MBS

PubSications

1-2213

A111Q5 ^ Technical Support for the

Consumer Product Safety

Commission 1979 Interim

Standards for Cellulose Insulation

David D. Evans

Sanford Davis

Center for Fire Research

National Engineering Laboratory

U.S. Department of Commerce

National Bureau of Standards

Washington, DC 20234

March 1981

Final Report

Prepared for: Consumer Product Safety Commission

"i le and Mechanical Engineering Group

' esda, Maryland 20202

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81-2213

1981

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*TECHNICAL SUPPORT FOR THE

CONSUMER PRODUCT SAFETY

COMMISSION 1979 INTERIM

STANDARDS FOR CELLULOSE INSULATION

MAY 1

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David D. Evans

Sanford Davis

Center for Fire Research

National Engineering Laboratory

U.S. Department of Commerce

National Bureau of Standards

Washington, DC 20234

March 1981

Final Report

Prepared for: Consumer Product Safety Commission

Textile and Mechanical Engineering Group

Bethesda, Maryland 20202

8 1981

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U.S. DEPARTMENT OF COMMERCE, Malcolm Baldrige, Secretary

NATIONAL BUREAU OF STANDARDS. Ernest Ambler. Director
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TABLE OF CONTENTS

Page

LIST OF FIGURES iv

LIST OF TABLES v

Abstract 1

1. INTRODUCTION 2

2. ATTIC FLOOR RADIANT PANEL TEST 3

2.1 Development of a Low Flux Profile 4

2.2 Effect of Specimen Density on AFRPT Results 6

2.3 Variations of Critical Radiant Flux with Preheat Time . 8

3. FLAME SPREAD TESTS ON CELLULOSIC INSULATION IN A LARGE-SCALE

ATTIC 9

4. SMOLDERING COMBUSTION TEST 12

4.1 Effect of Test Area Humidity on the Smoldering Combustion

Test 12

5. CONCLUSIONS 19

6. REFERENCES 20

APPENDIX 1. TECHNICAL RATIONALE FOR THE GENERAL SERVICES

ADMINISTRATION FEDERAL SPECIFICATIONS HH-I-515D

FLAME RESISTANCE PROVISIONS; DECEMBER 1, 1978 ... 38

iii
LIST OF FIGURES

Page

Figure 1. Regular and low flux profiles 21

Figure 2. Specimen flux profiles, with lowered specimen surface 22

Figure 3. Variation of critical radiant flux with preheat time,

material B 23

Figure 4. Variation of critical radiant flux with preheat time,

material E 24

Figure 5. Variation of critical radiant flux with preheat time,

material G 25

Figure 6. Large-scale attic 26

Figure 7. Cigarette smoldering test results under various

humidity conditions 27
LIST OF TABLES

Page

Table 1. AFRPT test results 28

Table 2. Effect of density on critical radiant flux, material G 29

Table 3. Effect of density on critical radiant flux, material E 29

Table 4. Critical radiant flux values 30

Table 5. Traverse of air temperature from the roof peak .... 31

Table 6. Total heat flux 10 cm above insulated joist spaces at

test conditions 32

Table 7. Flammability characteristics of test materials .... 33

Table 8. Large-scale attic test results 34

Table 9. Blown and settled density values for the test

insulations . 35

Table 10. Smoldering test data percent weight loss 36

Table 11. Predicted change in specific humidity to produce a significant change in the test results at 21°C, 52% RH 37

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TECHNICAL SUPPORT FOR THE CONSUMER PRODUCT SAFETY

COMMISSION 1979 INTERIM STANDARDS FOR CELLULOSE INSULATION

David D. Evans and Sanford Davis

Abstract

The attic floor radiant panel test (AFRPT) and

smoldering combustion test are two fire performance

tests required by the Consumer Product Safety

Commission (CPSC) as part of a mandatory standard

for loose fill cellulosic home insulation. In

providing technical support to CPSC, the sensitivity

to variations in parameters of each test method were

studied. Specimen density was found to have no effect on critical radiant flux values when measured

with the AFRPT for two paper-based cellulosic insulations tested at densities below 48 kg/m3. A low

2 flux exposure profile, ranging from 0.04 to 0.35 W/cm , was developed to extend the range of the AFRPT about

the region of greatest interest. The critical radiant

flux measured using the low flux profile was found

to be sensitive to changes in preheat time from the

prescribed two minute specimen preheat. Large scale

attic fire tests verified the predictive ability of

AFRPT measurements. Results from the smoldering

combustion test were shown to be sensitive to test

room humidity conditions over the range of 39 to 84% RH.

Key words: Attic floor radiant panel test; cellulose

insulation; smoldering; fire test; flame spread;

HH-I-515D.

1
1. INTRODUCTION

The Emergency Interim Consumer Product Safety Standard Act of 1978

(PL 95-319) [1]* required the Consumer Product Safety Commission (CPSC)

to enforce the corrosiveness and flame resistance requirements of the

General Services Administration (GSA) specification HH-I-515C [2] for

loose-fill celluloslc insulation, and to publish all subsequent related

amendments which GSA may publish. On June 15, 1978, GSA published an amendment to the specifications for celluloslc insulation and designated

it HH-I-515D [3]. This amendment contains two test methods developed by

the Center for Fire Research (CFR) at the National Bureau of Standards

(NBS) - the attic floor radiant panel test (AFRPT) and the smoldering

combustion test. Testing loose-fill celluloslc insulation in the AFRPT

was proposed to assure that the material had a specified resistance to

surface flame spread. The smoldering combustion test was also specified

to assure that insulation materials had some resistance to ignition by a smoldering source.

The CPSC insulation standard is based on fire performance test

methods developed previously for the General Services Administration

(GSA). The technical rationale for fire performance sections of the GSA

celluloslc insulation standard (HH-I-515D) were detailed in an unpublished

paper by S. Davis. For completeness of the documentation of NBS efforts

concerned with the development of the CPSC Insulation standard, S. Davis'

discussion of the technical rationale for the GSA standard is Included

as Appendix 1 to this report.

Before a final version of a mandatory standard based on HH-I-515D

could be Issued by CPSC, public comments were solicited. To aid CPSC in

responding to the comments, NBS prepared suitable responses to technical

questions about the standard; these responses were based on knowledge

about the test methods at the time of publication. Experimental work was

* The numbers in brackets refer to the references listed in section 6 of

the report.

2
necessary in some cases to gather adequate information to respond to

comments on the proposed AFRPT and smoldering combustion test methods.

In particular, round robin testing was conducted with the cooperation of

several Independent testing laboratories to determine the repeatability

and reproducibility of the two test methods by testing selected loosefill Insulation materials. Round robin testing was coordinated by NBS

on both the AFRPT and smoldering combustion test of HH-I-515D [7] specifications, the ASTM E 84-77a tunnel test of the HH-I-515C specifications

[8], and a new method to determine the settled density of loose-fill

insulation materials, the cyclone-shaker test [9],

Additional effort was directed towards modification of the measuring

range of the AFRPT and verifying that the measurements were meaningful

by testing materials in a simulated attic fire situation. The effects

of variations in specimen density and preheat time on AFRPT results were

investigated. The sensitivity of the smoldering combustion test method

to changes in test room humidity conditions was also explored.

This report serves to document the various activities conducted by

the NBS Center for Fire Research in technical support of CPSC’s interim

standards for cellulose Insulation,

2. ATTIC FLOOR RADIANT PANEL TEST

The Standard Method of Test for Critical Radiant Flux of Floor

Covering Systems using a Radiant Energy Source (NFPA 253, ASTM E 648)

was developed for evaluating flooring systems in corridors exposed to

radiation from fully developed fires in rooms. The range of critical

2 radiant flux measurable in this test included values down to 0,11 W/cm

that were appropriate for simulation of the potential total heat flux to an insulated attic floor from the heated attic air, the underside roof

surface, and the presence of a small ignition source. A new specimen

tray was developed to hold cellulosic loose-fill insulation and to

replace the standard specimen holder in the flooring radiant panel

apparatus (NFPA 253)

.

