§ 10.11 p.m.
§ Mr. Arthur Palmer (Cleveland)
I beg to move.That an humble Address be presented to Her Majesty, praying that the Thermal Insulation (Industrial Buildings) Regulations, 1958 (S.I., 1958, No. 1220), dated 25th July, 1958, a copy of which was laid before this House on 31st July, in the last Session of Parliament, be annulled.This Motion is a Prayer to annul the first Regulations which, I think, have been made so far under the Thermal Insulation (Industrial Buildings) Act, 1957. In the first place, I want to make it clear that I am not, in praying that these Regulations be annulled, in any sense criticising or opposing the principle of the Act itself. Indeed, I was, as the hon. Gentleman the Member for Kidderminster (Mr. Nabarro) knows, one of the sponsors of the Act, of which in many senses he was the prime mover.
The object of the Prayer is not against the principle of the Act, but rather to suggest that the Minister has been much too timid and cautious in the first Regulations which have been made under the Act. I suggest to the House that these Regulations have given a good deal of disappointment to many technical people outside the House who are very objective in their approach to this matter.
The House may or may not recall that the National Industrial Fuel Efficiency Service estimated that if we properly insulated new industrial and factory buildings the total amount of fuel that might possibly be saved in one year would be 968 no fewer than 6 million tons of coal or coal equivalent. I want to emphasise to the Parliamentary Secretary that I am using the words "coal equivalent".
It would be out of order for me to pursue it now, but on Wednesday we shall no doubt be discussing certain aspects of the fuel and power situation of the country. It may be said that at a time when there is a surplus of small coal perhaps the need to insulate factory buildings thermally is not quite as urgent as it was previously, but I think that the answer is that, whatever the source of the energy used, whether it comes from coal or from oil or from nuclear fission, it is in the interests of industrial efficiency and in the general national interest to use that energy as effectively as possible. From where we are to derive the energy is a different question.
It would be a great pity if these Regulations were drawn in such a fashion that the good intention of the Act was largely lost, because this is a rather technical Act which depends greatly for its effectiveness upon the Regulations. If the Regulations are weakly drawn, the good effect of the Act will go altogether. The Regulations are not as good as they might be and it may be that the Minister feels that caution is advisable. We are here in a somewhat difficult field. There may be some resentment on the part of industrialists and factory owners at the compulsion to insulate factories against loss of heat. There may be a certain hostility to the purpose of the Act. In those circumstances, the Minister may well feel that he should go slowly and try to lessen that hostility and avoid possible evasion of the Act.
This may be an unjust and unworthy suspicion on my part. If so, I should like to have an assurance from the Parliamentary Secretary to the Ministry of Power. But if it is not true that, as a matter of policy, the Minister is deliberately going slow, I suggest that the House deserves a full explanation of the practical basis of the Regulations as drawn. Does the hon. Gentleman really feel, speaking on behalf of his noble Friend, that the Regulations will carry this part of the Act into effect?
I submit that there are three failings in the Regulations. Unfortunately, in some senses this Act is a very technical business. Although I am an engineer by 969 profession, I dislike technical jargon, particularly if it is used in the House, but the Act, the Regulations and the Explanatory Memorandum are riddled with technical expressions.
There is one particularly formidable example. The Regulations refer on several occasions to a mysterious thing known as U-value. This has nothing to do with the sort of coefficient of gentility which would appeal to Miss Mitford. It is actually defined in the Explanatory Memorandum as being a measure of the quantity of heat in British Thermal Units which will pass in one hour from an area of one square foot of a structure when there is a difference in temperature of one degree Fahrenheit between the air on two sides of the structure. The House is now fully advised of what is meant by U-value.
I want to put my criticisms in as simple language as I can command, not only so that other hon. Members may understand what I am saying but so that I may understand it myself. My first criticism is that the insulation standard laid down is much too low. The best U-value is given as 0.3, which means that in certain conditions that is the amount of insulation which must be applied to contain within the factory the heat that might otherwise escape.
