Ar C.J. Walsh – Consultant Architect, Fire Engineer & Technical Controller – International Expert on : Sustainability Implementation + Accessibility (including Fire Safety) for All + Sustainable Fire Engineering
2020-09-08: Ignoring Britain’s silly sabre-rattling, toothless threats and boorish blackmail attempts reported in the Media during this past weekend, yesterday and today … the actual state of play in the tortuous Brexit Negotiations can best be judged from the following sources …
Michel Barnier’s Presentation to the Institute for International and European Affairs (IIEA), on 2 September 2020 … View it Here on YouTube
Map of Europe, in colour, showing the current extent of the European Union. Points to Note: a) Europe, as a continent, extends as far as the Ural Mountains in Russia; b) From 1 January 2021, after an implementation period of one year, Great Britain will be entirely outside the EU and the Single Market; c) The EU is not a Christian organization and as soon the political classes in certain countries (e.g. France and The Netherlands) get over their hysterical hatreds, Turkey will enter the EU as a full Member State; d) furthermore and eventually, an Independent Scotland will re-join the EU. Click map to enlarge.
This is the European Union (EU), a Single Market of approximately 450 Million consumers. The EU operates under the freedoms and protections of Codified / Written Law, i.e. EU Treaties ratified by all of the EU Member States, EU Secondary Legislation (Regulations and Directives), and EU Administrative Provisions.
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A suite of EU Regulations and Directives covers Industrial Products. While there is some flexibility with regard to how Directives are implemented at national level in the Member States, no such flexibility exists with Regulations. Construction Products can only be placed on the EU Single Market if they can be shown to comply with the requirements of the EU’s Construction Products Regulation (CPR) Framework, or in other words, be shown to be ‘fit for their intended use’ in the European Union …
EU Regulation 305/2011. Article 13(2) Before placing a Construction Product on the market, Importers shall ensure that the assessment and the verification of constancy of performance has been carried out by the Manufacturer. They shall ensure that the Manufacturer has drawn up the Technical Documentation referred to in the second sub-paragraph of Article 11(1) and the Declaration of Performance in accordance with Articles 4 and 6. They shall also ensure that the Product, where required, bears the CE Marking, that the Product is accompanied by the required documents and that the Manufacturer has complied with the requirements set out in Article 11(4) and (5).
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BREXIT ~ IMPLICATIONS FOR THE BRITISH FIRE INDUSTRY
Trade ‘No Deal’ or ‘Minimal Deal’ … from 1 January 2021, Great Britain will be completely outside the European Single Market, and the EU’s Construction Products Regulation Framework. The designation ‘Notified Body’ under that Framework will fall away from British Organizations. Construction Products/Systems manufactured in, or supplied from, Britain will then have to undergo an entirely new EU Testing and Approvals Programme in order to access the European Single Market. Fire Safety related Construction Products will have to be tested, and assessed or appraised, against all 7 Basic Requirements for Buildings together, during the same period of time (see Annex I, EU Regulation 305/2011) …
Mechanical Resistance and Stability
Safety in Case of Fire
Hygiene, Health and the Environment
Safety and Accessibility in Use
Protection against Noise
Energy Economy and Heat Retention
Sustainable Use of Natural Resources
… a process which will be very interesting to observe, since the Fire Industry (particularly England’s Fire Establishment, AHJ’s, etc) dislikes, with intensity, the whole idea of ‘environmental impact’ … the concept of ‘sustainable development’ is hardly understood … and no consideration is given to the reasonable fire safety and accessibility needs of ‘vulnerable building users’ (including people with activity limitations, refugees, migrants, etc).
The tragic 2017 Grenfell Tower Fire, and its sad aftermath, have demonstrated how dysfunctional, and rotten to the core, is the whole national system of Building Fire Safety in England. More than 3 years later … on the evidence to date of an ongoing, incompetent Inquiry and a series of shoddy responses from Government … will survivors and the victims’ families ever receive Justice, and find Peace ? cf. The 1981 Stardust Discotheque Fire in Dublin. Survivors and victims’ families are still waiting for the truth to be revealed.
In parallel, mutual recognition of British Professional Building Designers, e.g. Architects, Structural Engineers, Fire Engineers, etc., within the European Union will cease.
In parallel, British Fire Research involvement in EU Research Networks will also cease … unless a heavy price is paid to be involved as a 3rd Country. British Institutions should forget any notions they might have about Network Leadership.
In parallel, Information and Data Flows between Britain and the EU will be disrupted or cease altogether … unless Britain complies fully with the requirements of EU General Data Protection Regulation (GDPR) 2016/679. As a vassal state of the USA, this compliance may prove difficult for Britain !
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EU Fire Safety Related Product/System Manufacturers ~ A Word of Caution !
Many EU Construction Product/System Manufacturers continue to use the services provided by British Fire Test Laboratories and/or Fire Consultancy Organizations located in Great Britain … some of which have already established EU-based dummy companies and letterheads. These British organizations must be avoided altogether. For example, the practice of fire testing in England and later adding a title page of a Full Test Report with an EU location address is entirely unacceptable !
2019-11-11:Kensington and Chelsea’s wilful disdain for the Health, Safety and Welfare of ALL the residents within its functional area … and knowing neglect of its legal and ethical Duty of Care towards ALL … resulted in a significant number of people with activity limitations living high up in Grenfell Tower prior to June 2017 … in spite of the now incontrovertible fact that, in the event of a fire emergency, many would be left behind … to die.
‘All human beings are born free and equal in dignity and rights.’
Article 1, 1948 Universal Declaration of Human Rights
Colour photograph showing a Firefighter watching the horrific fatal fire scene at Grenfell Tower in London, on 14 June 2017, from a nearby balcony. Click to enlarge.
