The Effects of Regulatory Actions on the Marketing of Rigid

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Downloaded by UNIV OF CALIFORNIA SAN DIEGO on November 11, 2015 | http://pubs.acs.org Publication Date: November 30, 1981 | doi: 10.1021/bk-1981-0172.ch010

The Effects of Regulatory Actions on the Marketing of Rigid Polyurethane Foam Insulation ROBERT G. PILMER CPR Division, The Upjohn Company, Torrance, CA 90503

It is estimated that 615 million pounds of rigid polyurethane foam were made during 1979(1). The market for these foamed plastics has been growing at an annual 15 percent rate for the last few years. It is projected that similar growth may resume in future years. The construction market is the key to future growth, as the greatest share of rigid polyurethane foam is used in thermal insulation applications. The rate of buiding construction has been down for some while due to high interest rates and the scarcity of funds. This condition is expected to improve gradually. The consumption of rigid polyurethane foams as thermal insulation can be expected to increase with the renewed building activity. Regulations in various stages of adoption require energy conservation in the design of new buildings. The installation of thermal insulation is one of the means of meeting these proposed energy conservation standards. The Federal Department of Energy has a proposal out for comment called Energy Performance Standards for New Building(2). The state of California has also moved in this direction(3). As standards of this sort are introduced, the demand for thermal insulation for new construction should increase sharply. Because of their high thermal resistance, chlorofluorocarbon (CFC) blown rigid polyurethane foams may gain a greater share of this market in the future. Thermal insulation materials are rated by their resistance to heat flow. This is generally stated as the "R" value. The greater the R value, the better the insulation. Let us consider insulation sufficient to give an R of 19. In conventional 2 x 4 stud construction, sufficient thicknesses of some types of insulating material s cannot be emplaced in the nominal 3-5/8 inch space avail able to yield an R-19 rating. On the other hand, this level of thermal resistance can be achieved easily within this space when it is filled with a rigid CFC blown polyurethane foam. In addition, rigid polyurethane foams sprayed-inplace effectively seal the structure against air infiltration, a benefit derived from few other types of insulation. 0097-6156/81/0172-0113$05.00/0 © 1981 American Chemical Society In Urethane Chemistry and Applications; Edwards, K., et al.; ACS Symposium Series; American Chemical Society: Washington, DC, 1981.

