Fire Hazard Prohibition of Cheap Fans, Can Lights or Cut-In LED Edge Lights

The just-prior post at this blog is a  call that all residence attic access portals must be suitably air-tight and resistant to fire propagation. By the same reasoning, ban ceiling lights that penetrate drywall, leaking energy and propagating fire. Where the USA has surrendered leadership in lighting concepts to myriad fabricators in China, clip-in LED edge lights have become a madness tipping point. These clip-in lights dominate big-box store displays, ruining homes with ceiling cuts nearly as big as the light lens diameter.

Many posts at this blog deal with air-tight disk-LED installation in strong RACO 175 steel boxes. There is much reporting of the fire-resistant and efficient replacement of awful can lights, with box-mounted disk LEDs. With factory-produced drywall rings precut to can OD and RACO 175 octagon ID, and with some patching grout, a can light may be upgraded in an affordable few minutes. Of many jobs with lighting improvement, one of Winter 2014 is most memorable, for thorough presentation of the math of energy savings. This home built in 1988 was the subject of four blog posts already:

Math Of Under-R12 Attic Floor Insulation Rule, For Incentives, March 17,2014.

Daring To Collapse and Rebuild Crummy Loose-Fill Fiberglass Insulation, March 6, 2014.

A Skylight Insulated >R30, With Plywood Hard-Covering , July 14, 2014. Photos 

Can Light Replacement Math, January 2, 2016

I was called to improve personal safety and the capacity for attic storage. I added fire safety at the attic access, but was not yet mindful of other ceiling penetrations as matters of safety against fire propagation. 

A silly hinged wood door opening to dangerously small headroom, gave little storage potential nearby, over tops of 2x4 truss bottom elements, among loose-fill fiberglass insulation. Something smarter was wanted.

At planned egress to the attic under the roof peak, see that there is no fire separation of garage and house attics. An attic ladder to be added, must be thirty minutes fire-rated, matching surrounding 1/2" drywall. Yes, this garage ceiling has 1/2" drywall. 

I offered this new "Calvert Recovery" Size 2248 fire-rated attic ladder, set in 2x4 trusses strengthened as better than 2x10 framing. Good Calvert USA ladders with small premium for fire rating, were a fleeting opportunity in 2014. The Maryland attic ladder business operated for about ten years, beginning with a few wood attic ladder models built in the Czech Republic. Ladders then Made In USA had novel features including frames and steps built of best 3/4" plywood, stiffer and stronger than ordinary wood.  The factory closed in 2016.

The Calvert fire-resistant door is of heavy 3/4" thickness treated-composite wood. Not rated, but at least U = 0.25, with affordable heat loss when properly gasketed.

Here the installation is fire-sealed about the ladder frame, with a strong taper of flexible grout covering reveal of the wood ladder frame. I do not use wood trim, that usually just hides shimmed large clearances about the frame, defying the fire rating.

With the better access,  replace a badly-installed-as-usual noise-maker bath fan.

Plastic bodies, thin aluminum frames and large flame paths at air gaps are fire-propagation hazards.

Don't expect to find an offered fire-rated bath fan.

Prefer solid steel warm air ducts for bath fan exhaust. Never a plastic duct.

We find duct foolishness like this even with a kitchen exhaust fan sometimes, Here it is not a building code violation. A much shorter duct directed through-roof,  is just common sense, and is required by rebates sponsor Energy Trust of Oregon.

I offer only simple and rugged Panasonic bath fans as replacements. The solid steel body with penetration only at the duct bell, might sport a 30-minute fire rating if required. It clearly is improvement. The hard-plastic grill is not an accelerant of flame.

Preset the outlet bell assembly standing alone, clipped to drywall.

Insert the body from below, sliding past and securely attaching to the outlet bell assembly

There will be no fire propagation about the fan body.

Wall header gaps commonly 1/8" surely propagate fire that has penetrated walls. Learn to see sealing of gaps as mandated by fire-prevention codes.

My flexible grout, chemically similar to Custom floor tile grout, will not carry flame. 

Foam foolishly prescribed for weatherization contractors, is immediately skinning, and rarely bonds airtight. The foam itself is quite flammable. Foam sealing must be forbidden. I remove and replace foam whenever found. What a mess. What a crime.

