Drain-waste-vent: PVC, ABS No comments.

Windows: PVC No comments.

Although not directly relevant for the materials being studied, we believe information on the performance of vinyl roofing membranes provides valuable back ground information to the Task Group. Two recent studies are of particular relevance: (copies of both studies will be posted to tsac@green& #114;iver.org). The first study, which was done in conjunction with the National Research Council of Canada, documents the results of testing of samples from 44 PVC roofs located across Europe and North America. The average age of the roofs at the time of the survey was just over 20 years, with the oldest being 34 years old. All roofs were found to be in good condition and still hot air weldable. Even after on average two decades of service, the physical properties of the samples compared well to the requirements for new materials in the relevant standards.{Field Investigation and Laboratory Testing of Exposed Poly(vinyl Chloride) Roof Systems, Proceedings of the 20th RCI International Convention, April, 2005). The second study conducted jointly by the U.S. Army Corps of Engineers, the National Research Council of Canada and independent consultants compares the relative durability of 12 roofing materials after four years of exposure in three locations. The two PVC materials studied ranked first and third in two of the locations and second and fifth in the third location (out of 12 materials tested). In each of the three locations, the PVC products outperformed materials typically proposed as alternatives.{Predicitve Service Life Tests for Roofing Membranes, International Conference on Durability of Building Materials and Components, Lyon, France, April, 2005}

Service Life – PVC pipes for a variety of applications including wastewater and water transport have been in use for over 70 years. Evaluations of PVC pipe durability have been extremely positive. The most recent study was commissioned by the American Water Works Association Research Foundation (AwwaRF) and conducted by Australia's Commonwealth Scientific and Industrial Research Organization (CSIRO). The study entitled, “Long Term Performance of PVC Pipes” (AwwaRF project 2879), did not find any significant degradation or deterioration occurring and projected that performance through 110 years will be very good, i.e., with very few problems or failures. The report will be available from AwwaRF later this year (www.awwarf.org). Relying upon the many independent evaluations of PVC pipe service life, we would expect PVC DWV pipes and fittings to out last the buildings in which they are installed.

Based on technology advancements, many vinyl siding manufacturers offer lifetime warrantees on their products, or at least 50-year warrantees. When this warrantee evidence was presented to the National Institute of Standards and Technology (NIST), NIST used this information to estimate a minimum service life of 40 years for vinyl siding on a residential application, as part of its online service, NEST: National Economic Service-life Tools (http://www.pathnet.org/sp.asp?id=9710).

One of the many attributes of PVC pipe, including DWV is its resistance to corrosion. For this reason DWV will not corrode and National expects this piping product to provide a long service life that will out last the buildings that they are installed in.

Over the past 70 years, PVC pipes have been used extensively for a variety of applications, including transport of water and wastewater. The longevity of PVC pipe systems can be explained by their exceptional resistance to corrosion.

Because of their outstanding resistance to corrosion, the PVC DWV pipe systems manufactured by Ipex will provide end-users with years of trouble-free service. The service life of PVC DWV pipe systems will be superior to all competed products which are subject to corrosion. No building will see its service life being governed by the PVC DWV product used in it, which are expected to outlast most of the other building materials used for its construction.

Service Life: As a representitive of the Plastic Pipe and Fitting Association, I offer the following. For the DWV service life question posed on PVC, ABS and cast iron pipes, a majority of the PVC and ABS used as DWV outlasts the structure it is built into, with an estimated life of 100 years or more, (see Long Term Performance of PVC Pipes” AwwaRF project 2879)and therefore would only be removed during a significant or total demolition of the overall structure. Some small sections of cast iron might need to be replaced, during the building's life due to leaks from corrosion effects, but would likely be disposed of in a landfill and not recycled or incinerated either. DWV makes very low demands on plastic pipes and long service life is expected, as only corrosion in DWV systems would be a factor for replacement.