With the new specimen holder suitable for holding

3
loose-fill insulation, the apparatus became known as the attic floor

radiant panel. The minimum level of critical radiant flux for safe use

of insulation materials in the attic space was established as 0,12

2

W/ cm (Appendix 1) . Additional background on the development of the

test method is given in the Technical Rationale for the GSA Federal

Specification HH-I-515D Flame Resistance Provision included in this

report as Appendix 1.

2.1 Development of a Low Flux Profile

The CPSC interim standard for cellulosic insulation [6] requires

that cellulosic insulation materials have a critical radiant flux equal

2

to or greater than 0.12 W/cm as measured by the attic floor radiant

panel test (AFRPT) . For the flux profile specified in the standard, the

2 AFRPT can measure critical radiant flux values from 0.1 to 1.1 W/cm . 2 Since the pass-fail level of 0.12 W/cm is near the low end of that

range, the gas flow rate to the radiant panel was reduced to obtain a new heat flux distribution at the test specimen surface spanning the

2

range from 0.04 to 0,35 W/cm . For this "low flux" profile, the pass2 fail level of 0.12 W/cm occurs mid-length along the 100 cm test specimen.

The regular and low flux profiles are shown in figure 1,

Eight cellulosic insulation materials were selected to compare the

low flux profile to the standard (regular) flux profile. These eight

materials are identical to those used by Lawson in the study of the ASTM

E 84-77a Tunnel Test Method as modified for testing of loose-fill

cellulosic Insulation [7]. Materials D and F were untreated paper-based

material. The remaining materials were commercial paper-based materials,

except that H was cotton-based. All paper-based materials were tested

3

at a density of 40 kg/m . The cotton-based material was tested at 24

3 kg/m . Three replicates were run for each material under both conditions.

Critical radiant flux values, averages, and repeatability coefficients

of variation are listed in table 1.

4
In table 1 repeatability coefficients of variation (COV) values

for materials B, C, E, and G are listed for both flux profiles. The

repeatability COV as defined in table 1 is a measure of the withinlaboratory variability of test results. Averaging the COV values for

these four materials yields essentially equal values of 10.1% and 10,0%

for the regular and low flux profiles, respectively. This compares with

an average COV value of 11.7% based on the extensive testing in [8], and

suggests that this is the practical limit for materials of this type.

Four the eight materials tested, could not be compared directly at

both profiles. For the four materials that could be compared, the

differences in average critical radiant flux were 0.01, 0.02, 0.02, and

0.

04 W/cm for materials B, C, G, and E respectively. For three of

these four materials, there was no significant statistical difference in

the averages, using the two heat flux profiles, at the 95% confidence

level. But for material E, variations of test values below the 0,12

2 W/cm critical radiant flux value would cause this material to be judged

a failure in the low flux test while passing the regular flux test. For

2 material G, the critical radiant flux of 0,14 W/cm measured in the low

2 flux test was "statistically different" from the value of 0,16 W/cm

measured under the regular flux profile, because of the very low coefficient of variation for this material in the test.

An alternate method of obtaining a low flux profile was considered;

1.

e., by lowering the surface of the specimen while maintaining the

radiant source at the same intensity as used in the regular flux test.

No practical testing configuration of this type was found. To obtain a

2 heat flux of 0.12 W/ cm near the mid-length of the test specimen, its

surface must be lowered approximately 60 cm. This is Impractical since

it would necessitate a total reconstruction of the apparatus frame.

Figure 2 shows the flux distributions obtained at the surface of the

test specimen lowered from the normal position both 47.5 cm and 63.5 cm

respectively.

5
For most cellulosic Insulation materials, no significant change in

critical radiant flux rating is expected if tested using the low flux

profile.

2.2 Effect of Specimen Density on AFRPT Results

The effect of density on Attic Floor Radiant Panel test (AFRPT)

results was studied to support the CPSC responses to public comment on

the proposed amendment to the interim cellulose insulation standard.

Justification for testing insulation at the density obtained by blowing

("blown density") as specified in the standard was also sought. It was

found that variations in sample density can affect AFRPT results. This

2 2

was demonstrated using both the regular (0.1 W/cm to 1,1 W/cm ) and low

2 2

(0.04 W/cm to 0.35 W/cm ) flux profiles. For the two paper-based

Insulations (F and G) , critical radiant flux values were significantly

greater at specimen densities above 48 kg/m (3 Ibs/ft ) than below. No

significant variations in critical radiant flux values were found for

3 the materials tested at densities below 48 kg/m . The blown density is

recommended for testing cellulosic insulation materials in the AFRPT

because it is on the conservative side from the standpoint of fire risk.

Cellulosic insulation G was evaluated in the AFRPT using a two

minute preheat and the low flux profile at hand loaded densities of 24,

3 3

40, and 64 kg/m (1.5, 2.5, and 4.0 Ibs/ft ). To simulate installation

conditions, the material was first blown from a commercial blower before

hand packing into the specimen holders to the desired test density. A

3 settled density for this material of 42.3 kg/m was measured by the CPSC

laboratory using the Department of Energy (DOE) cyclone-shaker test

method [9]. Table 2 contains the data from triplicate evaluations of

the material at each of the three densities. At the lower densities, 24

3 2 and 40 kg/m , the critical radiant flux was 0.15 W/cm . At the higher

3 64 kg/m density, flames did not propagate as far down the samples. The

2 material was rated at a significantly higher 0.26 W/cm .

6
Cellulosic insulation E was evaluated in the AFRPT using a two

minute preheat and the regular flux profile at densities of 32, 48 and

3 3

64 kg/m (2.0, 3.0, 4.0 Ibs/ft ). The settled density for this material

3 of 46.8 kg/m was measured by the CPSC laboratory using the DOE cycloneshaker method. Table 3 contains the data from the triplicate evaluations

of the material at each of the three densities. At the lowest density

3

(32 kg/m ), the material had an average critical radiant (CRF) flux of

2 3

0.12 W/cm , At the middle density (48 kg/m ), the CRF was higher, but

2

not significantly different, with an average value of 0.14 W/cm . At

3 the highest (64 kg/m ) density, a significant change in average radiant

2 flux to 0.23 W/cm was recorded.

3 3

At densities below 48 kg/m (3 Ibs/ft ), no significant differences

in critical radiant flux were found for the two paper-based cellulosic

3 insulation materials. Above 48 kg/m , significantly higher CRF values

have been demonstrated in both the regular and low flux profile tests.

In other testing, AFRPT results for a cotton-based insulation material

3 have been shown to be sensitive to density variations below 48 kg/m . Therefore, extension of the conclusions of this report to non-paper

based cellulose Insulations cannot be justified.

The Consumer Product Safety Commission Interim Standard for Cellulose

Insulation [6] requires that the AFRPT be conducted with specimens

loaded by blowing the insulation into the tray using the blower/eye lone

apparatus. Suggestions have been made to perform the test at the settled

density. For both materials evaluated in this study, the settled density

3

was close to, but below, 48 kg/m . Based on the test results, no significant difference in critical radiant flux value would be expected for

these small density differences. However, because the critical radiant

flux values for the materials tested increased at higher specimen

densities, the density as blown should be maintained as the specified

specimen density for the AFRPT as the material CRF will be on the con- servative side from the standpoint of fire risk.

7
2.3 Variation of Critical Radiant Flux with Preheat Time

The sensitivity of measurements of the critical radiant flux for

insulation materials to changes in preheat time was examined. The CPSC

Interim Safety Standard for Cellulose Insulation [6] currently specifies

a two-minute preheat for the specimen before ignition. The sensitivity

of critical radiant flux to changes in preheat time is of interest to

support the + 5 second tolerances on the two-minute value specified in

the standard.

