Category Archives: Global

The readers of Insulation Outlook are usually involved in some facet of the commercial, industrial, or mechanical insulation business, whether manufacturing, installing, specifying, or evaluating the need for insulation. They are professionals and businesspeople, and they understand the need for a business to make a profit to remain viable. What is your company’s net profit at the end of the year? The National Safety Council estimates that $1 in direct costs from an injury can become $3 to $10 in indirect costs. How much of this can a business sustain and still make a net profit?

The number of individuals who have never thought of or have been unable to grasp the implications of safety as they affect the bottom line of a business is amazing. Business owners are constantly evaluating the economic viability of their businesses by looking at the cost of production versus net profit at the end of the year. Frequently, when these numbers are found to be unsatisfactory, anything seems to be fair game for blame—except a lack of attention to safety. Managers will point the finger at increased prices for raw materials, the insulation we are installing, and fuel; the expenses of employee wages and benefits; and so on. How many managers, when evaluating these economics, ever sit back and look at the cost impact that their safety program—or lack thereof—has had on the bottom line?

The Cost of Ignoring Safety

Let’s take a minute and look at some of those costs. Of course, with the small contractor, it only takes one accident to have a significant impact, whereas multiple claims can have a similar impact on a larger company.

This article examines just the economic impact of safety issues and ignores the collateral issues that can arise, such as intentional tort lawsuits, Americans with Disabilities Act (ADA) claims, and Family and Medical Leave Act (FMLA) claims. First, there is the injury itself. In a typical injury, the employee will be off work for a minimum of 6 weeks. So, for the 6 weeks the employee is off the job, the company has to have a replacement worker. If the injured employee is a good producer who performs high-quality work, the replacement employee might have to work overtime to accomplish a similar quantity and quality of work. So, for this period, the company may have an additional $100 to $200 a week in labor costs to accomplish the tasks of the injured worker. In addition, the employees who are on the job, depending on the nature of the injury suffered by the absent worker, may slow their production because of their concern about their own safety. This can add significant time to accomplish the tasks required and, again, add to the cost of getting the job done.

After the accident, management must frequently perform an accident investigation. Depending on the seriousness and the complexity of the accident, this can tie a crew up for an entire day or more. This downtime can result in contract penalties if it impedes the ability to get the contract accomplished on time and/or requires overtime to be paid to the entire crew to get the job finished per the contract.

After the accident, while the injured worker is on workers’ compensation leave, the company’s workers’ compensation insurance premium will be affected by the cost of the claim. If the injury results in a lost time claim, the company could see a significant increase in its insurance premiums. Again, while one on-the-job injury can have a significant impact on a small employer, multiple injuries may have a similar impact on a larger employer. Of course, the more employees a company has, the greater the likelihood of lost time injuries occurring, especially with an employer who is not taking safety seriously.

What To Watch For

Following an accident, an increasing number of employees are calling the Occupational Safety and Health Administration (OSHA) to complain about the safety conditions on the job site. They do this for a number of reasons. If they have retained the services of a lawyer to pursue their workers’ compensation claim, the lawyer may advise an OSHA complaint to cause an OSHA investigation. This typically results in a free accident investigation for the attorney of the injured worker, enabling the attorney to gather information that might be useful in bringing a lawsuit against the employer, the principal, the general contractor, or some other third party who may have had some impact in the causal connection with the on-the-job injury.

Of course, the OSHA inspection will most likely require the company to contact its legal counsel to determine what, if anything, can be done to prevent an adverse impact on its overall safety record because of that investigation. There is an increasing number of general contractors who are barring subcontractors from even bidding jobs if they have had a willful violation within the 3 to 5 years preceding the contractor bid. So, now the company’s unsafe work practices, which were not a big concern before, may have resulted in increased workers’ compensation premiums, increased job costs, and an OSHA willful violation, which could cost the company many jobs in the future. And, of course, if the company decides to defend the OSHA willful, it will probably incur the cost of an attorney to either negotiate or litigate the willful violation to minimize the impact of the citation.

If the OSHA violations stand, the company will have the increased cost of OSHA abatement necessary because of the citations. In addition to this, the OSHA abatement must be completed within a set period and can result in significant changes in work practices and procedures. This could require retraining employees or performing initial training which, because of time limits, cannot be performed economically.

While all of this is going on, management cannot even think about taking any disciplinary or job action against either the injured employee or any employees who participated in the OSHA inspection or investigation and/or the injured worker’s workers’ compensation claim. Most states have antidiscrimination policies to protect employees who file workers’ compensation claims, and OSHA has an entire section of the statute devoted to protecting employees who complain about safety issues on the job site. Again, there is an increased number of these types of complaints being filed by employees who believe they have been discriminated against because they raised safety issues or caused an OSHA inspection to occur. An OSHA citation for discrimination results in a totally new issue that has to be dealt with by legal counsel.

If the OSHA investigation reveals information that is useful to the injured employee’s attorney, he or she may decide that he or she has a cause of action against the general contractor, the principal, the company’s customer, or some third party. In either of the first two examples, the company may have an indemnification or hold harmless contract with that party. Of course, when such a suit is filed, the company will immediately receive a reminder from the party being sued of its obligation to defend them and hold them harmless from any liability for injuries to its employees.

Safety Program: A Worthy Investment

The preceding is merely a sampling of what can occur and the impacts it can have on a business. If management takes the time to sit down and compare the potential costs of having a safety program with the adverse economic impacts the lack of a safety program can have on a business, they will easily see that “an ounce of prevention is worth a pound of cure.”

Why take the chance? If your company does not have a safety program, start one. If it does have a safety program, take a closer look at it. Make sure the company’s employees and the supervisors take it seriously. Having a good safety program can save tens of thousands of dollars in post-accident costs, legal fees, workers’ compensation fines and penalties, and abatement costs, all of which can occur because of one on-the-job injury.

If you assemble a group of engineers—including men and women who have led professional societies or large engineering enterprises—and ask them about the future of mechanical engineering, they may talk about continuing globalization or the need to address social and economic issues, or the implications of technology on ever smaller and larger scales. None of them expects the world to grow any simpler.

Many of the ideas that emerge can be described by the term “integrated systems,” whether that means teams of people bringing a wide range of skills to bear on a single project or collaborating with colleagues in distant time zones.

The American Society of Mechanical Engineers (ASME) has been asking engineers, in focus groups and polls, about the future. It also put the question to a meeting in April 2008, the Global Summit on the Future of Mechanical Engineering, which brought together about 120 people from 18 countries to the National Academies building in Washington.

The Society’s goal in sounding out its members and others in the profession is to get a bearing on where the organization should set its course for the future. Much of the future for mechanical engineers, as is expected now, will involve integrating systems of all kinds.

As Charles Vest, president of the National Academy of Engineering, sees it, the twentieth century was the age of physics and electronics, typified by high-speed communications, for example, and transportation. The twenty-first will be the century of bioengineering and information technology—of energy, water, sustainability, food, and other global concerns.

“Engineering is about systems,” Vest told the participants in the Global Summit. As he explained it, the frontiers of engineering today are in tiny systems on the one hand and in macro systems on the other.

At the very small scale, in bioengineering, information technology, and nanotechnology, there no longer will be a significant difference between scientist and engineer, Vest said. As they work closely together, their roles will not always be sharply distinguished.

Meanwhile, macro systems involving solutions to issues of energy, environment, health care, manufacturing, communications, or logistics will need contributions from areas far outside the traditional sphere of engineering. Solutions may need the additional perspective of social sciences, business management, and the humanities.

The activities at both extremes call for teams of people who will bring knowledge from different disciplines, and their contributions must be integrated into the final result. Throughout the discussions at the meeting, numerous comments concerned the increasingly interdisciplinary nature of engineering practice.

Meanwhile, world population is currently more than 6 billion and growing. As Deborah Grubbe, vice president for group safety and industrial hygiene at BP International in London, pointed out, “Every year, India creates another Australia.”

In 20 years, there could be more than 8 billion people sharing the planet.

Rohit Talwar, chief executive of Fast Future, a consulting firm in London, said that taking people out of poverty is one place where engineering faces a challenge. “Life expectancy is growing,” he said. “Where will people live?” What’s more, how will they live?

Perhaps the world will see new technology, like some of the ideas that Talwar shared with the audience. Vertical farms, for instance, could use hydroponics and other means to take farming indoors, where it could be carried out in multi-tiered structures. If technology like this could be made practical, it could multiply the area available for agriculture.

A multibillion-dollar experiment in sustainable living has been proposed for the United Arab Emirates. The initiative aims to create a high-tech city that will have zero emissions and be entirely self-sustaining.

Engineers have been working to solve environmental and other challenges for some time. After all, enhancing the quality—or as some said, the joy—of life is what engineers do for a living.

In an attempt to get a sense of where the profession may be heading, ASME enlisted the services of the Institute for Alternative Futures (IAF), a not-for-profit research and educational organization that describes itself as working “with clients to create forecasts, scenarios, goals, and strategies that are the essential tools for transforming organizations to succeed in times of rapid change.”

