15-0903 v3.X HFRs in Insulation & Proprietary Ingredients


We would like to request two Red List exceptions in order to use the foil-faced rigid polyisocyanurate wall insulation on our project, Atlas Energyshield Pro. Requested exceptions are II10-E12 HFR's for exterior insulation, and II10-E4 Proprietary Ingredients. I have attached the manufacturer's letter below that addresses II10-E4. The product cannot be avoided in the project: in order to achieve code-required wall insulation values we must utilize exterior continuous rigid insulation. We need to use polyisocyanurate insulation because of space limitations and the need for the highest R-value per inch possible to achieve the net positive energy petal.


I10-E12 HFRs In Foam Insulation applies to exterior insulation products and therefore can be used in this case. Although based on the provided manufacturer documentation the proposed product does not meet the "1% or 1 ingredient" requirement of I10-E4 Proprietary Ingredients, such products may be used if manufacturers "confirm in writing that the product is Red List-compliant and state the total percentage [of ingredients] being withheld" per the August 2014 3.0 Materials Petal Handbook (MPH p13). The project team is encouraged to contact additional manufacturers in attempt to source a fully disclosed insulation product, but if they do not find a more transparent option, Exception I10-E4 may be used. All documentation must be addressed, including advocacy to the selected manufacturer for full ingredient disclosure and elimination of Red List ingredients in the proposed foam insulation product.

Post ID 3161

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