Two incandescent bulbs upon porcelain lamp-holders supplemented the twist CFL bulb of the garage door opener, in a dismal garage. The 2 7/8" fiberglass box with knockouts, and large gaps to drywall, both propagate flame.

There is no economy in junior box size. Crammed wiring is less safe. A best LED light now demanding converter space in the box, is not possible.

Install air-tight RACO 175 boxes with mount structures built of scrap 3/4" plywood and select 2x4 remnants.

Install Lithonia Versilite FMML 7 830, two places. 

I must fully grout the RACO 175 to drywall annulus despite nearly airtight enclosure when the luminaire is pulled against the ceiling. Keys for mounting screws admit bugs seeing light through the box annulus.

Lighting in the garage remains barely adequate. In a wished  return visit look for bugs in light lenses, and offer more light positions.

I have no room-side photo record of six can lights found  in the kitchen, holding hot 150 watt incandescent floods by my records. 6 1/4" OD cans had especially large annular gaps, to 7" drywall cuts. Can interiors must have been loaded with cobwebs.

Lightolier cans over the kitchen have the usual obstacles to absurd covering of a non-IC can with a Tenmat Hat, never air tight to the drywall, little resistant to fire, not resisting energy losses, certain to be thrown off by pressure differential in a fire.

Poorly-accessible space over the kitchen sink was warmed with lack of insulation, congenial to mud wasps.

The better kitchen ceiling has the 7" opening of a can invisibly and quickly replaced by a ring of GP Densarmor drywall, fitted to a heavy-gage steel RACO 175 deep junction box. There are no leakage paths from the box, to the attic. This is fire-proofing!

The drywall ring has full penetration grouting at the OD and at the RACO interface. I have built and installed hundreds of these mount structures built of scrap 3/4" plywood and select 2x4 remnants. Two screws attached through the ceiling drywall pull the patch into alignment.

6" Glimpse LED disks are not glaring. They are pretty.

A bit of fire-proofing, however much perpetual energy saving was the sure achievement. Those savings are detailed in the linked prior blog posts for this home. Copy the math statements here:

The can annulus diametral clearance was 7” - 6.25 = 0.75”, quite large. The frame was not pushed against the ceiling, and probably did not further constrict the passage of leaking air. Each can light had a gap of up to 7.8 sq in.  Apply Insulation Math for a Portland, Oregon home with a common 88%-efficiency furnace. The annual cost of heating lost air is $0.555*Path Area, $4.30 per year. At four places I replaced a 65 watt incandescent downlight with a 750 lumens 14.5 watt LED. Another can that had a long-dead 65 watt incandescent was patched out. At the sixth can, over-sink, I installed a 450 lumens 9.5 watt LED in place of a 150 watt incandescent downlight. 

Apply Insulation Math . Completing insulation in the floor should save, at each light:
$2.4 * Baffled Area, sf* (1/3 - 1/50)  = $0.75 * Baffled Area, sf
= $1.30 per year for an 18” baffled circle (1.8 sf).
= $3 per year for 4 sf uninsulated over the kitchen sink

There is about $6 per year typical savings from air sealing and insulating each very leaky non-IC can light. 

Additionally, credit $12 per year electricity savings vs. the found 150 watt incandescent flood bulbs, with basis $0.11 per KWH. 

Overall annual savings for the home due to my work:

$116 (22%) Fix Kitchen Lights

$160 (30%) Insulate Attic Walls to R30

$101 (19%) Seal Wall Headers

$199 (29%) Insulate Attic Floor to R38

$536 total annual energy savings

 A small flight of steps beyond the ladder egress serves much of the added storage area, little obstructed by truss uprights.

Treasure was was waiting to be found in the efficiency, safety and usefulness of an attic.

Added content 9/3/2023:

With the encouragement of a received comment, add details of the bath fan replacement, that is is fire-resistant as can be. I replace awful plastic noise-makers with solid-steel-boxed basic Panasonic fans. See posts Label Bath Fans , steel-ducted through the roof just as is code-required for kitchen exhaust fans with their grease-fire propensity.

All Residence Attic Ladders Must Be Fire-Rated

 Please accept this as a wake-up call from a global misunderstanding:

https://codelibrary.amlegal.com/codes/willcounty/latest/willcounty_il/0-0-0-48114 

The link brings up a specific regional ordinance, in Illinois.

