R-Value Comment

FEDERAL TRADE COMMISSION TRADE REGULATION RULE LABELING AND ADVERTISING OF HOME INSULATION: PROPOSED RULE 16 CFR PART 460 COMMENTS OF THE POLYISOCYANURATE INSULATION MANUFACTURERS ASSOCIATION (PIMA) September 18, 2003 PIMA Comments on the FTC July 15, 2003 Proposed Rule Labeling and Advertising of Home Insulation (16 CFR Part 460) Table of Contents I. Introduction…………………………………………………………………………… 1II. PIMA’s Comments on Specific Proposed Amendments to the Rule………………… 2III. PIMA’s Comments on Commission’s Additional Questions………………………… 14IV. Additional Recommendations for Modifying the R-value Rule……………………… 23V. List of Attachments…………………………………………………………………… 25 2PIMA Comments on the FTC July 15, 2003 Proposed Rule Labeling and Advertising of Home Insulation (16 CFR Part 460) I. Introduction On Tuesday, July 15, 2003, the Federal Trade Commission (“the Commission”) issued a proposed rule that would amend its trade regulation concerning the labeling and advertising of home insulation (“R-value Rule” or “Rule”). 68 FR 41872. The Commission solicited comments on the proposed amendments and additional issues. The Polyisocyanurate Insulation Manufacturers Association (“PIMA”) respectfully submits the following endments and on whether the Commission should propose additional amendments. PIMA is a trade association whose primary purpose is to advance the use of polyisocyanurate insulation (“polyiso”) in North ...