The Federal Trade Commission has proposed new rules for marketing home insulation, but the agency does not seem inclined to weigh in on a long-running debate among makers of competing types of plastic insulation.
Manufacturers are arguing about the best way to test their products, and while it sounds technical, ultimately the FTC position could have a significant impact on the marketing claims that can be made. The key technical issue is to what degree insulation loses its effectiveness over time and how that should be measured.
Various plastics industry trade groups are split on what the FTC should do.
The Expanded Polystyrene Molders Association, for example, urged FTC to ``substantially enhance'' the proposed rules by adopting a broad standard that measures the long-term heat retention value, or r-value, of the insulation over at least 15 years.
But other groups, like the Polyisocyanurate Insulation Manufacturers Association, say the agency is on the right track with its more cautious approach of essentially asking the industry for more input.
``Because of the complexity of it, they need to take some deliberate steps,'' said PIMA President Jared Blum.
PIMA endorsed long-term tests for polyiso roofing material, but said there are too many unresolved questions for a blanket FTC rule in other areas, like polyiso sheeting insulation. There, PIMA endorses a six-month test.
And others, like the Spray Polyurethane Foam Alliance in Arlington, Va., question whether the long-term tests will work for their segment of the industry.
FTC lawyer Hampton Newsome said the commission took note of improvements in the tests in the past few years.
``There's a recognition that there are these new tests,'' he said. ``Many people believe they are improvements. Whether it is the right time to apply those to everyone in the industry and all products, that seems to be an open question.''
FTC proposed the new rule July 15. Industry groups filed formal comments Sept. 22.
Newsome hopes the final rule can be adopted in a ``matter of months.'' The agency specifically noted that it was open to changing its views on an r-value standard if comments warrant.
PIMA, based in Alexandria, Va., said it would not object if FTC adopted one long-term test method, known as S 770, for permeably faced insulation like roofing materials.
Four years ago, when FTC first put out an initial proposal, PIMA opposed mandating a somewhat similar test, ASTM standard C 1303. But Blum said the industry since has become more comfortable with 770 and adopted it as an industry standard Jan. 1 for permeably faced materials.
``We absolutely support the rule, the need for disclosure and the need for empirical data for r-value information,'' Blum said. ``The only cautionary note we sound with the use of 1303 is to ensure replicability and applicability to impermeably faced products.''
Tests are under way to see if S 770 could work with impermeably faced products, Blum said.
Betsy Steiner, EPSMA executive director, said one standard is needed because it currently is very difficult for consumers to make sense of competing claims when they are determined by different test methods.
For example, expanded PS has an r-value of about 3.6, but it doesn't drop over time, while other materials, like polyiso, have r-values between 6.0 and 8.0, but they can lose effectiveness over time.