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Filing # 157975886 E-Filed 09/22/2022 04:05:33 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
LEE COUNTY,FLORIDA CIVIL ACTION
LESLIE KAHLER and
JAMES KAHLER,
Plaintiffs,
vs. CASE NO:
PARADISE FOAM,LLC,
a Florida Limited Liability Company,
Defendant.
/
COMPLAINT
COMES NOW the Plaintiffs, LESLIE KAHLER and JAMES KAHLER,(collectively
known as the "KAHLERS") by and through their undersigned counsel, sue Defendant,
PARADISE FOAM, LLC, a Florida Limited Liability Company,("PARADISE"), and state as
follows:
VENUE AND JURISDICTION
1. Venue is proper in Lee County,Florida because this cause ofaction accrued in Lee
County, Florida.
2. LESLIE KAHLER is a resident of Lee County, Florida and owns the following
real property located in Lee Coimty: 657 Rabbit Road, Sanibel, Florida 33957 (hereinafter
"Property").
3. JAMES KAHLER is a resident ofLee County, Florida and also owns the Property.
4. Upon information and belief, PARADISE is a Florida limited liability company
whose principal place of business is located in Charlotte County, Florida and is registered to
conduct business in the State of Florida.
5. Venue is proper in Lee County, Florida, because the real property which is the
subject matter ofthis dispute is located in Lee County, Florida.
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Table of Contents
Client’s Areas of Concern.......................................................................................... 1
Spray Foam Insulation Inspection Standards ............................................................ 1
Executive Summary .................................................................................................. 1
US EPA Health Concerns about Spray Polyurethane Foam ..................................... 3
Potential Chemical Exposures from Spray Polyurethane Foam ................................ 4
Possible Exposure Routes ............................................................................................................ 4
Vapors and Aerosols ..................................................................................................................... 4
EPA’s Ventilation Guidance for Spray Polyurethane Foam Application ..................... 4
Ensure Adequate Ventilation Following Application ...................................................................... 4
BASF Application Guidelines .................................................................................... 4
To Be Installed Only By Properly Trained Contractors .................................................................. 4
Pass Thickness and Multiple Passes ............................................................................................ 5
Processing and Application Instructions ........................................................................................ 5
Pre - and Post - Spraying .............................................................................................................. 5
Spray Polyurethane Foam (SPF) Insulation Inspection ............................................. 6
Recommendations .................................................................................................... 7
Specific Recommendations ....................................................................................... 8
SPF Sample Locations .............................................................................................. 9
Recommendations for Supply Ventilation ................................................................ 10
Report Limitations & Exclusions .............................................................................. 11
Guidance on Best Practices for the Installation of Spray Polyurethane Foam ........... 1
Ventilation Considerations for Spray Polyurethane Foam ............................................................. 1
Recommended HVAC Equipment ............................................................................. 4
Recommended Dehumidifier Ducting ........................................................................ 4
AMRC VOC Report ................................................................................................... 5
Inspection Pictures .................................................................................................... 7
Damaged Ceilings ......................................................................................................................... 8
Interior ......................................................................................................................................... 12
SPF Samples .............................................................................................................................. 22
Sample 1 ................................................................................................................................. 22
Sample 2 ................................................................................................................................. 28
Sample 3 ................................................................................................................................. 32
Sample 4 ................................................................................................................................. 37
Sample 5 ................................................................................................................................. 41
Sample 6 ................................................................................................................................. 48
Sample 7 ................................................................................................................................. 52
Sample 8 ................................................................................................................................. 56
Attic Condition ......................................................................................................................... 60
Indoor Air Quality Solutions, IAQS | PH (407) 383-9459 www.FloridaIAQ.com
5224 SR 46 Suite 380 Sanford, Florida 32771
eFiled Lee County Clerk of Courts Page 13
ATTN: Mr. & Ms. Kahler April 25, 2022
REF: Indoor Environmental Assessment
On April 8th, 2022, Indoor Air Quality Solutions, IAQS conducted an Indoor Air Quality and Spray
Polyurethane Foam Insulation Assessment of the home located at 657 Rabbit Rd. Sanibel, FL 33957
(property) and prepared this report for Mr. & Ms. Kahler (client) summarizing the findings.
Client’s Areas of Concern
Mr. & Ms. Kahler would like to know the installed condition of the retrofit Spray Polyurethane Foam,
SPF, Insulation that was recently installed in their home.
Spray Foam Insulation Inspection Standards
IAQ Solutions conducted a visual inspection of the applied spray foam insulation as an independent
third-party to determine whether or not the product has been installed in accordance with the agreed
upon specifications, manufacturer specifications, industry standards, and information contained
within the product data sheets.
The assessment was in accordance with the document; Guidance for Residential Homes and
Commercial Buildings established by the Spray Foam Coalition of the ACC Center for the
Polyurethanes Industry. The Spray Polyurethane Foam Installation Guidance is intended to provide
an overview of best practices to help professional installers use SPF effectively and efficiently to
insulate homes and commercial buildings. The SPF was inspected in accordance with the Spray
Polyurethane Foam: Guidance on Sampling Techniques for the Inspection of Installed SPF
Executive Summary
The home is a single-story single-family home with 3 bedrooms, 2 bathrooms, and approximately
1,232 square feet of living space built in 1984. The home’s attic was retrofit insulated with spray
polyurethane foam insulation.
The SPF was examined by BASF with the following conclusion. “The visible blown cells and the
higher open cell content are indicators that there was a lack of dwell time between passes and/or
the material was sprayed too hot. It also appeared that some passes were above the recommended
2” maximum thickness. All of these observations support the mild to strong odor that was detected
in each sample. Based on the samples that were provided to our lab and the results below, we would
recommend that sections of the jobsite with similar application deviations be removed and replaced
with material applied per our application guidelines.”
American Management Resources Corporation collected Limited Basic Volatile Organic Compounds
Assessment. They concluded that “at the time of the site visit, the measured VOC levels were low
inside the residence. However, there was a noticeable odor present.”
The spray polyurethane foam insulation installed in the Kahler attic was BASF, Spraytite 178.
Spraytite and Walltite Series products are closed-cell, medium density spray polyurethane foam
(ccSPF) insulation materials. These ccSPF are created by the chemical reaction between an
isocyanate and a resin. Spraytite and Walltite Series can only be processed with BASF Elastospray®
8000A Isocyanate. When these materials are combined in the spray gun’s mixing chamber, a
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chemical reaction occurs, releasing heat. This heat, or exothermic reaction, causes the blowing
agent to expand creating foam. The final cured Spraytite product is yellow/off white; the final cured
Walltite product is green. Spraytite LWP Series, Comfort Series and Walltite LWP Series are HFO-
based formulations, whereas all other formulas indicated above are HFC-based SPF products,
My review of the product specification and application guidelines all indicated that the property
should be ventilated during and after the application of the SPF. There was a single fan identified
on the property according to the Kahler’s. There were no supply air fans or containment. Just the
single fan at the top of the attic stairs. I have found that even properly applied SPF can be a serious
concern for the occupants if the attic and home aren’t properly ventilated during and after application.
Without proper ventilation, the attic and home will fill with the off gassing from the application.
