We asked the Cellulose Insulation Manufacturers' Association (CIMA) to respond to claims of false advertising. Here's what they said
April 18, 2017 by canadiancontractor
Recent media coverage of a June 2016 report from the the National Advertising Division (NAD) of the U.S. Better Business Bureau concerning advertising claims made by a leading cellulose insulation manufacturer Applegate Insulation elicited a strong reaction from the organization representing all cellulose insulation manufacturers. Canadian Contractor asked for point-by-point response from the Cellulose Insulation Manufacturers Association (CIMA). Here’s what we received from the group’s Executive Director.
It is illegal for CIMA or any trade association to control the marketing messages of its members, other than to prohibit fraud or outright misrepresentation of facts. With that disclaimer I would make the following observations.
Applegate’s statements of cellulose insulation performance superiority are based on independent studies and surveys that were widely reported starting in the mid-1980s.
In one case a housing authority in Massachusetts insulated four of its residential buildings with fiber glass and a fifth with cellulose. The cellulose-insulated building consumed 32% less energy for heating and cooling than the average of the other four buildings. Over an 11 month period from March 1985 through January 1986 the cellulose-insulated building consumed 30,694 KWH in the same period the best performing fiber glass building consumed 44,084 KWH. This survey was published in Energy Design Update, which was regarded as the publication of record for building energy efficiency. This is a fact, not a misrepresentation of anything by Applegate.
Applegate also cites a published study conducted by researchers at the University of Colorado School of Architecture and Planning, who monitored energy consumption by two test structures, one insulated with cellulose and one with fiber glass, between January 25, 1990, and March 30, 1990. During the test period the cellulose-insulated structure used 22% less energy to maintain an internal temperature of 65 degrees F. Again, this study was published and reported in EDU. This is a fact, not a misrepresentation of anything by Applegate.
Applegate reports and NAD rejected the conclusion of Oak Ridge National Laboratory that as the temperature differential between the cold side and the warm side of insulation in an attic increases the R-value of the insulation decreases due to convective flows within the material. The ORNL scientists demonstrated an inherent characteristic of light density fiber glass – far and away the most common kind – technicians at Owens Corning, a manufacturer of fiber glass insulation, discovered years earlier but never bothered to mention to the public or government officials. The ORNL researchers published their findings in a scholarly paper that was reported in EDU in 1991. This is a fact, not a misrepresentation of anything by Applegate.
NAD justifies discounting the significance of these studies because
1) they are old
2) fiber glass products “have changed since then.”
Certainly the dates of these studies and surveys are documented, but how did NAD determine that fiber glass products have changed? Apparently just because NAIMA and the fiber glass companies claim that they have changed. NAD doesn’t seem to have asked how they have changed or demanded any
supporting documentation of the alleged changes.
Here are the facts.
In the mid-1980s the core of the fiber glass industry product lines was R-11 and R-13 batts for nom 2 x 4 construction and R-19 batts for nom 2 x 6 framing. In attics fiber glass blowing wool with a 0.5 pcf density was the norm. Since then fiber glass products for spray and dry dense pack installation have been introduced and R-15 and R-21 batts are available.
Even fiber glass manufacturers now have displays demonstrating how much better their expensive new spray and dense pack products work than the batts and light density blowing wools that were the only materials they offered until relatively recently, and which still represent the bulk of
Batts, which are notoriously leaky regardless of their R-factor when tested in a laboratory machine, and blowing wools with design density of 0.5 pcf – the exact density tested by ORNL — are still the mainstays of the product lines of fiber glass companies. The “old” studies are still totally valid for most of the fiber glass materials being sold today.
Applegate’s “sin” is not that they misrepresented anything, but that they were not specific enough about the exact fiber glass products being compared with cellulose.
The claim that boric acid is five or six times less toxic than table salt is not true, but it is based on a misunderstanding not a deliberate attempt to mislead. The source for this statement is a report that cellulose insulation containing 20% boric acid is 5X or 6X less toxic than table salt. That factors in the dilution of boric acid as it is dispersed in cellulose insulation. The toxicity of boric acid itself (LD50 2,660 to 3,500 mg/kg of body weight) is actually about the same as table salt (LD50 3,000 mg/kg of body weight). The U.S. EPA considers boric acid to be low in acute toxicity.
As previously noted CIMA cannot dictate the marketing message of its members, but I have personally always advised members against using the term “non-toxic” since it is an axiom of toxicology that everything is toxic depending on the dose. Still, a very respected toxicologist has told me without qualification: “Cellulose insulation is about as non-toxic as you can get, as that term would be generally understood by the public.”
One may disagree with citing evidence that boric acid might lower the risk of some cancers, but such statements are hardly “unsupported.” Anti-cancer effects of boric acid on melanoma were reported in a study published in the journal The Analyst in August 2009. The study found that viability of melanoma cells decreased with an increasing concentration of boric acid, and the researchers concluded that high concentrations of boric acid have an anti-proliferative effect via promoting apoptosis — programmed cell death — of melanoma cells. Another study published in the journal Cell Adhesion and Migration in August 2008 found a similar result with breast and prostate cancer cells. These are published, peer-reviewed papers that are part of the literature, not something invented by Applegate.
Some CIMA members reportedly have laboratory test data supporting the superiority of their products intended specifically for acoustical purposes over competitive products, however a very thorough study of the acoustical performance of walls and ceilings by the National Research Council Canada determined that all fiber insulation materials are about equal in terms of their sound attenuation properties. I can’t help but comment that this study is old – all the wall work was done in the 1990s – so maybe cellulose products have changed since then and the NRC study is invalid. I make no such claim, but this is the logic NAD apparently used to rule that various statements made by Applegate in its literature are unsubstantiated.
Daniel Lea, Executive Director
Cellulose Insulation Manufacturers Association
136 S. Keowee St., Dayton, OH 45402
Phone: 888-881-2462 FAX: 937-506-8060
Direct line: 937-405-5943