Why VEET can't include insulation.
Included in this e mail submission are previous correspondences to Ministers and their
advisors on entering a roof space, amongst other issues which make very interesting
reading to further support my case summarised below, why VEET must not include
insulation until many issues have been addressed.
The DRAFT Standard AS 3999 Installation of Bulk Insulation allows the complete covering of
the ceiling joists, WHICH IS DANGEROUS AND NOT SAFE.
When any Government official contact Standards Australia, or an insulation industry
organisation, such as ICANZ, they will be told that the new Standard AS 3999 has addressed
the issues I am raising, "everything is OK."
Just as the bulk insulation industry advised the Federal Government prior to the failed Home
Insulation Program, where three deaths occurred because of the contravention of the
Standard Wiring Rules AS/NZS 3000, and an archaic out of date (some seventeen
years), Installation of Insulation Standard AS3999 as evidenced in the Royal Commission
Home Insulation Program.
Additionally, this defective new Standard DRAFT AS 3999 is in contravention of OH &S
guidelines for worker safety to navigate, and move within a roof space considering it is
almost pitch black and most workers would at best have a small head light.
Picture below is considerably illuminated with a powerful light.
NO way would a head lamp reveal this hazard of covering the ceiling joists to allow safe
"passage" of other workers, or indeed a home owner to move safely through the roof
space.
Yet, below page from the DRAFT Standard AS 3999 approves of this disgraceful and
dangerous "practice" of covering ceiling joists. WHY?
DRAFT Standard AS 3999 INSTALLATION OF BULK INSULATION
STANDARDS (INDUSTRY), DRAFT AS 3999 ABOVE, ALLOWS CEILING JOISTS TO BE COVERED
BY BULK INSULATIONS, YET INDUSTRY CONDEMN FOIL FOR COVERING CEILING JOISTS.

How does anyone navigate the roof space without lifting the bulk insulation?

How does anyone know that there is not unprotected cabling over the ceiling joists
in contravention of the Wiring Rules AS/NZS 3000 without lifting the bulk insulation?

This quote below from the Federal Government website Your Home supports my
claim.
There are disturbing omissions regarding unprotected wiring over ceiling joists.
WHY?
"There are hazards related to covering ceiling joists with insulation, e.g. safe places to
walk cannot be identified when accessing the roof space. If insulation is removed each
time the roof space is accessed it must be reinstalled in accordance with the Australian
Standard."

This quote below from the Federal Government website Your Home supports my
claim
There are disturbing omissions regarding unprotected wiring over ceiling joists.
WHY?
"Electrical wiring must be appropriately sized or it may overheat when covered by
insulation. Have it inspected by a licensed electrician."

This statement is completely misleading How would the average person or an
installer have a knowledge of wiring sizing, AND WOULD CARE. DRAFT AS399
STANDARD says simply that older wiring has to have spacing for this not to overheat.
WOULD THE DIY person even know there is an insulation Standard. See Section 2
part quoted from Standard DRAFT AS3999 below.

MORE DISTURBING. In Section 2 from Standard DRAFT AS3999 there is NO mention
of unprotected cabling/wiring. WHY?
 See the yellow highlighted underlined paragraphs below from quoted
sections of the Federal Government Your Home, website

Considering the unprotected cabling wiring issues were revealed during the
Queensland Coronial Inquiry into the three workers deaths in 2013. Why weren't
these issues addressed on this website? WHY?

Because Max Mosher is a paid public advocate that resides on a Standards
Committee BD 58, that is responsible for DRAFT AS 3999 which is about to go to the
printers with very skimp warning about unprotected cabling over ceiling joists It
seem "everyone" wants to ignore the very issue that killed the three worker during
the failed Home Insulation Program WHY?

I wonder why this Federal Government website has not been updated revealing the
truth?
http://www.yourhome.gov.au/passive-design/insulation-installation
Authors
Principal authors: Max Mosher, Caitlin McGee
Updated by Max Mosher, 2013
 Health and safety tips
Wear protective clothing, gloves and a face mask when installing glass wool, mineral
wool or cellulose fibre insulation. These materials can cause short term irritation to
skin, eyes and the upper respiratory tract. It is good practice to always wear protective
equipment when working in dusty roof spaces.
Wear adequate eye protection when installing reflective insulation, as it can give off a
painful glare, and be aware of the increased risk of sunburn.
Insulation materials containing reflective foil must be kept clear of electrical wiring
and fittings, and should not be secured using metal staples.
Electrical wiring must be appropriately sized or it may overheat when covered by
insulation. Have it inspected by a licensed electrician.
Allow clearance around hot flues, exhaust fans, appliances and fittings that penetrate
the ceiling to the manufacturer’s installation instructions.

Ceiling
Place ceiling insulation between the joists. Suitable bulk insulation includes batts,
loose-fill and polystyrene boards. In alpine climates two layers of bulk insulation may
be installed to increase thermal performance, one between the joists and the second on
top.
There are hazards related to covering ceiling joists with insulation, e.g. safe places to
walk cannot be identified when accessing the roof space. If insulation is removed each
time the roof space is accessed it must be reinstalled in accordance with the Australian
Standard.
Suitable reflective insulation includes multi-cell batts, which should be placed
between ceiling joists. Install insulation strictly in accordance with manufacturer’s
instructions. Failure to do so can significantly reduce insulation values.