Often, with retro fit applications of SPF, the home is not properly ventilated during the application of
the SPF insulation. We have found more issues with the accumulation of VOC’s from inadequate
ventilation during application than with misapplied SPF insulation. The method of venting the home
during the application of the SPF is unknown but a likely cause for the reported odors and measured
elevations of VOC’s within the home. There were several areas of the ceiling that were damaged
during the removal of the original insulation. These areas should have been contained to prevent
the SPF chemicals, airborne mists, and particulates from entering the Kahler home. Unfortunately
they were not.
A review of the BASF documents found that BASF refers the applicator to the Spray Foam Coalition
(SFC) of the Center for the Polyurethanes Industry (CPI) and the U.S. Environmental Protection
Agency (EPA) Ventilation Guidance for Spray Polyurethane Foam Application. Both of those
documents refer you back to the manufacturer for the actual rate of ventilation for the specific
product. It would appear that neither the manufacturer, industry association nor the US government
want to specify the actual ventilation requirements for BASF, Spraytite 178.
BASF ESR-2642 Supplement page 16. Ventilation of the work area is required and should be in
accordance with Ventilation Considerations or Spray Polyurethane Foam: Guidance on Ventilation
During Installation of Interior Applications of High-Pressure Spray Polyurethane Foam as published
by the Spray Foam Coalition (SFC) of the Center for the Polyurethanes Industry (CPI). The following
statement regarding ventilation of the work area is reprinted from the guidance document:
"Work zone mechanical ventilation during and after SPF installation is designed to prevent workers
and others in the area from being, exposed to SPF chemicals above recommended or permissible
levels. Potential health effects from exposure above recommended levels can range from no effects
to slight irritation of the eyes, skin or respiratory system to the development of chronic lung or
pulmonary disease depending on the individual person and level and duration of overexposure."
The spray area should be posted with keep out WARNING signs before and after spraying. Workers
only that are trained and have ·the necessary personal protection equipment are allowed inside the
spray area. All others must be kept out as well as pets. Ventilation of the spray area is to be done
incorporating the• guidance documents: "Ventilation Guidance for Spray Polyurethane Foam
Application," published by the U.S. Environmental Protection Agency (EPA), online Good Practices
– Engineering Controls and Ventilation," published by the American Chemistry Council's Center for
the Polyurethanes Industry, available online. The following general requirements must also be
followed, Code of Federal Regulations Title 29 CFR §192.20 Safety and Health Regulations for
Construction, General Safety and Health Provisions available online.
The applicators and building owners should visit www.spraypolyurethane.org and also
www.spf.basf.com for up to date information about spray polyurethane foam construction
applications before starting projects.
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According to the Spray Foam Coalitions Guidance on Ventilation During Installation of Interior
Applications of High-Pressure Spray Polyurethane Foam; When SPF is applied using high-pressure
application equipment, some SPF component chemicals may be present in the form of aerosol mists
and vapors over the occupational exposure level (OEL) or at levels that could be harmful to some
individuals
According to OSHA regulations, SPF contractors have a legal responsibility to provide a safe
workplace for all employees. In the case of high-pressure SPF application, use of engineering
controls and proper PPE in the work zone during and after spraying is an important consideration to
help achieve a safe workplace.
Proper ventilation during and after application includes three critical components; Containment,
Exhaust Air, Supply Air, and Negative Pressure.
1. Containment: Containment serves several important functions: Prevents airborne mists and
particulates from migrating to other parts of the building. Minimizes the total volume of the
work zone for ventilation, thus reducing the size and number of fans, and helps to direct airflow
across the point of SPF application. Establishes a defined boundary between the work zone
and other areas in the building.
2. Exhaust Air: The exhaust air system includes an exhaust point, ductwork and an exhaust
fan that captures contaminates at the source and sends them to a location outside the building
away from occupied areas and air inlets.
3. Supply Air: The supply air system provides a source of fresh outside air into the work zone
that is needed to replace the air removed by the exhaust system. This make-up air can be
provided passively through various penetrations in the containment (such as windows, doors,
exterior vents and other openings) or through a dedicated active forced-air inlet system
consisting of a supply point, ductwork and second supply fan.
4. Negative Pressure: A negative pressure within the containment zone assures that
contaminants are not forced into other areas of the building. With a two-fan system, negative
containment pressures can always be achieved when the exhaust fan capacity (e.g., CFM
rating) is greater than the supply fan capacity.
Without the proper ventilation, the home and its contents can be exposed to the chemicals from the
application of the SPF. These chemicals include isocyanates. Sensitization to isocyanates may
result from either a single exposure to a relatively high concentration or repeated exposures to lower
concentrations over time. It’s unknown what level of any chemicals were in the home or to what Ms.
Kahler was exposed to. Some people react to very low levels of isocyanates. Regardless, the levels
of isocyanates has long since dissipated below detection limits but remains at levels that sensitized
individuals can react to.
US EPA Health Concerns about Spray Polyurethane Foam
Isocyanates are a class of highly reactive chemicals with widespread industrial, commercial, and
retail or consumer applications.
Exposure to isocyanates may cause skin, eye and lung irritation, asthma, and “sensitization.”
Isocyanates are irritants to the mucous membranes of the eyes and gastrointestinal and respiratory
tracts. Direct skin contact can also cause marked inflammation. There is no recognized safe level of
exposure to isocyanates for sensitized individuals. Isocyanates have been reported to be a leading
attributable chemical cause of asthma in the workplace.
Dermal, eye, and respiratory exposures can trigger adverse health responses. EPA, other federal
agencies, states, industry, and other countries have taken a variety of actions to address risks posed
by exposure to isocyanates. Exposures to isocyanates should be minimized.
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Potential Chemical Exposures from Spray Polyurethane Foam
Possible Exposure Routes
When spray polyurethane foam is being used, the work site should be restricted to persons wearing
appropriate personal protective equipment. The information on this page is meant to underline the
importance of wearing protective equipment by explaining ways that chemical exposures from spray
polyurethane foam (SPF) may occur.
Vapors and Aerosols
• Spray application generates isocyanate vapors and aerosols.
• Research data indicate that inhalation exposures during SPF insulation will typically exceed
Occupational Safety and Health Administration (OSHA) occupational exposure limits (OELs)
and require skin, eye and respiratory protection.
• Vapors and aerosols can migrate through the building if the area is not isolated and properly
ventilated.
• After application, vapors may linger in a building until properly ventilated and thoroughly
cleaned.
EPA’s Ventilation Guidance for Spray Polyurethane Foam Application
This page describes basic ventilation principles and strategies to help protect workers and building
occupants and promote the safe use of spray polyurethane foam (SPF) insulation.
• Why is ventilation important?
• Overview of key principles
• Fundamentals of ventilation
• SPF ventilation challenges
• Basic ventilation design principles
• Establish air flow across the spraying area
• Establish enclosures to isolate and contain the work area
• Direct exhaust to a safe location
• Ensure adequate ventilation following application
Ensure Adequate Ventilation Following Application
Always remember to continue ventilating the area following application until the material has fully
cured, off -gassing has stopped, and vapors have been removed. During this time, worker re-entry
should be kept to a minimum and should only include those with appropriate respiratory protection
(and skin protection if contact with the SPF is possible). Occupant re-entry should only occur after
the building is fully ventilated.
