FSMA Compliance and Energy Savings with An Effective Building Envelope
White Paper/Technical Topic-2020 RETA National Conference
FSMA Compliance and Energy Savings with An Effective Building Envelope
SUBMITTED BY
Randall K. Bogrand
Chief Operating Officer, Vapor Armour, Inc.
14745 SE 82nd Drive, Clackamas, OR 97015
On 5.31.2020
FSMA Compliance and Energy Savings with An Effective Building Envelope
1. CONTEXT/Introduction
This paper’s purpose is to elucidate the Food Safety Modernization Act (FSMA) compliance and energy effects of a properly installed building envelope on freezers and coolers. It will be based upon industry research and the results from a 2-year long case study on 2 separate full building envelope installations in the Mid-west and Southern U.S. The results show 100% compliance with the ice and condensation restrictions of FSMA and an energy savings of 48% and 51%, respectively.
The primary objectives and scope of the study were to objectively determine what the effect of installing a state-of-the-art building envelope (correct insulation, vapor barrier and roofing membrane) on an existing freezer/cooler, if any. The rationale for the study was to obtain this missing information for Building Managers, General Contractors, Operational Teams and building owners to help determine a rational scope of action to FSMA, FDA, USDA and OSHA compliance and energy savings on their current, or to be constructed, freezers and coolers.
2. Understanding Listeria - L. monocytogenes
L. monocytogenes is an environmental pathogen that can contaminate foods and cause a mild, non-invasive illness (called listerial gastroenteritis) or a severe, invasive illness (called listeriosis). Commonly called Listeria, Listeriosis is characterized by a relatively high mortality rate compared to illnesses caused by most other foodborne pathogens (~20% compared to <1 % for Salmonella or E. coli O157) See Crerar S, Dalton C, Longbottom H, Kraa E. 1996. Foodborne disease: current trends and future surveillance needs in Australia. The Medical journal of Australia 165(11-12):672-675.; Scallan E, Hoekstra R, Angulo F, Tauxe R, Widdowson M, Roy S, Jones J, Griffin P. 2011. Foodborne illness acquired in the United States--major pathogens. Emerging Infectious Diseases 17(1):7-15
Persons who have the greatest risk of experiencing listeriosis due to consumption of foods contaminated with L. monocytogenes are pregnant women and their fetuses, the elderly, and persons with weakened immune systems. Foods that have caused outbreaks are typically contaminated from the environment during manufacturing/processing or packing (see Goulet V, Hebert M, Hedberg C, Laurent E, Vaillant V, De Valk H, Desenclos JC. 2012. Incidence of listeriosis and related mortality among groups at risk of acquiring listeriosis. 54(5):652-660. Pouillot R, Hoelzer K, Jackson K, Henao O, Silk B. 2012. Relative risk of listeriosis in Foodborne Diseases Active Surveillance Network (FoodNet) sites according to age, pregnancy, and ethnicity. Infectious Diseases Society of America 54 Supplement 5: S405-410.; Pouillot R, Hoelzer K, Chen Y, Dennis S. 2015. Listeria monocytogenes dose response revisited--incorporating adjustments for variability in strain virulence and host susceptibility. Risk Analysis 35(1):90-108.; U.S. Food and Drug Administration (FDA) and U.S. Food Safety and Inspection Service (FSIS). 2003. Quantitative Assessment of the Relative Risk to Public Health from Foodborne Listeria monocytogenes Among Selected Categories of Ready-to-Eat Foods. (https://www.fda.gov/Food/ScienceResearch/ResearchAreas/RiskAssessmentSafetyAssessment
/ucm183966.htm); FDA. 2012. Information on the recalled Jensen Farms whole cantaloupes. (https://www.fda.gov/Food/RecallsOutbreaksEmergencies/Outbreaks/ucm272372.htm) ; FDA. 2013. FDA investigates a multi-state outbreak of Listeria monocytogenes linked to certain Crave Brothers farmstead classics cheeses. (https://www.fda.gov/Food/RecallsOutbreaksEmergencies/Outbreaks/ucm359588.htm), 2013 ; FDA. 2014. Notice of Opportunity for Hearing (NOOH) - Roos Foods Inc, 3/11/14. (Letter dated March 11, 2014, from Margaret A. Hamburg of FDA to Ana Roos of Roos Foods, Inc.). (https://www.fda.gov/regulatoryinformation/foi/electronicreadingroom/ucm388921.htm)
Although temperatures below freezing slow the growth of Listeria, L. monocytogenes can multiply in -15-degree temperatures and therefore at much higher refrigeration temperatures. As a result, refrigeration is less effective as a control measure for L. monocytogenes than for other foodborne pathogens (such as Salmonella) see International Commission on Microbiological Specifications for Foods (ICMSF). 1996. Chapter 8. Listeria monocytogenes. In Microorganisms in Foods 5 - Characteristics of Microbial Pathogens. pp. 141-182. Blackie Academic & Professional, London; Lou Y, Yousef AE. 1999. Characteristics of Listeria monocytogenes important to food processors. In Listeria, Listeriosis, and Food Safety, eds. ET Ryser and EH Marth. pp. 131-224. New York: Marcel Dekker, Inc.; El-Kest SE, Marth, EH. 1992. Freezing of Listeria monocytogenes and other microorganisms: a review. Journal of Food Protection. 55: 639-648.; Institute of Food Technologists. 2001. Evaluation and Definition of Potentially Hazardous Foods. IFT/FDA Contract No. 223-98-2333. https://www.fda.gov/food/foodscienceresearch/ safepracticesforfoodprocesses/ucm094141.htm); Codex Alimentarius Commission. 2007. Guidelines on the application of the General Principles of Food Hygiene to the control of Listeria monocytogenes in foods. CAC/GL 61-2007.