Three cellulosic insulation materials, identified as materials B,

E, and G by Lawson [7], were used in this study. All critical radiant

flux (CRF) values were determined using the low flux profile (0.040.35

2 W/cm ). The materials were evaluated at 0, 1, 3, 6, 9 and 20 minute

preheat times. Values at 2 minutes preheat were available from previous

3 testing. All materials were evaluated at 40 kg/m density.

The low flux profile was chosen for use in this study to provide

better resolution at low critical radiant flux values. The low flux

profile also eliminates the erratic behavior observed for some materials

that may char excessively and fail to ignite using the regular flux

profile with preheat times greater than five minutes.

Figures 3, 4, and 5 are graphic presentations of the data obtained.

These data are also tabulated in table 4. For each material the critical

radiant flux decreased with increasing preheat time. The three materials

2

were rated above 0.12 W/ cm CRF with short preheat times and below with

long preheat times. The critical radiant flux for a material appeared

to be relatively insensitive to changes in preheat time for preheat

times greater than ten minutes. Critical radiant flux values were

sensitive to changes in preheat time in the range of the standard twominute preheat. The rate of change of CRF values with respect to

changing preheat time at two-minutes preheat was approximately 0.015

2 W/cm per minute.

8
The test results in the AFRPT using the low flux profile have been

shown to be sensitive to preheat time variations. It is expected that

test results using the regular flux profile would also be sensitive to

preheat time (and would also be more erratic because of specimen charring)

Therefore, the tolerance on the preheat time of + 5 seconds used in the

standard is justified to limit any effect on CRF to a negligible amount.

3. FLAME SPREAD TESTS ON CELLULOSIC INSULATION

IN A LARGE-SCALE ATTIC

A series of five large-scale attic fire tests were conducted to

demonstrate the applicability of the attic floor radiant panel test

(AFRPT) critical radiant flux ratings of cellulosic insulation to the

anticipated fire performance of the materials in end-use configurations.

The tests showed that materials with critical radiant flux values

greater than the surface heat flux generated in the simulated summer

attic conditions did not allow flame to propagate away from a small

torch ignition source.

The large attic mockup (2.84 m x 3.66 m base), used in previous

attic insulation tests as reported by Gross [10], was modified for these

tests. A nominal 14 cm deep duct was constructed to circulate hot air

over much of the exposed exterior peaked roof area. The attic space

could be heated up to 82°C by heat transferred from the hot surfaces of

the roof, simulating the type of heating that occurs in home attics.

Figure 6 shows a diagram of the large scale attic; key features are identified in the figure. As indicated, the attic was constructed in

two pieces: a base floor section and a removable peaked roof assembly.

The two pieces were mated for testing and separated for Installing and

removing insulation.

For testing, the middle three joist spaces, each 37 cm (nominal

14.5 in) wide, were filled with cellulosic insulation to the top of the

14 cm (nominal 6 in) deep joist for a distance of approximately 1.7

meters. Three small propane torch burners, mounted on a gas manifold

9
controllable from the exterior of the attic, were used as flaming ignition

sources for the tests. Flame spread was measured from the point of

ignition. As three joist spaces were filled with the same material and

each ignited separately, each attic test represented three trials for

the material tested.

For each test the insulation was blown through a commercial blower

into auxiliary containers. This blown insulation was loaded into the

joist space by hand and distributed uniformly to a pre-established

3 3 density of 44. 8 kg/m for the paper-based materials and 24 kg/m for

the cotton-based material.

Over a two to three hour period before testing, the attic assembly was preheated to temperatures near the test conditions. An attic air

temperature of 71°C was chosen for the conduct of the tests. This

temperature was measured in air over the center of the attic floor 0.69 m

below the peak in the roof. Stratification of the air within the attic

produced a considerable gradient in air temperatures with distance from

the peak in the roof. Typically, a drop in air temperature of 30 ®C was observed traversing the distance from the peak in the roof to the floor.

Table 5 contains the data from one vertical traverse made over the

center of the attic base.

The heat flux distribution over the area covered by the three joist

spaces was uniform to within 10%. Table 6 contains the data for total

heat flux measured 10 cm above the insulation surface. At test conditions

the nominal total heat flux near the surface of the insulation was 0.055

W/ cm^.

Four of the five materials tested were commercial materials. The

fifth material (S) was a special mixture that was a border-line failure

in the AFRPT with an average critical radiant flux of less than 0.11

2 W/cm . Table 7 lists the flammability characteristics for the cellulosic

insulation materials B, F, G, H, and S as determined in the AFRPT and

tunnel test.

10
In the large scale attic tests, none of the materials allowed flame

to spread a distance greater than 35 cm from the ignition source. None

of the materials allowed rapid or substantial flame propagation.

Table 8 summarizes the test results and conditions. Over a period

of two to three hours the attic was heated from laboratory conditions to

slightly over 70°C. Then the ignition burners were ignited, raising the

attic air temperature to between 75°C and 77°C at the time the burner

flames were applied to the insulation surface. Peak air temperatures

during the test were Influenced by the extent and rate of insulation

burning. Heat flux measured at the edge of the insulated joist spaces

2

(locations shown in figure 6) increased by a maximum of 0.01 W/cm

during the tests.

None of the insulation materials tested permitted surface flame

2 propagation under Initial total heat flux conditions of 0,055 W/cm . All materials tested in the attic had critical radiant flux values at or above 0.09 W/cm as determined in the AFRPT with low flux profile and

using the standard two minute preheat time. (As documented in the

previous section, critical radiant flux values are dependent on specimen

preheat time.) Based on the standard interpretation of AFRPT test

2 results, the measured 0.09 W/cm or greater critical radiant flux values

for the insulation material indicates that no flame spread would be

expected in the attic tests with initial flux of 0.055 W/cm regardless

of preheat time. As observed in these tests, no flame spread occurred

in the attic mockup.

The attic test conditions used in this study were representative of

a likely exposure in parts of the U.S. during the summer. The conditions

do not represent a worst case exposure. Larger ignition sources than

the torch flames could raise the air temperature in the attic and heat

flux to the floor to values above those found in these tests. Other

attic construction methods would also influence test conditions. Flame

spread over the exposed insulation surface would only be expected in

11
cases where the incident surface heat flux exceeds the critical radiant

flux of the insulation material as measured in the AFRPT.

4. SMOLDERING COMBUSTION TEST

A review of fire incident data by D. Gross [10] showed that the

most likely hazard associated with cellulosic insulation stems from

smoldering. The smoldering combustion test was introduced into the GSA

specification and the CPSC interim safety standard for cellulose insulation to assure that cellulosic insulation would have some resistance to

smoldering. In smoldering combustion test, a smoldering cigarette is

placed in a pan of insulation to serve as an Ignition source. The concern

is whether the smoldering, once started, will continue to propagate in

the cellulosic insulation. The test is Intended to simulate any localized

high temperature source (not limited only to a cigarette) , and to

determine if the smoldering will continue beyond the heated region.

The weight loss of the Insulation sample after testing is used to

determine the extent of smoldering. If a product does not exhibit any

smoldering tendency, a weight loss of less than 1 or 2 percent would be

expected. If the product is ignited by the smoldering cigarette, the

expected specimen weight loss would typically be in excess of 30 percent.

Because of the nature of the test results, a weight loss criterion of 15

percent was established as the maximum weight loss permitted for a material with acceptable smoldering resistance. Additional details of

the test backgrotind are given in the Technical Rationale for the General

Services Administration Federal Specification HH-I-515D Flame Resistance

Provision included in appendix 1.

