Guarantee
BRENNAN DEPOSITION
Should EIFS be used on American residential stick framed housing??? The following deposition is found on the internet and it sheds an interesting perspective on EIFS and its use on American residential buildings. This is found at: http://www.novashoc.org/brennan.htm. The entire NOVASHOC site is full of incredible information.

EDITOR’S NOTE: The Northern Virginia Association of Homeowners Coalition www.Novashoc.org website is no longer online.

NOVASHOC - Northern Virginia Stucco Home-Owner's Coalition

- The Brennan Deposition -

John J. Brennan was deposed December 7, 1998 in the Case of Eric J. and A. Therese Swensen vs. Lincoln Development Corporation, Inc. and David Neal. The deposition was filed in the Superior Court of Fulton County, State of Georgia, No. E-65553.

Following are excerpts. Please note, if you are a critic of Mr. Brennan and dispute facts as detailed in this deposition, please provide comment and relevant information that you can substantiate. Remember, a gratuitous assertion can be countered with another gratuitous assertion.

Q: Well, let me back up for a second. Who were you a consultant for?

A: Well, they're listed there [CV], but I've - virtually every manufacturer, very large distributors. I founded EIMA, so I made my living for a long time providing consultant services to the industry.

Q: And it says here on your CV, "1979 to 1982, board level management consultant to the world's largest EIFS co-inventor"

A: Uh-huh.

Q: Are you speaking of a specific manufacturer?

A: Yes

Q: And who is that?

A: It would be Sto Industries, today.

Q: And what did you consult on, specifically?

A: Technical expertise of EIFS.

Q: All right. It says here on your CV, "Founding Director of EIMA, Exterior Insulation Manufacturers Association; Chairman of Technical Standards Committee; would not allow use of EIFS on typical single-family dwellings during tenure".

A: That's correct.

Q: Could you explain that for me?

A: There was one major manufacturer in the the United States in the 70's, and that was Dryvit. Dryvit had a very limited product mix, if you compare it to the German products that had been developed in - for 40 years, that have evolved.

I brought the new German products into the United States. I was the founding director of EIMA, which originally was the Exterior Insulation Members - or Manufacturers Association. And as the founding director, I was responsible for getting the initial co-testing done in the United States. Shtutmeister Company [Shtutmeister GMBH - the original name of Sto Industries] did not allow the use of exterior insulation and finish systems on any structure that did not pass a vapor pressure analysis of the wall components.

The typical wood construction used in the United States will not pass that test, without severe - well, not severe, but without substantial modifications.

So there was a process in place to keep these materials off of wood-frame construction homes; and it was done technically, by saying, at EIMA, that you can't be an EIMA member, if you don't subscribe to these standards. If you subscribe to this standard, you agree to do a vapor pressure analysis on any contract, or any - on any project, before issuing the products, and the warranty; and it had to be also sold, or sold to a certified EIMA installer. So there was a process in place, and that process kept this product off of homes until the middle 80's.

I left EIMA. When I departed EIMA, Dryvit, who was not a member, moved in, and they excepted the board, did away with those technical specifications, and the stuff was on houses all over the country.

Q: Do you believe that the product should not have been used on residential houses?

A: The product should not be used on any structure that does not pass a vapor-pressure analysis of the wall component system.

Q: Now, you stated that before any contract would be given for use of the product, they would have to do this test. Did the Sto company go - well, who performed this test? Whose responsibility was it to do the test?

A: The EIFS technician in the field, and/or the trained distributor, and/or the architect, and/or whoever it was that was involved in it.

And typically, it would be - a manufacturer's rep, working with an engineer or an architect, would provide the factory with the finished wall components - or excuse me - would provide the technical department at the factory, the Sto factory, the components of the structure.

We would then, in-house, perform a vapor-pressure analysis, a dew-point analysis, a condensation analysis, and a temperature analysis on the wall-component system. And the purpose for that was to see if the wall component system would hold moisture, or not, or would it dissipate moisture, okay?