3. Stopping Listeria - FSMA Requirements
The FDA through The Food Safety Modernization Act (FSMA) specifically addressed Listeria in that it identifies ice and condensation as contaminates that are not allowed in Lo-Temp facilities that house food or pharmacy. FSMA, which became final in September 2015, requires food facilities to have a food safety plan in place that includes an analysis of hazards and risk-based preventive controls to minimize or prevent the identified hazards. (FSMA Final Rule for Preventive Controls for Human Food, https://www.fda.gov/food/food-safety-modernization-act-fsma/fsma-final-rule-preventive-controls-human-food, hereafter FSMA Final Rule)
FSMA Final Rule § 117.20 (b) 4) states in part:
(b) Plant construction and design. The… manufacturing, processing, packing, and holding… plant must:
4) Be constructed in such a manner that floors, walls, and ceilings may be adequately cleaned and kept clean and kept in good repair; that drip or condensate from fixtures, ducts and pipes does not contaminate food, food-contact surfaces, or food-packaging materials;
In simple terms, ice and condensation – which is proven to carry Listeria - is NOT allowed in lo-temp facilities that store food. See Appendix 1 for sources of Listeria addressed by the FDA
4. Traditional vs effective building envelope installation –
The traditional building envelope installation is far inferior to an effective building envelope installation:
Traditional lo-temp building envelope installation consists of:
· a metal deck,
· roofing insulation (PolyIso - Polyisocyanurate, XPS – Extruded Polystyrene) applied for an R-value of 35-50,
· reliance on roofing membrane as perimeter vapor barrier and
· an adhered roofing membrane (TPO or PVC or EPDM).
Effective lo-temp building envelope installation consists of:
· a metal deck,
· XPS roofing insulation applied for an R-value of 35-50,
· a Vapor Barrier around the perimeter of the roof deck; and
· a mechanically attached PVC roofing membrane over the top of the Vapor Barrier and insulation.
5. Effect as installed – traditional vs effective installations
The Traditional lo-temp building envelope installation does not hold temperature, will not keep ice and condensation from entering the building, is not FSMA compliant and contaminates food stored in the lo-temp facility. See Appendix 2 for examples
The Effective lo-temp building envelope installation will hold temperature, will eradicate ice and condensation and keep each from entering the facility, is FSMA compliant and will not allow contamination from ice and condensation.
6. Insulation usage – XPS versus PolyIso
The case for using XPS (Extruded Polystyrene) versus PolyIso (Polyisocyanurate) in all lo-temp building temperature zones throughout the typical distribution center building that has the following temperature zones:
· -20° ice cream freezer
· -5° to -10° freezer
· 38° cooler / dock
· 55°degree room
In the discussion that follows there will be 4 main indicia being discussed. The performance of the insulation when mean insulation temperatures are in:
1. Cooler/freezer rooms in cold climates;
2. Cooler/freezer rooms in moderate climates;
Once it is understood that the mean insulation temperature – the average temperature between the inside of the room and the outside – drops below 75o, XPS is the favored insulation as it retains its R-value per inch and, moreover, as the mean temperature of the insulation drops below 60o, XPS’s R-value increases as PolyIso’s R-value drops precipitously. Considering that most mean insulation temperatures are below 75o AT ALL TIMES means that XPS is clearly superior.