 150.060 FIRE RESISTANT CONSTRUCTION REQUIREMENTS.

   (A)   All conditioned spaces shall have all interior wall and ceiling surfaces covered with a minimum of one-half inch gypsum wallboard or approved equal. One inch nominal solid paneling shall not be required to have a drywall backing.

Who may argue that this doesn't apply in every home, in every jurisdiction, not excusing doors of attic ladders? It can't matter that rules for attic ladders in those jurisdictions may be forgiving. Failed enforcement is met with non-availability of suitable, affordable ladders. It must be believed that resistance to conflagration at every point, makes a difference. 

Plunker Access Has Been Treated Correctly

Here is an example of my writing and invention, at this blog. I improve upon persisting builder foolishness that despite a fragile and endangering gob of R30 insulation, is only R5.7.

This frame is 22.8” x 31.4”. The R38 unfaced batt is nicely square-cut 22” x 23”.

The fraction of drywall area covered by the batt is 22*23/22.8*31.4 = 0.707.
1/(Reff + 3) = 0.293/3 + 0.707/41
Reff = 5.7

Reff + 3 is the total heat transfer resistance number, and the inverse, U = 1/(Reff + 3), is 
U = 0.11

I'm all-in for 5/8" drywall in a factory-produced less-expensive and safer alternative, almost invisible and not to be hidden away within a closet. Perfection of a drywall cut with inserted steel edges is the same as I offer for attic ladder installations. The hatch here illustrated is over the garage of a modern home in Oregon City, Oregon, the subject of this blog post upon value of thoughtful attic access. Must I do better, against flame that may penetrate small gaps?

U-Value calculation for the hatch plug assembly:

Consider only the materials of the 1 1/2” framing 14%, and Rockwool, 86%. R4.3 per inch, R6.4. The R-value of wood is about 0.94 per inch, 1.41.

1/(Reff + 3) = .14/(1.41 + 3) + .86/(6.4 + 3) ; Reff = 5.1

Add three and invert, for U-value: 0.12.

Multiply this American U-value by 5.7, to obtain European U = 0.7

Drywall or better on doors of attic ladders too!

Until now I have been blind to nonsense where a hard-to-find and expensive fire-rated attic ladder is considered only for a garage with attic space that is in-common with attics of the rest of the house. A not fire-rated door typically has top and bottom facings of 1/4" MDF, wood edges and blocking, and well-fit pieces of factory-cast expanded polystyrene foam. It is not at all tolerant of fire!

At play is the simple enforcement of Building Codes. Current Energy Codes foolishly and hurtfully demand that ladder insulation value must match the surrounding attic floor R value. There has never been reason an attic ladder as a door, should have better energy retention than any exterior door. I must renew my campaign for r5portals.

The phrase R5 Portals is expressed as a challenge that every service or access door in a home must be at least R5, and let that not be exceeded in building code requirements.

Don't be taken in by foolish instruction that an attic access is a sin. An R5 hatch or ladder has smaller energy-replacement cost than any exterior door. Achievable savings in any practical improvement are of the order of just a dollar per year, as I presented for proposed  2016 revision of the International Energy Conservation Code. I was not respected and was not heard by judges helped-along in their needfully-hasty deliberations by ever-present lobbyists pinch-penny for the National Association of Home Builders. Prevailing new rules rules demand insulation values not achievable with practical fire-rated doors. Safe building codes must rule.

A fire-rated ladder can be compromised by thoughtless installation, big gaps all around, poorly hidden by flimsy wood or plastic trim, not air-tight despite careful gasketing. Here is frameless and air-tight trimming of the ceiling cut, that I practice, applied with a Swedish MidMade fire-rated ladder:

I admit not knowing how a door with thirty minute fire rating is built. See that a strong, square, tight edge of the ceiling cut is built by grouting-in pieces of steel angle.

Here is the inside appearance of a MidMade ladder thus framed. The rough frame, out of sight, is tightly fit to the ladder frame. There are no missed opportunities of placing full stuffing of insulation. A floor super-insulated forever, brightly lighted and clean, adds very much value to a home. Let a tall attic be your expansive carpentry shop, comfortable part of the day almost year-round. Make rugs.

