FTC Ruling on InsulTarp

Unknown

HR posted the same under
"FTC underslab Insulation Issues"

I called them yesterday and here is what they had to say:

"Because there is currently no test to determine the R value of reflective material the FTC can only consider thickness as the determining factor which is how they come up with R-2. According to Insulation Solutions' tests, which were done under a slab with a mean temp of 65*, they claim to have achieved R-7.54. They went on to say that the FTC required a mean temp of 75* which reduces that R value to 6.83 and this is where the issue lies. They continue to stand by their product based on it's actual performance and claim there have been no incidents where a job failed because the product did not perform to specs."

They were supposed to email me documentation but that has not happened as of yet. As I've stated in other posts, I do use the product and have had acceptable results with it. When I present it to the customer I also present the option of the styrofoam board and explain the differences, pros/cons of each etc but thus far all my customers have chosen the tarp.

Don't take this as me defending the product or their claims, only my willingness to continue to use it. I fully explain the whole R value vs styrofoam board issues when I sell a radiant job. I find other aspects of the product appealing and include that in my decision to offer it to my customers. Too many people want to lump it in with FFF or FBF products which, IMHO, is comparing apples to oranges.

Supply House Rick

Insul-Tarp doesn't have the R-value it advertized

A recent Federal Trade Commission ruling, as related to Insul-Tarp:

Meyers Enterprises: According to the FTC, these defendants sold an insulation product called Insul-Tarp between June 2007 and October 2008. The product, a thin blanket to be installed under concrete slab floors, was marketed with print and online materials that made deceptive claims about its supposed R-value. For example, the defendants claimed Insul-Tarp’s R-value is 7.54, but in reality Insul-Tarp’s R-value could not be more than 2. The FTC’s complaint charges the defendants with violating the FTC Act and the R-value Rule by failing to base their product’s R-value claims on required testing procedures, failing to provide consumers with the required R-value disclosures, and failing correctly to pair statements about the purported R-value and thickness of their product needed to achieve the claimed R-value.
The court order settling the charges prohibits the defendants from making any energy-related efficacy claims unless they are true and substantiated. It also prohibits violations of the R-value Rule, contains standard monitoring and record-keeping terms to ensure the defendants’ compliance, and imposes a civil penalty of $155,000.

Here is link to the news release on the FTC website:

http://www.ftc.gov/opa/2009/03/rvalue.shtm

http://www.ftc.gov/os/caselist/0823062/index.shtm

Mark Eatherton

Slap on the wrist...

Sounds like they got off easy. Their attorney's bill probably ran a lot more than that.

At least it serves as fair warning to the other hocus pocus insulation companies out there. Now, if we could just turn the attention of the FTC to internet peddlars of hydronic/radiant components....

Dream on...

ME

heatboy_24

Go easy there, ME!

For those of us that do radiant service, the Internet guys are a revenue stream for us.

Here is a picture of a 8 month old pump from one of my "Radiant Rescue" projects.

Unknown

Tell you what,,,

I have a MUCH bigger issue with Insultarp and the internet. My customer found it online for LESS than what I paid wholesale and that is including shipment. I read the riot act on that to them yestrday, he was sputtering something about having to check into it and get back to me when I was through with him. I used the word "bogus" in there somewhere and not in reference to their R numbers. lol....

Nice pump BTW.

Chris S

insultarp

mpf,
All of what you say makes sense sort of. The product has some value. We have installed it on several jobs, again as an alternative. The last piece I rolled out however had a sticker on it clearly marked R-10.
I currently have a job in the works which will get Crete Heat, now that I found a local supplier
Chris

Unknown

Agreed,

I can't defend their misrepresenting the R value nor will I try but I have used it on quite a few jobs and have no complaints with how it has worked. Personally, I see the multi layering to be of greater benefit than the reflectivity, even though they push the reflectivity as being it's advantage. Whenever I propose a job I always make it clear that it does not offer the same R value benefits as 2" of board but it does offer other benefits such as durability and ease of installation. I do not try to misrepresent it's R value and always mention that there is controversy on the subject. Then I let the customer decide for themselves. Invariably they have picked the tarp over the board. In other words I make every attempt to cover my you know what in regards to R values. I have a good mind to do a side by side comparison of my own just to see exactly what the story is. I heard ME did but I have never seen the results.

hot_rod

\"performs similar to\"

doesn't always mean it performs the same as R-10 tested to industry standards for insulation ratings.