As I said, the best standard that is laid down is 0.3, as I understand the Regulations and the Memorandum which goes with them. That would be all right if it were a fairly universal standard. My criticism is that this good standard need be applied only against heat loss when the design temperature of the building concerned is 70 degrees. That is how it is, as I understand it, and if I am wrong no doubt the hon. Gentleman will put me right. If, however, the factory owner or the occupier cares to select a lower design temperature, he can escape with a much inferior insulation, whatever the actual working temperature.
§ Mr. Gerald Nabarro (Kidderminster)
But if he selected a lower design temperature he would then contravene the appropriate Sections of the Factories Act, which require a minimum temperature and a minimum standard of comfort for all workpeople engaged in those shops.
§ Mr. Palmer
I am sure the hon. Gentleman is an expert and if later on when he speaks he can amplify what I have to say, and can improve on my argument, I shall be grateful for his support.
I am wondering whether or not this is a loophole. I know there is a standard of heat loss laid down; it is 12 B.T.Us. per square foot of room space, but I am in some doubt about how that standard is to be enforced once the building is designed. It seems to me that in general it would be much wiser if the Minister had started with a higher standard of insulation, irrespective of the assumed temperature.
My second point of criticism is that only the roofs are included, as I understand the drafting of the Regulations. There is no provision for floors or windows. I must assume that the Minister has taken adequate advice on the drafting of the Regulations and that they are supposed at least to carry out the letter of the Act. However, if we are allowing only for the roofs and not bringing in the rest of the factory building, it is doubtful if the Regulations are carrying out the plain intention of the Act, which speaks about the heat installation of buildings as such, and the building is obviously much more than just the roof.
It would, therefore, be unfortunate if the degree of effective insulation depended on the nature of the design. It would mean, for instance, that a factory, on a number of storeys would hardly be affected. That is the second point of criticism—that only the roofs seem to be covered by the Regulations on heat insulation, whereas it seems to me to be the intention of the Act that the factory as a whole should be looked after.
There is a further point. On this I have taken the advice of acknowledged experts in the matter. The technical memorandum tells those who desire information on standards of insulation the way in which certain materials can be used properly to carry out the intention of the Act. It takes such inquirers to two sources of outside authority, namely, to the Institution of Heating and Ventilating Engineers, a very eminent and respectable body of technical people, and also to a Stationery Office publication, where it is 971 stated that technical information may be obtained on the relative values of insulating materials. I am advised that these publications give differing and perhaps contradictory statements, and this does not help the factory owner and factory designer anxious to fulfil the legal obligations.
I suggest to the hon. Gentleman that it would be of great assistance if some agreed standard could be laid down by the Ministry after suitable technical discussions. This is in no way to cast any reflection on the work already done by the Institution which I have mentioned or to say that the Stationery Office publication is necessarily wrong. It is to argue that for the poor laymen who is trying to do his best there should be one agreed impartial standard. I should be very glad if the hon. Gentleman would look at the point.
I do not want to press my case too much—it is useful to have a discussion—but I wish to appeal to the hon. Gentleman to tell us that these Regulations are, for the moment, of an experimental nature—admittedly, this is a new field—and that they are not necessarily the final word and that, in that case, if later on it is found that the Regulations are too mild and are not carrying out, as I suspect they will not, the intentions of the Act it will be possible to have them looked at again.
There is the danger that factory owners who are anxious to comply with the intentions of the Measure may be misled, that because the standards are too low they may embark on, in the circumstances, wasteful capital expenditure on heat-providing machinery and plant when they could have improved on the standards when they were putting in the insulating materials so that, although it would cost them a little more initially, they would more than recover the money in future savings.
No doubt other hon. Members, including perhaps the hon. Member for Kidderminster, will have something to say on this matter, but I shall be grateful if the Parliamentary Secretary will take into account the points which I have made when he replies.
§ 10.28 p.m.
