15-0619 v2.X Red List Materials in Code Required Insulation


We are submitting the following request for an exemption to the Red List. Outlined below are the issues that the project is facing, which have resulted in the need for this request.

Formaldehyde in Fireplace Chimney InsulationOur project intends to install a fireplace within the L2 transect. We have vetted the materials for ICC Chimney's Renaissance Rumford Model 1000 fireplace, but upon researching the CAS numbers have come across formaldehyde being used as a binding agent within the insulation of the fireplace insert and the vent piping. CAS Registry Number 25104-55-6 is synonymous with Phenol and Urea Formaldehyde polymers and copolymers and range from 1-6% of the product. Insulation, more specifically mineral fiber insulation (Roxul), is required by code and to maintain the UL approval of the product, as fire safety is paramount in a product and application such as this. It appears that all mineral fiber insulation used in non-combustible applications contain formaldehyde as a form binder. 

We propose that this insulation product be treated in a similar fashion to the current exception (Post ID 2043) for exterior application use of rigid mineral wool insulation (with phenol formaldehyde). Is this pathway acceptable?PVC and Flame Retardant in Geothermal Cabinet Insulation.

Similarly, during the vetting process of the Hydron Module geothermal system, we found that the cabinet insulation (K-Flex USA Elastomeric Foam) contains a small amount of PVC and halogenated flame retardant in order to meet UL standards. When comparing the weight of these two items to the total unit weight, they are approximately 0.8% of the unit weight. Additionally, without this insulation we would have to forfeit the 2% leakage rate on the unit (this is the only cabinet currently available with this low of a leakage rate), which would result in increased energy consumption that would have to be offset by other means. 

Based on the need to meet the UL requirements and the small amount, by weight, that the red list materials amount to in comparison with the entire cabinet assembly, is this product acceptable?


It is acceptable to use Roxol Mineral Wool for a fireplace under Exception I11-E12 Spray Foam and Rigid Insulation per the May 2013 v2.1 Materials Petal Handbook (MPH p9). An Advocacy Letter must be sent to the insulation manufacturer. The PVC in the geo-thermal cabinet is allowed under Exception I11-E3 Small Components (MPH p7). The HFRs are not allowed under that exception but will be allowed in this case under I11-E1 General Red List (MPHp7). The team must document due diligence and advocacy as required.

Post ID 2996

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