BASF Application Guidelines
Application space must be properly ventilated during and after application. Consult the EPA’s
“Ventilation Guidance for Spray Polyurethane Foam Application” document and the American
Chemistry Council’s “Ventilation Considerations for Spray Polyurethane Foam” documents for
specific requirements. 24-hour re-occupancy time is advised. Page 3
To Be Installed Only By Properly Trained Contractors
Installation of BASF spray foams requires special equipment and training. Only individuals that have
completed training through verifiable sources (i.e. ABAA, Approved Distributor training, BASF TTC
Training, CPI Online Health & Safety Training, SPFA Professional Certification Program [PCP]
Training) can install ST & WT Series SPF’s. Page 1
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Pass Thickness and Multiple Passes
The heat created by the exothermic reaction during application creates a risk of scorching and/or
fire, as well as irritating odors. This risk increases with greater pass thickness. Page 2
If you spray a pass in excess of the maximum pass thickness, those areas must be immediately
removed from the substrate using a nonflammable tool such as a crowbar – do not use your hands.
After removal, break up large pieces of foam on a non-flammable surface using the non-flammable
tool. Large masses of SPF should be removed to an outside safe area, cut into smaller pieces and
allowed to cool before discarding into an appropriate trash receptacle.
When spraying multiple passes, a cooling/dwell time of 10 minutes per inch applied must be allowed
for the dissipation of heat. Not allowing adequate cooling/dwell time raises the risk of scorching
and/or fire. Once the installed material has cooled, it is possible to add additional passes in order to
increase the overall installed thickness of SPF. If a third layer of a material, at the maximum allowable
pass thickness, is required, there must be a cooling period of at least 1 hour between passes before
spraying additional passes. Maximum four passes, at the maximum allowable pass thickness, per
12 hrs.
Processing and Application Instructions
A small “test area” of spray foam should be applied and inspected prior to commencing the project.
• Check the reactivity, density, spray pattern, mix quality, and foam cell quality by test spraying
onto a disposable piece of substrate.
• This simple, low-cost test area can indicate inadequate adhesion, improper surface
preparation and/or primer requirements, surface contamination, improper substrate and/or
ambient temperature, equipment malfunctions, material contamination, or improper
application technique.
• Visual inspection of a sample cut from first test area and periodic job samples can reveal
potential problems that may be due to one or more of the above conditions.
Application space must be properly ventilated during and after application. Consult the EPA’s
“Ventilation Guidance for Spray Polyurethane Foam Application” document and the American
Chemistry Council’s “Ventilation Considerations for Spray Polyurethane Foam” documents for
specific requirements. 24-hour re-occupancy time is advised. Page 3
IT IS STRONGLY ENCOURAGED TO COMPLETE A QUALITY CONTROL DAILY REPORT AND
AN INSULATION CARD FOR EACH PROJECT.
Pre - and Post - Spraying
Applying residential insulation systems can be best done in a "picture framing" motion in which the
applicator surrounds the outside of the stud cavity allowing the foam to rise along the stud face.
About ten feet of wall can be done at a time. After picture framing a specified area return back to the
start point to fill in the center of the cavity. Additional lifts or passes are to be done after the initial lift
or pass has had adequate time to cool down (about 20 minutes for two-inch pass). Page 5.
There is also the issue with tightly sealed homes and the need to mechanically ventilate to maintain
good indoor air quality. The home is now sealed very tight and will require mechanical ventilation.
This is a critical conversation that must be had prior to the installation of the SPF. There is a specific
need for mechanical ventilation to meet the ASHRAE 62 ventilation rate. The Spray Foam Coalition
of the ACC Center for the Polyurethanes Industry also states on page 23 of their Guidance on Best
Practices for the Installation of Spray Polyurethane Foam, “SPF applications typically improve air
sealing of the structure, and it is important for building owners to understand how this impacts the
overall building and the potential need for new or additional ventilation.”
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In addition, the Spray Foam Coalition of the ACC Center for the Polyurethanes Industry also states
on page 24 of their Guidance on Best Practices for the Installation of Spray Polyurethane Foam in
the Retrofitting Attics section under the heading of HVAC Systems (Attics);
“The contractor and the homeowner should be aware that retrofitting an existing attic by employing
an unvented attic assembly technique can result in the existing HVAC system becoming “oversized”
in relation to the new demand. This situation is of special concern in the southern and coastal climate
zones where the HVAC also serves to reduce or otherwise manage moisture levels of buildings in
order to improve comfort and prevent moisture related problems, such as mold and mildew. If an
existing HVAC becomes “oversized” due to the increased thermal efficiency of the unvented attic
assembly, the HVAC system may begin to short cycle, or to quickly turn on and off, as it works to
manage temperature. This short cycling of the HVAC system may have negative impacts on the
comfort and efficiency of the building and possibly on the lifespan of the system. Involve an HVAC
consultant to adapt the system to the new, more efficient building envelope associated with the spray
foam retrofit.”
The conversation as outlined in the Spray Foam Coalition Guidance documents should have taken
place prior to the application of the SPF. The conversation would have allowed Mr. & Ms. Kahler to
make an informed decision regarding the purchase and application of the SPF. Mr. & Ms. Kahler
will now have to incur additional cost to bring their home to the necessary design considerations
required for the sealed attic as described in this report.
All homes insulated and air sealed with SPF must be designed to include adequate mechanical
ventilation/outdoor air supply for optimum IAQ (Indoor Air Quality). To ensure there are no odors,
accumulated VOC’s, elevated humidity, or condensation within the sealed attic air must be moved
through the sealed attic. Many manufactures are now including the need for mechanical ventilation
in their product specification sheets and websites. Icynene for example provides the following on
their website and within their product specification sheets.
“HVAC & Ventilation with Spray Foam. Appropriately combining spray foam and mechanical
ventilation contributes to proper moisture control management, improved indoor air quality and a
regulated air exchange. ASHRAE Standard 62.2 should be consulted to determine the mechanical
ventilation requirements for each home. Icynene website”
The Spray Foam Coalition of the ACC Center for the Polyurethanes Industry also states on page 23
of their Guidance on Best Practices for the Installation of Spray Polyurethane Foam, “SPF
applications typically improve air sealing of the structure, and it is important for building owners to
understand how this impacts the overall building and the potential need for new or additional
ventilation.”
Spray Polyurethane Foam (SPF) Insulation Inspection
The SPF insulation was inspected in accordance with the Spray Foam Coalition Guidance on
Sampling Techniques for the Inspection of Installed SPF. The inspection included a visual inspection
for the following.
2.5.1: Cracks 2.6.3: Blotchiness 5.1.2: Scorching
2.5.2: Surface Appearance 2.7: Blisters / Delaminations 5.1.3: UV Degradation
2.5.3: Shrinkage 2.8: Odor 5.2: Foam Profile (Cross-Sectional)
2.5.4: Gaps and Voids 2.9: Surface Profile 5.3: Cell Structure Consistency
2.6.2: Uniformity 5.1: Color 5.4: Knit-line Adhesion
The visual inspection of the applied spray polyurethane foam insulation found the surface of the SPF
to have a uniform color and appeared to be in good condition. This is shown in the inspection
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pictures. We removed 8 areas of applied SPF. The depth of the SPF was acceptable and adequate
in samples 1 thru 6. The required R-value was provided with the measured depth of the SPF
insulation. Samples 7 and 8 were very thin.