§ Mr. M. Philips Price (Gloucestershire, West)
I beg to second the Motion.
972 The Motion has been ably moved by my hon. Friend the Member for Cleveland (Mr. Palmer). This is a very technical question and I do not claim to have the technical knowledge which appears in published documents dealing with the matter. I am not an engineer, but I think I can apply a little common sense to this subject, and it seems to me that there is a case for asking the Ministry to look again at these Regulations, because economy of fuel is a matter of very great importance to the industrial efficiency of the country.
I have in my constituency a number of miners who may be threatened with unemployment and the closing of pits in the next twelve months. We do not know whether that will be so, but it certainly is so in other parts of the country. In spite of the fact that there is a depression and threatened unemployment in the coal trade. I still say that it is absolutely vital to ensure that the fuel consumed by our industries is used economically.
We have to consider the industrial efficiency of our industries and their capacity for competing in the markets of the world. Therefore, the Thermal Insulation (Industrial Buildings) Act, 1957, which I and other hon. Members, on both sides of the House, took some part in getting on to the Statute Book, is a Measure of no small importance. It empowers the Ministry of Power to lay down Regulations governing the insulation of industrial buildings and thereby secure the conservation of heat.
The Regulations which have just been issued by the Ministry seem to us to be insufficient and unnecessarily timid. As far as I can see, having read through the papers, there are two main points which seem to be the reason for asking to have the matter looked at again. First, the Regulations do not cover more than just the roof of an industrial building, whereas, so it seems, the heat can escape through the walls, the floors and the windows. There is nothing in the Regulations to cover that, it seems. If there is, I hope that the Parliamentary Secretary will explain it to us.
Secondly, there is the so-called U-value, which my hon. Friend has referred to and defined and which, I confess, is difficult to understand. But it is quite clearly a measure of the power to conserve heat within a building and it can be governed 973 by the type of insulation used upon the roof and walls.
The U-value laid down in these Regulations is fixed at the figure of 0.3. That, I understand, involves an internal temperature in the factory of 70° Fahrenheit. We art submitting that if, through better insulation, it is possible to keep the internal temperature down to, say, 60° Fahrenheit instead, then, obviously, heat would be conserved and fuel saved. I understand that it is quite possible to do that and that the U-value would be about 0.4. That figure could be obtained, and there is no reason why it should not be inserted in the Regulations instead of the figure 0.3.
I should like to refer to an article which appeared in the Financial Times of December last year by the Secretary of the Institution of Heating and Ventilating Engineers, Mr. Hodges, who said: 974A 38 per cent. saving in heat can be attained by insisting upon a half-inch thick insulation board in the factory roof.I do not think that that is what is laid down in the Regulations. I understand that if effective regulations governing insulation in factories were put into effect we could save about 6 million tons of coal a year, which would mean a reduction in overhead costs and thus greatly help towards lowering our costs and increasing our industrial efficiency compared with our competitors in the export markets.
We cannot expect all this to be done at once, and the Parliamentary Secretary may give us reasons why he intends to do what we suggest but is unable to do so at present. If that is so, I hope that he will explain why it is so, because we cannot see why Regulations of the kind that we have in mind could not be introduced now.
§ 10.36 p.m.
§ Mr. Gerald Nabarro (Kidderminster)
The House is indebted to the hon. Member for Cleveland (Mr. Palmer) and the hon. Member for Gloucestershire, West (Mr. Philips Price) for initiating this important debate. I do not rise in any spirit of criticism of the Regulations, but rather to welcome the opportunity to discuss them, for the principal Act under which these Regulations have been made, the Thermal Insulation (Industrial Buildings) Act, 1957, was the result of a party-political co-operative of six hon. Members opposite and five of my hon. Friends and myself seeking to do three things.
