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Fire Retardant In Foam Plastic Insulation?

Foam Plastic Insulation and Fire Safety

for High-Performing Buildings


High-performing foam plastic insulation, whether made of polyisocyanurate, polystyrene or polyurethane, is an innovative building product that significantly improves a building’s energy efficiency and helps control the indoor environment. These foams are widely used in roof and wall applications, insulated windows and doors, and appliances such as water heaters, refrigerators and freezers, and can serve as air barriers and sealants. Foam insulation not only improves energy efficiency, but also helps meet high consumer expectations about building performance and comfort. However, changes to the International Residential Code have been proposed that could result in the removal of a vital and desirable fire performance component found in these foams, threatening the safety and well-being of building occupants and fire safety professionals.


Building Codes and Flame Retardants Help Prevent Fires

Current building code fire safety provisions have been in place for decades, and are the result of years of analysis, testing and a robust and inclusive public development process. In today’s modern homes and buildings, building product manufacturers add flame retardants to their products in order to meet applicable fire safety standards and codes. In addition to insulation, building uses of flame retardants include electrical wires and cables, paints and coatings, structural and decorative wood products, roofing components, and interior finishes and trim.

Flame retardants in foam insulation serve as an important line of defense when it comes to fire safety. They can help delay ignition and slow fire growth of the foam plastic insulation, which gives occupants precious time to escape. Despite this, some advocacy groups and non-governmental organizations have advocated for changes in the ICC International Residential Code that would lower fire performance standards by allowing the use of foams that are manufactured without flame retardants and do not meet minimum fire performance criteria.  

This ill-considered course of action threatens public safety, and building code officials in Pennsylvania need to understand the serious implications of this proposal.


Expert Reviews of Science: Toxicology and Fire Safety

Flame retardants in foam plastic insulation help protect occupants, owners and workers from fire-related death and injury, and property loss. According to the Materials Flammability Group of the National Institute of Standards and Technology (NIST), products treated with flame retardants provide additional escape time compared to untreated products. Notably, no fire test studies have been published to date establishing that foam plastic insulation not treated with flame retardants, even when protected by a thermal barrier, provides equivalent performance to flame retardant-treated foam plastic insulation.

Those advocating the code changes claim that potential health hazards associated with flame retardants outweigh the fire safety benefits flame retardants provide; however, scientific risk assessments from around the world have consistently found low to no human health risk related to foam plastic insulation containing flame retardant.


  • The European Union’s May 2008 Risk Assessment on TCPP, a flame retardant that is used in polyurethane and polyisocyanurate foams, concluded that existing practices to prevent environmental or consumer exposure to TCPP are sufficient, saying, “[t]here is at present no need for further information and/or testing and no need for risk reduction measures beyond those which are being applied already.”

“Based on the adequacies of the margins between upper-bounding estimates of exposure to HBCD and critical effect levels, it is concluded that HBCD is not entering the environment in a quantity or concentration or under conditions that constitute or may constitute a danger in Canada to human life or health.”

  • The U.S. Environmental Protection Agency (EPA) performs risk assessments to evaluate the safety of chemicals. EPA recently indicated it will begin assessments on 20 substances used as flame retardants in a number of products, including TCPP used in polyurethane and polyisocyanurate foam insulation. The foam insulation industry supports this approach (
  • In a separate activity, EPA’s Design for the Environment (DfE) program has partnered with interested stakeholders to assess flame retardant alternatives to HBCD in polystyrene foam insulation for buildings, including new polymeric products. The final report is expected in fall 2013 (


Advocates of the proposed changes and those who oppose the use of flame retardants in foam insulation have been attempting to side-step one of the International Residential Code’s existing, minimum and basic fire performance test provisions, specifically the ASTM E84 Steiner Tunnel Test. However, the proponents of changing the code have not provided any test data showing that foams without flame retardants, even those with an additional thermal barrier, will provide sufficient or equal fire performance. Any reduction in fire performance or safety presents an unacceptable danger for occupants and first responders, and has legal liability implications for building owners, manufacturers and building professionals.


Set Flammability Standards Based on Performance Testing

The laws, regulations, building codes and performance standards that govern building fire safety are based on years of experience, analysis, testing, and a robust and public development process. Any assessment of potential health risk associated with the use of flame retardants in foam plastic insulation must be based on scientific research that takes into account hazard and exposure.

The current fire test and performance requirements outlined in the building codes were established through a deliberate public development process that continuously draws on the expertise of and analysis by fire scientists, the fire services, fire testing laboratories, code officials and other experts. As a result, any change to existing building code fire safety provisions should come after careful study, analysis and deliberation through a recognized voluntary standard development organization or code body. A rush to bypass the E84 requirement might undermine residential building fire safety and lead to terrible, unintended consequences.

Foam plastic insulation manufacturers are committed to product safety and effectiveness, and they support research and innovation to continually improve the performance of these materials. Foam plastic insulation with flame retardants delivers the energy efficiency, comfort and fire safety that today’s consumers demand and deserve.


 About the Author

Jesse J. Beitel is the code and fire consultant with Hughes Associates, Inc. He has provided consulting services on a wide range of flammability problems and issues to include technical studies, experimental programs and Code representation. Hughes Associates, Inc. clients include, among others, the Extruded Polystyrene Foam Association, a member of the Energy Efficient Foam Coalition (EEFC)


PENNBOC encourages members to read this and other on-subject documents and then form their own opinion on preserving the inclusion of flame retardants in foam plastic products. Members are encouraged to participate in code change hearings and supporting individual changes in a manner they deem most appropriate.

By Admin
Tue, 01 Oct 2013 19:47:03

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