The surface profile was very consistent without many voids, anomalies, or blisters as shown in the
site inspection pictures. There was a substantial amount of over spray throughout the attic. There
was good adhesion of the spray polyurethane foam insulation to the roof sheathing and framing
members. All samples had internal voids, inconsistent cell structure and poor knit-line adhesion as
shown in the Inspection Pictures.
1. Odor: During SPF applications, odors are common and normal. Once the project is completed
and the spray area ventilated, odors generally dissipate. Lingering odors may be the result of
several factors and can be a combination of numerous sources, making it difficult to identify
them.
2. Odors may be noticed while extracting samples or within the sample. Document the presence
of odor and describe its characteristics with descriptive words such as “fishy” or “rotten egg,”
along with other sample documentation.
3. Scorching: Scorching may occur when the SPF becomes excessively hot during its
application and cure phase. When SPF’s exothermic reaction results in the foam getting too
hot for too long a period of time, the foam may degrade, resulting in scorching indicated by a
brownish discoloration. The affected area is usually within the foam mass and not observable
without cutting a core sample.
4. Cell Structure Consistency: The foam profile (substrate to surface) is typically uniform, and
the cells are small and consistent. The cell structure is tight, small and consistent at the
substrate interface and on either side of knit lines. Potential cell structure defects could include
the following:
o Open, irregular cells: A layer of open, irregular cells may be an indication that moisture
was introduced or present on the substrate. Ifextensive, this can lead to structural
failure of the cell layer, blistering and/or delamination (Figure 18).
o Elongated cells: Isolated, occasional elongated cells that are visually detectable do not
normally constitute a defect. If extensive, then consider documenting
Recommendations
There are three options to correct the reported air quality issues within the home. With all three
options, we strongly recommend installing outdoor air supply ducted through a dehumidifier and out
to the air handler return to meet the minimum ventilation rate. The outdoor air damper should be set
to open no more than 25%. The thermostat will need to be replaced with a humidistat to control the
mechanical damper, dehumidifier, and air handler.
Option 1 completes the sealing and conditioning of the SPF attic along with improvements to the
HAVC system. The SPF remains in place, the attic is thoroughly cleaned, and HEPA vacuumed,
and the HVAC design is altered to accommodate the SPF sealed attic and to meet the minimum
ventilation rate for indoor air quality. Safe to occupy by all except those sensitized to SPF.
Option 2 also leaves the SPF in place except at the soffits and off ridge vents. The SPF would be
remove only as necessary to ensure the attic is properly vented. The original insulation and attic
debris will need to be removed but the attic will not need to be thoroughly cleaned as with Option 1.
The attic floor would then be sealed to prevent attic communication with the living space and
reinsulated with batt insulation. Soffit and off ridge vents would need to be installed to properly vent
the attic. Safe to occupy by all except those sensitized to SPF.
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Option 3 is the same as Option 2 with the full removal of the SPF insulation. Option 2 and 3 return
the home to the original design of a traditionally vented and insulated attic. Safe to occupy by all
except those sensitized to SPF.
It is very important to know that I’ve worked with dozens of clients sensitized to SPF either due to
the reoccupancy of their home that wasn’t properly ventilated or were exposed during the application
of SPF. Not once has anyone been able to reoccupy the home after Options 2 or 3 were completed.
Option 1 places the home in the best position without compromising the homes value.
Specific Recommendations
Option 1
• Remove the areas of identified SPF that was applied with deviations from the BASF published
guidelines.
• Clean the attic, remove all remaining original insulation, accumulated debris, HEPA vacuum
the attic to collect and remove the remaining dust and debris
• Ensure there are no major kinks in the suspended attic ducts
• Circulate air through the sealed attic
• Install outdoor air supply ducted through a dehumidifier and out to the air handler return to
meet the minimum ventilation rate. The outdoor air damper should be set to open no more
than 25%. Install a humidistat to control the mechanical damper, dehumidifier, and air handler
Option 2
• Remove the areas of identified SPF that was applied with deviations from the BASF published
guidelines.
• Remove the spray polyurethane foam, SPF, insulation at the soffits to allow traditional attic
ventilation.
• Remove the remaining original insulation and accumulated debris
• Replace the soffit vents around the home as necessary
• Add off ridge vents to complete the traditional attic ventilation
• Seal the attic to living space ceiling penetrations
• Ensure there are no major kinks in the suspended attic ducts
• Reinsulate the attic with traditional batt insulation
• Additionally Recommended - Install outdoor air supply ducted through a dehumidifier and out
to the air handler return to meet the minimum ventilation rate. The outdoor air damper should
be set to open no more than 25%. Install a humidistat to control the mechanical damper,
dehumidifier, and air handler
Option 3
• Remove all spray polyurethane foam, SPF, insulation
• Remove the remaining original insulation and accumulated debris
• Replace the soffit vents around the home as necessary
• Add off ridge vents to complete the traditional attic ventilation
• Seal the attic to living space ceiling penetrations
• Ensure there are no major kinks in the suspended attic ducts
• Reinsulate the attic with traditional batt insulation
• Additionally Recommended - Install outdoor air supply ducted through a dehumidifier and out
to the air handler return to meet the minimum ventilation rate. The outdoor air damper should
be set to open no more than 25%. Install a humidistat to control the mechanical damper,
dehumidifier, and air handler
HVAC
• Remove and replace the supply plenum
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eFiled Lee County Clerk of Courts Page 21
SPF Sample Locations
Indoor Air Quality Solutions, IAQS | PH (407) 383-9459 Page 9 of 11
5224 SR 46 Suite 380 Sanford, Florida 32771 www.FloridaIAQ.com
eFiled Lee County Clerk of Courts Page 22
Recommendations for Supply Ventilation
Indoor Air Quality Solutions, IAQS | PH (407) 383-9459 Page 10 of 11
5224 SR 46 Suite 380 Sanford, Florida 32771 www.FloridaIAQ.com
eFiled Lee County Clerk of Courts Page 23
Report Limitations & Exclusions
All the professional opinions presented in this
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Filing # 157975886 E-Filed 09/22/2022 04:05:33 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR LEE COUNTY,FLORIDA CIVIL ACTION LESLIE KAHLER and JAMES KAHLER, Plaintiffs, vs. CASE NO: PARADISE FOAM,LLC, a Florida Limited Liability Company, Defendant. / COMPLAINT COMES NOW the Plaintiffs, LESLIE KAHLER and JAMES KAHLER,(collectively known as the "KAHLERS") by and through their undersigned counsel, sue Defendant, PARADISE FOAM, LLC, a Florida Limited Liability Company,("PARADISE"), and state as follows: VENUE AND JURISDICTION 1. Venue is proper in Lee County,Florida because this cause ofaction accrued in Lee County, Florida. 2. LESLIE KAHLER is a resident of Lee County, Florida and owns the following real property located in Lee Coimty: 657 Rabbit Road, Sanibel, Florida 33957 (hereinafter "Property"). 3. JAMES KAHLER is a resident ofLee County, Florida and also owns the Property. 4. Upon information and belief, PARADISE is a Florida limited liability company whose principal place of business is located in Charlotte County, Florida and is registered to conduct business in the State of Florida. 5. Venue is proper in Lee County, Florida, because the real property which is the subject matter ofthis dispute is located in Lee County, Florida. Page 1 of7 eFiled Lee County Clerk of Courts Page 1 eFiled Lee County Clerk of Courts Page 2 eFiled Lee County Clerk of Courts Page 3 eFiled Lee County Clerk of Courts Page 4 eFiled Lee County Clerk of Courts Page 5 eFiled Lee County Clerk of Courts Page 6 eFiled Lee County Clerk of Courts Page 7 eFiled Lee County Clerk of Courts Page 8 eFiled Lee County Clerk of Courts Page 9 eFiled Lee County Clerk of Courts Page 10 eFiled Lee County Clerk of Courts Page 11 eFiled Lee County Clerk of Courts Page 12 Table of Contents Client’s Areas of Concern.......................................................................................... 