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Like most m a t e r i a l s that have become a s i g n i f i c a n t item of commerce, r i g i d polyurethane foams have become r e g u l a t e d . When a r e g u l a t i o n i s f i r s t i n t r o d u c e d , i t i n h i b i t s the sales of the a f f e c t e d m a t e r i a l s , and the experience with r i g i d polyurethane foams has been no e x c e p t i o n . What follows i s a d e s c r i p t i o n of the a c t i o n s of four d i f f e r e n t types of o r g a n i z a t i o n s t h a t w i l l a f f e c t the future sales of r i g i d polyurethane foams. The Model B u i l d i n g Codes Approximately 55 percent of the sales of r i g i d polyurethane foams has been i n the c o n s t r u c t i o n market i n recent y e a r s . This has not always been so. The uses and q u a l i t i e s of m a t e r i a l s used i n c o n s t r u c t i o n are regulated by the l o c a l b u i l d i n g codes. G e n e r a l l y , the l o c a l governing body adopts one of the model b u i l d i n g code s . Three o r g a n i z a t i o n s p r e s e n t l y write these model codes: The International Conference of B u i l d i n g O f f i c i a l s (ICBO), B u i l d i n g O f f i c i a l s and Code A d m i n i s t r a t o r s (BOCA), and The Southern B u i l d i n g Code Congress (SBCC). Each o r g a n i z a t i o n provides a means for b u i l d i n g o f f i c i a l s , a r c h i t e c t s , engineers, e t c . to meet with t h e i r peers, exchange i d e a s , and act to regulate b u i l d i n g c o n s t r u c t i o n i n a uniform manner. R i g i d polyurethane foams were not considered d i s t i n c t i v e i n the way they burn and were r e g u l a t e d , along with a l l other b u i l d i n g m a t e r i a l s , s o l e l y on the b a s i s of flame spread*. (^References to flame spread or numerical flame spread r a t i n g s throughout t h i s paper are not intended to r e f l e c t hazards presented by these or any other m a t e r i a l s under actual f i r e conditions.) The surface burning c h a r a c t e r i s t i c s (flame spread r a t i n g ) of c o n s t r u c t i o n m a t e r i a l s i s determined by a procedure c a l l e d a tunnel t e s t . For most a p p l i c a t i o n s a maximum flame spread r a t i n g of 75 or 200 was considered s u i t a b l e . In the l a t e I 9 6 0 ' s , r i g i d polyurethane foams able to meet these flame spread requirements were f i n d i n g t h e i r way i n t o more and more construction applications. Because of t h e i r high i n s u l a t i o n e f f i c i e n c y , a r c h i t e c t s and b u i l d e r s were becoming i n c r e a s i n g l y i n t e r e s t e d in polyurethane foams. I t was not c l e a r to e i t h e r the polyurethane industry or to the c o n s t r u c t i o n industry that foamed p l a s t i c s could present an unacceptable f i r e r i s k i f l e f t exposed i n an i n t e r i o r a p p l i c a t i o n , and no s p e c i a l precautions for i n s t a l l a t i o n were recommended. As a consequence, some foamed p l a s t i c s were i n s t a l l e d on the i n s i d e s of b u i l d i n g s and l e f t exposed or given only a coat of ordinary p a i n t . In l i g h t of t o d a y ' s knowledge, these were m i s a p p l i c a t i o n s of the product. In 1974, the Federal Trade Commission brought i t f o r c i b l y to the a t t e n t i o n of 26 manufacturers of foamed p l a s t i c s , raw material s u p p l i e r s , and The Society of the P l a s t i c s Industry t h a t , among other t h i n g s , the tunnel t e s t d i d not c o r r e c t l y evaluate the actual f i r e hazards of these m a t e r i a l s . Ttie b u i l d i n g codes responded a c c o r d i n g l y , and the f i r s t code language

In Urethane Chemistry and Applications; Edwards, K., et al.; ACS Symposium Series; American Chemical Society: Washington, DC, 1981.

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s p e c i f i c a l l y addressing foamed p l a s t i c s was i n t r o d u c e d . As often happens, the r e s u l t i n g regulatory a c t i o n s were not i n c l u s i v e and are probably e x c e s s i v e . At b e s t , i t must be stated that there are i n e q u i t i e s i n the present b u i l d i n g codes. Here b r i e f l y are the key points i n the b u i l d i n g codes of today. 1.

A l l foamed p l a s t i c s s h a l l be covered by a thermal b a r r i e r with the i g n i t i o n i n h i b i t i n g c h a r a c t e r i s t i c s o f 1/2 inch gypsum wall board (15-minute f i n i s h r a t i n g ) .

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The foamed p l a s t i c , when tested i n the thicknesses intended for use, s h a l l have a flame spread r a t i n g no greater than 75 and a smoke developed r a t i n g of no greater than 450.

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Each b u i l d i n g code has a l i s t of s p e c i f i c c o n d i t i o n s and requirements for the use of foamed p l a s t i c s . T y p i c a l l y , these cover t r i m , masonry c o n s t r u c t i o n , c o l d storage b u i l d i n g s , metal faced b u i l d i n g u n i t s , r o o f i n g a p p l i c a t i o n s , doors and e x t e r i o r s h e a t i n g .

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A l t e r n a t e m a t e r i a l s or c o n d i t i o n s of use may be permitted i f d i v e r s i f i e d t e s t s e s t a b l i s h that the i n t e n t of the code has been s a t i s f i e d .