4.1 Effect of Test Area Humidity on the

Smoldering Combustion Test

The temperature and humidity conditions for the smoldering test

defined in the CPSC Interim safety standard for cellulose insulation [6] are as follows:

12
1 . Condition the specimens at 21+3°C and 50+5 percent relative

humidity.

2. The test area shall be maintained at 21+3°C and 50+5 percent

relative humidity.

The temperature and humidity criteria in the test area were examined

to determine whether the specified limits are justified. Based on an experimental examination of the influence of the test area relative

humidity on specimen weight loss in the smoldering test, the allowable

humidity range of 45 to 55 percent is a justified restraint. In addition,

the experimental data indicated that a tolerance of + 2°C should be

specified for the 21°C test area temperature to assure that variations

in test area conditions do not significantly affect specimen weight

loss. Although not explicitly demonstrated in this testing, variations

in specimen weight loss due to changes in ambient humidity conditions

could influence the pass/fail rating of the material tested.

To study the effects of humidity on this test, a controlled

environmental chamber is needed. Since a commercial chamber of that

type was not available for this study, the humidity was controlled in a test module with a commercial humidifier-dehumidifier. Essentially,

this work was directed towards determining whether significant variations

in test results could be detected over a modest range of humidity conditions deviating from the recommended value.

The four cellulosic Insulation materials chosen for study were

selected from the group used in the smoldering test round robin conducted

by Lawson at NBS [7]. Using Lawson’s identification, the four cellulosic

insulation materials were C, E, F, and G. The round robin smoldering

tests conducted by NBS were performed at a specified density. For the

3 paper-based materials, E, F, and G, the specified density was 48 kg/m

3 (3.0 Ibs/ft ). For the less dense cotton-based material C, the specified

density was 24 kg/m^ (1.5 Ibs/ft^).

13
These smoldering tests were performed on material packed to the

settled density as specified in the CPSC interim safety standard for

cellulosic insulation [6], The settled density for each of the four

insulation materials was determined by the CPSC laboratory using the DOE

cyclone-shaker method. Settled density values for the four materials

are given in table 9.

Prior to testing, all the material was pre-conditioned in large

open bags for a minimum of 48 hours at 21°C and 50% relative humidity.

The samples were transported from the conditioning room in Building 225

to the Building 205 test facility in closed bags. The sample pans were

loaded and weighed outside the conditioned test room. The samples were

subjected to the smoldering test as quickly as possible after being

placed in the conditioned test room.

Different relative humidity levels were obtained in the conditioned

test room using a commercial home style humidlfier-dehumidifier. The

test room temperature, typically within + 2°C, was not controlled

separately; however, the Building 205 test facility, as a whole, is

temperature controlled. To obtain high and low values of humidity, it

was necessary to install a polyethylene vapor barrier over the interior

wall and celling surfaces of the room. The three conditions obtained in

the room for testing purposes were: 21“C, 84% RH; 21°C, 52% RH; and

24®C, 39% RH. Originally, it was proposed to examine an additional

humidity level between 50% RH and 84% RH. The data obtained in the set

of three measurements were sufficiently definitive to dispense with

additional tests.

Table 10 lists the test results for percent weight loss in the

smoldering test for each of the five specimens of four materials tested

under three conditions. Five specimens were chosen for the test because,

at the time this work was performed, some thought was being given to

changing the proposed standard test of three specimens to a test of five

specimens. (The CPSC Interim safety standard for cellulosic insulation

[6] specifies three specimens.) A specimen that had a weight loss

14
greater than 15% of its initial weight was considered a failure and is

indicated by an "F" in the table. The CPSC interim safety standard for

cellulosic insulation [6] specifies that all three specimens in the

sample must pass the test for the material to pass. All specimens of

material F passed and all specimens of material G failed under all

conditions tested. Two of the materials had split test results; that

is, some but not all of the five samples tested under the same conditions

were failures. Material C gave one split result only at the highest

humidity conditions tested.

The analysis of data resulting from the smoldering test, with the

widely different weight loss values for passing and failing samples and

the split test results, presents many problems. There is not a continuum

of weight loss values from passing to failing in this test; therefore,

extrapolation of data cannot be performed. To be explicit, the percent

weight loss for samples in the smoldering test is usually in the range

of either 0% to 4% or 35% to 60%. Values in the region between 4% and

35% are rare and extrapolation of test results into this region is

unjustified. This type of behavior can be understood if one thinks of

the smoldering test as a go/no-go ignition test. Once the cigarette

causes a small percentage (by weight) of the insulation in the sample

box to ignite and smolder, then the added heat generation within the

well insulated center region of the sample will be enough to guarantee

that the smoldering will continue. The smoldering, once initiated,

will progress to the edges of the container. There heat loss or lack of

fuel will cause the reaction to stop. To reach the edge of the container,

the smoldering front must consume a large portion of the sample. Thus

test results for percent weight loss have either very low or high

values

.

The critical amount of sample weight loss that can occur before

failure becomes imminent is unknown. This critical value will be sensitive

to the thermo-physical and reaction rate properties of the insulation

material, as well as specimen density and environmental conditions.

With this in mind, some caution should be exercised in generalizing the

15
smoldering combustion results of the limited sample of data presented in

this report.

In table 10, the weight loss data for each specimen tested are

recorded. For both materials F and C, some trials under high humidity

conditions showed negative weight loss. This indicates that, over the

test time of approximately 5 hours, more weight was gained by absorption

of moisture than was lost from smoldering. Just as in the standard test

method [6], no attempt was made to correct weight loss data for this

effect

.

Each trial of material G failed, with weight losses ranging from 38

to 56.5%. Materials F and C (excepting the one failure) had small

percent weight changes.

Test room humidity conditions may be quantified by use of specific

humidity, the ratio of the mass of water vapor to the mass of dry air

present. This parameter is preferred to relative humidity for this

study because the temperature in the test room was not held constant.

As a first step in analyzing the data, the split pass-fail test

results of material C under high humidity conditions must be considered.

If the one unexplained trial failure at the high humidity conditions is

considered significant, then a variation from the near-standard conditions

(21°C, 52% RH, 0.0078 specific humidity (SH)) to the high humidity

condition (21°C, 84% RH, 0.0133 SH) is sufficient to account for variations in material performance in the test. Excluding other chance

variations in test conditions, a change in specific humidity of 0.0055

can produce test result variations.

As an alternative method of detecting significant changes,

variations within the group of trials tested at the same room conditions

may be compared to variations between conditions. This information may

be used to establish a range of specific humidity conditions in which no significant variations in specimen weight would be expected. Although
significant variations in weight loss do not necessarily act to change

the overall evaluation of a material from passing to failure, they do

show that the test measurements are influenced by the change.

The one trial failure of material C has been considered as significant abcve to establish one limit on allowable moisture changes. On the

other hand, if that failure is neglected as being non-significant with

respect to high humidity, the following analysis pertains.

The data for material C, F, and G on average percent weight loss

and standard deviation recorded in table 10 are presented graphically in

figure 7. The error bars in figure 7 indicate plus and minus one standard deviation about the average value. Table 11 lists the average

weight loss and two standard deviations based on the data in table 10

for materials C, F and G tested at 21°C and 52% RH. Using the slope of

the straight line fits of the data in figure 7 to assess the amount of

change in measured weight loss with changing specific humidity, values

of specific humidity change necessary to produce two standard deviations

change in weight loss were evaluated. These calculated values of specific

humidity change are listed in table 11.

The CPSC interim safety standard for cellulose insulation [6]

specifies that the test area conditions must be maintained within the

range of 18°C, 45% RH to 24°C, 55% RH. This corresponds to a range of

specific humidity from 0.0059 to 0.0104. The change in specific humidity

over the range is 0,0045. This value is above the level for significant

variations in weight loss predicted for materials C and F (see table 11)

.