-5o to 55o Rooms: Based on Appendix 3, Tech Solution 127.1: Understanding Roof Insulation Performance in Cold Storage Buildings, 2017) XPS is superior to any PolyIso installed in Buildings whose rooms are at 55o or below in any climate. Specifically:
a) Efficiency- R-value: PolyIso begins to lose its R-value significantly starting at 55o mean insulation temperature and drops by 50% or more at the -20o range. Which means that it would take almost twice as much PolyIso (in thickness) to equal the same R-value as XPS on an Ice Cream Freezer. If it is assumed the R-value necessary at the Ice Cream Freezer and through to the 55o room is R-50, then Appendix 3 shows, IF ALL THE OUTSIDE TEMPERATURES ARE THE SAME:
o If 8.3” of XPS (R-50/6) is used that equals 16.6” of PolyIso (R-50/3) on the Ice Cream Freezer -20o room;
o If 8.77” of XPS is used that equals 16.6” of PolyIso on the -5o room;
o If 8.9” of XPS is used that equals 13” of PolyIso on the 38o room; and
o If 9” of XPS is used that equals 12” of PolyIso on the 55o room.
So, as the room temperature reduces, XPS increases its efficiency. Also, PolyIso boards come in 1” to 4” thicknesses (so, 12” = 3x4” (3 layers); 13” = 2x4” and 2x3” (4 layers); 16.6= 4x4” and 1x3” (5 layers) XPS comes in 4”, 3” 2” and 1.5” thicknesses. (8” = 2x4” (2 layers); 9” = 1x4, 1x3” and 1x2” (3 layers)) So, the installation efficiency of XPS is also obvious.
b) Moisture Performance - XPS possesses moisture performance over and above roofing grade PolyIso. In the event of condensation build-up or a roofing failure, moisture will be partially absorbed by the PolyIso rendering its R-value as 0. The moisture that is not absorbed by the PolyIso will be passed onto the rest of the building and, in the case of freezers, the PolyIso can become frozen and fully contaminated. Most PolyIso insulation carries a manufacturer’s warranty of 15 years. XPS is hydrophobic – it repels water. It does not become contaminated by moisture. If a roof needs replacement, the XPS (with a 50-year warranty) can be re-used. If the whole roof is water slogged, the XPS is unphased and continues its insulating efficiency. The same is true if the moisture/condensation is freezing in between the roof deck and the roof membrane – XPS maintains it insulating capabilities.
As stated earlier, except for PolyIso, there is a gradual increase in thermal resistance as the mean temperature is reduced. That is because Extruded Polystyrene insulation and roofing grade PolyIso use unique blowing agents and exhibit very different R-value versus temperature behaviors. The PolyIso line in Figure 1 of Appendix 3 shows increase in R-value down to a mean insulation temperature of about 55?F. As the mean temperature goes down the PolyIso insulation R-value drops due to condensation of the blowing agent. XPS behavior (XPS in Figure 2 of Appendix 3) shows that XPS thermal resistance continually increases with reduced mean temperature.
Summary re: insulation
Cold insulation mean temperatures:
Both XPS and PolyIso are excellent foam plastic insulations for roofing. However, these insulations perform differently as their mean temperature drops. PolyIso will see its thermal resistance increase from R5.6/inch to about R6.0/inch at 50 ?F. On further drop in mean temperature PolyIso thermal resistance worsens ….to a meager R3.6/inch at 20 ?F. On the other hand, XPS thermal resistance consistently increases with dropping mean temperature: from R5.0/inch at 75 ?F to about R5.5/inch at 20 ?F. XPS is clearly superior in Cooler/Freezers AND Office Space/Ambient rooms in Cold weather.
Moderate insulation mean temperatures
During the heating season of moderate climates, the exterior temperatures combined with normal interior temperatures will result in the mean temperature of the insulation layer lower than 75 ?F. As this insulation mean temperature drops, the XPS roof insulation R-value gradually improves to a point where it outperforms Roofing ISO insulation at the same operating mean temperature. The favored insulation for roofing in moderate climates is XPS.
Basically, it breaks out like this:
1. High Insulation Mean temp (over 75°) for only office space or ambient rooms - PolyIso is superior
2. Moderate insulation mean temp (under 75°), all uses - XPS is superior
3. Cold insulation mean temperature (under 50°) all uses – XPS is superior
CAVEAT - Pricing:
In any practical discussion regarding construction, material cost becomes a factor. It should be noted that XPS usually costs about 30% more than PolyIso. PolyIso costs between $.29 to $ .32 per board feet. XPS costs between $.39 and $.47 per board foot. On a typical lo-temp facility (900,000 bd. ft) the difference in price is substantial – PolyIso would cost $261,000 to $288,000; XPS would cost $351,000 to $423,000 – a $90,000 to $135,000 categorical difference and a 31% to 34% differential
7. Roofing membrane usage – PVC vs TPO vs EPDM
Terms.