Fresh Air is Almost Free

At 3/15/2024, look for naivete that might be criticized in overlooking cost of conditioning moisture in the air. Google: air conditioning: air conditioning: the relative cost of heat gain and humidity regulation. Choose this result: https://www.achrnews.com/articles/146975-nrel-discovers-humidity-is-why-a-c-units-consume-so-much-energy Find that for a portion, perhaps all,  of Cooling Degree Days, air conditioning cost should be doubled. The math gets messy, but this is a moot point. Whatever the cost, we must have that fresh air exchange. It doesn't matter whether air to be expelled, then somehow replaced, is driven by a clothes dryer, or a bath fan, or holes in walls of an otherwise airtight home. Where few of us will ever have opportunity to invest in expensive HRV or ERV, the neglect is not a dominant concern. The cost of comfort will still be mostly from defects of insulation perfection and window placement. The cost will be directly regulated by generation efficiency as in upgrade to heat pump technology.

At this post of February 23, 2023, Costs of Running A Miele Heat Pump Clothes Dryer

I share a surprising finding that conditioned air dumped outdoors in USA  ordinary clothes drying is replaced at very modest cost of about $6 to $16 per year, dependent on HVAC efficiency.  The very simple math for average-USA climate, is indisputable.

Healthy provision of fresh air in our homes at required 0.35 ACHnat, 7 ACH50, is at very small cost. That cost, about $100 per year for a well-built 1000 sf home, is unavoidable. If a home is more-expensively built to Passive House standards, less than 0.6 ACH50 , fresh air must be drawn in by other means, to a total of at least 7 ACH50. Those means can be absurd, perhaps with net increase of operating costs. Powered means may be unreliable with expense in operation and repair/ replacements. Occasional reporting of false economy in air tightness, in this blog , is not kindly regarded by readers.

The physics fact in this is that air has extremely small heat capacity, rising or falling in temperature without much gain or loss of thermal energy. In-home air-to-air regenerative heat exchangers save little energy vs. operating costs including maintenance. The value in regenerative heat exchange is related to the heat capacity of the moved fluid, mattering a lot for high delta-T liquid systems, and little for small delta-T gases.

I was not heard, when I spoke out to the full assembly of March 2016 hearings of proposed 2018 revision of the International Energy Conservation Code, Louisville, KY. I was dismayed by the many proposals sought to surrender the enforcement of construction quality, to  numbers in blower door tests. I call that Blower Door Madness.

In a few words I stated an Insulation Math finding that for  my Portland, Oregon 1000 sq ft single-story home with 8 foot ceilings, 4400 heating degree days, natural gas heat at $2 per therm, each ACH50 of fresh air brings a conditioning cost of only $10 per year. Tightening a home is almost irrelevant to the total of typical HVAC costs. The attention should instead be upon perfection of a complete home insulation envelope with thoughtfully-placed windows. The best insulation envelope is fully filled, precluding air convection, air-tight all-around, not determinant by a blower door.

Where it is accepted that a healthy home should have minimum 0.35 ACHnat,  times-twenty, 7 ACH50, air exchange in my home is at natural gas cost of a modest $70 per year. Home HVAC cost is very little related to provision of healthy fresh air. Don't we all know that pulling makeup air through gaps of ordinary good construction 24/7, is better than pulling outside air at a pipe to the HVAC return, only when the air handler is running? Those odd pipes in so many new homes, are not part of any regenerative heat exchange or of thoughtful filtration of the the outside air.

Where annual usage of natural gas might be at cost of $400 per year, the healthy fresh air cost $50 at estimated 5 ACH50 tightness, is about 12% of that total, and is unavoidable.  There is a gas clothes dryer perhaps accounting for 15% and reducible by about $50 per year by the investment in HPCD.  It will make sense for sure, when all natural gas service is terminated, with heat pump HVAC. Heat pump HVAC is interesting now, from need for summertime cooling not now provided.

I have no further possible savings in adding of insulation. Recent gas usage of about $470 per year are probably with comfortable temperature setting near 70°F. Where I lived alone in the house under its reconstruction, thermostat at 55°F, I demonstrated the potential of about 50% savings in a bearable life of dressing very warmly to be comfortable.

And then natural gas cost ramped up. Don't expect cost to come back down, ever. Pain boosts interest in all-electric heat pump HVAC.