The issue is still the trapped air bubbles. How long will the hold "trapped air" and what happens to the r value if or when they lose that air space.

I will say InsulTarp does have some closed cell foam layers in addition to the bubble wrap, and a much more robust jacketing. Still the r-value and it's ability to last is the gift that keeps on giving.

It's a tough problem to correct when underslab insulation fails to live up to the claim. Energy costs for the life of that building are what needs to be considered.

hr

Unknown

Interesting point,

What you're saying is over time the bubble wrap layer could go "flat"? That's something I hadn't considered.

The crete heat looks interesting but anyone who has laid the tube knows what a pain the turns can be if the set of the tube makes it want to twist in a different direction so I have to wonder how securely it is held in there. I'd like to hear from those who have used it.

Unknown

MPF:

it performs at nearly an R-2. Taht is the end of the story. the rest is handwaving and mirrors.

R-2 is much better than nothing. But when they claim much higher R-values "in testing", they are full of it. Period. This has been tested to death

http://www.healthyheating.com/Page 55/Page_55_o_bldg_sys.htm

is all the links to all the tests and info you will ever need. RIMA... the manufacturers' of this type of insulation trade association... proved it themselves in whole-assembly testing several years ago, the results are available on the RPA site members' section but the upshot is, again about an R2. with dirt, concrete, etc.

there is no need to do any more "side by side" testing. There is a need to stop using these products and pretending they are in any way comparable to 2" of rigid foam.

They might be enough on some jobs, but for the price, just use less rigid foam.

Unknown

holds the pipe great. knobs "deform" slightly when you push pipe in and holds it down nicely.

downside is you are at the bottom of the slab.. which isn't a huge deal. it's a small performance difference unless the slab is extra thick. But for purists, you'll lift it on mesh.

Unknown

Yup,

I've seen all this before, they are talking about FBF and FFF, not insultarp, and everybody includes the tarp by association. You'll never see me install either of those products underslab. Because of the multiple layers in the Insultarp I believe it is superior to any of those others. Do I believe the tarp is as good as or better than 2" of rigid foam in terms of R value? No, not at all but I do believe it offers enough to be a viable option. I've heard plenty of horror stories about what a mess rigid foam can be turned into with either the tube pulling away or the foam breaking up from being walked on. That is why I have steered away from it. We got stalled on the job I just did because of town requirements that caused us to hold off almost two months on the pour. The tarp and tube were laying there the whole time. We walked on it and worked on it during the wait. No problems whatsoever. Can't see doing that with foam board. We would have effectively been blocked from doing anything else for the entire time had we used board. There are other considerations than just R value to take into account, that's all I'm saying. Like I said, when I sell a job I offer both, I tell them straight up the board will provide more R value but the tarp offers other advantages that appeal to me as the installer.

Let's talk about one more thing that doesn't seem to come up in these discussions, Delta T or mean temp. If under my slab is 55* and my slab temp is 75* how much Delta T do I have? 20*? Given that, how much R value do I need to make the heat want to go up and out the top of the slab as opposed to down? Not much I'd say.

Again, I'm not defending their misrepresentation of the facts. I'm defending my willingness to use the product. I've achieved good results with it every time I've used it, why do I want to take a chance and start using something that I have no experience with when what I'm using is working for me?

