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The International Code Council (ICC) convened Public Comment Hearings from October 19-25, 2016, in Kansas City, Missouri. Hearing attendees debated proposed changes to a number of the ICC codes, including the International Residential Code (IRC). Among the proposed changes was RB152-16, which would exempt foam plastic installed beneath concrete slabs or in certain foundation wall applications, from fire test requirements in the IRC.1 Despite the fact that ICC code development committees or government voting members have rejected such proposals six times previously, proponents again sought to reduce fire safety in the building codes.

What Will RB152-16 Do?

This proposal would result in a reduction in code fire test requirements and create confusion. RB152-16 mixes foam plastic insulation that meets fire safety standards with foam insulation products that do not. The proposal does not clearly show where to use flame-retarded and non-flame retarded insulation, which could result in installation errors in the job site and increased complexity in inspections.

The potential for installation errors is of great concern since non-flame retarded foam with unlimited flame spread creates a fire safety hazard for building occupants and first responders. This proposal could also create fire safety hazards for workers at manufacturing facilities, warehouses and construction sites. Non-flame retarded foam plastic bundles stored at the construction site prior to use are potential fire hazards.

In addition, foam plastic manufacturers must comply with existing code measures that require products meet fire safety standards. RB152-16 would create a conflict with these codes since some products under RB152-16 may not meet fire safety standards and thus could not be labeled by labs that follow existing standards.

Rejected Past Proposals to Weaken Fire Safety

2015 Fire Safety Committee 

The premise of RB152-16 is that it would allegedly improve occupant and firefighter health by reducing the use of flame retardants in building insulation. This premise encourages insulation producers to disregard decades of U.S. fire and building performance experience. The ICC Fire Safety Committee has said that the proposals would in fact reduce overall fire safety to building occupants as well as emergency responders, including firefighters. Committee members have noted that the U.S. EPA, not the building code process, is the proper place to discuss chemicals policy.2

2015 Public Comment Hearing Assembly

Last year’s proposals were also recommended for disapproval by the ICC Governmental Voting members at the ICC Public Comment Hearing.3 While the proponents attempted to introduce modified language aimed at limiting the proposed installations and conducted a small-scale fire demonstration, the proponents were unable to convince the ICC voting members that there was sufficient reason to modify the long-standing and time-tested fire safety provisions in the code. More importantly, the proponents did not provide evidence of a health risk associated with the current code. Voting members were not swayed by the proponents’ limited fire experiment and were concerned about the potential for confusion on building sites regarding where flame-retarded and non-flame retarded foam plastic insulation could be used.

Maintain Fire Safety and Vote Against RB152-16.

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1 IRC-Building. 2016 Group B Committee Action Hearings.

2 2015 Report of the Committee Action Hearings on the 2015 Editions of the Group A International Codes, page 65.

3 Public Comment Hearing Results on the 2015 Proposed Changes to the International Codes—Group A.


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