The North American 

Insulation Manufacturers 

Association’s (“NAIMA”) Public Hearing Comments

Wednesday, January 4, 2012

1
Who Is NAIMA

 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

 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:

 Safe Work Practices and Training

 Extensive Exposure Database

 Extensive Medical and Scientific Research Data

3
Voluntary Reduction of HAPs

 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.

5
Energy Savings

 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.

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Energy Savings

 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.

7
Comfort

 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

 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

 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 StudiesFN4 Conducted By the Harvard School of Public 

Health Analyzed the Benefits of Increased Insulation and 

Projected Resultant Reductions of the Following 

Pollutants: PM2.5, 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.

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Insulation Reduces Pollution

 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

 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.

14
Jobs

 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 16,000FN5 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).)

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Jobs

 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).

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Jobs

 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).

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Product Stewardship

 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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