BTW, I always put the tube down low near the bottom of the floor and keep it there. I sat through Siggy's class, I heard what he had to say, I disagree with him but I kept quiet about it. The reason I put it and leave it down at the bottom is so it's harder for some bonehead to shoot a nail through it, end of story. When I leave it down I know precisely how much room I have between it and the top of the slab. As soon as the concrete guys start lifting the screen as they pour I no longer have that info. And wouldn't you know, others in the same class said the same thing, but to each other with furrowed brows, not aloud to the class. There's more than one way to skin a cat. Long as the skin comes off what difference does it make how it got that way? What I really have an issue with is those that will come along and bad mouth my job because I did it my way and not theirs.

Unknown

So you argue that slab insulation really isn't important. I disagree. I would say at least an R-5 would be nice in most cases, certainly more at the perimeter of many slabs. are you doing energy calcs? Or just moving on to the other "benefits"? You're right I"m going to badmouth poor insulation. Sorry if you find that offensive. That's a parasitic energy drain beyond your lifespan or the owner's. That's the very definition of short term thinking, and I'm sorry, I very strongly disagree that it's an acceptable choice in most cases.

I dont care about bottom of the slab vs center: I can tell you i have been involved with easily more than a thousand slab pours using foam board. Whether foam stapled or wire meshed (far more commonly) I can count on one hand mishaps that occurred in full slab pours. That is no justification for improperly insulating a building. Avoid walls, affix the tubing properly, use chairs with mesh if you are lifting or don't lift as you presumably are not doing now. Mishaps are relatively easy to avoid.

Foam board could be pulled up if you were going to be delayed months. Probably better for the pipe than sitting out exposed anyway. But a few sheets of plywood make fine runways as well, if needed in a pinch.

Foam is quite simply a better product. Even 1". At least, at the very least on the perimeter, where your optimistic 20 degree dt is wildly off the mark!

Mark Eatherton

It ALL ends up on the bottom of the slab...

As a master jack hammer surgeon, I have had the opportunity to see where it ends up, even when placed on rebar placed on chairs, and the answer is... (drum roll please) The BOTTOM!

Until they teach these 300 pound size 14 shoed concrete guys how to flap their arms as fast as Peter Pan, it will ALWAYS end up on the bottom. And the only time it really matters is the FIRST time it is turned on. Thereafter slab acceleration is not a big a deal as everyone thinks it is any way...

As for insulating or not insulating slabs, we agree, but certain respected officials of the RPA disagree.

ME

Unknown

All I can argue,,,

is that I have used the product on every job I have done and have had good results with it each and every time. From one end of the spectrum to the other. 20* is not imaginary, if my concrete is 75* and underslab is 55* that equals 20*, nothing imaginary there. Your edge point holds water only if the edge is above grade and even if it IS above grade when I space my tube 6" off the outside wall and the Insultarp is keeping the slab concrete from coming in direct contact with the wall concrete I will argue that there is very little heat transfer going on between the two. Case in point, the job I just finished is a slab over pour above grade. It snows here. I don't see the snow mysteriously melting away around the perimeter of the building. Then, when I started the ice cold slab in the 40* building the air temp in that space rose steadily as much as 2* per hour with only 100* water traveling through the tube, this seems pretty good to me. Within just a couple of hours the space began to feel comfortable. If I'm losing so much heat to the ground, how is this possible? The product works, that's all there is to it. One of these days I WILL do a side by side of my own and I will track the temps over several days. Let's pretend I'm from Missouri.

Unknown

Another case,

First radiant job I ever did. Turned the system on, ran it at 100* with TSP in it and left it overnight. In the morning I get a FRANTIC call from the GC. "OHHHH, I had to turn the boiler off!! Something is wrong!! Its boiling hot down in the basement!!" If I'm losing so much heat to the ground, how is this possible? Talk and numbers are one thing, actual performance is another.

Unknown

double post.

Unknown

You will argue incorrectly that there is little heat transfer on grade slabs at the edge. I know you seem to think there is little, but that's basic heat load calculation there. R-2 means you are costing your clients, and future owners, forever. the 55 degree dirt is best case scenario, center of slab or full buried basement only, and even that is forever... minimization isn't good.