These r e g u l a t i o n s , although c o n s e r v a t i v e , are a t t a i n a b l e . The e f f e c t of these b u i l d i n g codes has been to i n h i b i t the s a l e s of r i g i d polyurethane foams. Conversely, competing thermal i n s u l a t i o n m a t e r i a l s have b e n e f i t t e d from the r e s t r i c t i o n s placed on foamed p l a s t i c s . However, I fear that had not these r e g u l a t i o n s been put i n t o e f f e c t , i n c i d e n t s i n v o l v i n g the m i s a p p l i c a t i o n of r i g i d foamed p l a s t i c s might be o c c u r r i n g with alarming frequency. The news media have been known to pick up on a s e r i e s of i n c i d e n t s and prepare an expose. A s e r i e s of such a r t i c l e s has appeared i n The Los Angeles Times. The a r t i c l e s were c r i t i c a l of the combustible nature o f f l e x i b l e polyurethane foams. Statements made i n these a r t i c l e s have been i n t e r p r e t e d by some as applying equally to r i g i d foams. T h i s includes some of the l e s s knowledgeable b u i l d i n g o f f i c i a l s. The bad press for f l e x i b l e polyurethane foams has e f f e c t e d the perception of r i g i d polyurethane foams. F r a n k l y , I would rather have a r e s t r i c t i v e r e g u l a t i o n than a bad p r e s s . Where the b u i l d i n g codes have been enforced, r i g i d polyurethane foams have e s t a b l i s h e d a remarkably good f i r e - l o s s record. I feel that we are regarded with far l e s s s u s p i c i o n today than we were four or f i v e years ago and that acceptance has c o n t r i b u t e d g r e a t l y to the increased s a l e s of the past few y e a r s . I would l i k e to c i t e an example o f a manufacturer who has taken note of the b u i l d i n g codes and created a new product i n response. In d r y , windy weather, f i r e can jump from b u i l d i n g to



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b u i l d i n g by burning brands being blown from roof to roof. This has placed the wood shingle manufacturers i n a d i f f i c u l t position. The f i r e experience for wood shake r o o f i n g , with the c u r r e n t trend towards b u i l d i n g houses c l o s e r and c l o s e r t o g e t h e r , has been gradually g e t t i n g worse. The county of Los Angeles r e c e n t l y acted by banning untreated wood shingles for r o o f s . T h i s p a r t i c u l a r manufacturer created a composite panel c o n s i s t i n g of a g l a s s - f i b e r r e i n f o r c e d p l a s t i c outer s h e l l backed with a r i g i d polyurethane foam. The product looks l i k e a c l u s t e r of hand s p l i t wood shakes. When i n s t a l l e d , the panels i n t e r l o c k and look exactly l i k e a shake shingle roof to the casual observer. These panels have been tested and q u a l i f y as a Class A b u i l t - u p roof c o v e r i n g . In a d d i t i o n , they provide a much greater r e s i s t a n c e to the transmission of heat than wood shake s h i n g l e s . The panels are f a s t and easy to i n s t a l l and quite durable. In the f u t u r e , I a n t i c i p a t e greater acceptance of r i g i d polyurethane foams i n c o n s t r u c t i o n a p p l i c a t i o n s , and with the greater acceptance w i l l come growth. I would a l s o a n t i c i p a t e that the i n e q u i t i e s i n the b u i l d i n g codes w i l l be d e a l t w i t h . Whether these changes w i l l take the form of greater r e s t r i c t i o n s on competing m a t e r i a l s or l e s s r e s t r i c t i o n s on r i g i d polyurethane foams, I cannot p r e d i c t . E i t h e r event w i l l be b e n e f i c i a l to the growth of the r i g i d polyurethane foam market. L a s t l y , innovative ways of using r i g i d polyurethane foams, such as the roof panels I have d i s c u s s e d , w i l l surely o c c u r . These new a p p l i c a t i o n s w i l l also add to the growth. The Insurance S e r v i c e s