1 Spray Foam Insulation Inspection Standards ............................................................ 1 Executive Summary .................................................................................................. 1 US EPA Health Concerns about Spray Polyurethane Foam ..................................... 3 Potential Chemical Exposures from Spray Polyurethane Foam ................................ 4 Possible Exposure Routes ............................................................................................................ 4 Vapors and Aerosols ..................................................................................................................... 4 EPA’s Ventilation Guidance for Spray Polyurethane Foam Application ..................... 4 Ensure Adequate Ventilation Following Application ...................................................................... 4 BASF Application Guidelines .................................................................................... 4 To Be Installed Only By Properly Trained Contractors .................................................................. 4 Pass Thickness and Multiple Passes ............................................................................................ 5 Processing and Application Instructions ........................................................................................ 5 Pre - and Post - Spraying .............................................................................................................. 5 Spray Polyurethane Foam (SPF) Insulation Inspection ............................................. 6 Recommendations .................................................................................................... 7 Specific Recommendations ....................................................................................... 8 SPF Sample Locations .............................................................................................. 9 Recommendations for Supply Ventilation ................................................................ 10 Report Limitations & Exclusions .............................................................................. 11 Guidance on Best Practices for the Installation of Spray Polyurethane Foam ........... 1 Ventilation Considerations for Spray Polyurethane Foam ............................................................. 1 Recommended HVAC Equipment ............................................................................. 4 Recommended Dehumidifier Ducting ........................................................................ 4 AMRC VOC Report ................................................................................................... 5 Inspection Pictures .................................................................................................... 7 Damaged Ceilings ......................................................................................................................... 8 Interior ......................................................................................................................................... 12 SPF Samples .............................................................................................................................. 22 Sample 1 ................................................................................................................................. 22 Sample 2 ................................................................................................................................. 28 Sample 3 ................................................................................................................................. 32 Sample 4 ................................................................................................................................. 37 Sample 5 ................................................................................................................................. 41 Sample 6 ................................................................................................................................. 48 Sample 7 ................................................................................................................................. 52 Sample 8 ................................................................................................................................. 56 Attic Condition ......................................................................................................................... 60 Indoor Air Quality Solutions, IAQS | PH (407) 383-9459 www.FloridaIAQ.com 5224 SR 46 Suite 380 Sanford, Florida 32771 eFiled Lee County Clerk of Courts Page 13 ATTN: Mr. & Ms. Kahler April 25, 2022 REF: Indoor Environmental Assessment On April 8th, 2022, Indoor Air Quality Solutions, IAQS conducted an Indoor Air Quality and Spray Polyurethane Foam Insulation Assessment of the home located at 657 Rabbit Rd. Sanibel, FL 33957 (property) and prepared this report for Mr. & Ms. Kahler (client) summarizing the findings. Client’s Areas of Concern Mr. & Ms. Kahler would like to know the installed condition of the retrofit Spray Polyurethane Foam, SPF, Insulation that was recently installed in their home. Spray Foam Insulation Inspection Standards IAQ Solutions conducted a visual inspection of the applied spray foam insulation as an independent third-party to determine whether or not the product has been installed in accordance with the agreed upon specifications, manufacturer specifications, industry standards, and information contained within the product data sheets. The assessment was in accordance with the document; Guidance for Residential Homes and Commercial Buildings established by the Spray Foam Coalition of the ACC Center for the Polyurethanes Industry. The Spray Polyurethane Foam Installation Guidance is intended to provide an overview of best practices to help professional installers use SPF effectively and efficiently to insulate homes and commercial buildings. The SPF was inspected in accordance with the Spray Polyurethane Foam: Guidance on Sampling Techniques for the Inspection of Installed SPF Executive Summary The home is a single-story single-family home with 3 bedrooms, 2 bathrooms, and approximately 1,232 square feet of living space built in 1984. The home’s attic was retrofit insulated with spray polyurethane foam insulation. The SPF was examined by BASF with the following conclusion. “The visible blown cells and the higher open cell content are indicators that there was a lack of dwell time between passes and/or the material was sprayed too hot. It also appeared that some passes were above the recommended 2” maximum thickness. All of these observations support the mild to strong odor that was detected in each sample. Based on the samples that were provided to our lab and the results below, we would recommend that sections of the jobsite with similar application deviations be removed and replaced with material applied per our application guidelines.” American Management Resources Corporation collected Limited Basic Volatile Organic Compounds Assessment. They concluded that “at the time of the site visit, the measured VOC levels were low inside the residence. However, there was a noticeable odor present.” The spray polyurethane foam insulation installed in the Kahler attic was BASF, Spraytite 178. Spraytite and Walltite Series products are closed-cell, medium density spray polyurethane foam (ccSPF) insulation materials. These ccSPF are created by the chemical reaction between an isocyanate and a resin. Spraytite and Walltite Series can only be processed with BASF Elastospray® 8000A Isocyanate. When these materials are combined in the spray gun’s mixing chamber, a Indoor Air Quality Solutions, IAQS | PH (407) 383-9459 Page 1 of 11 5224 SR 46 Suite 380 Sanford, Florida 32771 www.FloridaIAQ.com eFiled Lee County Clerk of Courts Page 14 chemical reaction occurs, releasing heat. This heat, or exothermic reaction, causes the blowing agent to expand creating foam. The final cured Spraytite product is yellow/off white; the final cured Walltite product is green. Spraytite LWP Series, Comfort Series and Walltite LWP Series are HFO- based formulations, whereas all other formulas indicated above are HFC-based SPF products, My review of the product specification and application guidelines all indicated that