On behalf of the Resilient Floor Covering Institute the following comments are submitted:

There is very little consistency in the many life cycle assessments conducted over the last 10 years that compare the service life of various flooring materials, including the four flooring materials included in the TSAC PVC Draft Report. This is not surprising as typically floors are replaced not because they have worn out but rather because the building owner desires a fresh new appearance. It is not unusual today to find linoleum and vinyl flooring that was installed over 50 years ago and which continues to be very serviceable with an acceptable appearance. If a hard surface flooring material is maintained in accordance with the flooring manufacturer's instructions, the floor can last indefinitely because in most instances you are not walking on the floor but rather on a floor finish or a high performance coating. The service lives of most of the floors contained in the BEES program are based on replacement reports (The Whitestone Building Maintenance and Repair Cost Reference). The one exception is the service life of cork flooring where a cork flooring manufacturer advised BEES that its floor would last for 100 years, but BEES subsequently reduced the figure to 50 years. Thus, the service lives of the floors as identified in the BEES program do not relate to the end of life for the flooring product from a performance standpoint.

ISO/DIS 15686 - Service life planning - includes guidance for determining service life after the early life cycle stages by stating, "For succeeding life cycle stages (scenarios from current position to end of life), data should be predicted on the basis of product performance as well as the expected application context, where relevant." One way to predict flooring product performance and thus service life is to compare flooring products based on the flooring product's ability to resist abrasion, which is what happens when you walk on a floor. Thus if a building owner did not properly maintain a floor, the results of an abrasion test would provide insight into how long a floor may last.

ASTM Standard Test Method F510 establishes the laboratory procedure for determining the abrasion resistance of resilient flooring using a grit feeder. This test method is designed to simulate one kind of abrasive action and abradant that a floor may encounter in the field. Results should not be used as an absolute index of ultimate life because there are many other factors to consider. However, if you installed the four floors included in PVC Task Group Draft Report in the same location in a building, the loss of volume as a result of conducting a test under ASTM F510 would provide meaningful insight into the comparative life expectancy of each of the floors. The attached chart shows the results of volume loss in cubic millimeters per 100 revolutions based on the average of four tests conducted on representative samples of each of the four flooring types. These tests were recently conducted at the research laboratory of Armstrong World Industries.

The attached ASTM F510 test results indicate that cork flooring loses volume quicker than vinyl composition tile, sheet vinyl and linoleum flooring. It logically follows that, all things otherwise being equal, cork flooring would wear out and need to be replaced sooner than vinyl composition tile, sheet vinyl or linoleum flooring. This directly contradicts the assumption in the PVC Task Group's Draft Report that cork has a longer service life than each of the other three flooring products. Moreover, if each of the four flooring products were properly maintained, each would essentially have an indefinite service life. Thus, while ASTM F510 results should not be used as an absolute index of ultimate service life, the results support RFCI's position that the Task Group should use the same service life (18 years per the Whitestone Building Maintenance and Repair Cost Reference) for each of the four flooring products.

PVC pipes have been used for a variety of applications, including transport of water and wastewater, for more than 70 years. Their outstanding resistance to corrosion is one of the main reasons explaining the longevity of PVC pipe systems.

Royal Pipe Systems strongly believes that PVC DWV pipe systems will provide end-users with years of trouble-free service due in large part to this outstanding resistance to external and internal corrosion. Service life of PVC DWV will be superior to all competing materials which are all subject to corrosion. The service life of any building will not be governed by the PVC DWV installed in it, which will outlast most of the materials used for its construction.

Service Life

Please provide estimated or predicted service life data for these materials, and include

sources and explanations with any proposed numbers.

Windows: vinyl, aluminum, wood

· Vinyl window service life ranges from 25 to 50 years.

What is the basis for that number?

· This is based on the product warranties currently offered.

· It is also based on data gathered from two sources:

• History of installations in the U.S., beginning in the early 1980’s

• Accelerated exposure testing associated with the AAMA Vinyl Window Profile Certification Program