Of course, the weight loss data for materials C and F cannot be interpreted to indicate that for other materials a specific humidity change

of 0,0045 would change the overall evalution of from passing to failure

(or vice versa)

.

It has been suggested by CPSC that a 50 + 10% relative humidity

specification might be substituted for the current 50+5%. Under this

change, the test area conditions for specific humidity may range from

17
0.0052 to 0.0111, corresponding to 18°C, 40% RH and 24°C, 60% RH

respectively [11]. The change in specific humidity over this range is

0.0059. This value is greater than the level for significant variations

in weight loss predicted for all three insulation materials: C, F and

G. It is also greater than the 0,0055 SH change that may have been

responsible for the trial failure of material C discussed above.

In the interest of caution, considering only the limited testing

reported here, a change of the 50 + 5% to 50 + 10% relative humidity

specification for the testing space cannot be recommended at this time.

Further testing is needed to determine the effect, if any, of changing

test area temperature at a fixed specific humidity.

Again in the interest of being conservative, it is suggested that

the specific temperature limit variations be reduced for the smoldering

test to 21°C + 2°C and 50 + 5% RH. This would limit the allowable range

of specific humidity change to 0.0036, It should be noted that temperature

tolerance of + 2°C and a relative humidity tolerance of + 5% for standard

laboratory atmoshperes are the recommended in ASTM D-618 section 3d,

The erratic test results of material E made the data difficult to

utilize in this study, Lawson in his smoldering round robin tests [8]

found that material E was rated as passing in three of ten laboratories

and as a failure (Including split results) in the remaining seven

laboratories. It is possible that material E is a border line material

with respect to the pass/fail smoldering test, Lawson speculates that

material composition variations may be the source of the erratic performance. In addition, for the smoldering test other testing variations,

such as changes in local specimen density around the ignition source,

could become important in influencing test results.

The smoldering test has been shown to be sensitive to changes in

overall specimen density. As an example, material F used in this study was reported as a failure in the smoldering test in nine of the ten

laboratories in the NBS round robin [8]. In the round robin, the material

18
3

was tested at a density of 48 kg/m . In the work reported here, this

3 material was tested at a density of 41,3 kg/m . At this lower density,

each tested specimen passed (see table 10)

.

5. CONCLUSIONS

As part of the technical support for the CPSC 1979 Interim Safety

Standard for Cellulose Insulation, various parameters of the attic floor

radiant panel test (AFRPT) and smoldering combustion test were investigated. The low flux profile developed to extend the measurement range

2 of the AFRPT down to 0.04 W/ cm was shown to produce results equivalent

to those obtained using the regular flux profile for most materials

tested. Large scale attic fire tests have shown that, when the heat

flux to the surface of the insulation does not exceed the critical

radiant flux, flame spread does not occur. The AFRPT is applicable to

the prediction of resistance to flame spread for attic insulation.

No statistically significant variations in critical radiant flux

values for pre-blown paper-based cellulosic insulation were found for

3 variations of hand loaded specimen bulk density in the range of 24 kg/m

3

to 48 kg/m .

The critical radiant flux measurement in the AFRPT was found to be

sensitive to changes in the 2 minute preheat time, A tolerance of + 5

seconds on the standard preheat time is justified.

Smoldering combustion test results were found to be sensitive to

large changes in test area humidity conditions. Limiting the tolerances

on temperature and relative humidity to 21 + 2°C and 50+5 percent

respectively is considered necessary to ensure that significant variations

in test results are not produced by variations in test area conditions.

19
6 . REFERENCES

[1] Emergency Interim Consumer Product Safety Standard Act of 1978,

Public Law 95-319, July 11, 1978, 92 STAT. pp. 386-390

[2] Federal Specification HH-I-515C, Insulation Thermal (Loose Fill

for Pneumatic or Poured Application): Cellulose or Wood Fiber,

April 13, 1976

[3] Federal Specification HH-I-515D, Insulation Thermal (Loose Fill

for Pheumatic or Poured Application): Cellulose or Wood Fiber,

June 15, 1978

[4] Consumer Product Safety Commission, Cellulose Insulation, Proposed

Amendment to Interim Standard and Certification Rule, Federal

Register , Vol. 43, No. 173, September 6, 1978, p, 39720

[5] Consumer Product Safety Commission, Interim Standards for Cellulose

Insulation, Proposals, Federal Register, Vol. 44, No. 47, March 8,

1979, p. 12864

[6] Consumer Product Safety Commission, Interim Safety Standard for

Cellulose Insulation; Cellulose Insulation Labeling Requirement,

Federal Register , Vol. 44, No. 131, July 6, 1979, p. 39938

[7] Lawson, J.R. , An Interlaboratory Evaluation of the Consumer Product

Safety Commission Modified ASTM // 84-77a Tunnel Test for Cellulosic

Insulation, NBSIR 79-1922, Nov. 1979

[8] Lawson, J.R. , Interlaboratory Evaluation of the Attic Floor Radiant

Panel Test and Smoldering Combustion Test for Cellulose Thermal

Insulation, NESIR 79-1922, Nov. 1979

[9] Lawson, J.R. , Interlaboratory Evaluation of the Cyclone Settled

Density Test for Loose-Fill Cellulosic Insulation, NBSIR 79-1930,

Dec. 1979

[10] Gross, D. , A Preliminary Study of the Fire Safety of Thermal

Insulation for Use in Attics or Enclosed Spaces in Residential

Housing, NBSIR 78-1497

[11] Psychometric Chart, Reprint from ASHRE Brochure on Psychometry

Misc. Publications #7, 1947

20
Figure

1

—

P.egular

and

Low

Flux

Profiles

!