Office

There i s a second type of o r g a n i z a t i o n which has had an i n f l u e n c e on the p r o p e r t i e s of m a t e r i a l s used i n b u i l d i n g construction. That o r g a n i z a t i o n i s the insurance c a r r i e r . If the c a r r i e r who insures a b u i l d i n g disapproves of a material used i n i t s c o n s t r u c t i o n , or the manner i n which the material i s used, i t can impose a s u b s t a n t i a l d i s i n c e n t i v e to i t s use by i n c r e a s i n g the insurance premiums on the b u i l d i n g . Such an occurrence has taken place with the Insurance Services O f f i c e (ISO) i n the preparation of t h e i r Commercial F i r e Rating S c h e d u l e ' ! ) . They have reached a c o n c l u s i o n i n t h e i r r a t i n g f a c t o r s for foamed p l a s t i c s which simply does not c o r r e l a t e with the f a c t s . In t h e i r judgment, l e s s property damage i s l i k e l y to occur using exposed 25 flame spread foam (30 percent increase i n r a t i n g f a c t o r ) than with a 75 flame spread foam i n s t a l l e d behind a 15 minute thermal b a r r i e r (50 percent increase in r a t i n g f a c t o r ) . It i s most d i f f i c u l t to understand how they reached t h i s conclusion. C e r t a i n l y the Federal Trade Commission, the code w r i t i n g o r g a n i z a t i o n s , and the foamed p l a s t i c s industry would disagree. In my experience, a low flame-spread r a t i n g for a r i g i d polyurethane foam when l e f t exposed does not produce a lower l e v e l of l i f e safety hazard or expected damage l e v e l than



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t h a t which can be expected from a product with a somewhat higher flame spread r a t i n g but i n s t a l l e d behind an i g n i t i o n - i n h i b i t i n g thermal b a r r i e r . F o r t u n a t e l y , most people w i l l follow the b u i l d i n g codes and w i l l i n s t a l l an i g n i t i o n b a r r i e r over the foamed p l a s t i c . T h i s r a t i n g schedule does not, i n my judgment, f a i r l y evaluate the d i f f e r e n c e s i n performance between products with d i f f e r e n t flame spreads. These d i f f e r e n c e s are much smaller than the r a t i n g schedule would have you b e l i e v e . Secondly, t h i s r a t i n g schedule p e n a l i z e s foamed p l a s t i c i n s u l a t i o n covered with a thermal b a r r i e r d i s p r o p o r t i o n a t e l y to other types o f i n s u l a tions. I continue to receive c a l l s from our f i e l d s a l e s represent a t i v e s i n which t h e i r customers have run afoul of ISO. In several recent c o n t a c t s , the insurance r a t e r i n s i s t e d on 25 flame spread foam i n a roof i n s p i t e of the f a c t that the foam we proposed to o f f e r i s c l a s s i f i e d by the Underwriters L a b o r a t o r i e s as a component i n a Class A b u i l t - u p roof covering and the 25 flame spread rated foam chosen has not been rated i n r o o f i n g . The extra c o s t for a 25 flame spread rated foam often causes the buyer to think twice and reconsider the use of a polyurethane foam. The requirement for a 25 flame spread foam i n r o o f i n g seems p a r t i c u l a r l y i n a p p r o p r i a t e since unregulated a s p h a l t , t a r , and roofing f e l t s would be permitted and at no penalty whatsoever. The ISO r a t i n g schedule i s used mostly by the insurance companies who w r i t e p o l i c i e s on small i n d u s t r i a l b u i l d i n g s . Large f a c t o r i e s are insured by o r g a n i z a t i o n s such as Factory Mutual, and homes are insured by companies who, to t h i s p o i n t , d o n ' t care what type of i n s u l a t i o n i s used i n the c o n s t r u c t i o n of the house. If o r g a n i z a t i o n s , such as the Society of the P l a s t i c s Industry, and the i n d i v i d u a l members of the foamed p l a s t i c s i n d u s t r y can persuade ISO to examine t h e i r l o s s record more c r i t i c a l l y , I feel confident t h a t a f a i r e r r a t i n g schedule w i l l be forthcoming. When t h i s takes p l a c e , increased s a l e s of r i g i d polyurethane foams should r e s u l t . R-Value Representations As noted p r e v i o u s l y , thermal i n s u l a t i o n m a t e r i a l s are s o l d on the b a s i s of R - v a l u e s . The higher the R - v a l u e , the b e t t e r the insulation. Regulations to insure that accurate representations are made about the e f f i c i e n c y of thermal i n s u l a t i o n m a t e r i a l s are appearing i n many places around the country. Such a r e g u l a t i o n i s i n e f f e c t i n the s t a t e of Ohio The Federal Trade Commission has promulgated such a r u l e to be i n e f f e c t nationwide. However, congressional a c t i o n prevented the implementation of t h i s r e g u l a t i o n from l a s t August u n t i l t h i s June. The state o f C a l i f o r n i a also has adopted a s i m i l a r r u l e , but i t was enjoined by a C a l i f o r n i a c o u r t a c t i o n . The p r i n c i p a l motivation for these



