Mandatory Attic Access Walkways

I submitted the following among proposals for 2018 revision of the International Energy Conservation Code:

Proposal submitted 1/4/2016:

R402.2.4 Access hatches and doors. Hinged doors and lift portals from conditioned spaces to unconditioned spaces (e.g. attics, unconditioned basements and crawl spaces) shall be insulated to the Energy Star standards of exterior opaque swinging doors, and shall be air sealed with well-fitting gaskets. The portal frame shall be sealed air tight in its rough opening. (The standard says: U-Factor ≤ 0.17)

The entry to an attic space at a portal shall have a surround of an ample raised floor that does not diminish insulation value. Flooring shall protect insulation against trampling while giving safe passage, to all attic electrical service points including fans, lights and junction boxes. Junction boxes not accessible from heated space shall be raised above insulation and flooring levels, or where this has failed, shall be flagged as a decked service point. Accessible service points shall include static vents that require periodic cleaning. Where a service point is buried in insulation, insulation over the service point shall be in batt form and tolerant of displacement for accessing the service point.

Existing code of 2015 says:

R402.2.4 Access hatches and doors. Access doors from conditioned spaces to unconditioned spaces such as attics and crawl spaces shall be weatherstripped and insulated to a level equivalent to the insulation on the surrounding surfaces. Access shall be provided to all equipment that prevents damaging or compressing the insulation. A wood- framed or equivalent baffle or retainer is required to be provided when loose-fill insulation is installed, the purpose of which is to prevent the loose-fill insulation from spilling into the living space when the attic access is opened, and to provide a permanent means of maintaining the installed R-value of the loose-fill insulation. 

All of this, and supporting statements offered to conference readers, is summarized in page Better Building Codes For Access Portals, at my web site r5portals.

I defended my proposal at 2016 Committee Action Hearings of the International Code Council in Louisville, KY, on April 18, 2016. There was expressed disdain in the matter of insulation value of a practical hatch, that I cited rival Energy Star standards, and no acknowledgement of my comprehensive math proof, that modest insulation is best; more on that elsewhere. Here, address the second-paragraph flooring requirement, forcefully opposed by one of the rotating intervenors of the National Association  of Home Builders. I took this opposition as formidable, in judges unanimously disapproving my proposal. Several participants privately encouraged me to persist in this and some of my other proposals, but no one came forward as an ally, to help if I would double my onerous personal investment, to offer and defend revised proposals, in Public Comment Hearings, Kansas City.  Those "final" hearings were concluded a week ago, and I was not there. To not feel defeated, I must believe that I am intent upon readiness to try again in the next of the three-year code cycles; then having time to enlist allies.

Here, add defense of the second paragraph of my proposal. I have a really-good example to share, of work done in Oregon City, Oregon June to July, 2016. A customer had discovered that large areas of the attics in his two-year-old home had no insulation. Hard to believe, but evidence showed in zonal early frost melt on the roof, unlike neighboring homes. 500 sq ft was bare, some seen in this view.  I suggest that a mandatory walkway here and an access cut further on, would have led to different and better construction choices. Impaired access is not good, for anyone.

In this photo see beginning of rapid and easy change. The scattered temporary plywood is important to my safety. I have cut down a horrible 16"  OSB skirt about the small access hole.

Move interfering HVAC ducts, and temporarily detach a bath fan duct. Separate HVAC flex ducts at a wye, and move them under the diagonal truss members.

Many trips are needed along a new smooth and level walkway, upon 32" bridges of truss elements. Cut batts to fit, in the garage, and carry pieces in a growing collection of empty insulation bags. A safe passageway should not be an afterthought. Many good things, not least worker safety, result from good access. Let access be lighted too. At least, let workers find power outlets to not rely on a flashlight.

In this access exercise, learn some lessons about HVAC duct installation, attic ventilation and a further thoughtless neglect of access. Preserving duct length is very important as ducts are disassembled and reset. Yet, I must sacrifice about 6" from each flex duct at this wye, because of remnant bad advice of PTCS trainers in the service area of Bonneville Power Administration. Goop, no longer required, should never be applied for liner attachment.

Goop applied blindly and in risk of clothing, missed this under-side zone of the main branch of the wye. There was duct leakage, out of sight. UL181 Nashua 557 tape easily achieves zero leakage here, and is the right choice for easiest damage-free separation of ducts for maintenance or replacement. Know that flexible ducts have claimed useful service life of not more than ten years . See example of Thermaflex ducts as fallen-apart rat paths after about 25 years .