(ziUO/Ml Xmj 1¥3H

1

DISTANCE

(cm)
Figure

2

—

Specimen

Flux

Profiles

with

Lowered

Specimen

Surface

(zUl3/M) xnu 1V3H

22
Figure

3

—

Variation

of

Critical

Radiant

Flux

with

Preheat

Time,

Material

B

CM

23

PREHEAT

TIME

(minj
Figure

4

—

Variation

of

Critical

Radiant

Flux

with

Preheat

Time,

Material

E

24

PREHEAT

TIME

|minj
Figure

5

—

Variation

of

Critical

Radiant

Flux

with

Preheat

Time,

Material

G

(zui3/M) xnu iNviavii ivoiiuio

25

PREHEAT

TIME

(minj
Figure 7 — Cigarette Giaoldering Test Results

Under Various Humidity Conditions

RELATIVE HUMIDITY AT 2VC (%

00

00

C9

26

PERCENT

WEIGHT

LOSS
Figure 6 — Large-Scale Attic

27
Table 1, AFRPT Test Results

Regular Flux 0. 1-1.1 W/cm2

- Repeatability

Material Critical Radiant Flux W/cm Average COV

A 0.54, 0.46, 0.43 0.48 11.9%

B 0.19, 0.18, 0.15 0.17 12.4%

C 0.21, 0.17, 0.19 0.19 10.5%

D <.10, <.10, <.10 <.10 —

E 0.18, 0.14, 0.15 0.16 13.2%

F <.10, <.10, <.10 <.10 —

G 0.16, 0.17, 0.16 0.16 4.4%

H <.10, <.10, <.10 <•10

Low Flux 0.04-0.35 W/cm^

Material 2 Critical Radiant Flux W/ cm Average

Repeatability

COV

A >.350, >.350, >.350 >.35

B 0.196, 0.144, 0.142 0.16 19.2%

C 0.221, 0.196, 0.224 0.21 7.6%

D <.040, <.040, <.040 <.04 —

E 0.111, 0.138, 0.119 0.12 11.8%

F <.040 <.040, <.040 <.04 —

G 0.138, 0.139, 0.139 0.14 1.2%

H 0.113, 0.072, 0.073 0.09 26.6%

* Repeatability coefficient of variation (COV) as defined in Interlaboratory

Evaluation of the Attic Floor Radiant Panel Test and Smoldering Combustion

Test for Cellulose Thermal Insulation , J.R. Lawson, NBSIR 78-1588

28
Table 2. Effect of Density on Critical Radiant Flux Material G

Low Flux Profile

Specimen

Density

kg/m^

Critical Radiant Fltix

W/ cm^

Average + Standard Deviation

G-1 24 0.161

G-2 24 0.146 0.153 + .008

G-3 24 0.152

G-4 40 0.144

G-5 40 0.160 0.147 + .012

G-6 40 0.136

G-7 64 0.278

G-8 64 0.255 0.262 + .014

G-9 64 0.254

Table 3. Effect of Density on Critical Radiant Flux Material E

Regular Flux Profile

Density Critical Radiant Flux Average

Specimen kg/m^ W/ cm^ + Standard Deviation

E-1 32 0.13

E-2 32 0.11 0.12 + .01

E-3 32 0.13

E-4 48 0.14

E-5 48 0.15 0.14 + .01

E-6 48 0.13

E-7 64 0.23

E-8 64 0.23 0.23 + .01

E-9 64 0.24

29
Table 4. Critical radiant flux values

Material Preheat Time

(min)

B 0 0,126,

1 0.127,

2 0.196,

3 0.100,

6 0.130,

9 0.102,

20 0.096,

E 0 0.140,

1 0.156,

2 0 . 111 , 3 0.120,

6 0.088,

9 0.097,

20 0.082,

G 0 0.192,

1 0.180,

2 0.144,

2 0.138,

3 0.171,

6 0.127,

9 0.124,

20 0 . 110 ,

CRF Average CRF

cm^ W/cm^

0.119, 0.176 0.140

0.158, 0.144 0.143

0.144, 0.142 0.161

0.091, 0.126 0.106

0.130, 0.120 0.127

0.096, 0.107 0.102

0.096, 0.078 0.090

0.110, 0.124 0.125

0.197, 0.171 0.175

0.138, 0.119 0.123

0.098, 0.108 0.109

0.106, 0.098 0.097

0.099, 0.081 0.092

0.082, 0.089 0.084

0.212, 0.246 0.217

0.216, 0.208 0.201

0.160, 0.136 0.147

0.139, 0.139 0.139

0.172, 0.146 0.163

0.105, 0.119 0.117

0.116, 0.126 0.122

0.101, 0.086 0.099

30
Table 5 Traverse of air temperature from the roof peak

Distance Below Air

Peak, cm Temperature

18 83°C

31 83°C

46 77“C

61 72°C

91 61°C

119* 56°C

* Average of four thermocouple at comers of Insulated sections of the

attic base as indicated in figure 6.

31

I
Table 6. Total heat flux 10 cm above insulated

joist spaces at test conditions

Distance from Ignition

Point in Center of

Joist Space (cm)

0

30

61

91

122

2

Total Heat Flux W/cm

Joist Space

1 2 3

053 + .002 .053 .055

055 .053 .055

053 .057 .057

053 .055 .057

053 .053 .057

32
Table 7. Flanmabllity measurements on test materials

CRF FSC by ASTM

Material AFRPT E 84 Tunnel

F 0.15 Not Measured

G 0.16 32.7

B 0.17 31.3

H 0.09 22.1

S <0.11 35.8

2 Measured with low flux profile (0.04-0.35 W/cm ) Data from reference 7

33
Table 8. Large-scale attic test results

Max Spread

Material

Air

Preheat Temp

Air Temp**

at Ignition

Peak Air**

Temp

Flux to Floor

at Ignition Peak Flux

Along Three

Joist Spaces'

“C “C W/cm^ W/cm^

F 73 NM 102 NM NM 35 cm

G 71 76 79 0.055 0.060 10 cm

B 72 75 78 0.054 0.059 10 cm

H 72 76 90 0.055 0.065 > 15 cm

< 30 cm

S 72 77 86 0.052 0.059 30 cm

NOTE: NM - Not Measured

* Distances were judged from video tape recordings

maximum spread was difficult to detemine because

of the test,

of excessive

For material H, the

smoke production.

The maximum spread for material H was between 15 and 30 cm. All other measurements

are accurate to within 5 cm.

** Point of measurement 0,69 m below peak in roof

34
Table 9. Blown and settled density values

for the test insulations

Material

Blown Density* Settled Density*

Kg/m^ Kg/m^

C 19.10 26.80

E 32.52 49.33

F 27.08 41.30

G 29.59 44.39

* Average of three samples. Data supplied by CPSC laboratory.

35
Table 10. Smoldering test data percent weight loss

Cellulose

Insulation

C

E

F

G

Laboratory Conditions

Temperature 21°C

Relative Humidity 84%

Specific Humidity 0.0133

21°C

52%

0.0078

24°C

39%

0.0071

35.8 (F) 0.28 0.84

- 1.31 0.84 1.77

- 1.40 0.47 1.40

- 1.59 0.93 2.14

- 2.14 1.12 0.93

Av = - 1.61*

* Av = 0.73 Av = 1.42

a = 0.37 a = 0.34 a = 0.55

50.4 (F) 57.5 52.2 (F)

51.7 (F) 52.0 (F) 54.5 (F) - 1.01 0.10 54.0 (F) - 1.12 52.9 (F) 0.41

- 1.22 53.7 (F) 57.8 (F)

- 2.24 0.66 1.21

1.63 0.97 1.15

- 0.85 0.91 1.21

- 1.03 0.42 1.27

- 0.79 0.73 0.91

Av = - 0.66 Av = 0.74 Av = 1.15

a = 1.40 a = 0.22 a = 0.14

39.2 (F) 52.1 (F) 53.1 (F)

44.5 (F) 48.1 (F) 50.7 (F)

41.0 (F) 51.9 (F) 51.6 (F)

51.4 (F) 43.2 (F) 56.5 (F)

38.3 (F) 51.0 (F) 50.9 (F)

Av = 42.9 Av = 49.3 Av = 42.4

a = 5.32 a = 3.75 a = 1.99

(F) - Weight loss greater than 15%, falling result under HH-I-515D

* - Average and standard deviation calculated neglecting (F) data

Note: Negative weight loss values represent weight gain (due to moisture absorption)

36
Table 11. Predicted change in specific humidity to produce

a significant change in test results at 21“C, 52% RH

Materials Average Two Standard Deviations Change in Specific Humidity

c 0.73 0.68 0.0038

F 0.74 0.44 0.0016

G 49.3 7.50 0.0054

Average 0.0036

37
Appendix 1

TECHNICAL RATIONALE FOR THE GENERAL SERVICES

ADMINISTRATION FEDERAL SPECIFICATION HH-I-515D

FLAME RESISTANCE PROVISIONS

Sanford Davis

Fire Safety Engineering Division

Center for Fire Research

National Engineering Laboratory

National Bureau of Standards

Washington, D.C. 20234

December 1, 1978

Prepared for:

Division of Mechanical Textile Engineering

Directorate for Engineering and Science

Consumer Product Safety Commission

Bethesda, Maryland 20202

38
1. Introduction

When consideration was being given to revision of GSA Federal

Specification HH-I-515C for cellulose loose fill insulation, three

questions were asked about the flammability requirements: (1) Were the

existing test methods relevant to the real world? (2) If not, what test

methods should be introduced in their place? and (3) What would be

reasonable levels of acceptance in terms of fire safety of occupants?

Recognizing the typical combustible nature of single family home construction, the basic premise was that the addition of insulation should not

Increase the normal and expected level of fire risk to the occupants.

