The incident at Lewis and Clark helps illustrate how inept the federal government has been in assuring an ample supply of safe, effective insulation. Twelve percent of America's energy consumption goes for heating and cooling of homes, and President Carter has proposed insulating 90 percent of our homes by 1985, saving an estimated 1 percent of the energy used in the country, the equivalent of 180 million barrels of oil a year.
But the administration concocted its energy conservation program without enough homework. The Federal Energy Administration told the House Subcommittee on Housing and Community Development in May 1977 that some 64 million America homes needed more insulation. An FEA official said industry could make enough insulation to meet Carter's 1985 goal. Yet, when the official testified, consumer demand far exceeded supply and there was no federal or state law governing manufacture of insulation. (Later, in December 1977, the Department of Energy, successor to FEA, said it wouldn't help manufacturers increase supplies unless matters worsened.) Little Consumer Protection
THE NEWLY PASSED National Energy Act will not protect the public from unsafe insulation. The only "consumer protection" in it is the requirement that only federally approved products can qualify for the utility programs and tax credit. Under the act, utility companies are to help homeowners insulate their houses and consumers may receive a tax credit for the cost of insulation and other energy conservation products.
But a consumer who chose to pay directly for his own insulation might buy a product that did not qualify for the credit - for example, material made by a fly-by-night company. The only adequate way to protect consumers is to insure that all insulation manufacturers comply with minimum standards of safety and efficacy.
Except for the FTC, the administration and the federal regulatory agencies until recently ignored the dangers of unsafe insulation. The administration took no action; nor did the Consumer Product Safety Commission, even though the CPSC knew as early as June 1975 that some forms of cellulose insulation posed a fire danger.
When it became clear that the administration and regulatory agencies would not act to protect consumers, Sen. Wendell Ford (D-Ky.) and Rep. Toby Moffett (D-Conn.) introduced legislation to establish a safety rule for cellulose insulation. It become law July 11, 1978, and required that CPSC issue a cellulose insulation safety standard, which the commission did.
The law also ordered CPSC to seek an inproved cellulose insulation safety standard. But the legislation did not include standards for fibreglass, rock wool or any of the forms of plastic insulation. Congress didn't set safety standards for those products because so little is known about their hazards. When the National Energy Act was proposed, the entire federal research effort on insulation was a 16 page report on 19 samples of cellulose insulation.
In the area of supply, the Carter administration received something of a reprieve when the demand for insulation slackened beginning in late 1977. Congress had not yet passed the insulation tax credit, publicity came out about the dangers of cellulose and fuel supplies held up better than expected.
During the respite, the Department of Energy published two studies on insulation, one an assessment of the extent of our knowledge about the general subject and the other an examination of insulation housing in Minnesota. The department also proposed a thorough research program to fill in the gas in insulation knowledge. It is still unclear if the department and the Office of Management and Budget will fund insulation studies adequately. Voluntary Program
COMMERCE IS the only other cabinet departmenting to improve insulation safety or quality, and value of its contribution remains to be seen. The department recently started a voluntary program to accredit laboratories that test insulation materials.
The federal regulatory agencies have acted more vigously to protect the consumer from faulty insulation. FTC has proposed a rule covering the labelling and advering of insulation values of all forms of insulation. The rule does not mandate disclosure of safety informal about materials. But misleading advertising, such as claim that Tera Therm is fire-resistant, will still be illegal.
And the CPSC now requires disclosure of safety information about cellulose insulation. When the CPSC issued ruled promptly after passage of the Cellulose Insulation Safety Act, this was a welcome departure from the commission's earlier sluggishness in responding to congressional rectives.
However real, the improvements at CPSC and elsewhere limited. The Carter administration does not even know the exact extend of the problems with insulation quality a safety. And it must decide:
Whether federal assistance is needed to increase supply of safe, effective insulation.
What additional safety and quality standards are required.
What resources should be allocated to enforce insulation safety and quality.
What additional research in necessary.
All those questions should have been asked before the administration issued its policy on home insulation. Since they were not, they should be asked now - and answered.