the property should be ventilated during and after the application of the SPF. There was a single fan identified on the property according to the Kahler’s. There were no supply air fans or containment. Just the single fan at the top of the attic stairs. I have found that even properly applied SPF can be a serious concern for the occupants if the attic and home aren’t properly ventilated during and after application. Without proper ventilation, the attic and home will fill with the off gassing from the application. Often, with retro fit applications of SPF, the home is not properly ventilated during the application of the SPF insulation. We have found more issues with the accumulation of VOC’s from inadequate ventilation during application than with misapplied SPF insulation. The method of venting the home during the application of the SPF is unknown but a likely cause for the reported odors and measured elevations of VOC’s within the home. There were several areas of the ceiling that were damaged during the removal of the original insulation. These areas should have been contained to prevent the SPF chemicals, airborne mists, and particulates from entering the Kahler home. Unfortunately they were not. A review of the BASF documents found that BASF refers the applicator to the Spray Foam Coalition (SFC) of the Center for the Polyurethanes Industry (CPI) and the U.S. Environmental Protection Agency (EPA) Ventilation Guidance for Spray Polyurethane Foam Application. Both of those documents refer you back to the manufacturer for the actual rate of ventilation for the specific product. It would appear that neither the manufacturer, industry association nor the US government want to specify the actual ventilation requirements for BASF, Spraytite 178. BASF ESR-2642 Supplement page 16. Ventilation of the work area is required and should be in accordance with Ventilation Considerations or Spray Polyurethane Foam: Guidance on Ventilation During Installation of Interior Applications of High-Pressure Spray Polyurethane Foam as published by the Spray Foam Coalition (SFC) of the Center for the Polyurethanes Industry (CPI). The following statement regarding ventilation of the work area is reprinted from the guidance document: "Work zone mechanical ventilation during and after SPF installation is designed to prevent workers and others in the area from being, exposed to SPF chemicals above recommended or permissible levels. Potential health effects from exposure above recommended levels can range from no effects to slight irritation of the eyes, skin or respiratory system to the development of chronic lung or pulmonary disease depending on the individual person and level and duration of overexposure." The spray area should be posted with keep out WARNING signs before and after spraying. Workers only that are trained and have ·the necessary personal protection equipment are allowed inside the spray area. All others must be kept out as well as pets. Ventilation of the spray area is to be done incorporating the• guidance documents: "Ventilation Guidance for Spray Polyurethane Foam Application," published by the U.S. Environmental Protection Agency (EPA), online Good Practices – Engineering Controls and Ventilation," published by the American Chemistry Council's Center for the Polyurethanes Industry, available online. The following general requirements must also be followed, Code of Federal Regulations Title 29 CFR §192.20 Safety and Health Regulations for Construction, General Safety and Health Provisions available online. The applicators and building owners should visit www.spraypolyurethane.org and also www.spf.basf.com for up to date information about spray polyurethane foam construction applications before starting projects. Indoor Air Quality Solutions, IAQS | PH (407) 383-9459 Page 2 of 11 5224 SR 46 Suite 380 Sanford, Florida 32771 www.FloridaIAQ.com eFiled Lee County Clerk of Courts Page 15 According to the Spray Foam Coalitions Guidance on Ventilation During Installation of Interior Applications of High-Pressure Spray Polyurethane Foam; When SPF is applied using high-pressure application equipment, some SPF component chemicals may be present in the form of aerosol mists and vapors over the occupational exposure level (OEL) or at levels that could be harmful to some individuals According to OSHA regulations, SPF contractors have a legal responsibility to provide a safe workplace for all employees. In the case of high-pressure SPF application, use of engineering controls and proper PPE in the work zone during and after spraying is an important consideration to help achieve a safe workplace. Proper ventilation during and after application includes three critical components; Containment, Exhaust Air, Supply Air, and Negative Pressure. 1. Containment: Containment serves several important functions: Prevents airborne mists and particulates from migrating to other parts of the building. Minimizes the total volume of the work zone for ventilation, thus reducing the size and number of fans, and helps to direct airflow across the point of SPF application. Establishes a defined boundary between the work zone and other areas in the building. 2. Exhaust Air: The exhaust air system includes an exhaust point, ductwork and an exhaust fan that captures contaminates at the source and sends them to a location outside the building away from occupied areas and air inlets. 3. Supply Air: The supply air system provides a source of fresh outside air into the work zone that is needed to replace the air removed by the exhaust system. This make-up air can be provided passively through various penetrations in the containment (such as windows, doors, exterior vents and other openings) or through a dedicated active forced-air inlet system consisting of a supply point, ductwork and second supply fan. 4. Negative Pressure: A negative pressure within the containment zone assures that contaminants are not forced into other areas of the building. With a two-fan system, negative containment pressures can always be achieved when the exhaust fan capacity (e.g., CFM rating) is greater than the supply fan capacity. Without the proper ventilation, the home and its contents can be exposed to the chemicals from the application of the SPF. These chemicals include isocyanates. Sensitization to isocyanates may result from either a single exposure to a relatively high concentration or repeated exposures to lower concentrations over time. It’s unknown what level of any chemicals were in the home or to what Ms. Kahler was exposed to. Some people react to very low levels of isocyanates. Regardless, the levels of isocyanates has long since dissipated below detection limits but remains at levels that sensitized individuals can react to. US EPA Health Concerns about Spray Polyurethane Foam Isocyanates are a class of highly reactive chemicals with widespread industrial, commercial, and retail or consumer applications. Exposure to isocyanates may cause skin, eye and lung irritation, asthma, and “sensitization.” Isocyanates are irritants to the mucous membranes of the eyes and gastrointestinal and respiratory tracts. Direct skin contact can also cause marked inflammation. There is no recognized safe level of exposure to isocyanates for sensitized individuals. Isocyanates have been reported to be a leading attributable chemical cause of asthma in the workplace. Dermal, eye, and respiratory exposures can trigger adverse health responses. EPA, other federal agencies, states, industry, and other countries have taken a variety of actions to address risks posed by exposure to isocyanates. Exposures to isocyanates should be minimized. Indoor Air Quality Solutions, IAQS | PH (407) 383-9459 Page 3 of 11 5224 SR 46 Suite 380 Sanford, Florida 32771 www.FloridaIAQ.com eFiled Lee County Clerk of Courts Page 16 Potential Chemical Exposures from Spray Polyurethane Foam Possible Exposure Routes When spray polyurethane foam is being used, the work site should be restricted to persons wearing appropriate personal protective equipment. The information on this page is meant to underline the importance of wearing protective equipment by explaining ways that chemical exposures from spray polyurethane foam (SPF) may occur. Vapors and Aerosols • Spray application generates isocyanate vapors and aerosols. • Research data indicate that inhalation exposures during SPF insulation will typically exceed Occupational Safety and Health Administration (OSHA) occupational exposure limits (OELs) and require skin, eye and respiratory protection. • Vapors and aerosols can migrate through the building if the area is not isolated and properly ventilated. • After