MEMORANDUM TO Sheryl Chaffer, Acting Executive Director, HIA (WA Region) FROM: Laurie Moylan, President, ACIMA RE: Your 20 February 2007 letter re: Installation of R3.0 Loose Fill Insulation: ACIMA submission on why ceiling joists must be covered by insulation DATE: 13 March 2007 ______________________________________ 1. Introduction 1.1 Perth-based ACIMA members who received your abovementioned letter, have asked me to present ACIMA's policy (see item 2 below) in this matter to the HIA WA Technical Committee. ACIMA's policy directly addresses your Technical Committee's enquiry concerning a) loose-fill insulation and OH&S b) meeting the roof space insulation values as required under the BCA 2006 5 Star compliance method, using loose-fill insulation. 1.2 By way of background, ACIMA represents those cellulose insulation companies who supply more than 80% of Australia's cellulose insulation to the annual, national $650 million retail insulation market. 1.3 ACIMA promotes the use of correctly installed, Australian Standards-approved insulation technology as the most cost-effective means of improving building energy efficiency in Australia, thereby protecting our environment via reduced energy consumption & greenhouse gas emissions. . 2. Loose-fill Installation Method Improves Insulation Performance at No Cost 2.1 ACIMA's members Australia-wide have recently introduced a new installation method where cellulose insulation is installed over the ceiling joists to improve insulation performance in residential ceilings at no cost to builders. 2.2 The new installation method has been adopted due to the impact of government demands for improved building energy efficiency that has led to steadily increasing insulation levels in ceilings. 2.3 Ironically, it's because of these increasing, regulatory insulation levels, that ACIMA members are now able to address the long- standing, Australian insulation industry-wide problem of decreased insulation performance due to thermal bridging (i.e. heat loss or gain through ceiling joists). 2.4 ACIMA contends that thermal bridging has been `the elephant in the room' for the Australian insulation industry for many years, and it's only been recent government demands for increased building energy efficiency, that has forced the industry to face up to it now. Until this recent need to increase the actual depth of ceiling insulation above the height of the joists, most Australian insulation manufacturers have simply ignored the thermal bridging effects of the ceiling joists. This is despite the fact that AS3999 1992, the Australian Standard for installation of bulk insulation (i.e. loose-fill cellulose, glass wool & rock wool batts) 2.5 ACIMA further contends that all Australian insulation manufacturers need to come clean now on the thermal bridging issue, and start covering ceiling joists so as to deliver their product labels' claimed thermal performance. Only by covering ceiling joists with insulation will Australian insulation products actually achieve their claimed insulation performance. For example, an R 3.0 insulation batt installed in a softwood ceiling joist with a 450mm centre will lose 15% of its claimed installed insulation performance, reducing its performance substantially to R 2.3. (Refer `Report on Thermal Bridging of Insulated Building Systems for ACIMA, January 2003' attached) 2.6 For decades in the U.S and Europe, insulation has been installed over the ceiling joists so as to meet the need for climate-related high insulation performance. 2.7 WA HIA members need to understand that all insulation products will be required to cover the joists in the near future. Local research undertaken by ACIMA, coupled with the well- established worldwide practice of covering the ceiling joists with insulation, make the mandatory introduction of the practice into State & Territory building energy efficiency regulations only a matter of time. 3. OH&S Summary 3.1 Constant references by Australian insulation batt manufacturers over the two decades or so, regarding alleged OH&S issues due to the covering of ceiling joists by insulation, are nothing more than mischievous hearsay. 3.2 ACIMA scrutiny of State & Territory OH&S regulations dealing with safety in roof spaces & confined spaces do not preclude the covering of ceilings joists with insulation. 3.3 However, as should be the case for all tradespersons entering a roof space, ACIMA members' staff maintain stringent safe work practices in accordance with their respective State & Territory OH&S legislation. 3.4 A prime example of a hearsay issue as mentioned in item 3.1 above, is that it's necessary for all tradespersons to stand on ceiling joists while working in the roof space. ACIMA contends that because hanger beams exist in every roof space, and are placed well above the height of the joists, movement by tradesmen through the roof space is relatively easy. 3.5 However, where tradespersons need to access the ceiling joists, ACIMA recommends that they remove the insulation with a flat length of wood, and replace it on completion. Also, locating the ceiling joists even when covered with loose-fill insulation, is not difficult. 3.6 Finally, it is central to this discussion re OH&S that because ceiling joists are required to be covered under AS3999 1992, State & Territory regulators will insist on the practice to maximise thermal efficiency in roof spaces as residential energy efficiency targets rise. 3.7 Therefore, tradespersons working in roof spaces will in future have to move an insulation product from the joists when necessary, be it glass wool batts or cellulose or rock wool loose- fill. 4. Summary 4.1 There are no State/Territory OH&S procedures specific to loose-fill insulation installed over the joists in residential ceilings, either in West Australia or elsewhere in Australia. 4.2 In fact, ACIMA's West Australian members have recently introduced a new installation method where cellulose insulation is installed over the ceiling joists to improve insulation performance in residential ceilings at no cost to HIA members. 4.3 ACIMA contends that if the West Australian Government, the HIA & the State's building industry are intent on maximising energy efficiency in residential buildings, thereby further reducing energy consumption, they will jointly promote the elimination of thermal bridging, as a matter of priority. 4.4 Finally, ACIMA is currently petitioning Standards Australia to reconvene Committee BD004 to update the AS3999 1992 bulk insulation installation standard, which will emphasize to Australian building regulators, AS3999's current requirement that ceilings joists be covered by insulation. 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