They were, first, to prescribe minimum standards of thermal insulation to conserve fuel and prevent heat loss in all new factories put into use after 1st January, 1959; secondly, to prescribe certain standards in the use of materials employed in the insulation of factories which would prevent the spread of flame and thus diminish the risk of fire; and, thirdly, to exclude certain industrial buildings of a particular character, such as foundries, where little useful purpose would be served by attempting to conserve heat.
The Regulations broadly implement those objectives in the main Statute, and I should like to thank my noble Friend the Minister of Power for acting expeditiously in what is undoubtedly a highly complex and technical subject. The hon. Member for Cleveland is one of the few qualified engineers in the House and probably understands much more of the Explanatory Note than I do as a non-qualified engineer.
However, to lay Members, this is an extremely complex and difficult matter and, therefore, we should be a little careful before we unduly criticise the Regulations, which are undoubtedly the outcome of many months of very hard work and consultation between experts in the Ministry of Power and all the interested bodies who, in this context, comprise not only fuel technologists, but architects, chartered surveyors, quantity surveyors in the building industry and many other professional people who are concerned with the technicalities of factory building.
The Act and the Regulations made under it are unique in two material respects. First, we are the only legislature in the world which has sought to lay 976 down by Statute minimum standards for the thermal insulation of industrial Wildings, first, in the interests of fuel conservation and, secondly, in the interests of the factory employees working within those buildings. Secondly, it is unique within our own statutory arrangements in that this is the first time that the United Kingdom legislature had ever sought by Statute to impose minimum building requirements of any kind upon industrial and factory construction generally.
The first question I want to ask my hon. Friend is this: is he satisfied that there will be a proper liaison and cooperation in the matter of implementing Section 3 of the Thermal Insulation (Industrial Buildings) Act and Clause 7 of the Factories Bill which is at present before this House? This is an important matter. Paragraphs 4 and 5 of the Regulations require that certain materials shall be excluded for thermal insulation purposes because of their dangers of spreading flame in the event of fire taking place.
Had I known that the Factories Bill was on the stocks I might have sought to have added all the provisions of the Thermal Insulation (Industrial Buildings) Act to it, although it would have meant waiting for another year. But it is curious that the general requirements of the Regulations under paragraphs 4 and 5 will now be subject to what the Minister of Labour is proposing to this House under the Factories Bill, which has received its Second Reading and has been committed to a Standing Committee. I should like the Parliamentary Secretary to comment on that state of affairs and give us an assurance in that matter.
My second question rests upon the principal objective of the Thermal Insulation (Industrial Buildings) Act. When it passed through this House a year ago the objective was the conservation of fuel. Both hon. Members opposite have mentioned a possible economy of 6 million tons of coal a year from thermal insulation. With the greatest kindness I should like to state that that is a great exaggeration. The Thermal Insulation (Industrial Buildings) Act and the Regulations we are discussing this evening apply only to factory buildings brought into use after 1st January, 1959. 977 What the Industrial Fuel Efficiency Service said was that if all the factory buildings now in use in Britain could simultaneously be insulated to high standards then possibly the aggregation of coal savings might be the equivalent of 6 million tons per annum. They are two entirely different things. These Regulations might save 200,000 tons of coal a year.
Having made that slight correction to what has been said by hon. Members opposite, I ought to say that I felt a certain amount of disappointment at the standards which have been built into these Regulations for minimum requirements in the insulation of these new buildings brought into use after 1st January next. I wonder whether the climate against which these Regulations have to be set has become a little more inclement in the last twelve months because of the mounting stocks of coal. This is primarily a fuel efficiency Measure, and when it was carried through this House we were all imbued with an urgent and almost unanimous sense of wishing to conserve fuel and make the best use of the nation's coal.
Since then coal stocks have mounted and, today, they stand at 37 million tons. On Wednesday, we shall all be faced with the dilemma of dealing with the borrowing powers of the National Coal Board, and I ask my hon. Friend to assure the House that in the drafting of these Regulations the intentions and policy of his right hon. Friend and himself in regard to fuel efficiency and conservation have not been vitiated by these mounting stocks of coal. In other words, will my hon. Friend assure me that he proposes to pursue with vigour undiminished the need, that all of us have recognised for many years, to make the best use of the nation's coal?