application, vapors may linger in a building until properly ventilated and thoroughly cleaned. EPA’s Ventilation Guidance for Spray Polyurethane Foam Application This page describes basic ventilation principles and strategies to help protect workers and building occupants and promote the safe use of spray polyurethane foam (SPF) insulation. • Why is ventilation important? • Overview of key principles • Fundamentals of ventilation • SPF ventilation challenges • Basic ventilation design principles • Establish air flow across the spraying area • Establish enclosures to isolate and contain the work area • Direct exhaust to a safe location • Ensure adequate ventilation following application Ensure Adequate Ventilation Following Application Always remember to continue ventilating the area following application until the material has fully cured, off -gassing has stopped, and vapors have been removed. During this time, worker re-entry should be kept to a minimum and should only include those with appropriate respiratory protection (and skin protection if contact with the SPF is possible). Occupant re-entry should only occur after the building is fully ventilated. BASF Application Guidelines Application space must be properly ventilated during and after application. Consult the EPA’s “Ventilation Guidance for Spray Polyurethane Foam Application” document and the American Chemistry Council’s “Ventilation Considerations for Spray Polyurethane Foam” documents for specific requirements. 24-hour re-occupancy time is advised. Page 3 To Be Installed Only By Properly Trained Contractors Installation of BASF spray foams requires special equipment and training. Only individuals that have completed training through verifiable sources (i.e. ABAA, Approved Distributor training, BASF TTC Training, CPI Online Health & Safety Training, SPFA Professional Certification Program [PCP] Training) can install ST & WT Series SPF’s. Page 1 Indoor Air Quality Solutions, IAQS | PH (407) 383-9459 Page 4 of 11 5224 SR 46 Suite 380 Sanford, Florida 32771 www.FloridaIAQ.com eFiled Lee County Clerk of Courts Page 17 Pass Thickness and Multiple Passes The heat created by the exothermic reaction during application creates a risk of scorching and/or fire, as well as irritating odors. This risk increases with greater pass thickness. Page 2 If you spray a pass in excess of the maximum pass thickness, those areas must be immediately removed from the substrate using a nonflammable tool such as a crowbar – do not use your hands. After removal, break up large pieces of foam on a non-flammable surface using the non-flammable tool. Large masses of SPF should be removed to an outside safe area, cut into smaller pieces and allowed to cool before discarding into an appropriate trash receptacle. When spraying multiple passes, a cooling/dwell time of 10 minutes per inch applied must be allowed for the dissipation of heat. Not allowing adequate cooling/dwell time raises the risk of scorching and/or fire. Once the installed material has cooled, it is possible to add additional passes in order to increase the overall installed thickness of SPF. If a third layer of a material, at the maximum allowable pass thickness, is required, there must be a cooling period of at least 1 hour between passes before spraying additional passes. Maximum four passes, at the maximum allowable pass thickness, per 12 hrs. Processing and Application Instructions A small “test area” of spray foam should be applied and inspected prior to commencing the project. • Check the reactivity, density, spray pattern, mix quality, and foam cell quality by test spraying onto a disposable piece of substrate. • This simple, low-cost test area can indicate inadequate adhesion, improper surface preparation and/or primer requirements, surface contamination, improper substrate and/or ambient temperature, equipment malfunctions, material contamination, or improper application technique. • Visual inspection of a sample cut from first test area and periodic job samples can reveal potential problems that may be due to one or more of the above conditions. Application space must be properly ventilated during and after application. Consult the EPA’s “Ventilation Guidance for Spray Polyurethane Foam Application” document and the American Chemistry Council’s “Ventilation Considerations for Spray Polyurethane Foam” documents for specific requirements. 24-hour re-occupancy time is advised. Page 3 IT IS STRONGLY ENCOURAGED TO COMPLETE A QUALITY CONTROL DAILY REPORT AND AN INSULATION CARD FOR EACH PROJECT. Pre - and Post - Spraying Applying residential insulation systems can be best done in a "picture framing" motion in which the applicator surrounds the outside of the stud cavity allowing the foam to rise along the stud face. About ten feet of wall can be done at a time. After picture framing a specified area return back to the start point to fill in the center of the cavity. Additional lifts or passes are to be done after the initial lift or pass has had adequate time to cool down (about 20 minutes for two-inch pass). Page 5. There is also the issue with tightly sealed homes and the need to mechanically ventilate to maintain good indoor air quality. The home is now sealed very tight and will require mechanical ventilation. This is a critical conversation that must be had prior to the installation of the SPF. There is a specific need for mechanical ventilation to meet the ASHRAE 62 ventilation rate. The Spray Foam Coalition of the ACC Center for the Polyurethanes Industry also states on page 23 of their Guidance on Best Practices for the Installation of Spray Polyurethane Foam, “SPF applications typically improve air sealing of the structure, and it is important for building owners to understand how this impacts the overall building and the potential need for new or additional ventilation.” Indoor Air Quality Solutions, IAQS | PH (407) 383-9459 Page 5 of 11 5224 SR 46 Suite 380 Sanford, Florida 32771 www.FloridaIAQ.com eFiled Lee County Clerk of Courts Page 18 In addition, the Spray Foam Coalition of the ACC Center for the Polyurethanes Industry also states on page 24 of their Guidance on Best Practices for the Installation of Spray Polyurethane Foam in the Retrofitting Attics section under the heading of HVAC Systems (Attics); “The contractor and the homeowner should be aware that retrofitting an existing attic by employing an unvented attic assembly technique can result in the existing HVAC system becoming “oversized” in relation to the new demand. This situation is of special concern in the southern and coastal climate zones where the HVAC also serves to reduce or otherwise manage moisture levels of buildings in order to improve comfort and prevent moisture related problems, such as mold and mildew. If an existing HVAC becomes “oversized” due to the increased thermal efficiency of the unvented attic assembly, the HVAC system may begin to short cycle, or to quickly turn on and off, as it works to manage temperature. This short cycling of the HVAC system may have negative impacts on the comfort and efficiency of the building and possibly on the lifespan of the system. Involve an HVAC consultant to adapt the system to the new, more efficient building envelope associated with the spray foam retrofit.” The conversation as outlined in the Spray Foam Coalition Guidance documents should have taken place prior to the application of the SPF. The conversation would have allowed Mr. & Ms. Kahler to make an informed decision regarding the purchase and application of the SPF. Mr. & Ms. Kahler will now have to incur additional cost to bring their home to the necessary design considerations required for the sealed attic as described in this report. All homes insulated and air sealed with SPF must be designed to include adequate mechanical ventilation/outdoor air supply for optimum IAQ (Indoor Air Quality). To ensure there are no odors, accumulated VOC’s, elevated humidity, or condensation within the sealed attic air must be moved through the sealed attic. Many manufactures are now including the need for mechanical ventilation in their product specification sheets and websites. Icynene for example provides the following on their website and within their product specification sheets. “HVAC & Ventilation with Spray Foam. Appropriately combining spray foam and mechanical ventilation contributes to proper moisture control management, improved indoor air quality and a regulated air exchange. ASHRAE Standard 62.2 should be consulted to determine the mechanical ventilation requirements for each home. Icynene website” The Spray Foam Coalition of the ACC Center for the Polyurethanes Industry also states on page 23 of their Guidance on Best Practices for the Installation of Spray Polyurethane Foam, “SPF applications typically improve air sealing of the structure, and it is important for building owners to understand how this impacts the overall building and the potential need for new or additional ventilation.” Spray Polyurethane Foam (SPF) Insulation Inspection The SPF insulation was inspected in accordance with the Spray Foam Coalition Guidance on Sampling Techniques for the Inspection of Installed SPF. The inspection included a visual inspection for the following. 