IAF prepared a report, The Future of Mechanical Engineering 2028, based on published reports and focus group discussions and surveys of ASME members. The report gives a sense of the issues today that are expected to shape the profession in the future. Based on its research, the organization identified a list of nine influences that it calls “drivers of change.” They are:

  • Developing sustainability as emerging economies compete for the world’s resources
  • Engineering at the extremes of large- and small-scale systems
  • The competitive edge of knowledge, which will include demands for greater technical knowledge and more depth in management, creativity, and problem solving
  • The collaborative advantage, in which the dominant players will be organizations that are successful at working together
  • Nanotechnology and biotechnology, which are expected to dominate technological development in the next 20 years
  • Regulating global innovation to allow for both the increased sharing of knowledge and the protection of intellectual property
  • The diverse face of engineering, partly as a result of globalization and increased mobility
  • Designing at home, made possible by advances in computer-aided design, materials, and tools
  • Engineering for the billions of people who live in poverty

The first and last items on the list resonated most strongly with engineers at the Global Summit.

Maria Jesus Prieto-Laffargue, president-elect of the World Federation of Engineering Organizations, spoke of “a new concept of society” that will be marked by complexity and interdependence.

“Engineering stands out as the best system to address the challenges of the future: population growth, disparity in wealth, and the need for sustainable development,” she said. According to IAF’s report, “In 2028, the 10 largest economies in the world will include the rapidly developing economies of China, India, and Russia—followed closely by the fast growing economies of Brazil and Mexico. This rapid economic growth will add to global environmental pressures and competition for scarce resources. The mechanical engineering profession will be challenged to develop new technologies and techniques that promote sustainability.”

A representative from China said his country is working toward a more sustainable future and is taking steps to protect and restore its environment. Lu Yong-xian, president of the China Academy of Sciences and the Chinese Mechanical Engineering Society, said, “New materials and knowledge push forward our manufacturing to green manufacturing and services.”

Among Lu’s predictions for China in the future is an eventual “transition to an environment-friendly and sustainable energy system.” Lu said that the Chinese government has recently taken steps for stronger monitoring and rehabilitation of lakes, rivers, streams, forests, grasslands, and wetland ecosystems.

According to Miguel Angel Yadarola, president of the Pan American Academy of Engineering in Cordoba, Argentina, one impact of globalization will be “to pass from a national vision of the problems to an international vision.”

Prieto-Laffargue said, “The world today is not divided by ideology, but by have and have-not technology.”

G.K. Pillai, chairman and managing director of Heavy Equipment Corp. in Ranchi, India, said the challenges for engineering in the coming years are to develop means for “enhancing the joys of life, sustaining civilizations, and continuing advancement in spite of population growth.”

In passing, Pillai disagreed with one of engineering’s 14 Grand Challenges—a list published by the National Academy of Engineering this spring. He is not sure that the goal of securing cyberspace has much practical relevance in the world because so many people have no access to computers or to cyberspace, so only a minority will benefit from it.

How to prepare the engineers who will shape the future was a concern at the meeting. As James Duderstadt, president emeritus and a professor of science and engineering at the University of Michigan, pointed out, “In the United States, the engineering profession tends to be held in relatively low public esteem.”

Duderstadt’s comments were based on Engineering for a Changing World, a report he wrote for the university’s Millennium Project, a think tank for new ideas about education. One of his proposals is to restructure engineering education to a 4-year liberal arts education in preparation for the professional degree in postgraduate study. This could put engineering education on par with the legal and medical professions, and give students an opportunity for a wider range of learning than is possible in a 4-year professional course of study.

Duderstadt also proposes establishment of Discovery Innovation Institutes, research centers supported by federal funding on university campuses. In his report, he wrote, “These new centers would be created through a partnership, very much in the same spirit as the earlier land-grant acts, involving the federal government, the states, industry, and higher education.” The centers would carry out long-term research to convert scientific discoveries into the innovative technology “needed to sustain national prosperity and security in an increasingly competitive world.”

Duderstadt’s report is available on the Millennium Project website.

Yadarola suggested that schools reduce the number of specialties in undergraduate engineering programs to concentrate on “the main orientations.” Specialty studies would be the subject of postgraduate education. “The formation of an engineer tends to be more fragile the more specialized it is,” he said.

Marc Goldsmith, an ASME Governor, addressed the assembly near the end of the meeting and seemed to sum up the group’s spirit. Engineers share a passion for their profession, he said—a passion for discovery and creation. “The world needs a lot more engineers,” Goldsmith added, “if we are to make it a better and safer place to live.”

A major challenge of the construction industry in the near future will be an insufficient quantity of qualified craft workers, supervisors, managers, and staff. The following factors affect the entire construction industry, but many also apply to the insulation industry:

  • The “baby bust” from 1965 to 1976, resulting in a reduction of new work force entrants
  • An image problem that makes the construction industry an unattractive career choice, especially for young people
  • Competency levels of those attracted to construction, often below levels needed to meet minimum requirements for skilled labor
  • Retirement of thousands of long-time craft workers
  • Current federal immigration laws

To meet this challenge, the industry will need to develop and implement effective ways to attract and retain qualified workers. However, there are significant obstacles to be overcome. When asked, high school students rank “construction worker” 247 out of 250 career choice options. When 1,500 craft workers were asked if they would encourage their child to be a craft worker, 70 percent said no. Obviously, the industry has an image problem.
Retention is a significant factor in a contractor’s success. Recent Construction Industry Institute (CII) research found that contractors with a retention rate of 80 percent or greater realized expected profits on more jobs, completed more projects on or ahead of schedule, and experienced better project safety performance.

It is no secret that turnover negatively impacts productivity. CII research found that a 10 percent change in turnover results in an increase of 2.5 percent in craft worker labor costs, and each turnover results in a loss of 24 to 30 hours per craft worker.
Contractors can use five foundational attributes to attract and retain workers.

  1. Offer wages and benefits competitive with the construction and other industries.
  2. Provide job security to the extent possible, especially through multi-skilling.
  3. Provide a safe and healthy working environment by implementing the CII Zero Accident Techniques.
  4. Treat workers fairly and with respect.
  5. Provide good working conditions.

Offer competitive wages and benefits

The first step is to determine what competitive wages and benefits are in your area. Tools you might find helpful include wage and benefit surveys and governmental resources (such as the Bureau of Labor Statistics, www.bls.gov). Always keep in mind that workers have transferable skills and knowledge—your good workers have other options, and you may want to consider hiring someone whose skill set is similar to, but not exactly the same as, what you typically hire.

Provide job security

Personnel staffing plans can help you employ your workers effectively and creatively by accounting for seasonal slumps and other variables. Cross- or multi-skill training gives you more flexibility in who does what. Worker sharing can reduce the need for layoffs and rehiring.
Careful scheduling of project startups also can play a role. Owners in a local area who are considering when to start up new, large projects that might cause a shortage of craft workers should coordinate their efforts and not begin all the projects at the same time. Phasing projects in over time will prevent a drain of needed available craft workers out of the job market.

Multi-skilling is a labor utilization strategy in which workers possess a range of skills for more than one work process and are used flexibly. CII research shows that employers using multi-skilling benefit from a 35-percent reduction in project work force, a 46-percent increase in employment duration, and 5- to 20-percent cost savings for labor.

Provide a safe and healthy work environment

The first step toward a safe and healthy work environment is to adopt and maintain effective office and project safety programs. Include safety performance in all supervisor and manager performance evaluations, and implement CII’s Zero Accident Techniques in project-wide safety programs. CII’s comprehensive safety program consists of 170 attributes, 5 of which are the most important:

  • Pre-Project/Pre-Task Planning
  • Safety Orientation and Training
  • Written Safety Incentive Program
  • Alcohol and Substance Abuse Program
  • Accident/Incident Investigation

Treat workers fairly and with respect

Part of the challenge ahead lies in understanding the changing demographics of the work force and what they mean. Different generations hold different values and expectations of their work lives. People look for environments that support their values and meet their expectations. Participatory management techniques, such as those discussed below, can help attract and retain employees by helping fulfill those goals.

Provide good working conditions

Good working conditions are also important to workers. Start by maintaining organized work sites and providing rest periods and lunch breaks in clean, designated areas. A heated or cooled work space is important, as is readily available drinking water. It helps to implement and enforce dress and language codes and, of course, post and enforce anti-discrimination and harassment policies.

Changing Work Force Demographics

In the construction industry overall, there will be a decreasing number of native, Caucasian males in the work force, while the number of women and minorities will increase. More workers will be immigrants. As the work force ages, employers will be dealing with the largest number of different generations in the work force in history:

  • The Veterans: 1922 to 1943
  • The Baby Boomers: 1943 to 1960
  • The Xers: 1960 to 1980
  • The Nexters: 1980 to 2000

A more diverse work force means employers must consider a wider range of educational levels in employee development efforts and a wider range of worker values and expectations in company human resource endeavors. No longer can companies take a “one-shoe-fits-all” approach to their human resources.
The future work force expects more from a job than a paycheck. Many of them will want to work part time, share a job with another person, or have more flexible working hours.

Leisure time is important to these future workers, who probably will change careers at least once during their working life. They are likely to be less educated than existing workers, be retired and seeking a second career, and belong to a minority group. They also may be physically and/or mentally challenged, bilingual, and either a single parent or part of a two-income family. They are more likely to work two jobs at least occasionally and dislike repetitive work. These workers will want more opportunities for development and to be involved in decision making. They also will want feedback on their performance.

Attracting and Retaining Qualified Workers

In addition to adopting the five foundational attributes listed above, give some thought to where you are most likely to find workers. You might aggressively recruit at schools or pursue reduction-in-force workers who currently are not working. Try working with other contractors and recruit outside the project location. Written and performance tests are good ways to evaluate potential employees.

To keep your good employees, conduct a needs assessment for continuous training and continuous supervisory human relations training. Try tying wage progression to skill enhancement, while giving long-term preferential treatment to tenured workers.