· The term PVC stands for Polyvinyl Chloride. PVC materials are produced by a chemical reaction, known as polymerization. PVC is produced by the gaseous reaction of ethylene with oxygen and hydrochloric acid;
· The term TPO stands for Thermoplastic Polyolefin. TPO is a blend of polypropylene and ethylene-propylene rubber; and
· EPDM stands for Ethylene Propylene Diene Monomer. It is a synthetic rubber derived from oil and natural gas (ethylene propylene).
PVC
While it is true that PVC is a relatively hard substance, the PVC that is used for roofing material has the benefit of plasticizers, which are added to make the membrane more pliable. Most PVC membranes are mechanically attached, though fully adhered or even ballasted PVC roofing systems are still occasionally found.
Heat Welded. What is almost universal, though, is that the PVC membranes are heat-welded at the seams. This creates a monolithic structure that is very durable and able to withstand the constant expansion and contraction of the building structure throughout the day, throughout its life. And the reason why PVC membranes are most often heat-welded at the seams is because of the added strength, durability, and stability of the material itself. The seam becomes stronger than the surrounding membrane!!
Milage. PVC is relatively light and can be purchased in milages between 36 and 90 mils. However, the standard PVC roofing membrane is about 50 mils. Though the primary color of a PVC roofing membrane is white, in can come in other colors. It also has excellent resistance to bacterial growth, animal fats, as well as plant root penetrations.
Though PVC is usually a roll good system (meaning, it is ordered in 5- to 12-foot wide by 50- to 100-foot long rolls), its installation is not burdensome. As mentioned before, PVC seams are usually heat-welded and, because of the structural integrity of the membrane, this heat-welding can go relatively quickly and with a much better result than that of TPO/EPDM.
However, it is important to note that there is a PVC roof system manufacturer out there that actually custom pre-fabricates the membrane (Duro-Last). This means that your roof is measured, including your curbs, walls, penetrations, etc., and then the roof is custom designed to fit those dimensions. Such a methodology allows for all the benefits of larger sheet sizes as will be seen with EPDM, but with the added benefit of prefabricated curbs, walls, and penetrations. The new roof is designed specifically for the size and constraints of real-world existing conditions. This prefabrication process also eliminates up to 85% of all the field seams. By having about 85% of those seams already completed by the manufacturer in their quality-controlled environment, the roof is going to be significantly enhanced.
While most other roofing products can come in either reinforced or non-reinforced material, PVC is often reinforced right out of the box. Reinforcement typically indicates a polyester scrim, mat, or fabric mesh that is inserted into the material, like rod iron is used to reinforce roads or concrete walls. This reinforcement, which translates to quality, is one of the reasons why PVC is a little more expensive than TPO, though it is still competitively priced against EPDM. If overall quality is the criterion used to decide what your next roofing system would be, PVC should be at the top of the list.
2. TPO
TPO is probably the most widely used roofing product in the market today for two very good reasons: (1) it's relatively inexpensive and (2) it's white. Cheap doesn't always make something better, though. And being white isn't really anything special, not anymore anyway. Even EPDM, which is a naturally black membrane, is also available with a white laminated top. So, is there anything about TPO that makes it a viable option for your roof? Well, not really.
Shrinkage - Over the years TPO manufacturers have revised and re-revised their proprietary formulations simply to get it to work. TPO – as it is currently formulated – does not have a long or compelling track record. TPO is known to shrink and pull away from seams and curbs. Furthermore, there was an interesting article that appeared in Perspectives magazine, Volume 66, in May 2010 (www.benchmark-inc.com) . The roofing consultants of Benchmark, Inc. did an extensive hands-on study of TPO. Here's what author Jeff Evans, RRC, had to say:
"Our investigations of our clients' roofs continue to identify issues with some TPO membranes: splitting and crazing along rows of fasteners, accelerated aging along walk pads, polymer erosion to the point of exposing scrim reinforcement; enough issues for us to have concerns."
Also, "The MRCA T&R [the Midwest Roofing Contractors Association] committee recently released an "Advisory on TPO", noting TPO's potential susceptibility to deterioration from exposure to high heat and / or UV (solar) loads. Heat and reflected / focused sunlight are the primary concern in this advisory."