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r e g u l a t i o n s i s to see that the consumer has accurate information upon which to make a d e c i s i o n when he s e l e c t s i n s u l a t i o n for h i s home. One of the key features of each of these regulatory a c t i o n s i s that a l l statements about the thermal r e s i s t a n c e of a product (R-value) must be backed up with s u b s t a n t i a t i n g t e s t data. In each case, where a r e g u l a t i o n has been challenged i n c o u r t , the matter of the s u b s t a n t i a t i n g t e s t data i s at i s s u e . As example, a r i g i d polyurethane i n s u l a t i o n manufacturer may not make the statement t h a t 5-1/2 inches of h i s product has an R-value o f 34 unless he has t e s t e d samples 5-1/2 inches t h i c k and the product, indeed, had an R-value of 34. That sounds f a i r enough. But, t e s t instruments that w i l l accomodate samples o f t h i s thickness are extremely s c a r c e . R i g i d polyurethane foams are q u i t e e f f i c i e n t i n s u l a t o r s , so great thickness i s not required to achieve l a r g e R-values. In the case of the l e s s e f f i c i e n t i n s u l a t i o n m a t e r i a l s , R-value of 34 can be achieved only with thicknesses far greater than can be accomodated by any t e s t instrument. Therein l i e s the b a t t l e . The FTC trade r e g u l a t i o n r u l e w i l l now go i n t o e f f e c t September 29, 1980 except f u l l thickness t e s t i n g w i l l not be required. When the National Bureau of Standards has thick c a l i b r a t i o n standards a v a i l a b l e , the FTC expects to implement the f u l l thickness t e s t i n g requirement of the trade r e g u l a t i o n r u l e . The new NBS reference standards should be a v a i l a b l e January 1, 1981. S i m i l a r l y , a f t e r a one-year delay, the C a l i f o r n i a Energy Commission i s moving ahead to put t h e i r i n s u l a t i o n standards i n t o effect. A d d i t i o n a l hearings were conducted Wednesday, August 27, 1980. The l i t i g a t i o n , which was the cause of the suspension, has been terminated. R i g i d polyurethane foams have a s p e c i a l problem when i t comes to making a f a i r statement about t h e i r R - v a l u e s . Essent i a l l y , a l l of these products are expanded with c h l o r o f l u o r o carbon 11 (CFC-11), which i s t r i c h l o r o f l u o r o m e t h a n e . At the time of formation, a l l of these m a t e r i a l s have e s s e n t i a l l y the same R-value of about 7.5 to 8.0 per inch of t h i c k n e s s . At one time, t h a t i s how these products were marketed. The i n i t i a l thermal r e s i s t a n c e , however, changes with time. Where the foamed p l a s t i c i s exposed to a i r , the a i r migrates i n t o the c e l l s , d i l u t i n g the chlorofluorocarbon gas. The thermal r e s i s t a n c e decreases when t h i s takes p l a c e . T h i s i s a slow process and may go on for years. To the extent that the foam i s sandwiched between a i r impervious s k i n s , the process i s a l l but h a l t e d . Recall that the b u i l d i n g codes do not permit foamed p l a s t i c s to be l e f t exposed i n any c o n s t r u c t i o n a p p l i c a t i o n . Hence, there are always facings i n c l o s e proximity to the foamed i n s u l a t i o n . To the extent t h a t the facings are impermeable and are t i g h t l y attached, a i r i n t r u s i o n i s h a l t e d . On the other hand, some surfacing m a t e r i a l s , such as asphalt and asphalt-impregnated f e l t s which might be placed over the foam i n a r o o f i n g a p p l i c a t i o n , are semipermeable and a i r can enter i n t o the foam.