Keep your employees informed about project progress, and emphasize the “family side” of construction, such as company picnics, a newsletter, and other opportunities for your workers to bond.

Commonly used craft worker retention programs include training and re-training, improving working conditions, building morale, and paying overtime. The most effective retention programs include paying a retention bonus, improving working conditions, conducting multi-skill training, other work-related training and re-training, and paying overtime.

When it comes to cost effectiveness, the best craft worker retention programs are building morale, implementing re-employment plans, paying a retention bonus, training and re-training, conducting multi-skill training, and conducting exit interviews.
High-performing organizations provide the following.

  • Challenging and interesting work
  • Opportunities for learning and growth
  • Control over the factors that enable high performance and continuous improvement
  • Knowledge of results
  • Positive personal relationships
  • Sense of personal contribution and satisfaction
  • Support from management

Effective Management of the Changing Work Force

Management must create an environment where people are motivated to direct and control their own behaviors and outputs through involvement, participation, teamwork, and empowerment. To that end, assess the changing composition of your employees frequently and implement proven methods of attracting and retaining employees. Try improving your hiring practices through more effective interview methods and job matching, and hire under-utilized and non-traditional workers.
Training is critical and should include: annual training needs analysis and “360 degree” training for all employees; on-the-job task training for the less-qualified, entry-level workers; and training for supervisors and managers to be more effective leaders. Tie successful completion of training to wage/salary and benefit increases.

Your management practices and processes should adapt to accommodate the more diversified work force, including annual performance evaluations for all employees and keeping employees informed of their individual performance on a regular basis. Also, consider developing plans to extend the retirement age and keep older workers.

Conclusion

For your company to maintain a qualified work force, you need to have formal processes to attract and retain productive construction craft workers. Prepare now for the challenges that lie ahead by planning how you will find, train, and keep workers in the future labor market.

Figure 1

What kind of a safety program does your company have?

There are many possible answers to this question, including the following:

  • “I don’t know.”
  • “We don’t really have a safety program, because we have never had a bad injury.”
  • “With the economy the way it is right now, we can’t afford to do too much on safety.”
  • “We’re too small to have a safety professional.”
  • “Our Human Resources person takes care of that issue.”

Those who are having trouble answering this question should consider attending the Safety Roundtable session at the National Insulation Association (NIA) Annual Convention. In the years that this program has been presented, it has been one of the best attended and most interactive sessions at the convention. Yes, safety has become a hot topic. Safety is important. Safety is not something that can be ignored.

The Safety Roundtable at the NIA Annual Convention brings together many companies, including the winners and top finishers for the NIA Theodore H. Brodie Distinguished Safety Award. These companies share their experiences with regard to safety and pass on their ideas and information about their safety programs.

This article will discuss some of the concepts and ideas shared at this year’s Safety Roundtable by both the Safety Award winners and by their peers who attended the session. These comments apply to all employers, including insulators, manufacturers, and end users.

Safety Enforcement—and Reinforcement

One complaint that many companies often make concerns their inability to get employees to comply with safety rules and use their safety equipment. The heart of this problem is the fact that most companies do not have an effective safety enforcement program. This particular issue was probably the one most discussed at this year’s Safety Roundtable.

One insulation contractor—not one of the largest in the industry—shared his very effective safety program. He said he has learned that an effective safety program requires effective enforcement and that he is determined that his employees must take safety seriously. He is concerned with not only the effect on the bottom line, but also the impact a serious accident can have on the morale of all employees, especially with a small contractor.

To make his safety enforcement program effective, he has taken it to the next level. All warnings—even verbal warnings—provided to employees for safety violations are documented in the employee’s file. He also shared that with every safety violation and every disciplinary action, the employees at fault are retrained. This is a key aspect of having an effective safety program. Just telling them they have done something wrong is not necessarily the most effective way to correct their behavior. Perhaps they did not understand how to properly wear the personal protective equipment (PPE), why they should engage in certain safe conduct, or why a particular safety rule applies to the job they were performing. Rather than guess at whether retraining is needed, this contractor makes sure each employee who receives discipline for a safety violation is retrained. That retraining explains to the employee where and why he or she went wrong and how to avoid making the same mistake again.

One additional aspect of this company’s safety enforcement program was quite interesting: When an employee receives a safety disciplinary action, a copy of the disciplinary action is provided to the employee’s spouse. This action by the employer demonstrates to the spouse that the employer is concerned with the health and well-being of the employee. If the employee is injured, it also provides the spouse confirmation that the employer was doing everything possible to protect the employee from injury. Probably the most effective aspect of this program is that a spouse who receives notice of a disciplinary action is going to do everything possible to ensure that the employee begins complying with safety requirements and starts doing things correctly. Keeping things happy at home is a tremendous motivational force for the employee to comply with safety rules at work.

Another contractor shared an experience with a more strict enforcement program for management than for line employees. In some areas, the Occupational Safety and Health Administration (OSHA), as part of settlement agreements, is requiring employers to establish more stringent safety rules and a higher level of disciplinary action for management employees than for non-management personnel. One example provided was as simple as having a four-step disciplinary program for non-management employees, while management employees are subjected to a three-step disciplinary program. Therefore, a supervisor who violated a safety rule had three strikes before they were out, whereas a non-management or non-supervisory employee would have four strikes.

Another concept was that supervisory employees would be disciplined not only for their own safety rule violations, but also for violations by their employees. Of course, they would have available the defense of unpreventable employee misconduct in such a situation, but they would have to meet the same level of proof that the employer would be expected to meet when defending a safety violation in front of OSHA. This provides a tremendous incentive for management employees to not only comply with safety themselves and set a good example, but also to ensure that employees who work for them are complying with the safety rules.

Safety Incentive Programs

From discipline, the discussion moved into the area of safety incentives. Safety incentive programs might seem straightforward and relatively similar among different companies. However, as those in attendance learned, there are almost as many safety incentive programs as there are companies to administer them. Various attendees at the Safety Roundtable contributed information about their safety incentive programs. Their ideas for safety incentives included providing cash rewards to employees, having raffles where employees can win trips, and allowing employees to purchase items from a product catalog after accruing points through the safety incentive program and safety compliance.

All attendees agreed that safety incentive programs need to be tied to safety compliance, not lost-time injuries. Tying an incentive program into not having injuries at all or not having lost-time injuries is counterproductive. This encourages employees, especially through peer pressure, to “work hurt,” which can cause an increase in subsequent disability and seriousness of the injury so they can obtain a safety award.

Different ideas and criticisms were provided during the roundtable on incentives. Some attendees said cash rewards are not a good idea because once the money is spent, there is nothing for employees to see or hold on to that reminds them of the safety incentive. Others felt that using premiums for which an employee accumulates safety incentive points was a better idea, as long as the items would last for quite a while to remind employees of their safety performance.

Attendees raised concerns about safety incentive programs that rely on the lottery system. This system only rewards a few people at a time, and some employees might never benefit from a safe work performance because of the “luck of the draw.” Unless the system is structured so that all employees who work safely are guaranteed to receive some reward for that performance, a lottery system is not advisable. If the employer decides to have a raffle system that eliminates previous winners for the remainder of the year or until each employee has been rewarded, employees who are no longer in the system may lose that additional motivation to work safely.

No one should require an incentive to work safely. Unfortunately, some employees have become set in the way they perform their tasks without safety equipment or without concerns for safety, and it is difficult to motivate them to change their bad habits. Frequently, an incentive program is necessary. The bottom line is that the cost of an on-the-job injury is so significant that the cost of an incentive program pales in comparison. If a company is going to have an economic incentive program, management should consider one in which all employees who meet the criteria for an incentive receive one.

Are Employees Trained for That?

The final topic that was discussed by those in attendance at the roundtable was one concerning training and orientation. One company suggested that while most employers provide all safety equipment and PPE for their employees, some companies suggest that employees bring some of their own personal equipment. This may be equipment necessary to perform their job or certain types of safety equipment. This particular employer found it helpful to give new employees a list of equipment they should bring on the first day of work. This way, the employee has all the gear necessary to begin working safely on the first day. This list includes all the safety equipment provided to the employee by the employer on the first day of work.

Safety training and orientation take the following two basic forms:

  • Safety training provided to employees on the day they report to work
  • Ongoing communication to keep employees tuned in to safety issues throughout their entire working careers

Those in attendance shared their concepts of initial orientation of new hires. This ranged from providing new employees information on the company’s drug and alcohol policy to providing the 10-hour OSHA course and going over the company safety manual and safety compliance rules. Several attendees suggested new employee safety mentoring programs, where an experienced journeyman is assigned to each new employee to bring them along from the safety perspective. One or two companies suggested providing new hires either decals for hard hats or different colored hard hats for their first 60 to 90 days. This lets experienced employees keep an eye on new hires from a safety perspective, as well as from a productivity and quality of work perspective.

Most attendees agreed that even experienced employees need continued safety training. This can be accomplished by weekly toolbox safety meetings, daily safety job briefings, and periodic quarterly or semiannual company-wide safety meetings. In addition, if a company has not provided the OSHA 10-hour course to employees when they first are hired, most in attendance agreed that it should be provided during their first year or so with the company.

The information provided at the Safety Roundtable is varied and very helpful. Managers who have never taken the opportunity to participate in one of these valuable meetings should think about doing so at the next NIA Convention in April 2009.

It is anticipated that this fall’s election will cause the upcoming 111th Congress to enact some of the most sweeping changes to employment laws that have ever occurred. Employers need to familiarize themselves with the candidates’ positions on these proposed laws before voting. Moreover, employers need to understand the impact of this intended legislation so that they can prepare themselves for limiting their exposure to liabilities.