The TPO membrane can be mechanically attached or fully adhered (glued). When it comes to the seams and the detail work, the membrane can be glued, or heat welded. The materials of the TPO membrane, however, make it a difficult material to heat-weld correctly. Though some TPO membranes have at least some pliability, others are nearly board-like in their rigidity.
Laminated. A key component of a TPO membrane is its laminated nature. The material that you see on top is not the same material you see on the bottom. Often the top is white, and the bottom is gray. This is because it is not the same material through-and-through. A wearing surface is provided on top and filler material is provided on the bottom. Usually when you laminate something, it serves to create an added point of weakness. Fiber reinforcement can be added to a TPO membrane that does make it stronger and more durable, but that comes at the expense of added rigidity, which makes it harder to work with during the installation process.
Too many seams. TPO is a roll good system, meaning that it comes in relatively small rolls. The rolls average about 8 feet wide by 50 or 100 feet long. Other sizes are available, but they are still relatively small. This means that there are a tremendous number of seams created during the installation process. Seams are the weakest part of any TPO roofing system.
Milage. The primary thickness of a TPO membrane is 60-mils, with 45-mils still frequently used. There are also 72-, 80-, and 90-mil membranes available. Why such a wide range? In large part it is because consumers believe that "thicker is always better," and manufacturers often cater to that belief. But thicker is not always better, especially when the thickness is designed to mask the inherent weakness of the product. Furthermore, making a roofing membrane thicker also makes it heavier, which makes it more expensive to ship and much harder to properly seam in the field.
TPO membrane are already installed with millions more to come. This product is not going away, so you need to be able to identify if quality, durability, warranty coverage, or cost is your main concern.
3. EPDM
EPDM can be either vulcanized, which means it can be dried out and cured into sheets, or it can be non-vulcanized, which leaves the material in a semi-solid state. The vulcanized EPDM is what is used as a roofing membrane. The non-vulcanized EPDM is usually used for detail work or flashing of the cured roofing material.
Black. EPDM is a synthetic rubber, and it is fair to say that its main characteristic is that it is black. The marketplace has been saying more and more that a black roof is not good. First, white roofing membranes have really been pushed (from the federal government down to local business owners) and white roofing has really begun to be specified more and more. The second reason that black EPDM has been considered a less than stellar option is because the manufacturers themselves think so. Many manufactures have begun selling 'white-on-black' EPDM (in some cases for the second time), obviously trying to take a cue from the marketplace.
White on Black. The white-on-black EPDM (WB EPDM) is a laminate material, where the standard, black EPDM makes up the bulk of the membrane. WB EPDM is more expensive than the standard black. Not incidentally, if someone wanted a white roof in the first place, they'd often be better off with a roofing membrane that's white to begin with; i.e., TPO or PVC.
As already mentioned, WB EPDM is a laminate. The "white" in WB EPDM is laminated on top of a standard black sheet. Digressing slightly, the standard EPDM membrane contains carbon, which provides significant stability and structural strength to the material, but it also makes it black. WB EPDM is obviously white. This is because titanium oxide is added to the laminated piece. This produces the white color. But it also causes the surface to be very unstable. It chalks badly, which can make it very difficult to seam correctly. Usually by the time the warranty term is up, it has worn away to the point that all that is left is the black EPDM membrane underneath.
Laminated It is interesting that this titanium oxide is not added to the whole membrane; it is added to a separate piece that is laminated on the top of the standard membrane. Basically, the white laminate on top is to address the need for a white roofing material on a product that is by its very nature black. Some would conclude that if you are going to go with an EPDM roof, then go with the black and then coat it with a reflective elastomeric roof coating. But then you're back to the point where you'd need to ask yourself, 'why install a black roof and coat it white? Why not just get a roof that is white to begin with?'
Shrinkage. A properly seamed and installed black EPDM roof is very good at handling rain, snow, UV rays, abrasions, ozone, and temperature fluctuations. In higher temperatures, however, the membrane – especially at the seams – can begin to shrink and pull apart. Animal and vegetable oils, as well as petroleum-based products are typically not good for EPDM membranes because of the swelling and distortion that can occur when such products meet the membrane.
Maintenance. As with TPO roofing systems, the seams are the most precarious for an EPDM roof. The membrane can last a long time, but the seams – even when properly installed – will dry out, shrink, and create problems. Usually this is mitigated by an extensive repair and maintenance program that involves coating the seams with a white roof coating. This keeps the seams cooler and helps to prevent dry-out and shrinkage. A properly cared-for EPDM roof can last a long time. But it is expensive to maintain.