I know that regardless of found condition, I must replace cardboard soffit vent baffles. They rarely survive more than thirty years and when used are with no manufacturer thought or guarantee of acceptable service life (sixty years!). Here I have more than conscience in play. Curl with detached flimsy staples is ugly. Looking down at vent bird block, see poor bird block design employed by most builders. Slot placement demands vent baffles 3 1/2" down from roof sheathing, a large sacrifice of potential insulation depth over exterior wall headers. This bird block is needed in every available roof joist bay, not in every fourth.

Lumber for proper soffit vent baffles is free, in good employment of job scrap. Use 25 cents of good deck screws, not nails. I assembled six baffles in thirty minutes. This is quicker than setting a $1 cardboard baffle, thus less expensive. Wood sleds are easily adapted for obstructions, then set much more securely.

Baffles just 32" tall are ample over R45 batts. I can push R30 top-layer batts tightly against a baffle, for fullest insulation value, and that is the controlling economy.

A hidden attic around this corner was uninsulated too. The triangular access is new. Opportunity was concealed behind redundant OSB sheathing.

While I am at this I will insulate over the garage too, to just R15. I can't bear to crawl there carrying insulation, through this jungle of beam and variable trusses.

Cut in a new access for the garage, "factory built" in my shop. Where truss bottom elements are 2x4, they must not carry loads unless strengthened as composite beams. Leave a couple of 9" rips of plywood that I needed for my safety, but not more flooring.

Here is the fully-dimensioned plan of my hatch, offered to anyone as noted here.

At June 18, 2021, I revisit this post upon reading the post of this date at Insulation Institute Blog: A Hot New Home and Missing Insulation. I see that this post should go further upon process of inspection, not just means of inspection. Process should be for information to the builder and ultimate home owner and not just a manager of building permits. Building permits delve in the short-term self-interest of a builder, to get a certificate of occupancy. They involve inspection requirements  often flouted. by disinterested and unmotivated municipal employees, who take an easy path where inspection is difficult or impossible.

Get better results where inspection is primarily in service of the self interest of the home occupants ever-after. Those citizens of the community  are the real employers of the inspectors. Let these employers then receive indelible proof of critical performance items in the form of pdf documents I call Diligence Reports. A diligence report is created by a professional technical writer rated for integrity and skill in taking photos and notes from the builder daily to generate each required Diligence Report. Report contents are driven by task checklists, and comply with simple national standards. The involvement of three parties in the satisfaction of checklists ensures honesty. 

A recent customer was fascinated with the notion of Diligence Reporting, and made this hat for me! 

I wondered when I would first find cause to share the humor.

A Deep Crawl Space Light-Weight Insulated Cover and Stairs Invention

Please find the origin of this post, in Google Photos:

A Deep Crawl Space Light-Weight Insulated Cover and Stairs Invention 

This is the found-conditions crawl space access in the floor of a closet. Tug at the handle and feel a thirty pound anchor ready to pull you through a hole.

There are ways to drop the hatch cover in rotation off narrow ledges, out of the way.

Stowing back here is tippy and with too much dangerous hefting over the hole.

A new cover gasketed air-tight and insulated  R5, U 0.17 fits within the 1 1/2" thickness of adjacent 2x6 tongue and groove floor sheathing. The functionality of a cover only 1 1/2" thick is an important example to writers of the International Energy Conservation Code, which has failed of a proper statement for 2018 revision .

Here is the view down 60" to the crawl space floor, with a first try of a staircase that hangs from the floor sheathing.

Here are acceptable stairs, made better by removing the top step.  See that sides cut of 3/4" plywood are screwed to 3" thick sandwiches of 2x4. The on-flat 2x4 are bound to the floor sheathing by very many longest-usable  deck screws.

I deeply regret the set-backs cut on-job, to make the plywood sides less a block of passage. The passage to left side here is easier with the setback,  but I'm sure I should have stuck with my plans.

Here is a cross section view of the nine-pound lift-out cover. It is plenty strong. Very little could ever be placed atop in the low-ceiling closet.

Here is a plan view of the lift-out cover and gasketed frame.

As-built stairs, plan view. Note "Better 4th Step," achievable if I had not cut set-backs in the 3/4" plywood sides. The more-protruding step would not be in-the-way.

As-built stairs, cross section view from the side on right hand looking down-hole.