One of the ways politicians attempt to endear themselves to constituents is to propose employment legislation providing better wages, benefits, working conditions, and employment rights to those in our work force. This campaign season certainly is no exception to that rule. Many employment law experts call these anticipated changes in our employment laws “revolutionary” and “sweeping.” Many employers may just consider these proposed laws to be “threatening.” Here are a few of the potentially revolutionary employment-related legislative changes anticipated:

The Employee Free Choice Act changes labor law provisions in existence for over 75 years and eliminates a secret ballot election in a union representation proceeding. Instead, if the union obtains authorization cards of more than 50 percent of employees, the union would automatically be installed. And, if the company and the union don’t successfully negotiate a “first contract” in 90 days, one will be imposed. Organized labor believes this is the single most important piece of legislation in the 111th Congress, earmarked as the primary way for unions to regain power.

The ADA Amendment Act overrides several U.S. Supreme Court decisions that had construed the federal disability act conservatively. The definition of “disability” is construed broadly in this proposed law and thereby gives many more employees protection under the Act. For example, even if a hearing device restores hearing to 100 percent, the employee will be considered to have a substantial limitation. These amendments will cause an explosion of ADA litigation.

The Paycheck Fairness Act ensures women earn the same as their male counterparts and secures additional rights and civil remedies for violation of equal pay laws.

The Employment Non-Discrimination Act prohibits employers, employment agencies, and labor organizations from discriminating against workers based on sexual orientation. Federal law and most states’ laws do not prohibit such.

The Federal Healthy Families Act guarantees to employees 7 paid days off for personal illness, injury, or medical condition, as well as preventive health care, and would also secure this entitlement for time off for the needs of an employee’s children, spouse, or parents. It applies to employers with 15 or more employees. The right to sue employers over violations along with significant damages is secured by the proposed law as well. It is similar to the Ohio Healthy Families Act recently deemed too costly for enactment by Ohio Governor Strickland and withdrawn by its proponents. This proposed federal law was mentioned from the floor of the Democratic convention just recently.

The Civil Rights Act Amendment would remove the statutory cap on damages under Title VII of the Civil Rights Act and the Americans with Disabilities Act, leaving employers exposed to unlimited damages in these cases. It would also bar mandatory pre-dispute arbitration of EEO claims and allow compensatory and punitive damages as remedies under our federal wage-hour law. This legislation also gives the NLRB authority to award back pay to undocumented employees.

The Fair Pay Restoration Act amends Title VII, the Age Discrimination in Employment Act, and the Americans with Disabilities Act to make it easier for employees to sue for pay discrimination by restarting the statute of limitations each time a paycheck is issued.

The Re-Empowerment of Skilled Professional Employees and Construction Tradeworkers (RESPECT) Act would amend the National Labor Relations Act and upset case precedent exceeding 50 years in duration to change the definition of a supervisor so that supervisors with limited authority would no longer be excluded from bargaining units—thus making supervisors part of the union and no longer aligned with management.

With regard to the U.S. Supreme Court, at least two Justices may be replaced during the next presidential term—Stevens and Ginsburg. These appointments could seriously impact the rights of employees and the obligations of employers for decades to come.

Pay attention to the position of the candidates as we move toward the election, because their election to office may dramatically impact your ability to operate your business and to make a profit.

Disclaimer: This discussion is generalized in nature and should not be considered a substitute for professional advice. Readers are advised to contact counsel before embarking on any of the options discussed in this article.

Companies need to be proactive and have procedures to protect themselves against charges that they knowingly or intentionally employed an unauthorized alien. This article presents the issues and some strategies to consider implementing as part of an overall plan to avoid or defend against such claims. Companies should adopt comprehensive strategies that demonstrate that it has taken appropriate action regarding employment eligibility issues, as well as the company’s commitment to complying with the laws and the due diligence required with regard to its own employees and the employees of companies with which it contracts.

Importance of Attorney-Client Privilege and Attorney Work Product Protection

Companies that want to avoid being found to have knowingly or intentionally employed an unauthorized worker—and the civil and criminal penalties that may be imposed—should integrate the benefits of the attorney-client and attorney work product privilege regarding matters of identity theft or identity issues. It is very important for companies to consider these privileges to protect themselves and their employees from being targeted and prosecuted.

It may be advantageous to have legal counsel be the liaison between the company and government agents, police officers, or prosecutors, rather than a company employee or manager acting as liaison or writing and signing letters. If a company employee serves as the liaison or writes letters, the employee then might be named in a subpoena or named for prosecution. Steps should be taken to protect the company and its employees and still exhibit cooperation with law enforcement. Many companies today are outsourcing responsibility for requests for personnel data relating to identity issues to lawyers.

It is also important to have a legal team that includes not only employment attorneys to handle inquiries about personnel data from Immigration and Customs Enforcement (ICE), the Social Security Administration (SSA), the State Attorney General, or a County Attorney’s office, but also white collar criminal attorneys and corporate attorneys who may be needed as part of the team to implement some of the strategies to assist in defending Immigration Reform and Control Act (IRCA) prosecutions.

I-9 and Immigration Compliance

Federal law requires employers to verify the employment eligibility of all employees within 3 business days after the employee begins work by using the Form I-9. Regulations technically require the employee to complete Section 1 of the I-9 on the first day of employment, but the employer has 3 business days to complete the Form I-9. It is essential to have a complete Form I-9 for every employee, both because good faith compliance with the I-9 process can provide an affirmative defense if an employer is charged with knowingly employing an undocumented worker, and because failure to properly complete a Form I-9 may result in monetary fines being imposed on the company.

There are several steps a company can take to ensure that it complies with the federal I-9 requirements and build a defense if it ever is charged with knowingly employing an unauthorized worker. These are increasingly important to provide a good-faith defense—if an employer complies in good faith with the I-9 requirements, notwithstanding “isolated, sporadic or accidental technical or procedural violations.” Two basic steps are as follows:

  1. Print the company’s current payroll register and complete an audit of every employee’s Form I-9 to make sure that the company has complete I-9s for every employee. If the company does not have an I-9 form, or the form is incomplete, the employee should complete another Form I-9 and staple it to the original. Do not backdate the Form I-9. Use the original hire date in Section 2.
  2. Conduct I-9 and immigration compliance training for all employees who complete a Form I-9 on behalf of the company (Section 2 of the I-9 form). Train employees regarding what they may and may not do when completing the I-9 form on behalf of the company, and what to look for to ensure that the Form I-9 is fully complete.

Anticipate and Deal with Complaints or Inquiries Regarding Immigration Status

There will be immigration vigilantes motivated and empowered to make complaints to the government regarding persons suspected of not being authorized to work in this country. Businesses that are vulnerable to such complaints, including businesses that serve the public or that have a diverse work force visible to the public, may consider public relations and customer relations strategies for anticipating and dealing with the expected inquiries or complaints by the public regarding the alleged immigration status of the company’s employees.

Customer service personnel should be trained to respond to inquiries or complaints by the public politely but firmly, informing them that the company takes its obligations to comply with immigration laws very seriously, that it checks all documentation upon hire, and that it does everything that the law allows in checking to make sure that proper documentation is presented to the company upon hire, but that it is prohibited by law from taking more stringent actions against people based upon the way they look or dress, their last name, or other characteristics that appear foreign.

Responding to Government Inquiries

Companies should have procedures in place to respond to government investigations or inquiries from government agencies or others regarding employees or employees’ Social Security numbers. The procedures also should address investigations by the County Attorney or State Attorney General initiated by a complaint that the company is knowingly or intentionally employing an unauthorized alien. For those states that enact employer sanctions laws, employers may expect many more visits from government agents asking questions or demanding to inspect records about employees.

Company managers should be cautious about the manner in which confidential personnel information is disclosed. Most companies understand that they generally should not provide confidential personnel information about the company or its employees but should refer inquiries to a designated company representative. Front-line employees can tell investigators or others that the company is happy to cooperate, but that they are not the proper person to handle the inquiry and will refer it to the appropriate person or the company’s attorney.

Procedures for Human Resources Investigations into Identity Issues

Companies should develop and implement procedures to address identity issues. They need to have a procedure that is followed in all cases for two reasons: (1) to defend against charges that the company knowingly or intentionally employed an unauthorized alien by showing that the company takes reasonable steps when it learns information that could suggest an employee is using false personal information and may not be authorized to work in the United States and (2) to defend against charges of discriminatory treatment by demonstrating that all employees are treated the same and in accordance with a pre-established policy. The policy should contain provisions prohibiting discrimination based on national origin, race, ethnicity, appearance, language skills, and other protected characteristics.

Employment Policies and Hiring Paperwork

Use new-hire acknowledgement forms, where the employee affirms he or she understands the company’s commitment to employing only an authorized work force and that the employee is authorized to work in the United States. Make sure the company has a written immigration compliance policy and incorporate the policy into the company’s handbook. If the company does not have a handbook, it should consider distributing the policy to employees as part of the new-hire paperwork.

The company’s employment application should include a statement to be signed by the applicant affirming the accuracy of the information provided. For example: “I hereby state that all information that I provide on this application and in any interview is true and accurate. I am aware that false statements, misrepresentations of facts, or material omissions may be sufficient to disqualify me for employment, or if employed, may result in my termination.”

The company’s employment application should include a carefully worded question regarding whether the individual is authorized to work in the United States. Depending on how the inquiry is worded, it could be used as evidence of discrimination, however. An employer may not ask about citizenship status. The question “Are you legally eligible for employment in the United States?” or “Are you authorized to work in the United States?” has thus far been found to be acceptable.