London Fire Brigade was an easy target for the Grenfell Fire Inquiry’s Phase 1 Report, made all the more so following some careless, insensitive and ignorant public comments by its Commissioner, Dany Cotton. However, we must clearly distinguish between the behaviour of LFB’s Frontline Firefighters, who were brave and dedicated despite inadequate training, and lack of proper equipment, back-up resources and personnel strength … and LFB’s Senior Commanders … which is another matter.
Colour photograph showing the London Fire Brigade (LFB) Commissioner, Dany Cotton. In order to ensure that transformation of the LFB actually takes place in the short term, and is fully effective, Dany Cotton and all of her Senior Commanders must resign now, or be fired ! Click to enlarge.
In England … there is widespread indifference, and some rabid resistance, to answering the desperate needs, and mitigating the agonizing plight, of Vulnerable Building Users during fire emergencies … which includes people with activity limitations, children under 5 years of age, frail older people (not All older people !), women in late stage pregnancy, people with disabilities, refugees, migrants, the poor, and people who do not understand the local culture or cannot speak the local language. British National Standard B.S.9999 (not solely those sections previously contained in B.S.5588:Part 8) and England’s National Building Regulations – Approved Document B: ‘Fire Safety’ – offer only token, i.e. inadequate, protection for vulnerable people in fire emergencies. When a senior representative of BSI, the British Standards Institution, was directly approached by me, and requested to open up B.S.9999 for meaningful updating … the answer was a firm “NO” ! The same attitude is deep-seated among fire research organizations in the country, and among people who develop computer fire evacuation models.
Presentation Overhead, in colour, showing the ‘Fire Safety for All’ Matrix, which outlines the scope of its application in the Human Environment and the different social groups to be targeted. Balanced consideration must be given to people who use wheelchairs (physical function impairment) … and to people with visual, hearing, psychological, and mental/cognitive impairments … and to other vulnerable building users, e.g. people with health conditions. Click to enlarge. Matrix developed by CJ Walsh.Presentation Overhead showing the definition of ‘people with activity limitations’, with its equivalent French translation … also showing from where this term is derived … and who this term includes. During a fire emergency, confused and/or confusing disability-related language costs lives ! Click to enlarge.
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Grenfell Fire Inquiry’s Phase 1 Recommendations – Chapter #33
After hearing the first media reports about the tough Recommendations aimed at London Fire Brigade, I had naturally expected that the other Phase 1 Recommendations would be equally as tough. But NO … they are far from comprehensive … they are fragmentary, lack depth and any sort of coherence. Specifically with regard to Vulnerable Building Users, the Recommendations are pathetically and disgracefully inadequate !
And in case there is any doubt, the status quo in England – and to be fair, in many other countries as well – is entirely unacceptable !!
Few people realize that the fire safety objectives in current fire regulations/codes are limited and constrained. To implement changes to the flawed regulations in England, it will take many years … and, based on recent past history, implementation will be incomplete and unsatisfactory. Residents in high-rise buildings, whether public or private, must no longer wait in vain for this to happen. Instead, the time has arrived to become proactive, and to immediately initiate their own comprehensive programmes of Self-Protection In Case Of Fire … which go far and beyond the pathetic Recommendations in Moore-Bick’s Phase 1 Report.
Fires Similar To Grenfell Tower Are Frequent
[ Paragraph #33.5 ] … although not unprecedented, fires of the kind that occurred at Grenfell Tower are rare.
[ Response ] Not true … misleading, and a complete fallacy !
Just since 2010, fires similar to Grenfell Tower have occurred in South Korea, many in the United Arab Emirates, France, Chechnya, Australia, Azerbaijan, Russia, and most recently in Turkey. Each one of these fires has been recorded and illustrated on our Twitter Account: @sfe2016dublin. Seeing, and understanding, this striking pattern of unusual fire behaviour … a competent person would react and plan accordingly.
Effective Fire Compartmentation Is A Delusion … A Fantasy !
[ Paragraph #33.5 ] Effective compartmentation is likely to remain at the heart of fire safety strategy and will probably continue to provide a safe basis for responding to the vast majority of fires in high-rise buildings.
[ Response ] Not true … demonstrates a fundamental flaw in European fire safety strategizing !
In an environment of lax or non-existent compliance monitoring … the quality of architectural/fire engineering design and the reliability of related-construction will both, inevitably, be poor and unacceptable. Fire loads in today’s residential buildings are also far higher than a generation ago, for example, because of more electrical/electronic equipment and synthetic furnishings. And whatever about first-built, i.e. whether it’s good, bad or ugly, later alterations and other construction work will typically compromise the original performance of fire resisting doorsets and service penetration fire sealing. Modern ‘green’ building materials and construction methods are further aggravating these problems. A competent person would be aware of fire research at the UL Laboratories, in the U.S.A., which confirmed the above developments.
‘ Rigorous enforcement of building codes and standards by state and local agencies, well trained and managed, is critical in order for standards and codes to ensure the expected level of safety. Unless they are complied with, the best codes and standards cannot protect occupants, emergency responders, or buildings.’
U.S. National Institute of Standards and Technology. Final Report on the Collapse of the World Trade Center Towers. NIST NCSTAR 1. 2005.
‘Stay Put’ Policies Are Criminal
[ Paragraph #33.5 ] However, in the case of some high-rise buildings it will be necessary for building owners and fire and rescue services to provide a greater range of responses, including full or partial evacuation. Appropriate steps must therefore be taken to enable alternative evacuation strategies to be implemented effectively.
[ Paragraph #33.15 ]e. that policies be developed for managing a transition from ‘stay put’ to ‘get out’ ;
[ Response ] Too little … and far too late !
[ Solution ] Two fatal fires separated in time and space … the 2009 Lakanal House Fire, in London, and the 2017 Marco Polo High-Rise Apartment Building Fire, in Honolulu, continue to clearly demonstrate that effective fire compartmentation is a delusion. Even if carried out by a competent person … it is not possible to establish with reasonable certainty, by means of a visual/surface building inspection alone, whether or not fire compartmentation is effective in an existing building. The London and Honolulu buildings were not fitted with any active fire suppression system, e.g. fire sprinklers or a water mist system.
