Frequently Asked Questions - Safer Insulation Solution

Frequently Asked Questions
FS 170-15 and 171-15
What would FS 170-15 allow?
FS 170-15 adds the following exception to IBC 2603.3 Surface-burning characteristics: Foam plastic insulation located
between a concrete slab on grade and its subgrade. Such insulation shall also be exempt from the limiting oxygen index
(LOI) requirements of ASTM C578. IBC Section 1907 Minimum slab provisions would also apply, guaranteeing a minimum
thickness of 3.5 inches of concrete over foam plastic insulation.
What would FS 171-15 allow?
FS 171-15 adds the following exception to IBC 2603.3 Surface-burning characteristics: Foam plastic insulation located a
minimum of 6 inches (152 mm) below finished grade and separated from building interiors by a masonry or concrete wall
or foundation. Such insulation shall also be exempt from the limiting oxygen index (LOI) requirements of ASTM C578. IBC
Chapter 18 requirements for concrete or masonry foundations or foundation walls would also apply.
Why did the proponents submit two separate proposals, each adding a new exception to Section 2603.3?
FS 170-15 and FS 171-15 describe different below-grade uses of foam plastic insulation so they can be evaluated
separately in the context of other applicable code requirements for the installation conditions described.
Why exempt foam plastic insulation described in FS 170-15 and FS 171-15 from flame spread index (FSI), smokedeveloped index (SDI), and limiting oxygen index (LOI) requirements?
When installed in accordance with FS 170-15 and FS 171-15, foam plastic insulation is protected by concrete, masonry,
soil, or other barriers. It is not exposed to realistic ignition sources, and it does not have access to sufficient oxygen to
support a flame. As a result, the insulation does not pose a fire hazard to first responders or to building inhabitants.
The proposed exemptions from FSI, SDI, and LOI requirements would enable the optional use of foam plastic insulation
without flame retardants.
Why are FS 170-15 and FS 171-15 important?
The flame retardants used in foam plastic building insulation, HBCD and TCPP, pose a chronic health risk, and have
been associated with hormone disruption, developmental toxicity, and other health and ecological harm. In addition,
an emerging flame retardant for polystyrene insulation, PolyFR, poses similar hazards throughout its lifecycle (though
toxicity data is limited).
The presence of these flame retardants in foam plastic insulation increases formation of toxic halogenated dioxins and
furans during combustion or thermal processing. Exposure to materials containing flame retardants – like foam plastic
building insulation – and their combustion byproducts may contribute to higher rates among firefighters of certain
Where fire safety can be achieved without adding flame retardants, such as in uses of foam plastic insulation described
in FS 170-15 and FS 171-15, this risk of chronic health harm should not be tolerated, in keeping with the intent statement
of the IBC: “The purpose of this code is to establish minimum requirements to provide a reasonable level of safety, public
health and general welfare… from fire and other hazards attributed to the built environment and to provide a reasonable
level of safety to fire fighters and emergency responders during emergency operations.”
Is there precedent for the safe manufacture and use of foam plastic insulation without added flame retardants?
Yes. In 2001, Sweden changed building codes to allow for the use of foam plastic insulation without flame retardants.
Norway similarly updated building codes in 2004. As a result, approximately 96% of all polystyrene insulation
manufactured in Sweden and Norway does not contain flame retardants. Notably, there is no evidence of an increase in
fires or fire losses in Sweden and Norway since these materials entered the market; fire safety has been maintained with
minimal alterations to traditional building practices.2
Is it more hazardous to transport, store, or install foam plastic insulation when it does not contain flame retardants?
No. According to the Alliance for the Polyurethanes Industry, “(a)ll organic foam insulations, regardless of whether they
contain fire retardants, should be considered combustible and handled accordingly”. Large quantities of materials with
similar hazard profiles and/or combustibility are routinely shipped and stored safely. In addition, the International Fire
Code and other regulations apply to storage and transportation.
How would FS 170-15 and FS 171-15 impact construction costs?
The proposed code changes will not require any action that increases construction costs. FS 170-15 and FS 171-15 simply
enable the voluntary use of foam plastic insulation manufactured without added flame retardants.
Could specification of foam plastic insulation without flame retardants cause confusion for builders on the jobsite?
It is common for builders to track thousands of products for the construction of a single project, and there are
standardized methodologies to document the appropriate delivery, storage, and handling of products on the jobsite.
The Project Manual also catalogues each insulation material to be used during construction, which is typically crossreferenced in the drawing package (e.g. Division 7 of CSI MasterFormat:3).
What is the human exposure to flame retardants in foam plastic insulation?
The extent of direct human exposure to flame retardants from installed foam
plastic insulation is not yet known; more studies are needed to accurately evaluate
the magnitude of this exposure. However, exposure to these chemicals from the
overall lifecycle of insulation products could be significant, especially given that
building insulation is one of the largest end-uses of flame retardant chemicals –
amounting to thousands of tons of flame retardants each year. For instance, foam
plastic insulation is responsible for an estimated 87% of the environmental release
of the flame retardant HBCD, much of which is attributed to disposal of building
insulation at the end of useful product life. It’s replacement, PolyFR, poses
similar environmental hazards, though data is limited. Furthermore, occupational
exposure is a concern for those involved in manufacturing and installation, as well
as those involved in building renovation and demolition.
Concerns about HBCD
include possible human health
effects, aquatic toxicity, and
bioaccumulation. In animal
studies, it disrupts the hormone
system and adversely affects
the developing nervous system.
As of November 2014, HBCD is
banned under the Stockholm
Convention on Persistent
Organic Pollutants.4
Why should the International Code Council be concerned about chemical safety?
Regulations within the I-Codes currently lead to the use of flame retardant chemicals; indeed, IBC Section 2603.3
requirements for foam plastic insulation cannot currently be met without flame retardants. The Toxic Substances Control
Act, a 1976 federal law regulating the use of chemicals in consumer and other products, grandfathered more than
60,000 chemicals into approved use without requiring health and environmental data. Under TSCA, new chemicals can
be used in consumer products before extensive health and ecological testing is complete. Even with reform of federal
chemical policy, governmental agencies do not have sufficient resources to guarantee that chemicals used in building
products are safe. Building codes must be updated so that flame retardants do not need to be used when they do not
provide a fire safety benefit.
Who are some of the supporters of FS 170-15 and FS 171-15?
1 LeMasters, G.K. et al (2006): Cancer risk among firefighters: a review and meta-analysis of 32 studies. Journal of Occupational and
Environmental Medicine/American College of Occupational and Environmental Medicine, 48(11), 1189-1202.
Shaw SD, Berger ML, Harris JH, Yun SH, Wu Q, Liao C, Blum A, Stefani A, Kanna K. 2013. Persistent organic pollutants including polychlorinated
and polybrominated dibenzo-P-dioxins and dibenzofurans in firefighters from Northern California. Chemosphere, 91: 1386-1394.
2 Persistent Organic Pollutants Review Committee (POPRC) (2011) UNEP/POPS/POPRC.7/19/Add.1 Addendum: Risk Management Evaluation on
Hexabromocyclododecane, POPRC, Geneva; 2011.
4 Marvin C.H. et al. Hexabromocyclododecane: current understanding of chemistry, environmental fate and toxicology and implications for global
management. Environmental Science and Technology. 2011; 45(20), 8613–8623.
April 2015
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