§ Mr. Palmer
I accept the correction about the figure of 6 million tons, but I think the hon. Member would agree that if we take all the coal, or coal equivalent, it is a matter of saving energy from whatever source.
§ Mr. Nabarro
I agree. It is a matter of saving fuel in whatever form. It may be coal, coke, oil or the saving of electricity and gas, which, as refined fuels, contribute to the total of the nation's fuel bill, and using them as efficiently as 978 possible. That should be our general objective.
The third question I wish to ask my hon. Friend is this. Having regard to the fact that the minimum standards for thermal insulation provided in this Statutory Instrument and the accompanying Explanatory Note apply only to the roofs of factory buildings brought into use after 1st January next, is it his intention, and that of my right hon. Friend, to proceed with a further Statutory Instrument in the future to include minimum standards for factory walls, floors and windows?
Heat in a building is not conserved by insulating only the roof. I suggest that the roof, walls, floors and windows should be insulated. Though this Statutory Instrument deals with the most important, namely, the roof insulation, I should like some advice about future intentions, which I am sure will be strictly honourable and objective, as to the other three considerations.
Finally, I wish to ask my hon. Friend whether he has fully considered the axiom of my right hon. Friend the Minister of Labour in the matter of the huge losses incurred annually through factory fires. Paragraphs 4 and 5 of this Statutory Instrument are essentially fire prevention paragraphs. During the debate on the Second Reading of the Factories Bill, two or three weeks ago, my right hon. Friend used the axiom that prevention is better than cure, and indicated that he proposed to move in the general direction of prescribing certain essential building needs and specifications to prevent fires in new factories to be erected in the future. I wish to ask my hon. Friend whether he is fully satisfied that these fire requirements built into the Regulations not only satisfy the high standards imposed by the British insurance companies, for example, and the fire associations of Great Britain, but that those organisations have been taken fully into consultation; and whether the high standards applying to thermal insulation in fire preventative matters may be carried a stage further at a later date.
My view of these Regulations is that we have made a useful beginning. I hope that the House will pass them and that there will be no great opposition to them. This is a unique Measure, though a complex and technical one, and we have made a useful beginning. But I hope that it is 979 not the last word. I shall press my hon. Friend continually to raise the standard of minimum thermal insulation requirements, and to extend to all sections of factories the intention to see that continuously, in conjunction with future factory legislation, the standards of fire prevention are also raised.
§ 10.50 p.m.
§ The Parliamentary Secretary to the Ministry of Power (Sir Ian Horobin)
I gather that it is the wish of those hon. Members who have spoken in this debate that it should be considered an opportunity for some explanation and discussion, and that, generally speaking, the objects not only of the Act, but of the Regulations, commend themselves to both sides of the House.
I begin by making quite clear to the House that this is not one of the spheres of responsibility I have in the Ministry of Power on which I feel I have any special competence. I am not a constructional engineer I have never designed a factory; I have never even had occasion to criticise the design of one. Therefore, I am, much more than usual, dependent on the very expert advice I have obtained in the Department, but I have done my best, in the course of the preparation of these Regulations and while preparing myself for this debate, to try to see whether I could satisfy the House on one or two points which were likely to be raised, and have been raised.
Dealing, first, with the speeches of two hon. Members opposite, I would begin by reiterating and taking a step further the warning given by my hon. Friend the Member for Kidderminster (Mr. Nabarro), because it is essential we should get the scale of what we are talking about right. It would be quite hopelessly confusing to any discussion of this matter if we thought we were dealing in terms of a possible saving of 6 million tons of coal equivalent a year. For reasons which I think commended themselves to both sides of the House, when the Act was going through it was accepted with regret that it was impossible to deal with all existing factories. In practice, we could deal only with new ones. That, I am advised, brings down the possible saving very much further even than the modest 980 figure mentioned by my hon. Friend the Member for Kidderminster.