The company’s employment application could include a statement, to be signed by the applicant, which states, “If employed, I understand that I will be required to provide proof of identity and legal work authorization.”

Form W-9, Request for Taxpayer Identification Number and Certification, should be used with all new hires and current employees.

The company’s termination checklist should include as a possible reason for termination “Failure to properly complete a Form I-9.” Another reason for separation could be “Providing false information to the Company in violation of Company policy, practices, and procedures.” This could be the grounds for separation if, after an investigation, the company discovers that an employee provided false information to complete the Form I-9 or as part of a follow-up Human Resources investigation.

Employee Training

Companies should train their employees on the company’s immigration compliance policy and highlight to all employees the seriousness with which the company treats employment authorization matters. Additionally, managers and supervisors should be trained on what they should and should not do in interacting with employees and dealing with immigration status.

Supervisors and managers should understand that the company is committed to legal employment practices and that, as representatives of the company, they have special duties regarding legal work status. Supervisors and managers never should discuss the immigration status or work authorization of an employee, whether at or off work, whether they are speaking English or another language. Work authorization status is never a permissible topic of discussion after the employee has completed an I-9 form and satisfied the federal employment authorization verification procedures. All managers and employees should be made to understand that they should not ever discuss the legal status of an employee working for the company; this means 24 hours a day, 7 days per week.

Avoiding Charges of Discrimination

Federal law prohibits discrimination on the basis of race, national origin, and citizenship status. Companies need to take care that they are not overzealous in verifying the identity and work authorization of employees, or the company may face a discrimination charge.

The company should ensure that it has a strong anti-harassment and antidiscrimination policy and that it implements the policy. Companies should be very cautious of actions that could be construed as national origin or citizenship discrimination, or actions that could be construed as violating the antidiscrimination provisions of the IRCA.

Under current federal law, employers are prohibited from asking for more or different documents if the documents that the employee provides to complete Form I-9 “on their face reasonably appear to be genuine.”

The company should ensure that it does not make decisions based on race, national origin, language ability or characteristics, accent, physical appearance, clothing characteristics of an ethnic group, religious attire, or other national-origin characteristics.

Records Retention Policies

It is important for a company to review its records retention policies and make sure they are being followed at all the company’s locations. If the company is under government audit, it is restricted from destroying or eliminating documents. Similarly, if the company is involved in a lawsuit, it has a duty to maintain the relevant documents and electronic data.

The company’s record retention policy should cover a number of items including, but not limited to, I-9 forms, wage and hour records, leave records, Social Security no-match letters, safety records, resumes, e-mail correspondence, other electronic data, and other personnel information. Companies may want to consider having legal counsel review their records retention policies.

Companies should implement their records retention policies and make sure they are uniformly followed—as long as the company is not under a government investigation or involved in litigation or potential litigation, in which case relevant records must be retained. If it is not required that old documentation be retained, keep records clean. Shred I-9 forms and other personnel records that the company is no longer required to maintain.

Keep in mind that documents containing personal and confidential information, such as Social Security number, date of birth, home address, and medical information, must be disposed of in a manner that will ensure they cannot be stolen and used. The company should shred documents containing personal and confidential information, or use a document service that can provide that support.

Use of Leased Employees or Employment Agencies, or Outsourcing Work

Companies could consider using third-party leased or temporary employment agencies, rather than hiring employees directly. The employment agency would become responsible for verifying the work authorization of the employees it provides.
If the company decides to use a leased or temporary employee arrangement, it should require a strongly worded written agreement wherein the agency certifies its compliance with federal and state laws relating to employment verification and antidiscrimination. The contract the company has with the leased or temporary employee agency should contain a clause in which the agency agrees to indemnify the company against any liability based on knowingly or intentionally employing an unauthorized alien.

Contract Considerations

Any contract the company enters into could be impacted by immigration issues if the other party to the contract or the company were to have a license or permit suspended or revoked. When entering into contracts, companies should consider what might happen if one party to the contract has its license suspended or revoked. Companies should consider adding assignment provisions to all contracts, allowing them to be assigned to successor companies.

One also must consider the effect of the immigration-related issues on contract provisions regarding delays and penalties for delays, particularly in the construction industry. Usually there is a provision in construction and other contracts imposing liability for delays on the company that does not perform or cannot meet deadlines in the contract. Companies with contracts that include delay provisions may want to consider including an exception not only for acts of war, acts of God, and terrorist attacks, but also acts of the State that affect the company’s ability to conduct business because of immigration-related issues.

General contractors should consider adding a contract provision stating that subcontractors agree to comply with federal and state immigration and employment verification laws, and will indemnify the general contractor for any liability arising from any failure by the subcontractor to comply with the applicable laws. Companies should insert provisions in all contracts, whenever possible, relieving them from the obligation to perform or fulfill a contract if their license is suspended or revoked because of immigration-related issues.

All of a company’s employment contracts, handbooks, manuals, and policies should state that it shall immediately cease payment of any wages or the provision of all employee benefits to any employees if the company’s licenses are suspended or revoked. Such provisions are necessary so that the company does not face claims that additional wages are owed (or benefits must be provided) during a period when the company is not authorized to transact business because of any possible enforcement proceedings. Payments for all time worked must, of course, be made; businesses should consult with an attorney to ensure that they do not violate any Department of Labor regulations.

Companies should examine all their supplier and customer relationships and attempt to negotiate provisions in their contracts with respect to the consequences of a suspension or revocation of business licenses or permits on the part of the company, its vendors, or its customers. Obviously, companies will not be able to fulfill contractual obligations if they are not authorized to do business because their business licenses or articles of incorporation have been suspended or revoked. Performance guarantees, security interests, personal guarantees, or other measures may be necessary to protect companies from non-compliance.

Traditional building codes only allowed limited options for fire-resistant grease duct enclosure systems in commercial kitchens, and almost all required some type of rigid board material. Alternative grease duct enclosure systems, such as fire-resistant flexible wrap materials, have gained significant acceptance over the past 20 years for use in exhaust ducts. The design community is recognizing the design flexibility achieved with these newer, zero-clearance enclosure systems while the contractor community is recognizing the cost-effective installation options available. Finally, the building code compliance community understands that these alternative flexible wrap enclosure systems are tested to rigorous and specific fire tests, while many traditional rigid materials may have acceptance grandfathered in without full testing.

Flexible wrap grease duct enclosure systems should gain even more popularity now that all the major model codes in the United States clearly reference a specific testing standard—American Society for Testing and Materials (ASTM) E 2336—to show compliance. A specific test standard written to evaluate grease duct enclosure systems, ASTM E2336 was first published in 2004 and is now written into Section 506.10.3 of the 2006 International Mechanical Code and the 2008 Edition of National Fire Protection Association (NFPA) 96. This specific building code language mandates that the building construction community recognize the requirements of the new standard for fire-resistant grease duct systems and adapt its design accordingly (see Figure 1).

Nationally recognized testing labs (NRTL), such as Underwriters Laboratories (UL) and Intertek Testing Services (ITS), understand that ASTM E2336 is an American National Standards Institute (ANSI)–approved standard specifically written to comprehensively evaluate all fire performance–related aspects of fire-resistive grease duct enclosure applications. These NRTLs also recognize that ASTM E2336 is now required in the major model codes used in the United States and is therefore the standard of choice for future classification and listing support. Additionally, the International Code Council Engineering Service (ICC-ES) recognizes that the major model codes now require testing to ASTM E2336 and will therefore withdraw Legacy Building Code Reports that used the old UL 1978 test standard as basis for approval.

To make the transition from UL 1978 tested systems to ASTM E2336 tested systems go as smoothly as possible, UL, ITS, and ICC-ES have coordinated their activities and will all stop supporting systems tested to UL 1978 in January 2009. This makes it imperative that building owners, specifiers, contractors, and building officials all recognize this important change and transition to code-compliant systems on or before January 2009. Grease duct enclosure systems should be evaluated against ASTM E2336 beginning in 2009, regardless of the version of the model code a local jurisdiction is following. Compliance should be shown with either an ICC-ES building code report evaluated against the 2006 International Mechanical Code and ASTM E2336, or with nationally recognized laboratory listings that specifically evaluate all the criteria of ASTM E2336. Systems that are fully compliant are available on the market and can be found listed in the evaluation reports section of the International Code Council Engineering Service website (search for CSI Code 07815).

Evolution of Shaft Alternative Fire Test Methods

Within minutes, grease duct fires can reach temperatures of 1,600°F (871°C) to 2,000°F (1,093°C)—hot enough to melt aluminum and ignite surrounding combustibles in just seconds. Typical shaft construction, historically built from fire-rated gypsum or calcium silicate board assemblies, has traditionally been specified to contain such an internal fire risk (see Figure 2). Alternatives to rigid shaft enclosure construction, such as encapsulated, flexible grease duct wraps offering zero clearance to combustibles, have been used extensively since their introduction in the mid-1990s to successfully contain grease duct fires, save precious building space, and save on labor costs.

The test standards and acceptance criteria of these flexible enclosure alternatives have, however, been in a constant state of refinement and consolidation over that same period. Fire test standards in general have multiple objectives. First and foremost, fire test standards are designed to approximate expected real-life fire conditions. Actual fire conditions are affected by hundreds of factors, each of which may change the actual behavior of the fire in a real-life situation. Therefore, fire tests are designed to approximate the most likely situation based on all available fire history and input from the building and scientific communities. After the basis of the test is established, a fire test standard must have specific language that provides definitive instructions to the testing lab on how the test is to be conducted, thereby providing consistency between tests and test laboratories. Ultimately, fire test standards are written to evaluate products against expected fire conditions and to provide the design community with affirmation that the products it is specifying are suitable for the application.