Many people have made this crawl, unhappily, during and since house construction in 1989. The improvement is an inexpensive matter of safety.

Attic Ladder Safety Innovation, 2016

Captioned photos that follow are from web album Innovations In Attic Ladder Safety . The photos are in reverse chronology from Spring 2016 to Spring, 2015. Innovation never ends. I hope mine is speeding up.

The album and this post are in service of a consensus Year-2018 revision of the International Energy Conservation Code, Paragraph 402.2.4. My campaign for the revision began seven years ago, twice missing once every three year revision cycles. My web site R5 Portals  collects all of the campaign information. This blog post will be duplicated in a first installment for a new page at the r5portals site, Innovations In Safety .

2015 IECC states: "Access shall be provided to all equipment that prevents damaging or compressing the insulation. A wood- framed or equivalent baffle or retainer is required to be provided when loose-fill insulation is installed, the purpose of which is to prevent the loose-fill insulation from spilling into the living space when the attic access is opened, and to provide a permanent means of maintaining the installed R-value of the loose-fill insulation."

I believe we need much more access provision, for safe work and achievement in attics. Reaching far, my proposal asks this: "The entry to an attic space at a portal shall have a surround of an ample raised floor that does not diminish insulation value. Flooring shall protect insulation against trampling while giving safe passage, to all attic electrical service points including fans, lights and junction boxes. Junction boxes not accessible from heated space shall be raised above insulation and flooring levels, or where this has failed, shall be flagged as a decked service point. Accessible service points will include static vents that require periodic cleaning. Where there is burial in insulation at a service point, insulation must be of batt form, tolerant of the displacement."

Please judge what compromise here, serves best. 

A near step-through occurred where an inspector toppled from this fragile OSB rim. Such minimal yet expensive structure seems to be prescribed in 2015 IECC. The installed cost of a simple factory-built access plug and surround might be less than that of a plunker and drywall edging. Step through repairs are expensive and often imperfect, and such cost is nothing compared to consequence of injuries, that do happen. Years of energy waste in trampled insulation cancel savings, and those are pocketed by a builder.

Without new flooring requirements, a drop-down ladder here would be no safer. Cheapest ladders are framed for 2x4 floor joists, then if there is not mandatory flooring, again barricaded against initially-deep loose fill, by a similar OSB skirt.






The tentatively-approved 2018 revision of IECC R402.2.4 makes no change of rules that result in the dangerous construction in the photo above, where a drywall plunker would still need an R38 batt gob in Oregon, or an R49 gob in Minnesota. The tentative new rule just allows that, if a drop down ladder is installed, it may be about R8 (U<= 0.10). Present construction endangering workers and an obstacle to good attic weatherization, is not addressed. In debating best rule change that then considers worker safety, we must understand what is possible.

Please see that my IECC proposal is a large compromise of all I find necessary in my work, for my safety, and to guard against liability should a customer be injured. I hope that I can prevent an accident by offering always at no added cost, every safety feature I imagine.

This attic in action is served by a Fakro LTK 22/47 drop-down ladder set at safe 60° angle. 2x10 rough opening sides are suspended from 2x10 composite beams bearing upon hallway walls. A 2x4 safety pole is rigidly attached to floor framing and roof joists. A lighted switch on a safety pole grip empowers bright lighting while a worker is still securely standing on the ladder center section. Footing on the ladder top section is more tricky, then with a hand advancing to bear weight transfers, on  safety pole grips.

An added hinge in the center section is essential to convenient and compact deployment. Bend at the added hinges, and tug straight down. Without the added hinges, the deploying ladder would not clear the ladder frame. Leveler legs give best protection against floor scuffing. Soft-rubber leveler legs also resist the scary phenomenon of "kickout", where a bottom section may suddenly transfer upright if one leans forward, midway up the steps.

This ladder is directly over a garage door. While deployed, a 3-way switch below for attic lighting, acting as SPDT, overrides the garage door operator. Safety pole hand grips are fixed to a truss element.

I modify "Recovery" ladders by Calvert USA, with safer broad top steps. The new step gives match of ladder step pitch, for the 10" distance to the raised attic floor. Probing down with a foot, one will not be tricked by weight bearing on tops of ladder step sides or the top edge of the door. In ladders I prefer, by Fakro, Calvert USA and MidMade, door springs operate entirely upon the ladder door. There is little in the "hole" to snag a person or object carried.

