# 24 C.F.R. § 3280.208 (2026): Requirements for foam plastic thermal insulating materials

> Federal · Regulations · In force

URL: https://www.frixlaw.com/law-library/statutes/CFR_T24_P3280_S3280_208

## Section

- **Citation:** 24 C.F.R. § 3280.208 (2026)
- **Heading:** Requirements for foam plastic thermal insulating materials
- **Jurisdiction:** Federal
- **Kind:** Regulations
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** Title 24 CFR: Housing and Urban Development / Chapter XX: OFFICE OF ASSISTANT SECRETARY FOR HOUSING—FEDERAL HOUSING COMMISSIONER, DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT / Part 3280: MANUFACTURED HOME CONSTRUCTION AND SAFETY STANDARDS / Subpart C: Fire Safety / § 3280.208: § 3280.208   Requirements for foam plastic thermal insulating materials.

## Text

(a)
General.
Foam plastic thermal insulating materials shall not be used within the cavity of walls (not including doors) or ceilings or be exposed to the interior of the home unless:
(1) The foam plastic insulating material is protected by an interior finish of
5/16
-inch thick gypsum board or equivalent material for all cavities where the material is to be installed; or
(2) The foam plastic is used as a sheathing or siding backerboard, and it:
(i) Has a flame spread rating of 75 or less and a smoke-developed rating of 450 or less (not including outer covering of sheathing);
(ii) Does not exceed
3/8
-inch in thickness; and
(iii) Is separated from the interior of the manufactured home by a minimum of 2 inches of mineral fiber insulation or an equivalent thermal barrier; or
(3) The foam plastic insulating material has been previously accepted by the Department for use in wall and/or ceiling cavities of manufactured homes, and it is installed in accordance with any restrictions imposed at the time of that acceptance; or
(4) The foam plastic insulating material has been tested as required for its location in wall and/or ceiling cavities in accordance with testing procedures described in the Illinois Institute of Technology Research Institute (IIT) Report, “Development of Mobile Home Fire Test Methods to Judge the Fire-Safe Performance of Foam Plastic Sheathing and Cavity Insulation, IITRI Fire and Safety Research Project J-6461, 1979” or other full-scale fire tests accepted by HUD, and it is installed in a manner consistent with the way the material was installed in the foam plastic test module. The materials must be capable of meeting the following acceptance criteria required for their location:
udge the Fire-Safe Performance of Foam Plastic Sheathing and Cavity Insulation, IITRI Fire and Safety Research Project J-6461, 1979” or other full-scale fire tests accepted by HUD, and it is installed in a manner consistent with the way the material was installed in the foam plastic test module. The materials must be capable of meeting the following acceptance criteria required for their location:
(i)
Wall assemblies.
The foam plastic system shall demonstrate equivalent or superior performance to the control module as determined by:
(A) Time to reach flashover (600 °C in the upper part of the room);
(B) Time to reach an oxygen (O
2
) level of 14% (rate of O
2
depletion), a carbon monoxide (CO) level of 1%, a carbon dioxide (CO
2
) level of 6%, and a smoke level of 0.26 optical density/meter measured at 5 feet high in the doorway; and
(C) Rate of change concentration for O
2
, CO, CO
2
and smoke measured 3 inches below the top of the doorway.
(ii)
Ceiling assemblies.
A minimum of three valid tests of the foam plastic system and one valid test of the control module shall be evaluated to determine if the foam plastic system demonstrates equivalent or superior performance to the control module. Individual factors to be evaluated include intensity of cavity fire (temperature-time) and post-test damage.
(iii)
Post-test damage assessment for wall and ceiling assemblies.
The overall performance of each total system shall also be evaluated in determining the acceptability of a particular foam plastic insulating material.
(b) All foam plastic thermal insulating materials used in manufactured housing shall have a flame spread rating of 75 or less (not including outer covering or sheathing) and a maximum smoke-developed rating of 450.
[49 FR 32008, Aug. 9, 1984, as amended at 70 FR 72043, Nov. 30, 2005. Redesignated at 78 FR 73982, Dec. 9, 2013]

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/CFR_T24_P3280_S3280_208. Check the current official text before relying on it. Not legal advice.