While grease ducts have been around for a long time, the actual process of writing fire test procedures specific to an expected grease duct fire was first completed with the publication of UL 1978 in 1995. Even then UL 1978 was not specifically a fire test standard, but more of a comprehensive standard for evaluating and listing factory-built grease ducts, of which one component was an internal fire test to determine whether the integrity of the duct could withstand the expected internal temperatures that might be reached if a grease fire were to ignite inside the duct. The first laboratory design listings for grease duct enclosure materials were based on the fire test portions of UL 1978, as it was the best and only available test standard at the time when innovative flexible enclosure materials were first contemplated.

With the already wide acceptance of shaft alternative materials within the building community and the eventual emergence of a national model code body (ICC), the time had come in 2002 to develop an ASTM standard that could be applied nationally. When the ASTM E05 committee was given the task in 2002 to develop a consensus standard for grease duct enclosure systems, the task group reviewed the acceptance criteria already being used within the United States and chose to model ASTM E2336 after the more stringent but arguably more application-specific criteria laid out in ICC-ES Acceptance Criteria 101 (AC101). ASTM E2336 was first published in April 2004 and is titled “Standard Test Methods for Fire Resistive Grease Duct Enclosure Systems.”

ASTM E2336 subjects grease duct enclosure systems to the following five separate fire tests, each of which is distinct and is intended to test an important characteristic of the enclosure system:

  1. Section 4.1 of ASTM E2336 describes a noncombustibility test defined by ASTM E 136. This ensures that the enclosure material does not add significant fuel to a fire during the evaluation period.
  2. Section 4.2 of ASTM E2336 describes a fire resistance test of a vertical wall with the enclosure material subjected to the fire conditions defined in ASTM E 119. This is a severe test designed to model a building fire external to the duct and to determine whether the external fire will ignite the combustibles within the duct (see Figure 3).
  3. Section 4.3 of ASTM E2336 describes a test defined by a modified ASTM C 518 and designed to ensure the enclosure material does not change over time when subjected to normal elevated temperatures found near operating grease duct exhaust systems.
  4. Section 4.4 of ASTM E2336 describes an internal fire test, which requires that an elbow-shaped grease duct with both a horizontal and vertical component be subjected to 4 hours of 500°F temperatures and 30 minutes of 2,000°F temperatures. This is a severe test designed to model a likely fire scenario inside a duct and to establish that materials directly against the enclosure system will not combust. Passing this test gives an enclosure system a Zero Clearance to adjacent combustible construction rating (see Figure 4).
  5. Section 4.5 of ASTM E2336 describes a fire test in which an elbow-shaped grease duct with both a horizontal and vertical component is subjected to an external fire engulfment defined by ASTM E119. The integrity and stability of the duct is evaluated after the 1- or 2-hour rating period, and the through penetration of the vertical leg is evaluated against the acceptance criteria of ASTM E814 for through penetration firestops.

Sections 4.2, 4.4, and 4.5 of ASTM E2336 include grease duct access doors in the fire testing, since this is deemed to be part of the entire enclosure system.

Compliance With ASTM E2336

The tests defined by ASTM E2336 are different from the acceptance criteria previously based on UL 1978. In particular, the internal fire test is more specific, more repeatable, and consequently more difficult for enclosure systems to pass. The fire resistance portion of ASTM E2336 (defined in Section 4.2) is a totally new requirement from those previously specified by testing labs.

Because these tests are different in significant ways from UL 1978, the flexible wrap type enclosure systems available on the market today that meet all five criteria of ASTM E2336 are all applied in a minimum of two insulation layers. In fact, most of the two-layer systems available today that meet all the requirements of ASTM E2336 are two layers of a thicker, heavier insulation material than that in the previous single-layer system that passed acceptance criteria based on UL 1978. Therefore, it is important that specifiers, contractors, and inspectors not only look for systems that have met all the requirements of ASTM E2336, but also are thinner, lighter, flexible, and have installation advantages.

Compliance to ASTM E2336 can be proven with an ICC-ES Building Code Report, which evaluates the enclosure system against the 2006 International Mechanical Code. These reports will list testing per ASTM E2336 in the evidence submitted portion of the test report. An ICC-ES building code report (ESR Report) is an important tool all the way through the construction design, plan approval, building, and inspection process. It gives the architects and engineers all the information required to specify a compliant system without diving into all the specific test details, which sometimes do not translate well into a specification. The design community can simply specify “2-hour, fire-rated duct enclosure system applied directly to the duct with zero clearance from the enclosure material to adjacent combustible construction, tested per ASTM E2336, and installed per the requirements of a valid ICC-ES building code report (ESR report),” and they will get a code-compliant installation that will breeze through plan review and construction inspection.

Laboratory design listings can also show compliance but should clearly evaluate the enclosure system against all criteria of ASTM E2336. Sometimes design listings are partial listings because one component of the test standard may be applicable to more than one construction assembly. For example, Section 4.5 of ASTM E2336 is applicable to both air ventilation ducts and grease ducts, so a separate design listing might list “tested per Section 4.5 of ASTM E2336.” On first glance, this might look like compliance to ASTM E2336, but in reality it is only partial compliance to one part of the complete test standard.

Innovation Driving Evolution

The United States can boast that it has the safest buildings in the world largely due to the innovation of its construction industry, the consensus process in which codes and standards are developed, and the cooperative efforts of architects and engineers who design to code, contractors who build to code, and code officials who enforce the code. This process has worked again, starting with innovation of grease duct enclosure systems in the early 1990s, acceptance by the building community over the past 20 years, and refinement of testing standards and building codes to adapt to new technologies. This process has culminated into an ANSI-approved consensus standard, ASTM E2336, which is written specifically into the major model building codes in the United States.

With these major milestones achieved, previous acceptance criteria will no longer be accepted by the nationally recognized testing laboratories come January 2009, and as such it is important that the building community specify, install, and inspect to ASTM E2336 starting in January 2009. Be sure the grease duct wrap specified in 2009 can pass the test.

Figure 1

Flexible Grease Duct Enclosure System

Figure 2

Traditional versus flexible alternative shaft enclosures.

Figure 3

ASTM E 2336: Wall Panel Fire Test.

Figure 4
Figure 5

One of the greatest risks at any industrial facility is the unanticipated failure of process piping. Almost all piping is susceptible to internal and/or external degradation; however, piping exposed to a marine environment or subjected to water or chemical spray has a higher probability of corroding much faster. Insulated piping is susceptible to external corrosion because the insulation may become wet, accelerating the corrosion of the pipe while hiding the corrosion from detection. Most plants will remove the insulation from obviously damaged areas to see if the pipe is corroding. In many cases, the pipe appears to be in good condition. The problem is that water will seek the lowest level possible and, usually, the lowest level of the piping run will not coincide with the damaged area. Therefore, a false confidence is achieved when the piping directly underneath damaged insulation is found to be in good condition, while anywhere from a few feet to hundreds of feet away, a corrosion cell is actively destroying the integrity of the pipe, ultimately leading to a leak or catastrophic failure.

Very few nondestructive inspection techniques are available to identify corroded areas on insulated piping. Most of the available techniques involve some removal of insulation to inspect the pipe. In many cases, the removal of insulation shows minimal, if any, corrosion at inspection, but because the insulation was breached, corrosion cells may later occur at or near the locations where the insulation was removed and replaced. The best policy is to avoid disturbing the insulation unless absolutely necessary.

According to statistics published in Keep it Running, Keep it Safe—Process Machinery Safety and Reliability (W. Wong, 2004), the causes of pipework failure ranked in descending order include the following:

  • Leakage at flanged joints
  • Leakage from corroded pipe (especially under insulation or lagging)
  • Leakage at small-bore piping
  • Failure at pipe supports
  • Leakage at bellows
  • Leakage at instruments
  • Failure of steam traps
  • Modifications
  • Wrong materials
  • Over-pressure

The second highest failure rate of process piping is corrosion under insulation (CUI). Insulated piping is also the most difficult to inspect with most available technologies today.

The Lixi Profiler is one of the new tools on the market designed to quickly and accurately detect CUI. It can detect almost any anomaly in process piping that causes a change in density from one area of pipe to another. The Profiler may be used to inspect insulated piping without insulation removal, including straight runs of pipe, elbows, tees, reducers, weld-neck flanges, and most other piping components.

How the Profiler Works

After calibration using two known thickness values, a Profiler scan will reveal the presence of density variations caused by corrosion, welds, wet insulation, product buildup on the walls of the pipe, and any other indication caused by a change in density (see Figure 2). The Profiler is capable of inspecting all known materials used in pipe fabrication, including carbon steel, stainless steel, cast iron, aluminum, plastic, and PVC. No barricades are required, so this inspection method will not adversely affect any other personnel or craft near the device.

Results of a Profiler inspection are graphically displayed in real time to the operator (see Figures 3 and 4). With a couple days of training and a few weeks of use, most Profiler operators are able to quickly and accurately assess process piping systems. Corrosion or other problems are found in real time, and the pipe may be marked for additional remedial action or monitored for further degradation over time.

