# The North American Insulation Manufacturers

Association’s (“NAIMA”) Public Hearing Comments Wednesday, January 4, 2012

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# Who Is NAIMA

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# NAIMA Is the Association For North American Manufacturers of Fiber Glass Insulation Products.  

# NAIMA Promotes Energy Efficiency and Environmental Preservation Through the Use of Fiber Glass Insulation Products.

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# Summary of Comments

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# NAIMA’s Comments Focus On:

− The Environmental Benefits of Fiber Glass Insulation  

### Energy Savings  

### Pollution Reduction  

### Comfort  

### Recycled Benefits



## − Fiber Glass Insulation Manufacturing Provides Well - Paying Jobs and Provides Economic Benefits In the Communities Where They Operate.

− Fiber Glass Insulation Manufacturers Are Responsible Stewards of Their Products:

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### Safe Work Practices and Training  

### Extensive Exposure Database  

### Extensive Medical and Scientific Research Data 3

# Voluntary Reduction of HAPs

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# The Majority of the Wool Fiberglass Industry Has Significantly Reduced Formaldehyde Emissions Through the Industry’s Voluntary Conversion To Non- Formaldehyde Binders.

− Other Companies Have Announced a Schedule To Convert To Non- Phenolic Binders

− Building Insulation Industry For Wool Fiberglass Will Use Non- Phenolic Binders  

# The Reduction In HAPs Is Significant

− So Significant That MACT Standards Are Not Applicable

− Major Sources In Industry Dramatically Reduced  

# EPA Has Recognized That This Was Environmentally Friendly Action 4

# Energy Savings

 

# Insulation Saves Energy.  

# Fiber Glass Insulation Is a Cost- Effective and ReadilyAvailable Tool For Energy Efficiency.  

# Indeed, Energy Efficiency Is a Resource.  

# Energy Efficiency, Including Insulation, Has Been Deemed the Greatest Untapped Resource Available To Address the Current Energy Crisis and Climate Change.  

# Unlike Energy Efficiency Measures, Such As Energy Efficient Appliances Or Light Bulbs, Insulation, Once Installed, Requires No Additional Energy To Save Energy.

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# Energy Savings

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# The McKinsey Quarterly’s “A Cost Curve For Greenhouse Gas Reduction” Identifies Building Insulation As the Most Cost Effective Energy Efficiency Measure.  

# Both the EPA and DOE Websites State That Up To 30 Percent Savings On Heating and Cooling Energy Can Be Saved Through Increased Insulation. (http://www.energy.gov/insulationairsealing.htm; www.epa.gov/region1/eco/energy/heatingefficiency.html)  

# Since Buildings Are the Largest Users of Energy, Insulation Tops Lists of Suggestions For Energy Savings.

− Buildings Represent One of the Last Great Frontiers of Wasted Energy. 6

# Energy Savings

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# Fiber Glass Insulation Saves 12 Times As Much Energy Per Pound In Its First Year In Use As the Energy Used To Produce It.

− In Other Words, Every Btu (British thermal unit) Consumed In the Production of These Products, 12 Btu’s Are Saved Each Year the Insulation Is In Place.  

# Insulation In Place In Residential Buildings Throughout the United States Saves At Least 10.41 Quadrillion Btu’s Annually.  

# Insulation In Place In Commercial Buildings Throughout the United States Saves 1.51 Quadrillion Btu’s Annually.
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# Comfort

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# Insulation Keeps Your Home Warm In the Winter and Cool In the Summer.  

# Insulation Has Fundamental Health Benefits.  

# Medical Professionals Identify a Home As a Critical Element In Gaining and Preserving Good Health: “A house should protect its occupants from extremes of heat and cold, moisture and dryness,” and Maintain “a comparatively constant interior temperature.” FN1
1 Hubert O. Swarthout, Modern Medical Counselor: A Practical Guide to Health (Mountain View, California: Pacific Press Publishing Association, 1943), p. 97.
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# Comfort

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# Modern Insulation Proved So Fundamental To Good Health That the Modern Medical Counselor in 1943 Urged Readers To Follow This Advice: “If modern insulating materials are used in the building of a new home, it will be better protected against the extremes of heat and cold and will conserve fuel.” FN2  

# Dr. Hubert Swarthout’s Book Even Featured a Photograph of Fiber Glass Insulation Being Installed. FN3
2 Hubert O. Swarthout, Modern Medical Counselor: A Practical Guide to Health (Mountain View, California: Pacific Press Publishing Association, 1943), p. 101. 3 Hubert O. Swarthout, Modern Medical Counselor: A Practical Guide to Health (Mountain View, California: Pacific Press Publishing Association, 1943), p. 101. 9

# Insulation Reduces Pollution

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# By Reducing the Demand For Energy, Thermal Insulation Products Help Conserve Non- Renewable Fuel Supplies and Reduce the Amount of Pollutants That Are Released Into the Atmosphere Through the Burning of Fossil Fuels.  