Local-Option Energy Codes are not the best or only tool for meeting municipal carbon goals through residential energy conservation.

 I found this message in news feed 6/9/2021, from group Onward Oregon:

Tell your legislators to support 100% clean energy and stronger local energy efficiency standards

A message from our friends at Climate Solutions:

House Bills 2021 and 2398 are concrete steps we can take to reduce air pollution, address the climate crisis, and help protect our state's beauty and livability for decades to come.

 

Please urge your state legislators to prioritize climate action by passing House Bills 2021 and 2398 this year!

Bill; 2398 action touted at the  link is mainly the adoption of Reach Code, 

Relating to building codes; declaring an emergency.

Adds Reach Code to state building code as specialty code and gives power of administration and interpretation of Reach Code to Director of Department of Consumer and Business Services. Requires director of Department of Consumer and Business Services] to follow same process in adopting or amending Reach Code that director follows in developing residential and commercial building codes and to ensure that statewide Reach Code mandates achievement of not more than 90 percent of site energy use that other statewide residential and commercial building codes require. Requires director to adopt Reach Code not later than October 31, 2021, and at same time director adopts corresponding residential specialty code or corresponding structural specialty code, updating Reach Code at least every three years. Permits municipality to adopt Reach Code and require adherence to code as minimum construction standard and method within municipality's jurisdiction notwithstanding requirement that state building code be uniform and applicable to all municipalities in state. Provides that municipality's adoption of Reach Code is not amendment to state building code and does not require approval of director. Provides that municipality that does not adopt Reach Code does not need to enforce Reach Code within municipality's jurisdiction. Declares emergency, effective July 1, 2021.

Learn about Reach Code at the following links:

https://www.oregon.gov/bcd/codes-stand/Pages/reach.aspx

https://www.oregon.gov/bcd/codes-stand/code-adoption/Documents/21reach-res-draft.pdf

Good heat pump water heaters are further supported. There is modest improvement of exterior wall insulation, with 2x4 framing allowed. There is no change of attic insulation required.

Where my interest is in the achievable improvement of existing homes, I am disappointed in this push upon me to support legislation. Building codes apply only to new homes prior to first occupancy. And, yet, outdated and interfering Plumbing Codes are addressed in municipal permitting of the HPWH opportunity. We must not let permitting delay, or even halt, energy conservation.

I believe this is feel-good action to do something for residential energy conservation, to be credited to municipal goals in carbon reduction, via easy change of building codes.A simple "Reach Code" is the largest break from statewide codes that might get past opposition. The goal isn't really-better building code. It is the allowance at all, of local options.

Local option is not limited to code adoption. Much more can be achieved toward municipal goals by actually directly inspiring prospective new-home owners, and especially, existing-home owners through financing benefits that might be offered with burgeoning public-bank deposits of the revenue of existing  accepted, carbon taxes. In Oregon, these taxes include mainly our Public Purpose fund take of 3% on residential and commercial energy consumption in the form of electricity and natural gas. In City of Portland, largest corporation profits are now subject to a 1% carbon tax on profits. All of this existing carbon tax is spent-down every year with little benefit to consumers and to green jobs workers in clean energy.

My wishful thinking upon proper use of carbon tax revenue as funding of beneficial  loans-only from perpetual and growing funds. is addressed here:

Good Things: Oregon Carbon Taxes and an Oregon State Bank

Improvements in my thinking are overdue.  They might grow through beginning at last, of legislative action. The first needed action is a constitutional amendment to undo a still-in-effect absurd badly-spelled 1880 Oregon Constitution prohibition upon a State Bank.

Article X!, Section 1. Prohibition of state banks.

The Legislative Assembly shall not have the

power to establish, or incorporate any bank

or banking company, or monied [sic] institution

whatever; nor shall any bank company,

or instition [sic] exist in the State, with the

privilege of making, issuing, or putting in

circulation, any bill, check, certificate,

prommisory [sic] note, or other paper, or the

paper of any bank company, or person, to

circulate as money. —

Note: The semicolon appearing in the signed Constitution

after the word “whatever” in section 1 was not

in the original draft reported to and adopted by the

convention and is not part of the Constitution. State v.

H.S. & L.A., 8 Or. 396, 401 (1880).

The public surely supports repeal of this prohibition. Let's get that done.