Over a year ago, Kilo Villager Clayton Meier wrote a blog post on Foamed Plastics and Factory Assembled panels where he starts off the article stating:
As our communities and governments recognize the benefits of energy efficiency in construction, the use of foamed plastic insulating materials has also increased. The use of foamed plastic in buildings is considered to be acceptable, provided the foamed plastic is protected in a way that limits risk to occupants and buildings. Foamed plastic materials are permitted in all buildings and all occupancies, even high buildings that fall within the scope of Subsection 3.2.6. and buildings required to be of noncombustible construction in conformance with Subsection 3.1.5.
His post deals specifically with factory assembled panels, but that is not the only Code provision for foamed plastic insulation that is extremely confusing, and requires additional discussion and clarification.
I’ve recently been asking myself. Does all foamed plastic insulation need to be tested to CAN/ULC S102 and have an flame spread-rating (FSR) of not more than 500?
My gut and heart say yes, but my analytical rabbit hole brain is not quite sure. And in discussions with various colleagues on this question specifically…I’m not sure anyone is sure.
Feel free to follow my thought process below, and add your two cents into the comments. I’m very intrigued in what conclusion others have come to.
- Subsection 3.1.4. applies to all building. If the building is required to be of noncombustible construction, then Subsection 3.1.5. needs to be applied as well, but you still need to consider 3.1.4. There are mixed feelings on this one, but it does not make sense to me for 3.1.4. to be more restrictive than 3.1.5.
- Sentence 3.1.4.1.(2) has requirements for foamed plastic anywhere in any building of combustible construction. This means that any foamed plastic requires a FSR of not more than 500 on any exposed surface, or any surface exposed when cutting through it.
- Articles 3.1.4.2. and 3.1.5.15. are requirements for how that foamed plastic is protected, after we have confirmed that it is allowed in the building (CAN/ULC S102 – FSR 500)
- Sentence 3.1.5.15.(1) confuses people as it says it is allowed in certain locations in noncombustible buildings (above roof decks, outside foundation walls below ground level, and beneath concrete slabs on ground), but not what the requirements for the insulation are.
The dilemma I’ve run into is foamed plastic insulation above a roof deck in a noncombustible building. It is interpreted by a product manufacturer that since the foamed plastic insulation is above the roof deck, testing to CAN/ULC S102 is not required for their product. If it was a combustible building, it would seem as though testing is required per 3.1.4.1.(2).
Perhaps I’ve talked myself in circles and thought too much about this one…or perhaps there are Code inconsistencies that are creating great confusion. I see two outcomes:
- Best case scenario, 3.1.5.15. can be read as though testing is not required above a roof deck and wording in 3.1.4.1.(2). has not been updated appropriately. This would imply that the risk was considered and it not an issue.
- Worst case scenario, all foamed plastic insulation used in the construction of a building should be tested to CAN/ULC S102…and we now have a bunch of non-compliant buildings scattered across the county because many products are being installed that have not been tested.
To me, a simple solution would be for a clarification to be provided by NRC and product manufacturers be required to have training on the Code requirements that are applicable to their product.
Too many times I’ve spoken to product manufacturers or sales representatives who don’t have a clue about what Code requirements are to be considered for their product, based on the application and location, and in what type of building (occupancy and construction type). I’m extremely not okay with the status quo of them not providing correct information.
What do you think? What ideas to you have to make the confusion more clear?
2 Responses
Foamed insulation is such a can of gummy worms.
Whether it is lumberyards passing off froth packs as an approved insulating material, or fly-by-night contractors a decade ago installing sprayfoam as a retrofit insulation or roof cladding, resulting years later in expensive repairs or even major fire losses, the use of spray foam is hard to get ahead of.
I agree 100% with your frustration and call for better regulations.
IMHO the regulations are quite clear. Recent changes to the 2018 BC Building Code have clarified semantics which has improved both interpretation and application of Subsection 3.1.4 and 3.1.5. Not completely, but greatly improved upon. Further, Subsection 3.1.4 does NOT apply to all buildings as stated in the above blog post. Only the construction requirements set out in 3.2.2. determine when a building is permitted to be of Combustible construction or a combination of Combustible or Non-combustible construction types. Thus, Subsection 3.1.5 applies to buildings requiring to be Non-combustible construction with some exceptions for combustible components. Spray-foam is one of these. If one reads the regulations with the above in mind, one should arrive at some different conclusions for requirements. Perhaps, the BCBC has some variations that other provinces yet to adopt or should consider adopting for clarity.