Buildings must remain structurally ‘serviceable’, not merely structurally ‘stable’, for a Required Period of Time. See the Presentation Overhead below.
Presentation Overhead, in colour, explaining the concept of ‘Structural Reliability’ in fire conditions … and defining ‘Required Period of Time’, during which a building must remain serviceable. Click to enlarge.
Authorities Having Jurisdiction (AHJ’s), firefighters, client organizations, design teams, and building owners/managers must not, therefore, direct, or even suggest, that any of its building users wait (‘stay put’) in that building during a fire emergency. A competent person always connects building fire performance with its structural performance, and vice versa … and always learns from the evidence of ‘real’ fatal fires.
All Lifts/Elevators Must Be Used For Fire Evacuation
[ Paragraph #33.13 ] When the firefighters attended the fire at Grenfell Tower they were unable to operate the mechanism that should have allowed them to take control of the lifts. Why that was so is not yet known, but it meant that they were unable to make use of the lifts in carrying out firefighting and search and rescue operations. It also meant that the occupants of the tower were able to make use of the lifts in trying to escape, in some cases with fatal consequences.
[ Response ] There is a ridiculous assumption in Moore-Bick’s Phase 1 Report that it is only firefighters who use lifts/elevators during a fire emergency, and that it is dangerous for anybody else to use them.
[ Solution ] In order to adequately protect Vulnerable Building Users … ALL lifts/elevators in a building must be capable of being used for fire evacuation during a fire emergency.
Until such time as firefighters arrive at a building fire scene in sufficient strength and are properly prepared to carry out effective firefighting and rescue operations … Firefighter Lifts/Elevators must be used for the fire evacuation of building occupants/users. Prior liaison and pre-planning with local fire services is always necessary with regard to the use of firefighting lifts/elevators for the evacuation of occupants/users.
Colour photograph showing a typical sign outside most lifts/elevators around the world … ‘In The Event of Fire, Do Not Use Lift’. This is a pre-historic dinosaur of a policy which places Vulnerable Buildings Users in immediate and very serious danger during a fire emergency. Click to enlarge.
A fundamental principle of fire safety design is that there must be alternative, safe and accessible evacuation routes away from the scene of a fire, which can occur in any part of a building during its life cycle ; these evacuation routes must be capable of being used by all building users, including people with activity limitations.
This is why there must always be at least 2 Fire Evacuation Staircases in High-Rise Residential Buildings !
The location of lifts/elevators and lobbies, within peripheral building cores, must always be considered in relation to the position of adjacent fire protected evacuation staircases, which must be easily found by building occupants/users, and the areas of rescue assistance adjoining those staircases.
To be used for fire evacuation, a lift/elevator must be ‘fit for its intended use’, must operate reliably during a fire emergency, and must comprise a complete building assembly which meets specific performance criteria.
A Lift/Elevator Fire Evacuation Assembly is an essential aggregation of building components arranged together – comprising a lift/elevator, its operating machinery, a hard-construction vertical shaft enclosure, and on every floor served by the lift/elevator a sufficiently large, constantly monitored lobby for people to wait in safety and with confidence, all robustly and reliably protected from heat, smoke, flame and structural collapse during and after a fire – for the purpose of facilitating the safe evacuation of building occupants/users throughout the duration of a fire emergency.
If a building is located in a Seismic Zone, Lift/Elevator Fire Evacuation Assemblies which can safely operate during an earthquake must always be specified and installed.
Gravity Evacuation Chair Devices, which are not electrically-powered and operate by gravity, facilitate downward movement, only, on straight flights of stairs. Having descended a staircase, with the user having left his/her wheelchair behind, these devices are not fully stable when travelling the long horizontal distances necessary to reach an external ‘place of safety’ remote from a building, perhaps over rough terrain.
Colour photograph showing a Gravity Evacuation Chair and how it is used during a fire emergency. Click to enlarge.
If lifts/elevators in existing buildings undergo a major overhaul, or if they are replaced, they should then be made capable of use for fire evacuation.
Lifts/elevators used for fire evacuation must always have a fire protected electrical supply which is separate from the main building electrical supply, in order to ensure that they can continue to operate without interruption during a fire emergency.
In addition to conventional passive fire protection measures, Lift/Elevator Lobbies must also be protected by an active fire suppression system. Water mist is the preferred fire suppression medium, because it is user-friendly, will not greatly interfere with user visibility, uses far less water compared to water sprinklers, and is also climate-friendly. Furthermore, because people with activity limitations will be waiting for evacuation in lift/elevator lobbies, building designers and managers must ensure that these lobbies are properly fitted out with appropriate fire safety equipment, facilitation aids, smoke hoods, signage and communications, etc., etc.
Proper Use of Personal Emergency Evacuation Plans (PEEP’s)
[ Paragraph #33.22 ]f. that the owner and manager of every high-rise residential building be required by law to include up-to-date information about persons with reduced mobility and their associated PEEP’s in the premises information box ;
[ Response ] There is No Recommendation or explanation in Moore-Bick’s Inquiry Phase 1 Report concerning the ‘what’, ‘why’ or ‘how’ of PEEP’s.
[ Solution ] A Personal Emergency Evacuation Plan is a person-specific and location-specific document, and is an integral part of the overall Fire Emergency Management Plan for a building. It is intended for regular occupants/users who may be vulnerable in an emergency situation, i.e. those with limited abilities in relation to self-protection, independent evacuation to an external place of safety remote from the building, and active participation in the building’s fire emergency procedures.
In new buildings, which are effectively accessible (including fire safe) for all, Personal Emergency Evacuation Plans are not necessary.
In existing buildings, Personal Emergency Evacuation Plans must not be used to limit or restrict access by an individual to any part of a building and its facilities. To ensure this, sufficient accessibility works must be carried out and appropriate management procedures put in place.