If it did not dissipate moisture, we would not approve the project for the use of our product, period. We would not ship the the product. And every single structure was that way. Everything.

But that was a commercial business, and the commercial business had a technician on the site, so we could do that, all right? And that's why we never could do it in the home business, because it would turn a high-technology construction product, into a commodity product, put it in the hands of people that didn't know what it was, and present us with a marketplace that has significant damage. And that's -

Q: And do you believe that's what has happened?

A: Oh, it's clearly what happened. There's no question.

Q: And is it your opinion that EIFS - we'll call it exterior installation [sic] and finish system. EIFS. E-I-F-S - that EIFS should never be used on residential homes, even today?

A: No. It should never be used in a home that doesn't pass a vapor-pressure analysis.

Q: In your experience, have you come across any homes that have passed this vapor -

A: Pressure analysis.

Q: Pressure analysis?

A: The answer to that is yes, but you have to make modification to the design, in order to get it to pass. And those modifications are not esthetically acceptable, generally, in the marketplace.

It works well in Phoenix, and other areas that have a deep-well window, but it doesn't - it esthetically does not work, to do this.

And if I may, I'll explain to you what the problem is.

Q: Please do.

A: The problem is, the transfer of moisture from the inside of the house, to the outside of the house. That's the fundamental problem.

If we have a stainless steel wall, we have no moisture transfer - we agree on that, if you have a stainless steel wall. But we don't have that - we have wood-frame construction. And we have insulation on the outside [EIFS], and then we put insulation inside the cavity.

When you do the physics of those components, you wind up with, essentially, plastic on the outside of the studs, and plastic on the inside of the studs.

Because of this, in geographic areas like the Southeast, moisture will not transfer though the system; and in some cases, it collects on the interior of the system, in terms of condensation. But if it gets wet from another way [intrusion], it won't dry, because the physics will not allow that to happen.

And to give you an idea, if we took a board and we put it on the ground, on the outside, and then we laid a piece of plastic over that board, that board would disappear [rot] very, very quickly. That's what happens, in a sense, in some of these EIFS houses, because of the use of insulation on the inside, and the use of insulation on the outside.

Q: And whose idea, if you will, is it, to have insulation on the inside and insulation on the outside?

[Attorney objects - objects to rephrased question. Directs witness to answer without speculation.]

A: The product came out of Europe, as an answer to using rubble as a building material after World War II, with a secondary requirement for saving energy inside of these restored buildings, that they used the rubble to fix the walls with, to be able to insulate the walls. Because Europe was devastated after WWII, and had no energy. So they really created the energy-conservation construction market. The products that you see today basically came out of Europe.

Europeans - in fact, no one - nowhere in the world are you going to find wood-frame construction, with the exception of North America.

This product had no history, when it came into the United States from Europe, on use on wood-frame construction homes. It had no specifications, it had no history, it had no testing. Because the Europeans make their homes, or build their structures, out of masonry. And that's fundamentally what happened.

When I brought the product to the United States for Sto, we only put it on commercial buildings that were masonry substrates. So that's why you have - 95 percent of the market commercial, and then 5 percent is residential, according to EIMA. And the problems are in the residential market.

Q: Do you know how the product came to be used on residential structures, if it was not intended for that use?

A: Absolutely. Sure. It's a high-technology construction product, as we viewed it - "we" being the people that invented it: Schtutmeister Company and Dryvit. It's come a long way in the last 15 years. And some of the other major players. It was a high-tech product.

The problem is that the materials could be accessed by untrained individuals. Once that occurred, the product began showing up in the housing market, without any specific specifications to install it on wood-frame construction.

Those specifications were developed, and they were just never - I'll just use the word "enforced". That's the only thing I can say, is they've never been enforced; so we wind up with all these houses improperly built, from a specifications point of view.

 
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