Older housing stock, remembering homes built now become older stock once they
become occupied. So therefore, how do you fix the problems outlined in this e mail,
as well as all the correspondences Tim Renouf and I provided the Royal Commission,
and Standards Australia (industry, because industry reside on the Standards working
groups along with the State Electrical Offices via ERAC that compose the structure of
Standards.
o How does anyone know that there is not older deteriorated wiring without
lifting the bulk insulation
o With older wiring an untrained person not aware of the issues of overheating
of older wiring could cause fires with some types of insulation of similar
thickness
o How do we define older, for "older housing stock"?
Logic says, once a house is built, it will usually be considered older than one
just completed and not lived in, with the exception of a completed house
that has not been lived in at all for a period of time which can occur.
The dictionary reference below verifies the concept of "older housing stock" I
believe
http://dictionary.reference.com/browse/older
Synonyms
Older, elder imply having greater age than something or someone else. Older
is the usual form of the comparative of old: This building is older than that
one.
Elder, now greatly restricted in application, is used chiefly to indicate seniority
in age as between any two people but especially priority of birth as between
children born of the same parents: The elder brother
Examples from the web for older
Look for wood from the previous season's growth, which is often lighter in color
than older wood.

WHY A PHYSICAL PRE ELECTRICAL SAFETY INSPECTION MUST BE DONE, and any
rectification completed before installation OF ANY INSULATIONS, WHETHER THIS BE
IN A NEWLY CONSTRUCTED, IN THE "COURSE OF CONSTRUCTION", OR OLDER
EXISTING HOME.

DRAFT AS3999 is completely confusing. Section 4 talks about a pre electrical
inspection by a competent person, see 4.3 (a) NOTES: 1 below.

Who would be a competent person? Who would know what electrical issues
to inspect in a roof space? It's hard enough for a qualified electrician with
years of experience.

As revealed at the Queensland Coronial Inquiry into the three deaths from
the Home Insulation Program, the Coroner's report ascertains that some of
the companies of the dead workers were electricians, and they did not report
to my knowledge any electrical faults, being the key issue of non compliant
wiring over ceiling joists in contravention of the Standard Wiring Rules
AS/NZS3000 in the roof space.

Choosing to close a "blind eye," which as we know, killed those young
workers.

If they did report faults, such as unprotected cables/wiring over ceiling joists,
there was no evidence from the Queensland Electrical Safety Office, or was
there?

These cables were in contravention of clause 3.9.1 of AS/NZS 3000, electrifying the
foil they were stapling, causing the foil to be blamed for the deaths, when in fact the
unprotected cabling location was the "root of the evil," as revealed during the Royal
Commission

Why haven't Standards Australia made a public response to the report?

Who are Standards Australia, protecting?

The electrical industry, and ERAC (all State Electrical Offices) that reside on
Standards committees?

YET, requirements to install electrically conductive bulk insulation, which is
reflective foil which insulates in a completely different physical way is placed
almost at the back of the Standard AS 3999 see page 108 of 109 pages below,
AND is informative. If this is the case, Appendix K should have been after or
combined with Section 4 in the main "body" of the Standard par quoted
above WHY hasn't it ?

Perhaps the bulk insulation industry has "done a deal" with the electrical
industry, and ERAC to protect one another, from public exposure, and
scrutiny compliments of Standards Australia, which these parties reside on
Standards Committees.

In an attempt to give the DRAFT Standard AS3999 credibility, it references
the different State OH &S workplace safety regulations for the installer to
adhere to.

If State OH & S regulations require a pre electrical inspection for all
insulations, this should be enforced, not as written below in clause 4.2.

This is ridiculous, why not reference the same requirements for foil as for
bulk insulations. The way Standard AS 3999 is written, the reader completely
confused.
The requirement for compliance of the Wiring Rules AS/NZS 3000 to protect cabling should
be "spelt out" in the Standard, and so should OH &S rules, because no one will bother to read
two documents.
As an example would be Section 4.3 ELECTRICAL SAFETY below
Below would be my suggestion of part (ii) rewrite this spells out what people should
be viewing when they entering a roof space.
This clause and others in the DRAFT Standard AS 3999 must be written in
unambiguous manner part (ii) should have said:
(ii)
Check and note the location of electrical cables, more so noting unprotected
electric cables shall not be positioned in locations where they are vulnerable to
damage such as over the tops of ceiling or floor joists in the area to be insulated, as
the Standards AS/NZS 3000 the Wiring Rules Clause 3.9.1
Additionally, check and note the location of electrical equipment and
in the area to be insulated
accessories
The OH &S rules must be the same, no matter what State, just as Standard AS 3999 is
Australia wide. Otherwise, don't have a Standard or OH & S rules.
The Royal Commission and Standards Australia have been notified by myself over the past
twelve months regarding many issues such as mentioned here, and Standards Australia have
completely ignored my concerns.
Now going to a vote of approval of DRAFT AS 3999 ready for printing, even before the
Government have commented to the Royal Commission Report.
I know Standards Australia are committing "wilful negligence," as demonstrated above.
Unless the Victorian Government exercise due diligence when considering to include
insulation back into the VEET scheme, which they shouldn't they will be no better than
Standards Australia.
The case for a compulsory inspections by a qualified electrician for all insulations materials
should be enforced. WHY NOT? This is why if insulation is to be included in the VEET Scheme
compulsory electrical inspections must be mandated