In buildings of historical, architectural and cultural importance, where the historical, architectural or cultural integrity of the building must be protected, Personal Emergency Evacuation Plans may limit or restrict access to parts of a building and some of its facilities. Refer to the ICOMOS 1964 International Charter for the Conservation and Restoration of Monuments and Sites.
There are No Recommendations in Moore-Bick’s Inquiry Phase 1 Report concerning these critical issues.
[ Solution ] There are many fire safety problems associated with high-rise and tall buildings. Evacuation by staircases alone can take many hours ; the physical exertion involved in descending even 10 floors/storeys by staircase is too much for many able-bodied people and is impossible for most vulnerable building occupants/users, particularly people with activity limitations. Passive fire protection of staircases, alone and/or supplemented by pressurization to prevent smoke ingress, is far too unreliable. And heavily equipped firefighters cannot be expected to ascend more than 10 floors/storeys by staircase before carrying out arduous firefighting and search/rescue operations. Furthermore, uninterrupted lift/elevator shafts, extending throughout the full height of a tall building, pose a significant risk of uncontrolled fire spread.
Colour photograph showing the very narrow, single staircase in the Grenfell Tower, London. How anybody – ANYBODY – could ever imagine that this staircase would be adequate to serve the fire evacuation needs of a diverse occupant population in a high-rise residential building is beyond belief ! A Syndrome is a cluster of symptoms which occur together and can be taken as indicative of a particular design abnormality. Click to enlarge.Presentation Overhead, in colour, illustrating a sufficiently wide fire evacuation staircase … minimum width 1.5m between handrails … which will accommodate Contraflow and the Assisted Evacuation of people in wheelchairs … with a sufficiently large, directly adjoining Area of Rescue Assistance … which will accommodate people unable to independently evacuate during a fire emergency. The space provided in an Area of Rescue Assistance, on each floor/storey, is calculated in relation to the design occupant/user population of a building. Even if a building is fully sprinklered, an Area of Rescue Assistance must adjoin every fire evacuation staircase. Click to enlarge. Staircase design by CJ Walsh.
A Floor of Temporary Refuge is an open, structurally robust floor/storey in a tall building – having an exceptionally low level of fire hazard and risk, ‘intelligently’ fitted with a suitable user-friendly and climate-friendly fire suppression system, e.g. water mist, and serviced by sufficient accessible, fire protected lifts/elevators capable of being used for evacuation during a fire emergency ; it is designed and constructed to halt the spread of heat, smoke and flame beyond that floor/storey, and is intended as a place of temporary respite, rest and relative safety for building users before continuing with evacuation, and as a forward command and control base for firefighters.
In a high-rise, tall, super-tall or mega-tall building, every 20th floor must be a Floor of Temporary Refuge, even if the building is co-joined with another building, or there are sky bridges linking the building with one or more other buildings.
Special provision must be made, on these floors, for accommodating large numbers of building occupants/users with activity limitations … and because people will be waiting on Floors of Temporary Refuge, perhaps for extended periods of time, building designers and managers must ensure that these floors/storeys are properly fitted out with appropriate fire safety equipment, facilitation aids, smoke hoods, signage and communications, etc., etc.
Presentation Overhead, in colour, illustrating and explaining the design concept of Floors of Temporary Refuge. Click to enlarge.
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Conclusion: Fire Engineering Capacity in England is Lacking
In England … the very important 2005 and 2008 U.S. NIST Recommendations following the 9-11 (2001) Attacks on the World Trade Center, in New York City, were completely ignored. Following the 2009 Lakanal House Fire, in London, the 2013 Coroner’s Recommendations were only partially implemented.
With regard to Vulnerable Building Users … there is NO capacity within the English Fire Establishment, including the National Fire Chiefs Council (NFCC), English Authorities Having Jurisdiction (AHJ’s), and its Building Design and Fire Engineering Communities … to properly respond to … never mind understand … the Fire Safety, Protection and Evacuation for ALL in Buildings.
As we approach the First Anniversary of the Grenfell Tower Fire Tragedy, in England, on 14 June … a few days ago, on 4 June 2018, the first batch of Grenfell Expert Witness Reports were uploaded (https://www.bbc.com/news/uk-44356660) to the Grenfell Tower Inquiry Website (https://www.grenfelltowerinquiry.org.uk/) for public view.
At this time, in London … multiple, fragmented investigations are taking place into the actual fire incident … the role of the Local Authority, and building management … those involved in the refurbishment (‘tarting up’) design and construction … the fire services, particularly their ‘Stay Put’ Policy and how it adversely impacted on vulnerable Tower occupants during the emergency … and the highly flawed regulatory model of Building and Fire Codes with light-touch Control, which is still operating in England. One of Murphy’s Laws immediately springs to mind with regard to the intended ineffectiveness of this overly-complex process !
Colour photograph showing Grenfell Tower in the background … undergoing an almost complete ‘cover-up’ … with, in the foreground, mementos of the Fire Tragedy fixed to railings by local residents. Click to enlarge. Photograph taken by CJ Walsh. 2018-04-29.
Many other countries have adopted some or all of this modern English regulatory model which, after the repeal of an older Bye-Law format, has been shaped by political expediency, cost-effectiveness and general ineptitude … with little or no adaptation to local conditions in the adopting jurisdictions. Ireland adopted this model with some, but not a lot, of adaptation.
Fire Safety In Ireland ?
On 6 June 2018 … while that investigative activity was hitting the headlines in England … Minister Eoghan Murphy, T.D., Ireland’s Minister for Housing, Planning and Local Government, quietly published the Report: ‘Fire Safety in Ireland’ … http://www.housing.gov.ie/local-government/fire-and-emergency-management/fire-safety/eoghan-murphy-publishes-report-fire … by a High-Level Task Force within his Department’s National Directorate for Fire and Emergency Management, after serious concerns and fears had been expressed in the public media that a similar fire tragedy might also occur in this jurisdiction.