# Two Studies FN4 

# Conducted By the Harvard School of Public Health Analyzed the Benefits of Increased Insulation and Projected Resultant Reductions of the Following Pollutants: PM 2.5 

# , NOx, and SO2 

# . 4 Jonathan I. Levy, Yurika Nishioka and John D. Spengler, “The public health benefits of insulation retrofits in existing housing in the United States,” Environmental Health: A Global Access Science Source, April 2003, pp. 1 - 16; and Yurika Nishioka, Jonathan I. Levy, Gregory A. Norris, Andrew Wilson, Patrick Hofstetter, and John D. Spengler, “Integrating Risk Assessment and Life Cycle Assessment: A Case Study of Insulation,” Risk Analysis, Vol. 22, No. 5, 2002, pp. 1003- 1017. 10

# Insulation Reduces Pollution

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# The Harvard Studies Have Determined That Improving Energy Efficiency of Homes Not Only Saves Energy and Reduces Environmental Air Pollution, But Also Has a Significant, Immediate, Positive Impact On Public Health.  

# The Harvard Studies Demonstrate That Properly Insulated Buildings Significantly Reduce the Release of Sulfur Oxide, Nitrous Oxide, and Fine Particulate Matter.  

# With Every Btu of Energy Produced From Fossil Fuel Combustion, Harmful Gases Such As Nitrous Oxide and Sulfur Oxide Are Released Into the Air, Causing Pollution In Our Communities.
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# Insulation Reduces Pollution

 

# A Well- Insulated Home, Commercial Building, Or Industrial Facility Reduces the Amount of Energy Required To Maintain a Comfortable Living Or Working Environment.  

# Reducing Energy Consumption Means Power Plants Burn Less Fossil Fuel To Produce the Energy and the Result Is a Reduction In Polluting Gases Emitted Into Our Communities.  

# Each Btu Saved Through Energy- Efficiency Technologies Such As Insulation Means Cleaner Air and Improved Public Health.

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# Other Environmental Benefits

 

# Fiber Glass Insulation Products Use Significant Quantities of Recycled Materials, Which Is Yet Another Environmental Benefit.  

# Fiber Glass Insulation Manufacturers Used More Than 2.9 Billion Pounds of Recycled Glass In 2006 and 2007.  

# Use of Recycled Glass By NAIMA’s Members Has Almost Tripled Since NAIMA First Surveyed Its Members In 1992.

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# Other Environmental Benefits

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# Using Materials Derived From Secondary Sources Not Only Reduces the Demand On Virgin Resources, It Saves Landfill Space By Diverting Glass Containers and Other Glass Items From the Solid Waste stream.  

# Today’s Fiber Glass Insulation Contains Upward of 40 Percent Recycled Glass.  

# Fiber Glass Insulation Is Also the Second Largest User of Glass Cullet.

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# Jobs

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# NAIMA’s Members Operate Over 40 Manufacturing Plants In North America That Are Located In Every Region of the Country.  

# The Fiber Glass and Rock and Slag Wool Insulation Industry Employs Well Over 16,000 FN5 

# Workers In 40- Plus U.S. Plants In High- Paying Manufacturing Jobs At a Time When U.S. Businesses and Consumers Have Increasingly Turned To Many Foreign Manufactured Products.
5 The U . S . mineral wool manufacturing industry “comprises establishments primarily engaged in manufacturing mineral wool and mineral wool (i . e. , fiberglass) insulation products made of such siliceous materials as rock, slag, and glass or combinations thereof .” (See U . S . Census Bureau, 2002 Economic Census : Mineral Wool Manufacturing, Appendix B (Jan . 2005) (Ex. 46-64) . ) 15

# Jobs

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# Fiber Glass Insulation Products Provide Tens of Thousands of Other Jobs For Fabricators and Installers. FN6  

# OSHA Estimated That Over 225,000 Workers In the United States Are Employed In Fiber Glass Insulation Production and Installation. FN7  

# NAIMA’s Members Thus Provide Valuable Manufacturing Jobs To American Workers At a Time When Many Industries Are Moving Operations and Jobs Overseas.
6 Occupational Safety and Health Administration, “OSHA Priority Planning Process : Announcement of the Results of the OSHA Priority Planning Process,” p . 58 (Dec. 13 , 1995) . 7 Occupational Safety and Health Administration, “OSHA Priority Planning Process : Announcement of the Results of the OSHA Priority Planning Process,” p . 58 (Dec. 13 , 1995) . 16

# Jobs

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# A Domestic Fiber Glass Insulation Industry Helps Maintain a Viable Economy In North America.  

# The U.S. Fiber Glass Insulation Industry Has Been Able To Supply Virtually All of the Needs of the Domestic Building Industry For Residential, Commercial, and Industrial Insulation Products Without Turning To Either Imported Insulation Products Or Offshore Production. Many U.S. Manufacturers Have Shut Down Or Moved Production Overseas To Other Countries, But Fiber Glass Insulation Manufacturers Have Remained In the United States and Preserved Many High- Paying Manufacturing Jobs. FN8 8 Joel Popkin and Company, Securing America’s Future: The Case for a Strong Manufacturing Base, p . 9 (June 2003) . 17

# Product Stewardship

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# NAIMA Maintains a Product Stewardship Program:

− Work Practices

− Training Materials

− Extensive Medical and Scientific Research Data  

# NAIMA Maintains An Extensive Exposure Database.  

# Fiber Glass Insulation Is the Most Thoroughly Researched Insulation Product On the Market.  

# Actions By:

− International Agency for Research on Cancer (“IARC”)

− National Toxicology Program (“NTP”)

− California Office of Environmental Health Hazard Assessment (“OEHHA”) 18

# Product Stewardship

 

# Fiber Glass Insulation Products Are Safe To Manufacture, Install, and Use When Recommended Work Practices Are Followed.

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