It is important to remember that the concern here is whether the cellulose

insulation is the first item to Ignite or is the cause for flame spread

and not whether it becomes involved in the later stages of a fire. The

effectiveness of any test method should be a function of how well it

predicts the performance of a product in the real world and how well it

evaluates the criteria for which it was developed,

2, Smoldering Test

A review of fire incident data (NBSIR 78-1497, A Preliminary Study

of the Fire Safety of Thermal Insulation for Use in Attics and Enclosed

Spaces in Residential Housing, D, Gross, July 1978) showed that the most

likely hazard associated with cellulose insulation was smoldering. More

than 80 percent of the fires associated with insulation involved cellulose

insulation started from overheated electrical light fixtures and other

electrical sources, heated flues, etc. When exposed to a heat source,

whether in an attic or in side walls, cellulose Insulation could be

induced to smolder unless properly treated. Sufficient evidence was available to demonstrate that temperatures in excess of 260°C (500°F)

could be obtained in contact with Insulation, such as in attics from

recessed light fixtures [(a) Final Progress Report, Detection of Exothermic

Reactions in Cellulosic Insulation, D. D. Evans, September 30, 1978,

Center for Fire Research, NBS; (b) Test Report NR 8TS026, Lighting

39
Fixture Temperature Survey, for Tinker AFB Fire Department, February 17,

1978, Engineering Laboratory, Oklahoma City ALC; (c) Testing of Cellulose

Insulation, performed by the Consumer Product Safety Commission Engineering

Laboratory, July 31, 1978] and from glowing wire connections in side

walls (NBS Building Science Series 103, Exploratory Study of Glowing

Electrical Connections, W.J. Meese and R. W. Beausollel, October 1977)

and that this temperature was sufficient to induce smoldering. However,

neither of the tests for flame spread referenced in HH-I-515C or D

address the smoldering problem.

The smoldering test Introduced into HH-I-515D utilizes a smoldering

cigarette as the ignition source. The cigarette specified has a maximxim

temperature of about 700°C in the very small glowing region (NBSIR 78-1438,

Back-up Report for the Proposed Standard for the Flammability (Cigarette

Ignition Resistance) of Upholstered Furniture, PFF 6-76, J. J. Loftus,

June 1978), which is sufficient to Initiate smoldering if it is going to occur. (There are also cases where cellulose insulation has been ignited

by a cigarette.) What is of concern is whether the smoldering will

continue to propagate in the cellulose insulation once it has been

started. This condition simulates the behavior of a material which is

heated to a sufficiently high temperature to initiate smoldering and

then continues smoldering beyond the heated region. A review of some available smoldering data, e.g. , Gross (Ref. cited) and Lawson (NBSIR

79-1588, Interlaboratory Evaluation of the Attic Flooring Radiant Panel

Test and Smoldering Combustion Test for Cellulose Thermal Insulation, J.

R. Lawson, February 1979), shows that if a product does not exhibit

smoldering tendency the weight loss of the specimen would be of the

order 1 or 2 percent. On the other hand, if the product is ignited by

the smoldering cigarette, the weight loss of the specimen would be

upwards of 30 to 35 percent. Because of the nature of the test results,

it is reasonable to impose a weight loss criterion midway between these

values, hence the 15 percent weight loss requirements. Although no instances of flaming combustion have been observed from a smoldering

specimen, it seemed appropriate to Impose this requirement also. The

test as currently defined will screen out many, but probably not all,

40
materials which will permit the propagation of smoldering in the common

insulation- covered recessed light fixture scenario which might be

encountered in residential use.

Research is continuing to determine the feasibility of carrying out

the test at elevated temperatures or by other modifications to better

simulate real world occurrences.

3. Flammability Test

The basic test for flammability in HH-I-515C in the ASTM E-84

Standard Test Method for Surface Burning Characteristics of Building

Materials (tunnel test). A fixed orientation and exposure is used for

all materials: wall and ceiling linings, plumbing and electrical piping,

adhesives, all types of insulation, etc. Since different products are exposed to Ignition sources and to different levels of fire exposure

depending on their end-use configuration, due consideration should be

given to an appropriate exposure. In the retrofit insulation market, in

particular for residential occupancies, cellulose loose fill insulation

has two major applications: (1) on the floors of attics in an exposed

condition and (2) in exterior side walls. It was felt that the attic

floor application was more critical and this problem should be addressed

first.

Examination of the fire test methods in HH-I-515C shows that the

E-84 is inappropriate for testing cellulose insulation installed on the

floor of an attic. Cellulose loose fill insulation is not normally

applied over a metal screen nor is it likely to be exposed to flames

from below. In a typical fire situation in the attic, the cellulose is

not subjected to a 5000 BTU/min fire and/or a wind velocity of 240

ft /min. It is apparent that none of the above factors which are all

part of the E-84 tunnel test have any relation to evaluating insulation

on the attic floor. Gross (ref. cited) points out that the tunnel test

has been shown to be invalid for low density fire retardant treated

plastic foams; its applicability to and appropriateness for other low

41
density insulation materials may also be seriously questioned. For

example, a flame spread classification of 25 for a 2 pcf. insulation has

no relation to a flame spread classification of 25 for 40 pcf, treated

lumber. It should also be noted that untreated cellulose insulation,

which would be considered to be totally unacceptable, has been reported

to have flame spread classifications from about 50 to 120; however, in

real fire situations, these materials burn more rapidly than plywood

having flame spread classifications of 150 to 200,

Having discussed above the shortcomings of the E-84 test, it

remains to be shown how the insulation, in its end-use configuration in

an attic, could become involved in a fire. The insulation is applied

between and over floor joists in an attic, where the air is relatively

still and the temperature and humidity vary depending upon the season,

the geographical location, the geometrical arrangements, the extent of

free or forced attic ventilation, etc. The most severe exposure is

likely to develop during periods of elevated outdoor temperatures plus

solar radiation, A small ignition source, such as an electrical failure

causing an arc or a carelessly applied propane torch, would be typical

ignition sources.

This scenario, insulation on the floor of the attic in still air

exposed to radiation from the roof and subjected to a small ignition

source, is modelled by the conditions of the Standard Method of Test for

Critical Radiant Flux of Floor Covering Systems Using a Radiant Heat

Energy Source (NFPA 253, ASTM E-648) which was originally developed for

evaluating flooring systems in corridors exposed to radiation from fully

developed fires in rooms. The test method involves a graded radiant

2

exposure varying from 0,1 to 1,1 W/cm , corresponding approximately to

the differences between direct solar radiation in the summer to the

irradiance on the floor from a moderately severe flaming fire on the

ceiling. However, it also has been shown that the test method is

applicable to flooring systems exposed to small fires in rooms (NBSIR

76-1013, Flame Spread of Carpet Systems Involved in Room Fires, K,-M, Tu

and S. Davis, June 1976). This test, commonly known as the Flooring

42
Radiant Panel Test, was adapted to accommodate insulation specimens and

was introduced into the GSA HH-I-515D standard as the Attic Floor Radiant

Panel Test. In the attic floor radiant panel test, the material under

evaluation is exposed to a graded irradiance and ignited with a pilot

burner at the high flux end of the specimen. The flxix at the farthest

point where the flame extinguishes is known as the critical radiant

flux.

In order to obtain an estimate of attic temperatures for some of

our preliminary work, temperatures were measured in the attic of a private home in the Washington, D.C. area during July 1977. Daytime

temperatures as high as 140°F were measured. A temperature of 160°F is

used as a design value for attic fans by the American Ventilation Association (The Handbook of Moving Air, Houston, Texas, 1977). This temperature would correspond to the underside of the roof acting as a black

2 body radiator imposing a flux level of 0.08 W/cm onto the insulation.