To be crystal clear … this Report is a Bureaucratic Whitewash … an insult to the Public ! Nice sounding technical ‘blarney’ camouflages a failure to deal directly with critical issues, and answer concerns … while other important issues are avoided altogether.
.May 2018 – Ireland’s Department of Housing, Planning & Local Government Report
Expanding on my comments in the Interview with Barry Lenihan, on RTE Radio 1’s Drive Time early evening news programme on Friday (2018-06-08) …
A. Initially, Irish Local Authorities were requested to carry out a preliminary survey to identify all buildings of more than six storeys, or 18m in height. Specifically, they were asked to identify those buildings which had an external cladding system which might be a cause for concern.
This height threshold of six storeys/18m is arbitrary … an external cladding system can be just as much a cause for concern in a building which is lower. Imagine discarded cigarette butts or a rubbish fire at the base of such a system … and the resulting speed of fire spread and development across a building façade !
B. The highly flawed regulatory model of Building and Fire Codes, with light-touch Control, which resulted in the Grenfell Tower Fire Tragedy … we also have. Wake up and smell the coffee Ireland !
At the beginning of the 1990’s, when Ireland had been persuaded by the European Commission to finally introduce legal, national building regulations having a functional format … our National Authority Having Jurisdiction, in desperation, grabbed the then Approved Documents for England & Wales … brought them back to Ireland, put Irish covers on them, and originally called them ‘Technical Documents’ … but, after seeing a tiny ray of inspiring light, later changed their title to the more accurate ‘Technical Guidance Documents’ ! This hunger for adopting all things English which are fire safety related continues to this day … with a similar, ongoing division of Technical Guidance Document B: ‘Fire Safety’ into 2 Separate Volumes.
This may have been a convenient response under pressure … but it has been very short-sighted. It has impeded the growth of a comprehensive and coherent philosophy on Safe, Inclusive, Age-Friendly, Resilient, Sustainable Planning, Design and Construction Codes/Controls which is suited to an Irish context and responsible local needs (not desires!).
C. Everywhere … this Report has a lot – too much – to say about Fire Risk Assessment ! After the Grenfell Tower Fire, however, Fire Risk Assessments must only be carried out by competent persons … and the process of Fire Risk Assessment, itself, must be radically improved ! And of course, prior to any Risk Assessment … a proper Fire Hazard Appraisal must be carried out.
D. To accurately present Fire Safety Trends in Ireland … it is not enough to furnish reliable fire fatality statistics. It is also necessary to produce reliable fire injury statistics … and reliable information on direct/indirect socio-economic losses.
E. The quality of fire safety related construction on Irish Building Sites continues to be very poor and problematic. Fire Compartmentation is nowhere near being adequately – never mind acceptably – reliable ! And during the last few years we have had quite a number of close-calls concerning fire incidents in medium-rise residential buildings.
F.Fire Evacuation for people with activity limitations is still handled atrociously in our current building regulations. This is ironic because, on 20 March 2018 last, Ireland had to be dragged screaming to ratify the U.N. 2006 Convention on the Rights of Persons with Disabilities (CRPD) !
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Positive Progress By Another Path !
1. Abandon the outdated English functional requirements in THEIR building regulations … and adopt a far better, more up-to-date body of functional requirements which is already on the Irish Statute Books … Annex I of the European Union’s Construction Products Regulation 305/2011. And because there are important horizontal linkages between requirements … immediately finish the ridiculous current separation between Fire Safety requirements and all of the other requirements. And yes … new Technical Guidance Documents will have to be drafted.
.Regulation (EU) No 305/2011 of the European Parliament and of the Council, of 9 March 2011, laying down harmonized conditions for the marketing of construction products and repealing Council Directive 89/106/EEC
2. Yes … ‘Persons Having Control’ of buildings have responsibilities with regard to fire safety. But that is only one side of the coin ! National and Local Authorities Having Jurisdiction have greater responsibilities.
If we are at all serious about Consumer Protection … bad, inadequate, faulty construction must be prevented beforehand … it is too late, too costly and, in many cases, too impractical to correct afterwards. Self Regulation by building design professions and construction organizations is NO Regulation ! Stringent, independent technical control inspections must be carried out on all projects by Building Control personnel … which used to happen in Dublin City/County and Cork City/County prior to the introduction of legal building regulations in the early 1990’s … and, depending on complexity, must also be carried out at critical stages during the construction process.
Building Control Sections in all Local Authorities must be properly resourced with competent personnel, equipment, training and support infrastructure.
Inspections concerning compliance with all functional requirements in the building regulations, including fire safety, must be carried out only by Building Control Personnel. Chief Fire Officers must not be allowed to manage or be involved in any aspect of Building Control. On the same project … a Disability Access Certificate Application and a Fire Safety Certificate Application must be inter-linked and overlap sufficiently, showing no gaps in compliance. Inspections must be carried out in connection with all Certificate Applications. Building Control personnel must satisfy themselves that actual construction at least matches, if not improves upon, what is shown in design documentation.
Building Control Inspection Reports must be made available for public view.
3.Firefighters are NOT a disposable Social Asset ! National and Local Authorities Having Jurisdiction … and some Chief Fire Officers … must begin to understand this fundamental truth !
Fire Services in all Local Authorities must each be properly resourced according to local needs … with competent personnel, equipment, training and support infrastructure. Shared provision of resources looks very neat on paper but, in practice, works very badly. Refer to the Grenfell Tower Fire and London Fire Brigade having to borrow firefighting equipment from other Fire Services.
After the 2015 Tianjin Regional Fire Devastation, in China, and the 2001 WTC Attacks on 9-11, in New York City … front line firefighters must be supported by Specialist Hazard Appraisal and Structural Engineering Units.