It generally works out that a ladder acts parallel to floor and roof joists, with egress in attic at roof peak. Hold on while moving about the safety pole. Guide yourself by the safety pole. Rails about the hole obstruct, raising new dangers, and I rarely build them.

Here a drywall plunker hole to the attic, replaced by a Fakro LTK 22/47 ladder, is not patched out. A hoist via that opening is offered, where some items appropriately stored in attic conditions, might be very heavy. The LTK ladder has 300 pound rating, but there is more danger in falling while carrying a clumsy object, than in some breakage of the ladder. Observe neat lines and near-invisibility of hatches edge-dressed with flexible grout.

Here is a hoist concept for attic storage of clumsy objects.

A loading hatch might rarely be used. It is closed by a prototype of an R6 factory-built plug. Where usage involves access from the attic via a parallel ladder, added insulation might be placed under the lid, upon the plug, saving perhaps $1 per year of heating cost. Don't spend more than $10 for the pillow!

Portland's 2014 Better Living Show, Attic Access

For more than you may want to know about the contractor view of being in a "green" trade show, please download a PDF album , at Google Docs. The Better Living Show is an annual event in Portland, Oregon. I participated this year with some new messages. My principal display was a working attic ladder, Fakro Model LTK 22/47 . A ladder display may inform in national controversy about required insulation value in the ladder door. An attic ladder has less thermal demand than an exterior door, and need not exceed the insulation requirement of an exterior door, about R3. Most ladders I install are about R5. Several jurisdictions in USA require an attic ladder to exceed R10, causing great confusion.

Fakro LWS-P 22/47, R 5.2
$2.10 per year replacement heat cost

Fakro LTK 22/47, R 7.5
$1.64 per year replacement heat cost

Fakro LWT 22/47, R12
$1.15 per year replacement heat cost, at ladder price higher by about $300, than for LWS ladders. Where the savings in replacement heat cost are more by only $.95 per year, payback on the larger investment is an absurd three hundred years.

Show visitors might support reasonable decisions on required ladder insulation, preferring minimum R5 .

I really like the R7.5 show ladder, but can not sell it at price much higher than that of the very nice LWS ladders. I think the better LTK features are worth another $100, but that can not be for better R-value. 

Here is the LTK ladder upon a display structure imagined and built for the show.

This is much nicer than confusing displays I presented at shows in 2008 and 2010:

This is the compact deployment of a ladder that I achieve by cutting ladder sections, adding hinges. Please see deployment I call "friendlier", in a slide show that plays as a movie.
Compact Attic Ladder Deployment . 

LED lights displayed are those I honor at Pinterest . Please see there how you may buy them. These lights are the subject of many blog posts . I keep a small inventory of these lights, and employ them as a large factor in weatherization savings that I achieve.

A visitor might have climbed the display ladder to see how I install ceiling light junction boxes. Here I ran out of time, and did not run wires. For more detail in this, and for other innovation in electrical device mounting, please consult this Picasa album .

I hoped a home builder would stop by, and would order a few insulated attic access plugs. This is much less expensive than framing in and drywalling the surround of the usual leaky drywall plunker with a useless R38 batt tied on. Know the batt pulls away from drywall in closure, and has no insulating effect, just one more bad joke on new-home owner. This is tolerated by jurisdiction authorities, some smart enough to know better; here now, is exit from fraud. Exit too from harm to those struggling upon a stepladder, worried about defacing or breaking the fragile drywall, about to fall. I imagine a finger-grip in the drywall face; push up twist and tug down, and stow clean against your hallway wall. There is some weight, from 5/8" drywall for a ceiling with 1/2" drywall, compensating for gasket thickness.

A worker in the attic may close the hole for many good reasons including his safety. There are so many good reasons for this, and the show visitors took no notice.

Here are drawings of the show access plug. I imagine demand might establish a usual opening about 20.5" by 30" in 24" framing.

Let's do Portland, Oregon gas-heated home Insulation Math on this plug:
Plug is 18.25" x 20", 2.53 sf
R7.5 foam is 16.75" x 18.5", 2.15 sf
Wood frame at  R1.4 is 2.53 - 2.15 = 0.38 sf
2.53/(Reff +3) = 2.15/(7.5 + 3) + 0.38/(1.4 + 3)
Reff = 5.7
Annual heat cost = 2.4*2.53/(5.7 + 3) = $0.70
vs. R38 floor: 2.4*2.53/(38 + 3) = $0.15
Vs. no access, this plug adds 55 cents per year to home annual heat cost.