Full adhered. In addition to the rigorous maintenance that an EPDM roof should get, a main reason it is not an especially cheap roof is because of the way it is installed. Unlike TPO and PVC roofs that are often mechanically attached, an EPDM roof is most often fully adhered. This means that it requires glues to adhere it to what's underneath. The seams are either glued with the rest of the roof (different process, same result) or they are taped. But the point is that glues used to fully adhere an EPDM roof are not cheap. Also, because it is often installed over insulation, which is mechanically attached, significantly more fasteners are required to secure the underlying material to which the EPDM is glued.
Summary
PVC seems to be the most cost effective, warrantable, flexible and long-lasting value in the lo-temp market. See the table attached as Appendix 4 - explaining the valuation propositions of each. See also, National Roofing Contractors Association at www.nrca.net. Much of the information contained here was developed from research done through that source.
8. Vapor Barrier usage
Vapor Barrier/Air Barrier – what is it?
Vapor Drive - Most construction or maintenance personnel may not know that Vapor Drive is costing them 15 to 35% in lost energy costs, violates FSMA, FDA and violates USDA regulation. What is vapor drive? It’s simply the movement of humid warm air from one location to another. In temperature-controlled environments, vapor drive results in drastically decreased energy efficiency and ultimately, condensation and ice buildup. (see exhibit 5 for Vapor drive locations)
Why Ice forms - Ice formation and contamination seem to be a universal problem in cold storage facilities. Whenever there is a discontinuity in the vapor barrier, warm, moist air flows over the tops of walls, in from loading docks, and between freezer, cooler, and battery rooms. The warmer air condenses from vapor to water, then freezes, contaminating insulation and product, and creating a costly, ongoing cleanup project.
Current Practice - roofing detail
From experience, the author knows that General Contractors rely on roofing manufacturers to address the vapor or air barriers on a lo-temp construction project. The author has been unable to find public details regarding vapor or air barriers from roofing manufactures addressing vapor barriers in lo-temp buildings. However, there are numerous articles by the roofing manufacturers that speak to vapor retarders and air barriers as they relate to roofing systems. One of those came closest to the issues when it was stated (emphasis added):
“When we use a vapor retarder in a roof system it will also act as an air barrier as long as it is sealed at all perimeters and penetrations and is tied to the wall air barrier. …. A roof design that includes an adhered roof membrane with multiple layers of insulation (with board joints offset and staggered) over a vapor retarder/air barrier helps lower the risk that air—and the moisture it carries—will infiltrate the roof system. That reduction of air and moisture infiltration can then help improve roof longevity. See Vapor retarders, air barriers, and roofing systems: What architects need to know, James R. Kirby, AIA, November 13, 2018, https://www.aia.org/articles/6074126-vapor-retarders-air-barriers-and-roofing-s.
There are 3 details that immediately arise from this approach: 1) with what is the roof system sealed; 2) how is the retarder tied to the wall barrier; and 3) helps “lower the risk” of Vapor Drive – not eliminate it. Those details are NOT included with most construction details from the roofing manufacturer. Most architects put in their plans that the detail “will be supplied by others”. The General Contractor relies on the roofing contractor and the roofing contractor “seals” the “vapor retarder” as they are used to doing. Like a roof. NO ONE IS TAKING RESPONSIBILITY FOR THE VAPOR BARRIER, and author could find no roofing manufacturer, nor General Contractor, nor Architect, nor roofing installation company that would guarantee that their vapor barrier would eradicate the ice/condensation cause by vapor drive.
A roof is a great water barrier. As the above points out, all penetrations and all perimeters must be sealed to make it an air barrier. Vapor Drive is moist air that infiltrates from the outside of the building. Under a roofing detail, even assuming a 100% normal roofing seal, air will be driven into the building because the sealant of the roof will not keep out air over time – it’s not designed to do so.
Effective practice – install separate Vapor Barrier system stopping air
When one understands the nature of vapor drive and understands the industry’s approach as delineated above, then one can understand the following comment:
The goal of using an air (vapor) barrier is to reduce the leakage of conditioned air out of a building. Therefore, air barriers must be part of the building envelope. This should be a hint that air barriers are systems — a combination of materials — and the individual components of the building envelope have to all link together in such a way as to prevent air leakage…..