In the Sample Report (Figure 5), Gamma Graphics inputs the pipe size and schedule as provided by the client, along with the Lixi Profiler readings. The spreadsheet calculates the wall loss in three ways. The “Less Nom” column is the adjusted Profiler reading minus the nominal wall value. The “Worst Case” column takes into account a mill tolerance of 12.5 percent. The “Divided by 2” column assumes any corrosion is equally distributed on two walls of the pipe. Positive values in the “% Wall Change” column denote more dense areas than expected and usually indicate the presence of wet insulation or debris in the pipe.

Compared to more conventional inspection methods like ultrasonic thickness testing and industrial radiography, the Profiler is capable of collecting much more data in a short period. Typically, on insulated pipe, approximately 20 to 30 radiographs can be taken and about 30 to 50 ultrasonic thickness readings can be taken in a day. In contrast, approximately 150 to more than 300 piping locations may be inspected in a day with the Profiler.

Some of the more recent technologies for pipe inspection, like long-range ultrasonic testing, can be negatively affected by the number of direction changes in a section of pipe, the condition of the pipe where the insulation is removed to place the test collar, and even by wet insulation. Because the Profiler is handheld, simple to use, and not reliant on complicated physics, it can perform in most process environments and provide quick, reliable results.

Real-World Scenarios

At a power station, the Profiler was used to verify the condition of insulated piping during a routine maintenance outage. A particular section of pipe was known to have some erosion and was being monitored on the extradose of an elbow with periodic ultrasonic thickness testing. In a 20-second scan, the Profiler found that the elbow and adjacent piping had actually eroded much more severely than the ultrasonic testing results showed. The insulation was removed, and the elbow was replaced. Inspection of the removed elbow showed a remaining wall thickness of only 0.03 inch; it would probably have failed during start-up of the plant if it had not been located and repaired.

A furnace at a refinery was being cooled down for maintenance. As part of the maintenance routine, a cleaning pig was installed in the serpentine furnace coils and forced through the piping by pressurized air but became lodged in the pipe. Under normal circumstances, all the return elbows in the furnace would have to be removed, the furnace piping cleaned individually, and the return elbows rewelded to the piping. That would mean the refinery furnace would be out of commission for approximately 2 weeks. However, an inspector at the refinery recommended the Profiler for locating the stuck cleaning pig. In a matter of a few hours, the pig was located. Only two return elbows had to be removed, and the pig was forcibly removed with pressurized fluid. The furnace was back in operation within a day.

At a refrigerated warehouse, the Profiler was used to inspect ammonia refrigerant piping. A small section of piping was found to have significant corrosion. A maintenance person remarked that the section of pipe in question was replaced only 3 years previously and he doubted very much that the pipe had corroded significantly in that time, especially when the rest of the piping system was over 40 years old. The insulation was removed and the corrosion was visually confirmed.

At a West Coast refinery, an inspection crew worked for over a month trying to locate blockage in a feed line with no success. The Profiler was finally tried on the line, and the blockage was located within 20 minutes. Other tests were used to confirm the location of the blockage, and remedial action was taken. Had the Profiler been one of the first inspection methods instead of one of the last, the refinery’s production would not have been diminished for over a month. The Profiler has proved to be an efficient tool in terms of time and cost for finding CUI, identifying changes in pipe schedules in process piping lines, locating wet insulation and ice in insulation, and determining anomalies in process piping systems that could affect production or jeopardize worker safety.

Figure 1

The Lixi Profiler.

Figure 2

Profiler display of piping anomalies.

Figure 3

Profiler display of corrosion.

Figure 4

Technician using the Profiler.

Figure 5

Sample report of Profiler results.

Calcium silicate is used to insulate high-temperature pipes and equipment and for fire endurance applications. It is manufactured and sold in three different forms: preformed block, preformed pipe, and board. Today’s calcium silicate manufactured in North America is noted for its high compressive strength, corrosion-inhibiting properties, and high-temperature structural integrity. It can withstand continuous temperatures up to either 1,200°F (Type I, for pipe and block) or 1,700°F (Type II, fire endurance boards). Structural calcium silicate for applications requiring higher temperature resistance and greater strength is not covered in this article.

History

Calcium silicate evolved about 1950 from earlier high-temperature thermal insulations: 85-percent magnesium carbonate and pure asbestos insulation. At first, calcium silicate insulation was typically reinforced with asbestos fibers. By the end of 1972, most North American manufacturers had switched to glass fiber, plant fibers, cotton linters, or rayon. Now North American–manufactured calcium silicate contains no asbestos.

When industrial facilities started asbestos insulation abatement programs in the 1970s, asbestos-free calcium silicate was widely used as the replacement material on piping and equipment at oil refineries, petrochemical plants, power plants, steam distribution lines, and in other high-temperature applications requiring a high-strength insulation material. Today, there are only two manufacturing plants producing calcium silicate insulation in North America.

How Calcium Silicate is Made

Calcium silicate is made from amorphous silica, lime, reinforcing fibers, and other additives mixed with water in a batch-mixing tank to form a slurry. This slurry is pumped to the preheater, where it is heated to boiling and quickly poured into molds. After a few minutes, the material is removed as a wet and fragile solid. These formed pieces are placed into an indurator (a sort of steam pressure cooker) for several hours, where the chemical reaction takes place to form calcium silicate. The pieces are then placed into a drying oven. After drying, the pieces are trimmed, slit into two or more pieces, and packaged. The process is relatively low energy, as the highest temperature reached is only about 380°F.

The molded, cured insulation material is essentially a crystalline formation with more air space than solid space (greater than 90 percent air). Millions of tiny air spaces separated by low-thermal-conductivity crystalline walls give calcium silicate its insulating characteristics. Very little infrared radiation is able to pass through it, so it is an effective high-temperature insulation material.

Product Characteristics

American Society for Testing and Materials (ASTM) C533, “Standard Specification for Calcium Silicate Block and Pipe Thermal Insulation,” establishes minimum acceptable standards for both Types I and II. Type I is rated to a maximum-use temperature of 1,200°F and has a maximum density of either 15 pounds per cubic foot (lbs/ft3) or 22 lbs/ft3, whereas Type II is rated to 1,700°F and has a maximum density of 22 lbs/ft3. The as-manufactured compressive strength for both types is greater than 100 pounds per square inch (psi), at a 5-percent deformation, the highest of any nonstructural high-temperature insulation material in the ASTM materials specifications. The maximum linear shrinkage, after exposure to the maximum use temperature, is only 2 percent, and the flexural strength is greater than 50 psi for both types. Both the flame spread and smoke developed index are 0 per ASTM E84, since the material does not contribute to combustion. Max-imum allowable mass loss values in the ASTM specification are 20 percent and 40 percent after tumbling for 10 minutes and 20 minutes, respectively, demonstrating its resistance to breakage.

Thermal conductivity and compressive strength are not adversely affected after testing for maximum use temperature, in accordance with ASTM C411. North American calcium silicate is formulated and manufactured to inhibit corrosion under insulation (CUI) on both stainless and carbon steel. This material is also classified as noncombustible per ASTM E136.

Calcium silicate insulation is typically covered with a protective jacketing: conventional aluminum sheet, stainless steel sheet, polyvinyl chloride (PVC) sheet, glass cloth with weather barrier mastic, or a multi-ply laminate. To prevent water intrusion, a bead of sealant should be used on sheet metal jacketing overlaps.

Common Applications

Calcium silicate is typically applied on high-temperature (greater than 250°F) pipe and equipment in industrial facilities, such as chemical plants, refineries, and steam electric power plants. Since it is a rigid material that has a relatively flat thermal conductivity curve, extremely high compressive strength, high flexural strength, a Class A rating for Flame Spread/Smoke Developed, and is noncombustible (ASTM E136), it is widely used in high-temperature, industrial applications subject to physical abuse.

Due to its high compressive strength (greater than 100 psi), high flexural strength (greater than 50 psi), and resistance to damage from tumbling, plus its ability to maintain those properties over time up to its rated 1,200°F, calcium silicate can withstand considerable physical abuse without loss of insulating efficiency. In addition, calcium silicate can withstand vibration induced by high-temperature steam flow around internal pipe obstructions, such as valve internals, measuring devices, and flow restriction orifices.

Summary

Calcium silicate offers high-temperature structural integrity, high compressive strength, and corrosion inhibition. It can also be a major contributor to conservation. The energy used to manufacture a linear foot of this size calcium silicate is only about 154,000 British thermal units; the ratio of energy used to predicted energy saved is 575:1 for 1 year and 11,500:1 for 20 years.

Readers who are interested in learning more about the insulation material featured here should visit the MTL Product Catalog or visit the NIA Membership Directory to find a manufacturer.

Figure 1

Calcium silicate being installed on a pipe at an industrial facility.

Figure 2

Horizontal pipes, when insulated with calcium silicate, can withstand some foot traffic without sustaining severe damage.

Figure 3

A number of different codes and standards for thermal insulation are related to fire safety—ASTM E84, ASTM E136, ASTM E119, and UL 1790, as well as regulations about fire penetration seals, grease ducts, and so forth. It can seem a maze of confusing standards to those who do not spend much time dealing with fire safety. It makes one wonder whether there need to be so many, and whether there is overlap. What needs to be specified when one simply wants thermal insulation that will not catch on fire, release smoke and toxic fumes, and harm people?

A True Disaster: the Station Night Club Fire

In February 2003, a fire broke out at the Station Night Club in West Warwick, Rhode Island. One hundred people died—most from fire injury, smoke inhalation, or being trampled. Many news stories at the time reported that the acoustical insulation caught fire from the band’s pyrotechnics, and the fire spread so quickly that people did not have time to escape. The subsequent investigation revealed that the soundproofing consisted of exposed foam insulation containing no flame retardants. Was this simply a case of some construction manager not reading the fine print on a box of foam insulation? Why did this happen when there are codes and standards to address this sort of thing?