For Firefighter Safety in buildings and to quickly find people with activity limitations waiting in Areas of Rescue Assistance and/or other survivors in different locations … a portable and reliable Thermal Imaging Camera is an essential piece of every firefighter’s equipment.
And Firefighter Safety begins with good building design. In all but the most simple building types, Circulation Routes must be designed for Contraflow … people moving away from a fire in a building and towards safety while, at the same time, heavily equipped firefighters are entering the building and moving towards the fire.
Colour photograph showing Contraflow on a building staircase … people moving down a staircase away from a fire and towards safety while, at the same time, heavily equipped firefighters are moving up the staircase towards the fire. Click to enlarge.
There is no place for ‘Stay Put’ Policies in Irish Residential Buildings of any height.
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Ireland’s 2017 Oireachtas Report: ‘Safe As Houses’ …
December 2017 – Houses of the Oireachtas – Joint Committee on Housing, Planning & Local Government
This was a good effort by our public representatives … but they missed core issues !
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After The Grenfell Tower Fire !
Further to my last Blog, dated 2017-10-10 …
The 2017 Fire in England was not an extraordinary fire. Since the beginning of this decade, we continue to see a series of such fires: South Korea (2010) – UAE & France (2012) – Chechnya (2013) -Australia (2014) – UAE, Azerbaijan & UAE again (2015) – UAE (2016) – UAE & Russia (2017) – Turkey (2018).
With regard to Command & Control of Large Scale Emergencies … English AHJ’s should have paid attention to the 2005 & 2008 U.S. National Institute of Science & Technology (NIST) Recommendations following the 9-11 WTC Buildings 1, 2 & 7 Collapses.
The Fire Safety Objectives in current Building & Fire Codes/Regulations are very limited. In Ireland, this is clearly stated in Technical Guidance Document B …
‘ Building Regulations are made for specific purposes. Part B of the Second Schedule to the Building Regulations is therefore primarily concerned with the health, safety and welfare of persons. The fire safety measures outlined in this guidance document are intended for the protection of life from fire.’
Only insofar as it is necessary to protect the lives of able-bodied building users/occupants … is there a concern for property protection.
There is only inadequate, token concern for the protection of people with disabilities.
Client organizations, facility managers, building designers, construction organizations … and journalists … must fully comprehend these limits.
In the photograph below … look closely at the External Firefighting Operations at the bottom of the Tower. There are limits to what can be achieved from outside a building !
Colour photograph showing the developed fire at Grenfell Tower, in London. At the bottom of the Tower, external firefighting operations can be viewed. Click to enlarge.
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A Fire Suppression System (Water Sprinklers/Mist/Hybrid) is an essential Fire Protection Measure in ALL Medium and High-Rise Residential Buildings … which include Apartment Blocks, Hotels, Hostels, Student Accommodation & Social Housing, i.e. ANYWHERE there is a Sleeping Hazard.
A Reliable and Credible Fire Detection & Warning System is an essential Fire Protection Measure in ALL Buildings … and must be capable, under the control of Building Management, of transmitting warnings in many formats, i.e. Audible + Visual + Multi-Lingual Voice + Tactile.
Fire Evacuation Routes in Buildings must be designed for CONTRAFLOW … people moving away from a fire and towards safety while, at the same time, heavily equipped firefighters are entering the building and moving towards the fire.
Good Fire Evacuation Route Design is INTUITIVE and OBVIOUS. In many buildings, however, this is not always the reality. Effective Fire Evacuation Signage … comprising high-level signage, low-level signage, with both supplemented by photoluminescence … must be installed in ALL Buildings.
For the purpose of protecting Vulnerable Building Users in Fire Emergencies, ALL Lifts/Elevators in Buildings must be capable of being used for Evacuation.
Fire Risk Assessments must NO LONGER be carried out by people WITHOUT COMPETENCE in Fire Engineering AND Building Design & Construction … and the Fire Risk Assessment Process itself must be thoroughly re-examined and upgraded.
Media reaction, in Ireland, to this News Release was hysterical and grossly ill-informed !
“A revolution is not a dinner party, or writing an essay, or painting a picture, or doing embroidery ; it cannot be so refined, so leisurely and gentle, so temperate, kind, courteous, restrained and magnanimous. A revolution is an insurrection, an act of violence by which one class overthrows another.”
So here are some images from the ‘real’ Cuba … or ‘real’ images from Cuba … whichever you prefer …
Fidel Castro was one of the Principal Leaders of the Cuban Revolution. Raul Castro, President of Cuba (and Fidel’s brother), is now the only surviving member of that Group. Click to enlarge. [M-26-7 = Movimiento 26 de Julio. See below.]In 1961, the United States of America attempted a Counter-Revolutionary Invasion of Cuba at the Bay of Pigs. This attempt was an embarrassing failure for the USA … but a resolute and consolidating success for Cuba and the Revolution. Photograph by CJ Walsh of a museum exhibit at Playa Giron. 2007-04-13. Click to enlarge.Playa Giron … one of the 1961 Invasion landing areas in the Bay of Pigs. Photograph by CJ Walsh. 2007-04-13. Click to enlarge.Every group of houses … every street in a community … has its own Committee for the Defence of the Revolution (CDR) … an important cohesive feature in a Socially Resilient Society. Photograph by CJ Walsh. 2007-04-04. Click to enlarge.
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Hatuey, Indigenous ‘Taino’ Chief … Cuba’s First National Hero … burned at the stake in 1512 by Spanish soldiers … at Yara, Cuba. Photograph by CJ Walsh. 2007-04-10. Click to enlarge.Monument dedicated to Perucho Figueredo, who wrote the Cuban National Anthem: ‘La Bayamesa’ … in Bayamo, Cuba. The Anthem was first played in a local church, 1868. Photograph by CJ Walsh. 2007-04-10. Click to enlarge.Statue of General Antonio Maceo … Plaza de la Revolución … in Santiago de Cuba, Cuba. Photograph by CJ Walsh. 2007-04-09. Click to enlarge.Mausoleum of José Martí, Santa Ifigenia Cemetery … in Santiago de Cuba, Cuba. Photograph by CJ Walsh. 2007-04-09. Click to enlarge.