It is impossible to be accurate in this matter, and I do not want to pretend to a greater accuracy than can be obtained, because when we are speaking of the saving we do not know how much saving would have been produced anyway by wise architects and their clients, quite apart from the Act. After all, fuel is now so expensive that there is a very great economic incentive when building a new factory to save on running costs of fuel and capital costs of heating installation. Therefore, to a certain extent it is a matter of opinion. However, I am advised that the probable saving would be much nearer 100.000 tons of coal equivalent than 200,000 tons, but 100,000 tons is very well worth saving, and let us save it. I make that point only because once we get to that kind of figure the cost of what would be involved in making a further saving by a higher standard becomes more relevant than if we were talking in terms of millions of tons of coal.
On this point, I would reassure the hon. Member for Cleveland (Mr. Palmer) that while, of course, there have been criticisms and differences of opinion, broadly speaking—I do not want to go further than is fair—there is no question of hostility from the great organisations concerned. There has been a desire to obtain workable and more or less agreed Regulations. In fact these Regulations are, broadly speaking, agreeable to the great local authority organisations, great organisations of industry and great professional organisations concerned.
I do not think that it would be very useful for me to go in great detail into coefficient measurements of value and U-values. They are merely ways of measuring the amount of heat which goes through a particular substance or a specially constructed roof under certain conditions. I want to get right, at the start, a point which I do not think has been quite clearly appreciated by at least two hon. Members. They have accepted, rightly or wrongly—I am coming to the point of whether it was right—a certain U-value, a certain standard of insulation for a given temperature. It is a matter of arithmetic to decide what values would give the same heat loss at a different temperature inside the factory. Therefore, it is not the degradation of the 981 standard which, in some curious way, the owner or designer of the factory can achieve by lowering the temperature. All we are doing is this. Having picked a given loss of heat at a standard temperature, we have adjusted the measurement of the U-values to provide the same loss of heat at different temperatures.
Having dealt with that, I come to the more important point of whether the standard value designed for a temperature of, say, 70° Fahrenheit is correct. Of course, one must accept from the start that if we spend enough, if we take elaborate enough precautions, we can produce complete insulation. The whole point is to try to pick a standard which will give the bulk of the saving in fuel at the least possible expense. Having consulted a wide range of bodies, the Minister came to the conclusion that we would obtain the great bulk of the possible saving by using the standard we have chosen.
I am not talking now about whether we should include the walls, but dealing simply with the roof. We should obtain the great bulk of this saving by this standard. And we came to the conclusion that by trying to put that standard higher we should get very rapidly falling additional savings for a very rapidly increasing cost. Our own view, very roughly, is that if, as we believe, these Regulations in their present form will save from 100,000 to 120,000 tons of coal equivalent a year, to save another 10 per cent. or 15 per cent. would multiply the cost out of all reason. We thought that that small addition—and doubtful addition—would probably have very little effect on the size of the heating installation put in, and, to put it crudely, the game does not seem to us to be worth the candle.
I come now to why we have chosen the roof. There are two broad reasons for this. First, I remind the House that we are dealing with new factories. I am advised—and I confess that I was surprised, but I have checked the figures and find that they are correct—that about 80 per cent. of new factories are one-storey buildings. Not only so, but modern roof construction is very frequently of a kind of saw-edge shape, so that the area in the roof through which heat escapes is out of all proportion to the amount of heat lost through floors and walls—
§ Sir I. Horobin
And windows, yes.
Therefore, we are advised, again, that by dealing with the roof we are dealing with the great bulk of the problem, though not, I agree, with all of it.
The other reason comes back to cost. I am advised—and here I can only take the views the experts have put to us—that the complications of dealing with walls—and still more with dealing with floors—are out of all proportion to the complications of dealing with roofs. For those two reasons, in general terms, we feel that we are doing the right thing in, as it were, skimming the cream of the saving by going for the roof and leaving the others.