It should be obvious that roofing materials block air and might therefore be considered “air barriers.” But to fully function as air barriers, they need to be installed correctly and tied into the wall elements and penetrations in such a way as to ensure there are no air leaks at those junctions and penetrations. Air Barriers vs. Vapor Retarders, James R. Kirby, AIA, on April 20, 2018 https://blog.gaf.com/air-barriers-vs-vapor-retarders/
Accordingly, Dr. Kirby is elaborating that:
Vapor Barriers should tie in all the building envelope components – roof membrane, roof insulation and wall structures. The Vapor Barrier should be a separate system but integrally linked to each building envelope component. Dr. Kirby was referring to generic buildings but in the case of lo-temp construction ANY air leakage (vapor drive) causes either ice or condensation to form either inside the cooler/freezer or under the roofing insulation in the ribs of the metal roof deck.
Separate Vapor Barrier system integrated to the roof membrane, insulation, roof deck and outside wall. Vapor Armour Inc. installs a patented, building envelope integrated vapor barrier system. See Appendix 6 for detail. Note integration with the roof deck, the wall structure, the insulation and the roof membrane. A separate system but integrated. This system, according to Vapor Armour sales literature, is adhered to the roofing membrane and buried underneath it.
Warranty – according to their literature, Vapor Armour, Inc supplies a 15-year NDL “No Ice No Condensation No Cost “warranty ensuring their Vapor barrier will stay sealed and eliminate Vapor Drive. If the company is tasked to supply the whole building envelope (Insulation, roofing membrane and vapor barrier) Vapor Armour supplies a Building Envelope 20-year Systems Warranty “No Leaks, No Contaminated Insulation, No Ice and No Condensation.”
Summary – the experts agree that to stop air infiltration, ice and condensation from Vapor Drive the vapor/air barrier must separate from and integrated into the building envelope.
9. CASE STUDIES SUMMARIZED (attached in full)
Case study 1 - Florida
1. PRE-INSTALLATION - From the Forensic Evaluation, it was determined:
a. Of the Facility’s total roof deck’s 98,400 Square Feet, at least 17,220 square feet (17.5%) was contaminated;
b. Of the Main Freezer and Ice Cream Freezer’s roof deck’s 48,096 square feet, at least 10,336 square feet (21%) was ice contaminated
c. As stated previously, of the Ice Cream Freezer’s roof deck’s 7750 square feet, 100% was ice contaminated.
d. With the help of customer and customer’s structural engineer, it was determined that there were at least 326,000 lbs. of ice on the roof (163 tons). It was a concern that the structural roof load was being stressed and there was a small concern that the Ice Cream Freezer roof ice weighed over the allowed structural roof load.
Final determination – VA determined that:
· the vapor barrier had been compromised around the perimeter of the facility, around the perimeter of the Ice Cream Freezer, the devising wall between Main Freezer and Loading dock and a viable vapor barrier needed to be installed
· the Polyisocyanurate (PolyIso) Insulation had been totally contaminated – moisture and ice had destroyed its R-value - and it needed to be removed and replaced with Extruded Polystyrene Insulation (XPS)
· The ammonia pipes needed to be vapor barriered, insulated and sealed
· Because the PolyIso insulation was compromised and the age of the roof, the roofing membrane needed to be replaced.
2. INSTALLATION – VA was contracted to
a. remove all contaminated roof insulation and replace with XPS;
b. re-roof the whole facility in PVC roofing membrane;
c. install Vapor Armour? vapor barrier to the Main Freezer, Ice Cream Freezer, Loading Dock perimeters and devising wall;
d. Install Pipe Lock? vapor barrier to the 15 pipe stands;
3. RESULTS
We analyze the results from this project in at least 5 variants: Specific Concerns recalculated to actual, Future Results, Energy Savings, ROI, and FSMA regulatory compliance.
a. Actual Concerns – after evaluation there were at least 326,000 lbs. of ice on the roof (163 tons). In actuality, we removed over 451,000 lbs. (225 tons) of ice from the roof. The extra hundred twenty-five thousand pounds means that the roof load was actually stressed another 38% over what was first calculated.
b. Future Results – because this building envelope replacement came with VA’s 20-year systems warranty, if the roof should leak, the insulation become contaminated, or Ice or condensation forms from Vapor leaks, the roof will be fixed or replaced, the insulation removed and replaced and the Vapor Barrier fixed or replaced - at no cost to customer and without calibration for age.
c. Energy Savings – We have reviewed the energy consumption for the 24 months previous to the project and for the 12 months after the project. We have been informed and have determined that the total reduction in Energy usage attributable to the Building Envelope was 48% - representing a yearly savings of $276,379
d. Return on Investment – ROI
On a simple pay back analysis, the cost of the project divided by the energy savings alone gives a payback of 4 years 1 months – a 20.04% per annum return.
e. FSMA and other Regulatory Compliance
With this VA building envelope replacement and its 20-year warranty, the customer and the building can be FSMA Compliant.