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Moncada Army Barracks (formerly) … now a school and museum … in Santiago de Cuba, Cuba. On 26 July 1953, an attempted attack on the Barracks, led by Fidel Castro, failed. Photograph by CJ Walsh. 2007-04-09. Click to enlarge.The Sierra Maestra Mountains … in Eastern Cuba … birthplace of the second, successful phase of the Cuban Revolution … which began with the landing of the Granma in December 1956. Photograph by CJ Walsh. 2007-04-10. Click to enlarge.Early photograph of Dr. Ernesto ‘Che’ Guevara de la Serna Lynch, in Cuba. Photograph by CJ Walsh of a museum exhibit in Yara. 2007-04-10. Click to enlarge.1958 Armoured Train Ambush Site & Monument … in Santa Clara, Cuba. The successful ambush, on 29 December, was led by Che Guevara. Photograph by CJ Walsh. 2007-04-14. Click to enlarge.Bosque de los Héroes … Santiago de Cuba, Cuba … white marble monument in honour of Che Guevara and the comrades who died with him (1967) in Bolivia. Photograph by CJ Walsh. 2007-04-08. Click to enlarge.
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José Martí Statue, Parque Central … in Havana, Cuba. Photograph by CJ Walsh. 2007-04-03. Click to enlarge.The Capitolio … in Havana, Cuba. Photograph by CJ Walsh. 2007-04-03. Click to enlarge.Statue of the Republic, Capitolio … in Havana, Cuba. Photograph by CJ Walsh. 2007-04-04. Click to enlarge.Salón de los Pasos Perdidos, Capitolio … in Havana, Cuba. Photograph by CJ Walsh. 2007-04-04. Click to enlarge.Gran Teatro de La Habana … in Havana, Cuba. Photograph by CJ Walsh. 2007-04-03. Click to enlarge.El Floridita Bar & Restaurant … in Havana, Cuba. Photograph by CJ Walsh. 2007-04-07. Click to enlarge.Main Staircase, Museo de la Revolución (formerly the Presidential Palace) … in Havana, Cuba. Notice the bullet holes in the marble ! Photograph by CJ Walsh. 2007-04-06. Click to enlarge.Salón de los Espejos, Museo de la Revolución (formerly the Presidential Palace) … in Havana, Cuba. Photograph by CJ Walsh. 2007-04-06. Click to enlarge.Paseo del Prado … in Havana, Cuba. Photograph by CJ Walsh. 2007-04-03. Click to enlarge.The Malecón … in Havana, Cuba. Photograph by CJ Walsh. 2007-04-07. Click to enlarge.Ministerio del Interior, Plaza de la Revolución … in Havana, Cuba. Photograph by CJ Walsh. 2007-04-04. Click to enlarge.
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Mural de la Prehistoria (1959-62, and restored in 1980), by Cuban painter Leovigildo González, in the Valle de Viňales … Pinar del Rio, Cuba. Photograph by CJ Walsh. 2007-04-05. Click to enlarge.Tobacco Harvest … in Pinar del Rio, Cuba. Photograph by CJ Walsh. 2007-04-05. Click to enlarge.Statue of Benny Moré (1919-63) … Cuban singer, bandleader and songwriter … Paseo del Prado, Cienfuegos, Cuba. Photograph by CJ Walsh. 2007-04-14. Click to enlarge.
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International Work Brigade (December 2011 – January 2012) at the Campamento Internacional Julio Antonio Mella … in Caimito, Cuba. Click to enlarge.
2016-05-16: Media coverage of the Brussels Hive Attack, on 22 March 2016 … and, more recently, my own experience travelling in the Rome Metro, where the lines have been constructed deep in the ground to avoid the city’s vast and rich archaeological heritage … made me seriously wonder about how vulnerable users of the built environment can possibly cope in emergencies.
Escalators (moving stairs) and Travellators (horizontal moving walkways) are very common in public buildings. They greatly facilitate convenient and comfortable circulation for everybody … especially in large, extensive and complex building types. Escalators are absolutely essential in metro environments, both for access and egress.
Escalators which are static … which don’t move, for one reason or another … are dangerous. The rise of steps in the main part of the escalator is usually very high, too high for any type of public building … and at the top and bottom of the escalator, the step rise varies dramatically … which is a recipe for trips and falls, particularly in any sort of emergency.
AND … we know that during a fire emergency in a building, many people will attempt to evacuate that building by re-tracing their route of entry … whatever the hazard and wherever it is located.
Too many Standards and Guideline Documents take the easy option … and recommend that lifts/elevators, escalators and travellators should all be shut down during emergencies, and their use prevented. For the moment, I am thinking of just two examples:
European Standard EN 115: Safety of Escalators and Moving Walks – Part 1: Construction and Installation. 2008-05-29, including Amendment 1 2010-02-23.
Guidelines for the Safe Operation of Escalators and Moving Walks, published by the Safety Assessment Federation (GB), in consultation with the British Health & Safety Executive. Issue 1, 2011-05-24.
These Recommendations … this Guidance, or Advice, or Whatever … show absolutely no consideration for the Safe Evacuation of People With Activity Limitations (2001 WHO ICF) in an Emergency.
These Recommendations … this Guidance, or Advice, or Whatever … are WRONG !
Subject to some simple requirements, e.g. a separate fire-protected electrical supply in each case, and appropriate management and fire service control, etc … Lifts/Elevators, Escalators and Travellators should all be available for use by people evacuating a building/facility during an emergency … and for use by firefighters accessing that same building/facility.
Building Designers, Fire Services & Standards Organizations … please take careful note !!