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In other i n s t a l l a t i o n s , there might be a gap between the foam and the required thermal b a r r i e r , thus p e r m i t t i n g a i r i n t r u s i o n . The phenomenon of decreasing R-value has presented the industry with a dilemma. What i s the proper statement to make about the thermal r e s i s t a n c e of one's r i g i d polyurethane foam i n s u l a t i o n ? The lower the R-value statement you make, the l e s s competitive your product w i l l be. In the p a s t , i t has been d i f f i c u l t to a d v e r t i s e the aged R-values when your competition a d v e r t i s e s only the i n i t i a l R - v a l u e s . A l l regulatory bodies are i n agreement. You cannot represent your product based upon i t s i n i t i a l performance. Representative samples of the product must be aged p r i o r to testing. There i s s u b s t a n t i a l unanimity as to the aging conditions. Chiorof 1 uorocarbon-expanded foams must be aged e i t h e r 90 days a t 140°F or two years at room temperature before testing. Promotional statements may only be made based upon the r e s u l t s of such t e s t i n g . When these r u l e s are enforced, t h a t w i l l end t h i s debate. What e f f e c t the r e p o r t i n g of lower R-values for r i g i d p o l y urethane foams w i l l have i s not c l e a r . The values w i l l s t i l l be b e t t e r than f o r any other type of i n s u l a t i o n . One would have to presume that these products would look l e s s a t t r a c t i v e and, t h e r e f o r e , sales might s u f f e r . However, other i n s u l a t i o n m a t e r i a l s w i l l a l s o be impacted by these r e g u l a t i o n s . Loose f i l l m a t e r i a l s s e t t l e , and may al so look l e s s a t t r a c t i v e . The r e g u l a t o r y agencies have taken note of t h i s and require t h a t t e s t s be performed on these m a t e r i a l s i n the s e t t l e d c o n d i t i o n . R i g i d polyurethane foams, of course, do not s e t t l e . To the extent that urea-formaldehyde foams shrink c r e a t i n g v o i d s , they, too, w i l l be r e q u i r e d to a d v e r t i s e what r e a l l y happens to the thermal r e s i s t a n c e of t h e i r products. R i g i d polyurethane foams do not shrink i n t h i s manner. Some types of i n s u l a t i o n m a t e r i a l s do not give 1inear increases i n thermal r e s i s t a n c e with i n c r e a s i n g t h i c k n e s s . T h i s t o o , must be a c c u r a t e l y reported according to the r e g u l a t i o n s . R i g i d polyurethane foams, on the other hand, improve i n performance above a s t r a i g h t 1ine relationship. I t i s my b e l i e f that t h i s r e f l e c t s the e f f e c t of fewer torn and broken c e l l s i n t h i c k e r foams. In the t h i n n e r c r o s s s e c t i o n s , the torn and broken c e l l s allow greater amounts of the chlorofluorocarbon blowing agent to escape and the optimum thermal r e s i s t a n c e i s not r e a l i z e d . It i s d i f f i c u l t to p r o j e c t , at t h i s p o i n t , how a l l of these changes i n the r e p o r t i n g of product R-values w i l l u l t i m a t e l y a f f e c t polyurethane foam s a l e s . I do not expect any big surprises. I expect only small s h i f t s i n market p o s i t i o n . It should be expected that those products sold with air-impermeable faces attached w i l l show the strongest sales performance.