AGAIN, if not, deaths will occur, as they did during the failed Home Insulation
Program, and Standards Australia will demonstrate wilful negligence. Haven't
industry and Government advisors learnt from the three deaths during the failed
Home Insulation Program? OBVIOUSLY NOT, it's more important to sell more bulk
insulation, people are just casualties for the cause, more profit in the so called quest
for building energy efficiency.

If you walk on the polyester batts shown below, or any other thick bulk insulation
which obliterates the ceiling joists, it is impossible to identify the ceiling joists before
walking on these OR accidentally standing on the ceiling lining and fall through the
ceiling OR there is a chance that the ceiling plaster will be fractured, and eventually
the ceiling will collapse into the room below, as has been reported in "A Current
Affair," and other similar TV shows.
THE CASE FOR COMPULSORY PRE ELECTRICAL INSPECTIONS
Cables/wiring must be positioned to avoid mechanical damage, as per Clause
3.9.1 of the Wiring Rules below, to prevent being walked on, and damaged.
Standards Australia will make every assurance "under the sun" that the critical
Standards AS 3999 Installation of Bulk Insulation and AS/NZS 3000 Wiring Rules
have been correctly revised in accordance with the Royal Commission
directive. THIS A LIE. PROOF see above DRAFT Standards AS3999 page 45.
ALSO confirming this is insulation installed as demonstrated in picture above,
potentially covering unprotected cabling over ceiling joists, older wiring or non
conforming wiring from overseas suppliers, as evidenced in the media recently,
will occur AGAIN.
Insulation installers will do the same again, having no regard for electrical
issues in a roof space, once Government money, IN ONE FORM OR ANOTHER,
"flows" again via VEET, just as happened during the Home Insulation Program.
FURTHER EVIDENCE
See Greg Hunt picture below as further evidence of covering wiring and
plumbing in a roof space during the failed Home Insulation Program.
NOTICE BELOW:
Two layers of insulation pink and covering yellow completely covering the ceiling joists,
just as the new AS 3999 Standard above ALLOWS!
Greg Hunts right elbow is directly over an unprotected cable/wire in defiance of the Wiring
Rules AS/NZS 3000. and would not be seen by a person entering the roof space keeping in
mind Greg Hunt is pictured standing on a ladder looking through the manhole.
Its more than likely that Greg Hunt could not reasonably have known that the cables/wiring
below his right arm were in complete violation of the Wiring Rules. Four Corners should
have been advised also by the electrical union. WHY?
The electrical union should have known and advised Greg Hunt regarding the unprotected
wiring/cabling, they were quick to say that the downlight transformer could over heat and
cause a fire. WHY not the cabling/wiring issues
Anyone entering this roof space would have to remove the yellow layer of insulation to
navigate the roof space. WOULD they replace this as they found it on the way out. NO
Upon entering the roof space the chances of stepping on these cables with a solid work boot
could damage the wiring, creating a life threatening electrical hazard.
NOTE: The wire /cable directly under the yellow insulation of Greg Hunts left hand, this is an
example of a protected cable/wire over the ceiling joist, because it is secured to a protecting
timber as per the Wiring Rules.
GREG HUNT PICTURE
ABC Four Corners Program Apr 26, 2010
A Lethal
Miscalculation
http://www.abc.net.au/4corners/special_eds/20100426/insulation/
Below is a picture taken fully illuminated I provided the Royal Commission that was
presented to a witness from the electrical industry to comment on. Imagine what a person
would be confronted to in almost pitch black, with just a light on their head?
This is what I am endeavouring to stop.
For the reasons I have demonstrated above, until worker safety via Standards "meshing"
and intertwining with OH &S guidelines, VEET must NOT ALLOW insulation to be included.
In conclusion
If the Victorian Government allows insulation to be included in the VEET scheme this will
amount to wilful negligence, just as Standards Australia are party to not fulfilling their
directive to thoroughly revise Standard AS 3999 and AS/NZS 3000, and there will be serious
ramifications.
That's why 27 million dollars of tax payers money was spent for the Royal Commission
Home Insulation Program to ensure workers aren't killed on the job.
Finally, how can Standards Australia allow DRAFT AS 3999 to be approved as is happening
right now, and how can the State Government allow including insulation in VEET, until the
Federal Government releases its reply to the Royal Commission report.
If the Federal Government don't address these issues in their reply, preferably direct
Standards Australia to re - draft AS 3999, AND clarify issues in AS/NZS 3000, they to will join
Standards Australia as wilfully negligent.
I await an urgent reply to my correspondence.
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