§ Mr. Nabarro
I am grateful for that explanation, for that is exactly what I was hoping to draw from my hon. Friend—that the principal saving is to be found in the roof. But does he regard this as a permanent policy, so far as he can see, to restrict the Regulations only to heat conservation through the roof, and will there not be any attempt in future to evolve Regulations for walls, floors and windows?
§ Sir I. Horobin
I would not like to look too far into the future, or to hold out any hope that we have in the Ministry at present any intention of going further than this. We should have to see what happens. Our feeling at present is that to go any further would raise complications which would not be worth while. But nothing is eternal in this world.
I would make one reference to the third point, about the possible confusion in the two documents to which reference is made. Here I can only be guided by our specialist advice, and I am advised that the differences are more apparent than real. But there is an appeal to the Minister. The position would be that the plans would be presented; they might be turned dawn by the local authority, and the person putting them up might say, "This is due to taking a standard figure given in one and not in another." and he thought he really had a case.
There is an appeal, and we shall have to take it as a matter of fact to try to judge between them. But our advice—and that is why we put these two documents in—is that the experts, when they come to negotiating with the local 983 authority, will find that the differences between them are more marginal, if they exist at all. In any case, I understand that the B.S.I. is preparing a code of practice which may take the matter a step further.
My hon. Friend the Member for Kidderminster was good enough to refer to the great work that has been put into this in the way of consultations. I am not going to count them up, but I have here three foolscap pages of people with whom we have bean consulting: half a page of people like the Institutions of Civil Engineers, Electrical Engineers and Structural Engineers; another page and a half of people like the Association of British Chambers of Commerce, the London Chamber of Commerce and the British Employers' Confederation; and yet another page of the purely technical people like the National Federations of Master Painters and Decorators of England and Wales, and of Plumbers and Domestic Engineers (Employers). We have really tried to consult everyone and to get something which will be workable.
My hon. Friend raised the question of fire risk, and here I want to make the position quite clear. The general protection of works against fire risk is a matter for the Minister of Labour under the Factories Act. This is not what we are concerned with here. Our concern is that we did not want to encourage insulating designers and builders, in their efforts to obey the Regulations made as laid down in the Act, to produce roofs which were highly insulated, but which, in themselves, in the search for high insulation, led to possible fire risk.
I should make it quite plain, because there has been some misconception, that no material is, in fact, prohibited by these Regulations. They say, in effect, that if one uses certain kinds of materials—some materials which, for instance, have as part of their constitution straw and 984 rubber, and things of that kind—they must be so used as not to increase the risk of fire. But we are not laying down a code against fire risk. All we are doing is to put in a caveat, as it were, against seeking to obey these Regulations by using insulating material some of which might have special risks of fire unless they are used in a particular way or are treated in a particular way.
My hon. Friend referred to the question of exemptions. I do not think that I need say much about that. There are a number of exemptions. It would clearly be absurd, for instance, to include boiler houses, where the trouble, as a rule, is to make them cool, not to make them hot, and a number of other things of that kind. In fact, we have tried to make them reasonable and sensible.
I can give an absolute assurance to my hon. Friend that these standards have in no way been affected by a change of view as to the necessity for fuel economy. We have heard some weird arguments about coal, and no doubt we shall hear more, but I do not think that any hon. Member on either side of the House has suggested that we ought to waste coal in any way we can as a means of getting rid of stocks. There is nothing in that at all. What we have tried to do by these Regulations is to present a workable code in a rather complicated field which will encourage people to seek those economies which are reasonable. I think we have succeeded.
The cost, as far as I can make out, will be about £3 million or £4 million a year, which will be worth while if we save a substantial amount of coal or of any other fuel. I believe that we have made a reasonably good job of this. I am not going to say that these Regulations will last for ever, but I certainly think that they are a very good beginning and will last some time. I hope that, with that explanation, the Prayer will not be pursued.
§ Question put and negatived.