2.5.1: Cracks 2.6.3: Blotchiness 5.1.2: Scorching 2.5.2: Surface Appearance 2.7: Blisters / Delaminations 5.1.3: UV Degradation 2.5.3: Shrinkage 2.8: Odor 5.2: Foam Profile (Cross-Sectional) 2.5.4: Gaps and Voids 2.9: Surface Profile 5.3: Cell Structure Consistency 2.6.2: Uniformity 5.1: Color 5.4: Knit-line Adhesion The visual inspection of the applied spray polyurethane foam insulation found the surface of the SPF to have a uniform color and appeared to be in good condition. This is shown in the inspection Indoor Air Quality Solutions, IAQS | PH (407) 383-9459 Page 6 of 11 5224 SR 46 Suite 380 Sanford, Florida 32771 www.FloridaIAQ.com eFiled Lee County Clerk of Courts Page 19 pictures. We removed 8 areas of applied SPF. The depth of the SPF was acceptable and adequate in samples 1 thru 6. The required R-value was provided with the measured depth of the SPF insulation. Samples 7 and 8 were very thin. The surface profile was very consistent without many voids, anomalies, or blisters as shown in the site inspection pictures. There was a substantial amount of over spray throughout the attic. There was good adhesion of the spray polyurethane foam insulation to the roof sheathing and framing members. All samples had internal voids, inconsistent cell structure and poor knit-line adhesion as shown in the Inspection Pictures. 1. Odor: During SPF applications, odors are common and normal. Once the project is completed and the spray area ventilated, odors generally dissipate. Lingering odors may be the result of several factors and can be a combination of numerous sources, making it difficult to identify them. 2. Odors may be noticed while extracting samples or within the sample. Document the presence of odor and describe its characteristics with descriptive words such as “fishy” or “rotten egg,” along with other sample documentation. 3. Scorching: Scorching may occur when the SPF becomes excessively hot during its application and cure phase. When SPF’s exothermic reaction results in the foam getting too hot for too long a period of time, the foam may degrade, resulting in scorching indicated by a brownish discoloration. The affected area is usually within the foam mass and not observable without cutting a core sample. 4. Cell Structure Consistency: The foam profile (substrate to surface) is typically uniform, and the cells are small and consistent. The cell structure is tight, small and consistent at the substrate interface and on either side of knit lines. Potential cell structure defects could include the following: o Open, irregular cells: A layer of open, irregular cells may be an indication that moisture was introduced or present on the substrate. Ifextensive, this can lead to structural failure of the cell layer, blistering and/or delamination (Figure 18). o Elongated cells: Isolated, occasional elongated cells that are visually detectable do not normally constitute a defect. If extensive, then consider documenting Recommendations There are three options to correct the reported air quality issues within the home. With all three options, we strongly recommend installing outdoor air supply ducted through a dehumidifier and out to the air handler return to meet the minimum ventilation rate. The outdoor air damper should be set to open no more than 25%. The thermostat will need to be replaced with a humidistat to control the mechanical damper, dehumidifier, and air handler. Option 1 completes the sealing and conditioning of the SPF attic along with improvements to the HAVC system. The SPF remains in place, the attic is thoroughly cleaned, and HEPA vacuumed, and the HVAC design is altered to accommodate the SPF sealed attic and to meet the minimum ventilation rate for indoor air quality. Safe to occupy by all except those sensitized to SPF. Option 2 also leaves the SPF in place except at the soffits and off ridge vents. The SPF would be remove only as necessary to ensure the attic is properly vented. The original insulation and attic debris will need to be removed but the attic will not need to be thoroughly cleaned as with Option 1. The attic floor would then be sealed to prevent attic communication with the living space and reinsulated with batt insulation. Soffit and off ridge vents would need to be installed to properly vent the attic. Safe to occupy by all except those sensitized to SPF. Indoor Air Quality Solutions, IAQS | PH (407) 383-9459 Page 7 of 11 5224 SR 46 Suite 380 Sanford, Florida 32771 www.FloridaIAQ.com eFiled Lee County Clerk of Courts Page 20 Option 3 is the same as Option 2 with the full removal of the SPF insulation. Option 2 and 3 return the home to the original design of a traditionally vented and insulated attic. Safe to occupy by all except those sensitized to SPF. It is very important to know that I’ve worked with dozens of clients sensitized to SPF either due to the reoccupancy of their home that wasn’t properly ventilated or were exposed during the application of SPF. Not once has anyone been able to reoccupy the home after Options 2 or 3 were completed. Option 1 places the home in the best position without compromising the homes value. Specific Recommendations Option 1 • Remove the areas of identified SPF that was applied with deviations from the BASF published guidelines. • Clean the attic, remove all remaining original insulation, accumulated debris, HEPA vacuum the attic to collect and remove the remaining dust and debris • Ensure there are no major kinks in the suspended attic ducts • Circulate air through the sealed attic • Install outdoor air supply ducted through a dehumidifier and out to the air handler return to meet the minimum ventilation rate. The outdoor air damper should be set to open no more than 25%. Install a humidistat to control the mechanical damper, dehumidifier, and air handler Option 2 • Remove the areas of identified SPF that was applied with deviations from the BASF published guidelines. • Remove the spray polyurethane foam, SPF, insulation at the soffits to allow traditional attic ventilation. • Remove the remaining original insulation and accumulated debris • Replace the soffit vents around the home as necessary • Add off ridge vents to complete the traditional attic ventilation • Seal the attic to living space ceiling penetrations • Ensure there are no major kinks in the suspended attic ducts • Reinsulate the attic with traditional batt insulation • Additionally Recommended - Install outdoor air supply ducted through a dehumidifier and out to the air handler return to meet the minimum ventilation rate. The outdoor air damper should be set to open no more than 25%. Install a humidistat to control the mechanical damper, dehumidifier, and air handler Option 3 • Remove all spray polyurethane foam, SPF, insulation • Remove the remaining original insulation and accumulated debris • Replace the soffit vents around the home as necessary • Add off ridge vents to complete the traditional attic ventilation • Seal the attic to living space ceiling penetrations • Ensure there are no major kinks in the suspended attic ducts • Reinsulate the attic with traditional batt insulation • Additionally Recommended - Install outdoor air supply ducted through a dehumidifier and out to the air handler return to meet the minimum ventilation rate. The outdoor air damper should be set to open no more than 25%. Install a humidistat to control the mechanical damper, dehumidifier, and air handler HVAC • Remove and replace the supply plenum Indoor Air Quality Solutions, IAQS | PH (407) 383-9459 Page 8 of 11 5224 SR 46 Suite 380 Sanford, Florida 32771 www.FloridaIAQ.com eFiled Lee County Clerk of Courts Page 21 SPF Sample Locations Indoor Air Quality Solutions, IAQS | PH (407) 383-9459 Page 9 of 11 5224 SR 46 Suite 380 Sanford, Florida 32771 www.FloridaIAQ.com eFiled Lee County Clerk of Courts Page 22 Recommendations for Supply Ventilation Indoor Air Quality Solutions, IAQS | PH (407) 383-9459 Page 10 of 11 5224 SR 46 Suite 380 Sanford, Florida 32771 www.FloridaIAQ.com eFiled Lee County Clerk of Courts Page 23 Report Limitations & Exclusions All the professional opinions presented in this