2 A 50 percent safety factor would bring the flux level to 0,12 W/cm ; for comparison purposes, the solar radiation reaching the surface normal

2

to the sun's rays on a clear s ummer day in Florida is 0,11 W/cm (350

2 BTU/ft hr). This means that a fire would not propagate in the attic

insulation if the energy delivered to the insulation is less than 0.12

2 W/cm . The critical radiant flux for plywood, wood joists, etc. is 0,35

2 2

to 0.40 W/cm ; the test requirement of 0,12 W/cm represents a minimum

level for safety, not an equivalent to existing materials.

The Gross report describes some large-scale attic mockup tests in

which several cellulosic products were exposed to temperatures of 160

and 180°F. These experiments supported the use of the attic floor

radiant panel test and the criterion chosen for recommendation to GSA,

In addition, we are aware of some tests run at Undeirwriters Laboratories

from which they concluded: "Cellulosic Insulation with a (critical)

2 radiant flux level of 0.12 W/cm or greater, as determined by the floor

and attic (sic) radiant panel test, resisted flame propagation under the

highest ambient temperature conditions of the attic simulation fire

" The highest temperature used in their study was 160°F. There is

43

test.
no correlation between critical radiant flux and flame spread classification by ASTM E-84; low flame spread classifications may be either

2 above or below a critical radiant flux of 0.12 W/ cm .

4. Flame Resistance Permanency

Another aspect of the HH-I-515C standard which needs to be mentioned

is the flame resistance permanency test referenced in ASTM C-739 [Standard

Specification for Cellulose Fiber (Wood-Base) Loose Fill Thermal Insulation]. This test requires that a cellulose insulation product be

evaluated in the E-84 Tunnel before and after the following prescribed

temperature and humidity cycling program:

24 hours at 180°F and 96% relative humidity

24 hours at 80°F and 50% relative humidity

24 hours at 180°F and 96% relative humidity

24 hours at 80° F and 50% relative humidity

Under some circumstances, the use of a two-foot tunnel is permitted in

place of the 25-foot tunnel; the current CPSC requirements would permit

this only if the flame spread classification of the product was 20 or

less. The two-foot tunnel test is not a standard ASTM method and its

use does not imply that there is a correlation with the E-84 method

(ASTM C-739-77). Some limited work was carried out at NBS to evaluate

the cycling process; the HH-I-515D flammability test methods were used

to evaluate the effect of temperature and humidity cycling on the

flammability of cellulose Insulation. Three conclusions came from this

work. (1) Immediately following the last 24-hour period at 80°F and 50%

relative humidity, the specimens appeared to be too wet to test; the

specimens were conditioned for 10 days additional at 21°C and 50%

relative humidity, (2) the cycling process appears to Improve the flame

retardance of the cellulose insulation slightly by causing the soluble

salts to be "driven" into the cellulose fibers, and (3) the cycling

procedure appears to be an attempt at an accelerated aging test but does

not appear to take into account the following:

44
(a) possibility of liquid water dropping on top of the

insulation (from condensation or ice formation in

winter, or roof leakage) and removing the fire

retardant salts from the surface layer,

(b) a relative humidity gradient versus a uniform

relative humidity, and

(c) final cycle to a low relative humidity level (20 to 30

percent relative humidity) typical of a dry season.

It was not convincing that this test from ASTM C-739, or any slight

modification or it, was an appropriate measure of flame resistance

permanency; hence, it was not considered for inclusion in HH-I-515D. It

must be emphasized, however, that such a test should be required and

that research is needed to define a suitable test.

One aspect of flame resistance permanency which was not addressed

in HH-I-515C is the problem of physical separation of flame retardant

chemical from the cellulose fibers. The accumulation of chemical at the

bottom of the bag has been observed on several occasions. During the

recent interlaboratory program evaluating the HH-I-515D flammability

tests described by Lawson (ref, cited) it was noted that there was considerable separation of chemical in one of the products; this

material gave the most erratic results in the smoldering test. In the

future consideration of a permanency test, this problem will be examined.

5 . Smoke

It was presumed that there was no need for a smoke test unless

smoke (toxic gases or obscuring particulates) was shown to be a problem.

In the attic, the principal problems are smoldering ignition or rapid

flame spread on the exposed surface. If both processes are prevented by

appropriate tests and criteria, then the smoke generated will be limited.

Therefore, it was considered inappropriate to impose any requirement for

smoke determination.

45
6. Test Method Precision

As part of the development of the flammability test methods for

HH-I-515D, an interlaboratory program was conducted to evaluate the

repeatability and reproducibility of the methods for cellulose Insulation.

Details of this study are described by Lawson (ref, cited). The results

for the critical radiant flux determination showed that the pooled

coefficient of variation for repeatability (within laboratory) was 12

percent and the average coefficient of variation for reproducibility

(between laboratory) was 25 percent; these values were not significantly

greater for loose fill cellulose insulation than for other materials and

compare favorably with precision estimates available from other standard

fire tests.

Because of the split test results (some pass and some fail) for the

smoldering combustion reported by several of the laboratories, it did

not appear practical to put the data through a rigorous statistical

analysis. Agreement among the laboratories was relatively good; it

appears that some variation in laboratory procedures contributed to the

scatter of data.

Based on the work of this study, there is reasonable assurance that

results from different laboratories evaluating the same material for

compliance with Federal Specification HH-I-515D will be consistent.

46
NBS«114A (REV. 2 *80 ) U.S. DEPT. OF COMM.

BIBLIOGRAPHIC DATA

SHEET (See instructions) 4. TITLE AND SUBTITLE

PUBLICATION OR

REPORT NO,

NBSIR 81 -221

2. Performing Organ, Report No, 3. Publication Date

3

Technical Support for the Consumer Product Safety Commission 1979 Interim Standards

for Cellulose Insulation

5. AUTHOR(S)

David D. Evans and Sanford Davis

6. PERFORMING ORGANIZATION (/f jo/nt or other than NBS. see in struction s) 7. Contract/Grant No. national bureau of standards

DEPARTMENT OF COMMERCE 8. Type of Report & Period Covered

WASHINGTON, O.C. 20234

9.

SPONSORING ORGANIZATION NAME AND COMPLETE ADDRESS (Street. City. State. ZIP)

Consumer Product Safety Commission

Textile and Mechanical Engineering Group

Bethesda, Maryland 20202

10.

SUPPLEMENTARY NOTES

I I Document describes a computer program; SF-185, FIPS Software Summary, is attached,

11.

ABSTRACT (A 200-word or less factual summary of most significant information. If document includes a significant

bibliography or literature survey, mention it here)

The attic floor radiant panel test (AFRPT) and smoldering combustion test are two

fire performance tests required by the Consumer Product Safety Commission (CPSC) as part of a mandatory standard for loose fill cellulosic home insulation. In providing technical support to CPSC, the sensitivity to variations in parameters of each

test method were studied. Specimen density was found to have no effect on critical

radiant flux values when measured with the AFRPT for two paper-based cellulosic insulations tested at densities below 48 kg/m^. A low flux exposure profile, ranging

from 0.04 to 0.35 W/cm^, was developed to extend the range of the AFRPT about the

region of greatest interest. The critical radiant flux measured using the low flux

profile was found to be sensitive to changes in preheat time from the prescribed two

minute specimen preheat. Large-scale attic fire tests verified the predictive ability

of AFRPT measurements. Results from the smoldering combustion test were shown to be

sensitive to test room humidity conditions over the range of 39 to 84 percent PJ1.

12. KEY WORDS fS/x to twelve entries; alphabetical order; capitalize only proper names; and separate key words by semicolons)

attic floor radiant panel test; cellulose insulation; smoldering; fire test; flame

spread; HH-I-515D

13. AVAILABILITY

ifvl Unlimited

1 1 For Official Distribution, Do Not Release to NTIS

1 1 Order From Superintendent of Documents, U,S, Government Printing Office, Washington, D,C,

20402.

Order From National Technical Information Service (NTIS), Springfield, VA, 22161

14, NO, OF

PRINTED PAGES

51

15. Price

$8.00

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