There were numerous fire code violations involved in the Station Night Club disaster that this article will not address. To those of us who work with thermal and acoustical insulation, however, it seems basic that exposed insulation material should meet the building code requirements of at least being rated 25/50 by ASTM E84, which translates to a Flame Spread Rating of 25 or less and a Smoke Developed Rating of 50 or less in the so-called Tunnel Test. When the insulation consists of an organic material, such as a foam, it should contain fire-retardant chemicals. If the soundproofing insulation at the Station Night Club had been rated 25/50 and thereby met the building code requirements, the disaster may well have been prevented.

ASTM E84, 25/50 Flame/Smoke Rating

Building insulation is normally not exposed once construction is complete. Figure 1 shows wall insulation that has yet to be covered with drywall. This insulation material does not have to be rated as 25/50 because after it is covered with drywall, the assembly will be 25/50 and will meet other building fire codes.

By contrast, Figure 2 shows metal building insulation that is exposed at all times. This insulation has a vapor retarder facing that, in combination with the insulation and adhesive, must be rated 25/50.

In fairness, ASTM E84 and a 25/50 flame/smoke rating would not necessarily accurately predict what a particular insulation material exposed to the pyrotechnics at the Station Night Club that night will do. E84 is a laboratory test conducted in a “tunnel” with the material installed upside down (as in a ceiling configuration). A flame is started, air is blown down the tunnel at 240 feet per minute, and the rate of flame propagation and quantity of smoke released are measured. The ratings are both relative to cement board (0 flame spread and 0 smoke developed) and red oak (100 flame spread and 100 smoke developed). While results of a laboratory test may not match events in a real-world setting, if the soundproofing insulation at the Station Night Club had met the building code requirements by having a 25/50 rating, the fire likely would have spread more slowly or not at all, giving music fans time to escape.

Mechanical Insulation and ASTM E84

Pipe and duct insulation installed within a building is unlike wall and ceiling insulation that is flat and continuous over a large area. Pipe and duct insulations are often located above a suspended ceiling in an area that acts as a plenum (for air distribution). In the case of insulation on water pipes above a suspended ceiling that acts as a plenum (for air distribution), a fire could be become much worse if the insulation material were to spread the fire quickly and release a large quantity of smoke. Thus, the pipe insulation above a suspended ceiling that acts as a plenum should be 25/50 flame/smoke rated and is typically specified as such. However, areas above a suspended ceiling are often but not always a plenum. Figure 3 shows an application of factory jacketed pipe insulation that is a 25/50 flame/smoke–rated material. Incidentally, all duct insulation within a building interior should be 25/50 flame/smoke rated regardless of whether the space above the ceiling acts as a return air plenum or not.

Mechanical Applications and Non-combustibility

ASTM E136 is used to classify a material (not necessarily thermal insulation) as “non-combustible” (sometimes the similar standards ISO 1182 or U.S. Coast Guard 164.109 are used). The adjective “non-combustible” is actually more stringent than it sounds. “Non-combustible” means the material will not support a fire, and when exposed to the temperature of a fire high enough to thermally decompose organics into gases, these gases will not appreciably feed that fire. The requirement that a material be rated “non-combustible” is not always specified for building construction materials. It is commonly specified for applications in confined spaces, such as on ships, or for high-temperature industrial applications with flammable fluids, such as petrochemical facilities where there is constant danger of fire from leaking flammable fluids.

The E136 test itself does not appear related to the reality of a fire. A small sample is inserted into a small furnace that has been preheated to 1,382° F (750° C). To be rated “non-combustible,” several conditions must be met: no flame must be observed for 30 seconds; the measured temperature of the sample’s center must not increase by more than 54° F (30° C); and, after the test is complete, the sample must not have lost more than half its weight. Figures 3 and 4 show two different samples: one that meets the requirements for being “non-combustible” and the other that does not (hence a rating of “combustible”). For a material to be rated “non-combustible,” it must have a relatively low organic content, around 0.10 pounds per cubic foot of material volume or less.

Mechanical Insulation and Fire Endurance

With fire endurance testing of a mechanical insulation system, the goal is to demonstrate that the system will protect a particular pipe or piece of equipment from heating up too quickly. Since thermal insulation only reduces the rate of heat transfer, rather than stopping it, greater thickness for a particular material generally offers protection for a longer period—but not forever. Of course, the insulation material must be able to withstand the fire temperature itself, generally around 2,000°F.

Two commonly specified standard time–temperature fire tests are used: ASTM E119 and UL 1709. The curves for both are shown in Figure 5.

The ASTM E119 fire test is used primarily for building construction, and the time–temperature curve more or less represents that of a cellulosic-type fire. For example, certain types of insulation in certain thicknesses are used to prevent fire from spreading from one building floor to the next. The tests to qualify the particular construction are frequently run following the ASTM E119 fire cure. In Figure 5, the fire starts at room temperature (75°F in this case) and gradually increases to 2,000°F in 4 hours.

By contrast, the UL 1709 fire curve represents a much more severe fire, in this case a hydrocarbon fire (such as might occur at a petrochemical facility), which increases from 75°F to 2,000°F in 5 minutes. In addition (not shown in Figure 5), the fire must generate a minimum quantity of heat—65,000 Btu/hr, a truly intense fire. The objective of the insulation is to prevent the insulated pipe or equipment from reaching 1,000°F for a minimum period of time, typically 30, 60, or 180 minutes, depending on the requirements. The results of this test depend not only on the insulation thickness and characteristics, but also on the characteristics of protective jacketing and of the pipe or equipment being insulated. For example, for a given insulation system, pipe diameter, and type of steel, it will take longer for a thick steel pipe to reach 1,000°F than for a thin steel pipe to do so, simply because the thick piece has greater thermal mass.

It is important to recognize that the results of a UL 1709 fire test on an insulated steel pipe depend on several variables: the insulation type and thickness, the steel type and pipe thickness, and jacketing characteristics. Thus, the question “Does this insulation material meet a 1-hour fire rating per UL 1709?” is not useful to ask. The correctly worded question must be more detailed: “Can this insulation material provide a 1-hour fire rating, per UL 1709, on a 12-inch NPS, Schedule 80 carbon steel pipe with 22 gauge stainless steel jacketing, and if it can, what minimum insulation thickness would be required?”
As with many technical issues, “the devil is in the details.” And with time–temperature fire-rating tests, the details are extremely important.

Mechanical Insulation and Firestopping

Mechanical insulation is sometimes used as a firestopping material where a pipe passes through a wall. The objective is to prevent passage of fire from one side of the wall to the other. Since the pipe is likely insulated anyway for energy efficiency, condensation control, or both, that same material may meet the firestopping standards required by code for the project. This insulation essentially prevents the fire’s spread through the annular space between the pipe and the wall.

In building construction, the ASTM E119 time–temperature test described above would be used. The wall thickness, pipe size and type, and insulation thickness and type are important variables. Sometimes a combination of insulation materials is employed to meet the requirements.

In industrial applications, pipe penetrations also need to be fire rated. If the combustibles of concern are hydrocarbon liquids, then the fire curve employed would be UL 1709. If they are simply cellulosic materials, the ASTM E119 curve would be used for the system test.

Mechanical Insulation on Grease Ducts

Insulation of grease ducts, used as exhaust ducts above commercial kitchens, is a special case. The outsides of the ducts are insulated with a material with a high maximum-use temperature. The objective of the insulation is to prevent the building materials near the ducts from catching fire when the built-up grease in the ducts catches fire (which it eventually will; this is not considered a disaster, but an inevitable event). The time–temperature curve used in the internal grease duct test likewise is unique. Typically, with the duct surrounded by ambient air, the air inside the duct is heated to 500°F for 4 hours, during which time the temperature at the surface of the duct at its midpoint must not exceed 117°F above ambient temperature (e.g., if the ambient temperature is 75°F, the maximum allowable internal temperature during this time is 75 + 117 = 192°F). The temperature is then increased to 2,000°F for 30 minutes. The insulation’s external temperature is not allowed to increase by more than 325°F during this time or at any one point, or by an average of over 250°F.

Conclusions

Several different tests for fire safety exist that involve thermal insulation materials. Some are specific to mechanical insulation. While not everyone needs to be a fire safety expert, it is useful for those who deal with mechanical insulation to have a cursory knowledge of what the tests are, how they differ, and why and when they are specified. For a material to be qualified to a particular fire safety performance, it must be tested. Sometimes, the configuration and conditions of the test are critical to its results.

Everyone needs to pay attention to those details.

Figure 1

Wall insulation with Kraft facing, prior to installation of drywall. Since it will be covered with drywall, the insulation itself is typically not required to meet a 25/50 Flame Spread and Smoke Developed Rating. With Kraft facing, it typically does not.

Figure 2

Metal building insulation with exposed facing that is rated Class A per ASTM E84.

Figure 3

Tests on an insulation material rated “non-combustible.” The photo was taken 35 seconds after the sample was inserted into the 750°C furnace. Note that the sample is not in flames.

Figure 4

Tests on an insulation material rated “combustible.” The photo was taken 35 seconds after the sample was inserted into the 750°C furnace. Note that the sample is in flames.

Figure 5

ASTM E119 and UL 1709 time–temperature fire curves.

Figure 6

Grease ducts can be effectively insulated with specially designed and tested high-temperature-rated insulation systems.