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EPA vs. Chlorofluorocarbon Blown Foams To this date, the Environmental Protection Agency (EPA) has restricted the use of chl orof1uorocarbons (CFCs) only when used as aerosol propel!ants, and not when used as blowing agents as they are in the manufacture of foamed plastics. I am sure you are all aware that the EPA intends to expand its regulations on the uses of chlorofluorocarbons. At this point, it appears that this agency will act to limit the manufacture and sale of CFCs to that of the year 1979 and no more. The EPA is also considering reducing this maximum in future years. The effect of this action could be quite severe. Market forces will, no doubt, drive up the price people are wi 11ing to pay for CFCs. Hopefully, other materials will become available to replace CFCs in many applications. There are apparently alternatives to CFCs in some products, such as flexible polyurethane foams. Vapor degreasing operations may also find acceptable alternate materials. Certainly, with a fixed or diminishing supply of CFCs, those material s which are most cost effective will best be able to afford the increased cost. In mechanical refrigeration uses of CFCs, where the refrigerant is vital and adds but a small amount of the cost of the total product, i t is hard to conceive of a price which is prohibitive. In rigid polyurethane foams, the impact of a price increase in CFCs will be more strongly felt. CFCs constitute a significant portion of the total product (12-18 percent). In those applications where the rigid polyurethane foam is no longer cost effective, a switch to other insulation materials will surely take place. Such an application might be where the difference in performance of a CFC-expanded polyurethane and some competitive types of insulation is small. There are other applications where rigid polyurethane foams are most cost effective and a price increase in the CFC component of the foam will have l i t t l e , i f any, impact. An example of such an application might be where the rigid polyurethane foam permits a savings of space and/or weight due to its combination of thermal and structural properties. The differences in thermal performance between CFC expanded rigid polyurethane foams and other types of insulation materials are greatest where impermeable facings are applied over the foam. Summary There are other regulatory agencies whose actions have had some effect on the cost of making polyurethane foams. OSHA, for example, has established an upper limit of 0.02 ppm of isocyanate vapors in the atmosphere that workers breathe. This limit has been in existence for several years and is not expected to change in the future. With the current raw materials in use today, this threshold limit is easily met with simple ventilation equipment. You will note that three of the regulatory activities discussed here are directed toward construction applications — the building codes, insurance ratings, and insulation efficiency In Urethane Chemistry and Applications; Edwards, K., et al.; ACS Symposium Series; American Chemical Society: Washington, DC, 1981.


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statements. There is also a substantial market outside of the construction industry. This market is not impacted by these three regulatory activities, but will be impacted by a limitation on the amount of chlorofluorocarbons that may be produced. It is typified by the transportation insulation market - - e.g., trucks, trailers, and railroad cars. In these applications, the rigid polyurethane foam is valued not only as an insulation material but also as a structural component. Glass fiber insulation and loose f i l l insulation lose some of their insulation efficiency due to settling and compaction that occurs from the continual bumping and pounding of the road. Rigid polyurethane foams are not affected in this way. Rigid polyurethane foams are particularly valued in this way of application since the amount of space which must be devoted to insulation can be reduced. The exterior dimensions of these vehicles are fixed by statute and, therefore, thinner insulation permits a greater interior productive capacity. However, this market is much smaller than the construction market, and polyurethane foams have fairly well saturated this market. The greatest potential for future growth lies in the sales of rigid polyurethane foams into the construction market. It is my strong belief that as building officials cane to understand foamed plastics better, and as the manufacturers of foamed plastics come to understand the building codes, the codes will become less and less of a hinderance to the sale of rigid polyurethane foams. I would expect a similar scenario with insurance rates. I am less optimistic about the effect of EPA's proposal to reduce the amount of chlorofluorocarbons available. Our product is already relatively high priced. Further increases in price will, no doubt, have a significant effect on some segments of sales. Where rigid polyurethane foams can be sold as the insulation material with a plus, the future is bright. Where rigid polyurethane foams must compete only as straight insulation, the future is more uncertain. What does the future hold? For the innovative and those who learn to live with the regulations, sales should be good. I believe it will be worth the effort. Literature Cited 1. Urethane '79 - The Americas, B-7366, The Upjohn Company, Polymer Chemicals Division, 1979. 2. "Energy Performance Standards for New Buildings," Federal Register, Department of Energy, November 28, 1979. 3. "Energy Conservation Standards for New Residential and Non-Residential Buildings," California Energy Commission 127B:01, December 6, 1978. 4. Uniform Building Code, 1979 Edition, International Conference of Building Officials. 5. Basic Building Codes, 1978 Edition, Building Officials and Code Administrators (BOCA). In Urethane Chemistry and Applications; Edwards, K., et al.; ACS Symposium Series; American Chemical Society: Washington, DC, 1981.


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6. Standard Building Code, 1979 Edition, Southern Building Code Congress International, Inc. 7. "Commercial Fire Rating Schedule", Insurance Service Office, April, 1978. 8. Ohio Insulation Rule, Substantive Rule 109:4-3-14, effective December 7, 1978. RECEIVED

June 1, 1981.


The Effects of Regulatory Actions on the Marketing of Rigid

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