Having poor slab insulation doesn't mean the system won't work. It just means you made a bad choice for lifetime energy usage. and in a slab on grade, on the perimeter, it's an indefensibly bad choice if you do the math.

Unknown

but if you're on top of the rebar, at least you're sure the tubing is fully encased in concrete. that will make a small difference in performance and downward heatloss.

I'm not a purist on the "tubing on the bottom" thing, myself, but there is a small difference.

Unknown

Until the FTC,,,

or anyone else for that matter comes up with a viable test that includes reflectivity in the equation when figuring heat loss through a material the use of words like "bad choice" and "indefensible" are matters of opinion and conjecture on your part. If the product was as bad a choice as you want to infer, it wouldn't work at all and I would not see the results I am seeing. The FTC did no testing, they simply looked at thickness as the entire story and went from there. It's not their fault really, it's all they have to go on. Personally, I think you're splitting hairs. And I have to further wonder if a lot of this bad publicity being generated is not that of one manufacturer trying to make another's product look bad in order to boost sales. Wouldn't be the first time that happened, not by a long shot. You're so worried about it, do something about developing or causing the development of a standardized test to back up your claims. Then we can talk some more. Meanwhile you do your jobs your way, I'll do mine my way. I've been in this business since 1976, if I had a nickle for every guy that thought his was the only right way to do things I'd have retired by now. There may be a difference between the two products and maybe 2" of board is better but I believe the difference is negligible, even in the long run and not as dramatic as you would like to think.

Unknown

Lots of people do stuff because "it works". And that's why our country is filled with monstrously oversized boilers running at 50% efficiency or less seasonally. I don't take "it works" as an argument. It all depends on your definition of "works". Generally it's just a euphemism for a lack of client complaints. I don't find that a very high bar to meet.

You're losing something like an extra gallon of natural gas per year, per linear foot of slab edge, in a 5000 HDD climate just from the vertical edge of a grade slab, assuming you do a good job getting that insultarp up on the vertical edge of the slab (and the same holds true for the rigid foam side too).

Not the biggest deal ever; nowhere near massive system failure;. But it's a continual drain that can be easily rectified only now, when the slab is new. And that does NOT assume anything for wet ground, clay, rock, or other more highly conductive ground situations which will elevate the loss, naturally it's more important in colder climates as well. But it will work. If you're in milder or sandy areas, your comparison is less severe. But on a 30x40 SOG residence, you just blew something approaching 150 gallons of natural gas/year.

The testing is out there. robert bean's page has most of it. Ignoring it is really the equivalent of just plugging your ears and yelling.

Unknown

Well,

I'm going to ease my position a bit although I STILL think the stuff performs better than a simple R-2 based soley on my experiences with the time it takes for the slab to come up. Possibly reflectivity is a factor.

Who has info on an actual independent test done by anybody on the product Insultarp, I would love to see this. Here's why. I just talked to Architectural Testing which is the firm that did the report claiming the R-6.83. Insulation Solutions sent me the report this morning. As a matter of fact, I talked to the guy that actually did the test. What he told me is that IS sent them the test slab fully assembled. It consisted of a board covered by a layer of gravel, covered by a layer of sand, then a layer of Insultarp and then a layer of concrete (which I assume was 4"). It also had tube imbedded in the concrete. They tested the entire "sandwich", hot on the top, cold on the bottom. The 6.83 includes the sand, gravel and concrete as well as the tarp. He said he factored out the board. That's a bit different than testing the Insultarp only, which is what one would assume reading the report. The guy says he's been getting calls on this report "for a couple years now". So, isn't that interesting? Anyhow, I have another call in to him to call back about how much it would cost to have him do another test with Insultarp only. Meanwhile, do I call Insulation Solutions back and ask about this? Hmmm... Not right now.

