected at the firm -cr in cOm!r,erci:'. And 3. ~~ether t~e CPSC considers cellulos~ ins~lation to carry an un~~asonable risk of fire hazard if: a) it is properly ir::stalled (inclu.ding protective barriers around potential heat scurces); b] after installation the product does not P2SS the CPSC standard. If the cellulos~ insulation is properly installed and ac.equate barriers have b~er. placed around all attic heat sources, the pl.·oduct "'·ould not preseTlt an unreasonable risk of fire. Fires :may occur • • .'ith the ir.s:tallation or complying cellulose insulation .... ~en the ir,sulatior: is ilr.properly installed too clOSE to a hEat source. In. your letter you indicated that the City of P<=llo Altr:> has not e:A:perienced any fires associated ~ith cellulose insulQ.~io'l' You also indicated that a task force found that a statistically insignificant nu=ber cf fires ~ere associated .... ith cellulose insulation as the first material tc ignite. GiVEn the absence o~ fire related incidents vith cellulose i~sulation, and the importance of proper installation, the &taff believes that a~ after installat ion pro.:hlct \.:1', iet. does not ::r,eet the 5t~ndard do(;s not represent an u~reascna~le risk of fire. 4. ~-nether further risk ar-,alysis is .... arrEinted and, if so~ vi 11 the CPSC participate in the performance and/or funding of such an analysis. Because of li~ited ris% associated with cellulose ireulation ~hen installed prcperly and the limited budget of t~e U. -:. Consumer Product Safety CO.7.;:issicr'J, \ole feel that. further risk analysis is not ~drra~tej en our part. , [ The CUI rent standard is still i~ effect and there are no ~lans to revoke the standard and defer to the ASTM C 739 Voluntary Standard. This interpretation is based solely on the infonnction. currently available to the staff and the enforct:''1lent postur-e the CPSC currently has in effect~ It could be chailged if the facts change, ~nd could be superseded by t~e Co~,is~ion. r hope this inforrration ..... ill be helpful. It" yOLl have any questio:r:ls, yOlJ may .'rite to lne at the above address or call at 301-492-6400. -_i, ~, ; Sincerely, ~--/~ /%~~ FranClS J. Kr1vca Division of Regclatory Managecent Directorate of Compliance and Administrative Litigation