Case study 2 - Illinois
1. PRE-INSTALLATION - From the Forensic Evaluation, it was determined:
From the Forensic Evaluation, it was determined:
· -10° Freezer - freezer perimeter had extensive frozen insulation 40 feet into the roof field – over 54% of the roof’s insulation was frozen (1240’x 40’= 49,600 sq. ft. / 90,425 = 54.8%)
· 35° Cooler – of the 98,175 sq. ft., 76,800 sq. feet of insulation was contaminated -- which is 78.2%
· 40°Loading dock – 18,400 sq. feet – 100% of the insulation was contaminated
· Vapor Armour’s forensic evaluation determined the loss of R-value of the insulation caused by the failed perimeter vapor barrier caused the temperature issues the facility was experiencing.
Final determination – VA determined that:
· the vapor barrier had been compromised around the perimeter of the facility, around the perimeter of the Freezer, Cooler and Loading dock and a viable vapor barrier needed to be installed
· the Polyisocyanurate (PolyIso) Insulation had been totally contaminated – moisture and ice had destroyed its R-value - and it needed to be removed and replaced with Extruded Polystyrene Insulation (XPS)
· Because the PolyIso insulation was compromised and the age of the roof, the roofing membrane needed to be replaced.
2. INSTALLATION – VA was contracted to
· install Vapor Armour? vapor barrier to the Freezer, Cooler and Loading Dock perimeters;
· install VA’s patented expansion joint in the freezer portion of the building.
· remove all contaminated roof insulation and replace with XPS; and
· re-roof the whole facility in PVC roofing membrane.
3. RESULTS
We can discuss the results from this project in at least 4 variants: Future Results, Energy Savings, ROI, and FSMA regulatory compliance.
a. Future Results – because this building envelope replacement came with VA’s 20-year systems warranty, if the roof should leak, the insulation become contaminated, or Ice or condensation forms from Vapor leaks, the roof will be fixed or replaced, the insulation removed and replaced and the Vapor Barrier fixed or replaced - at no cost to customer and without calibration for age.
b. Energy Savings – We have reviewed the energy consumption for the 13 months previous to the project and for the 24 months after the project. We have been informed and have determined that the total reduction in Energy usage attributable to the Building Envelope was 40% - representing a yearly savings of $357,888
c. Return on Investment – ROI
On a simple pay back analysis, the cost of the project ($1,359,744) divided by the energy savings alone ($357,888) gives a payback of 3 years 10 months – a 26.08% per annum return.
d. FSMA and other Regulatory Compliance
With this VA building envelope replacement and its 20-year warranty, Ice or Condensation caused by vapor leaks or vapor barrier discontinuity is eradicated and the building can be FSMA, FDA, USDA and OSHA Compliant.
10. CONCLUSION
FSMA compliance and Energy savings with an effective Building Envelope
The primary objectives and scope of this paper and Case Studies were to objectively determine what the effect of installing a state-of-the-art lo-temp building envelope (correct insulation, vapor/air barrier and roofing membrane) on an existing freezer/cooler, if any. I have tried to clearly explain the effects a properly installed building envelope on freezers and coolers will have on Food Safety Modernization Act (FSMA) compliance and energy savings. The industry research and the results from a 2-year long case study on 2 separate full building envelope installations in the Mid-west and Southern U.S. show the results:
An effective lo-temp building envelope includes:
· a metal roof deck,
· XPS roofing insulation applied for an R-value of 35-50,
· a separate Air/Vapor Barrier around the perimeter of the roof deck;
· a mechanically attached PVC roofing membrane over the top of the Vapor Barrier and insulation; and
· all installed in a manner that ties the IMP walls, roof deck, and roof insulation into the separate air/vapor barrier system
The results of this properly installed, effective building envelope is:
· keeps Lysteria from entering the facility through Vapor Drive and congregating in the ice/condensation (Lysteria leads to contaminated food products);
· 100% compliance with the ice and condensation restrictions of FSMA, USDA, FDA and OSHA restrictions on Ice and Condensation
· A provable energy savings of as much as 38% and 40%, respectively.
The purpose of this study was to educate Building Managers, General Contractors, Operational Teams and Building Owners to help determine a rational scope of action to building envelope construction in lo-temp facilities that also comply with FSMA regulatory demands and energy savings on current, or to be constructed, freezers and coolers.
Respectively Submitted this 31st day of May 2020
Randall K. Bogrand
Chief Operating Officer, Vapor Armour, Inc.
14745 SE 82nd Dr
Clackamas, OR 97015