Unknown

You might be right... I personally doubt that insultarp is really that much better, but hey, maybe. But we all KNOW what R-10 or even R-5 foam board does. no guessing, no wishing for testing, no hand waving about reflectivity, nothing, no question, no argument, it's about as tried and true as it gets. I don't know why we'd fool around with questionable, to put it charitably, claims. Turn your assumptions around and say to clients hey, I know exactly what the r-10 will do. The tarp? Well they, and almost every company like them has been sued for lying, but I'm sure it's good anyway. Then see what they choose. It's all in how you frame it

but even an R-2 provides an extremely significant thermal break that would allow a slab to come up to temperature quickly. Also, slab heating is so variable based on concrete moisture content, that would be very hard to use as a gauge. R-2 is better than nothing by a mile; you would notice that compared to an uninsulated slab. But that doesn't make it good. R-2 in a wall is much better than nothing too, but you wouldn't stop there (not that it's the same!).

Sorry I got kind of heated. I do have some passion for this issue.

Unknown

Not a problem

I got my you know what right in the middle of it, so I'm a bit impassioned myself.

You have to understand, in my mind the tarp is tried and true, that's why I'm having a hard time believing it's such a dog.

Unknown

It'll cost,,,

$500 to get the test done and get a report.

Who's in? <-- just kidding

Supply House Rick

Hey Rob

I'm just glad I didn't start a REHAU floor panel thread...

Unknown

Hey Rick,,,

Why? I'm afraid the innuendo is lost on me.

BTW, I will get the test done, you watch.

Looky what I found:

http://www.grip-rite.com/files/Curing Blankets.pdf

Unknown

they have a study I am also passionate about refuting, because it's misleading marketing. However, the panel itself is very good for sure.

Unknown

also read the R-values shown for those products. that's uncompressed.

Unknown

Yes,

I know. But at least they're honest about it.

Unknown

Oh,,,

now I get it. lol...

BTW, the test costs $300, the official report cost another $200. I'm not ready financially to do this right now but I plan to get it done within a month or so. The story really is that there is no way for them to test it under actual installation conditons. The testing company and I agree the slab thing was probably their attempt to mimic actual conditions but they went way wrong by trying to pass it off as the results of the tarp alone. I had a fairly long conversation with the guy and he agrees that there is at least the potential that reflectivity adds to the formula but there is no way to prove it with a heat flow meter, even though we're going to see what happens anyways. The closest you could come goes back to the timed side by side with an insulation of known R-value but that, of course, has no official guidelines or endorsements to base it on.

Supply House Rick

MPF

It was an inside joke for Rob, when he's passionate about something you'll know...

Mark Eatherton

True but...

I had a GC and a structural engineer advise me against tying my tube to their rebar, Said it would keep the rebar from being completely imbedded in concrete and could affect the structural integrity of the slab.

As well, I have seen a lot of tube that DIDN'T get complete surround, and it still worked just fine.

ME

Unknown

Yep,

so I'm finding out!

Cosmo_3

aaaaaah, can u say open system?

Wow

Cosmo

Stephanie Custis (yes, Mark's wife)

Reflective material

doesn't work unless there is air between the heat source and the reflective material. >>>think solar, or when ppl use reflective solar for tanning. The small amount of air in the bubble foil stuff is not enough for it to be effective (reflective). Remember, heat goes to cold! If you just use regular concrete reinforcing rebar to lift the pex off the slab, it will be enough to give it a push to send the heat up. BTW, I am talking about a gypcrete radiant pour over a slab without insulating between. It also works with a poured slab if the rebar is set higher than half the thickness of the pour. I agree that insulation is better, but our outcomes on energy efficiency on these systems vary little.

Stephanie Custis (yes, Mark's wife)

Raupanel

works great on a bathroom floor in a house that already has a boiler with baseboard heat.

Supply House Rick

Hands down the best floor system out there

RAUPANEL Rules!

Unknown

Should we be,,,

running for cover right about now? lol...

Unknown

as long as I don't see a certain attachment come up, no one gets hurt

Cam_2

You mean this?

hello rob