2015-02-01: This important Event is still a few months away, but the following update will be of interest …. a mixture of some good news and some bad news …
To Register / To Attend … please go to the Event WebSite: www.fire-safety-for-all.eu … places are limited in the New Conference Venue.
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1. 2015 Dublin ‘Fire Safety for All’ Declaration – A Call to Action & Successful Implementation !
From the beginning, we promised that this would not be a polite gathering in Dublin. It will, instead, be a time for hard work and straight talking by everybody attending … and a good opportunity to have some fun also. Dublin is a very ‘sociable’ city !
Proposed 2015 Dublin Declaration on ‘Fire Safety for All’ in Buildings
If you would like to comment on this document, or if you have any questions … please send an e-mail message to: fireox@sustainable-design.ie
Drafting of the CIB W14 Research Working Group V Reflection Document has already commenced.
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2. Dublin Fire Safety for All Event’s First Press Release
A strong message from and about the Dublin Event must be widely disseminated at international and national levels … download and read / forward / circulate / publish FireOx International’s First Event Press Release (PDF File, 49 Kb), dated 1 February 2015 …
FireOx International’s First Event Press Release
Please help us to spread the word !
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3. Embarrassment about Original Conference Venue
Accessibility of a Building … encompasses the complete cycle of independent use, in a dignified manner and on an equal basis with others … and includes the approach, entry and use of a building and its facilities, egress during normal conditions and removal from its vicinity … and, most importantly, safe evacuation during a fire incident to a place of safety which is remote from the building and reached by way of an accessible route.
As I write … Ireland has a truck load of accessibility-related National Building Regulations and EU Safety at Work Law (transposed at national level a long, long time ago). We have strong Equality Law. We have ease of access to accessibility-related International Standards (such as ISO 21542: 2011) and National Standards from other European Countries, North & South America, and Asia. We have accessibility-related National Guidance Documents coming out of our ears, and easy access to all sorts of other guidance from around the world. Lots and lots and lots and lots of paperwork, in digital and hardcopy formats !
Ireland today … is still one of only a few remaining countries which have yet to ratify the United Nations Convention on the Rights of Persons with Disabilities (CRPD), the principal aim of which is to ensure that the Human Environment (including the built, social, economic, virtual and institutional environments) is sufficiently accessible for people with activity limitations to participate positively in all aspects of their local communities … a basic human right, which every able-bodied person takes for granted !
” This is not just a national disgrace, it is a huge embarrassment for our country when you consider that the European Union itself and most of the EU’s Member States have already ratified this UN Convention.”
AND … as I look around Dublin … the City is NOT accessible for its many vulnerable residents and foreign visitors !
Colour photograph showing the Main Entrance to Dublin Castle’s Printworks Building. Telepathy is required to be ‘aware’ that there is a ramp located way down at the far end of the building. Notice the limited extent of ground tactile information at the bottom of the steps in the foreground, and the unmarked glazing on the left of the Entrance Doors above.
Are you sitting comfortably ? Then I will tell you a short story … a ‘real’ story, not a fairy tale … about the Original Conference Venue …
Mr. Sean Sherlock, T.D., Minister of State at Ireland’s Department of Foreign Affairs with responsibility for Overseas Development Aid, has agreed to open the Event on the evening of Thursday, 9 April 2015. All of Irish Aid’s Partner Countries in Africa have ratified the UN Convention on the Rights of Persons with Disabilities.
Given the serious, socially transformative topic of this Conference … the Minister had also kindly offered to waive the fee for the hire of the Printworks Building in Dublin Castle – a very prestigious location in the City, and a building which was been extensively refurbished in time for Ireland’s recent Presidency of the European Union. The audio-visual fit-out for this building is magnificently elaborate. Most unfortunately, the building’s accessibility is entirely inadequate (‘ATROCIOUS’ would be a better word to describe it) !
Colour photograph showing a marked Set Down Area at the front of Dublin Castle’s Printworks Building. Bollards prevent a Taxi from dropping off a passenger, who uses a wheelchair, at the bottom of the ramp.
However, with the right attitude and positive co-operation from the Venue Management Team, many improvements to the building’s accessibility could have been made for the Conference. From the beginning, however, the Management Team’s response to this issue was negative.
” It is entirely unacceptable that this State’s New and Heritage Building Stock is designed, constructed, and/or managed without a full and proper consideration … and successful implementation … of Accessibility for All and Fire Safety for All ! “
Colour photograph showing, from above, the Main Entrance Steps of Dublin Castle’s Printworks Building. Also notice the hazardous lack of visual colour contrast in platform and step surfaces.
The Venue Management Team has refused to honour the Minister’s waiver.
Colour photograph showing the Top of the Ramp at the side of Dublin Castle’s Printworks Building. Notice the lack of ground tactile information.
We have had no other option but to move the Conference and Workshop to a far better Venue just around the corner … the Radisson Blu Hotel in Golden Lane, Dublin.
Colour photograph showing the Bottom of the Ramp at the side of Dublin Castle’s Printworks Building. Notice the difficult approach to the Ramp, and also no indication of where there are level surfaces to rest when using the Ramp.
A Building which is NOT Accessible is difficult, if not impossible, for everybody to evacuate during a real fire incident …
‘Rigorous enforcement of building codes and standards by state and local agencies, well trained and managed, is critical in order for standards and codes to ensure the expected level of safety. Unless they are complied with, the best codes and standards cannot protect occupants, emergency responders, or buildings.’
(2005 U.S. NIST NCSTAR 1: Final Report on the Collapse of the World Trade Center Towers … Page 202, Chapter 9: Recommendations)
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United Nations Convention on the Rights of Persons with Disabilities
UN CRPD Article 33 – National Implementation & Monitoring
1. States Parties, in accordance with their system of organization, shall designate one or more focal points within government for matters relating to the implementation of the present Convention, and shall give due consideration to the establishment or designation of a co-ordination mechanism within government to facilitate related action in different sectors and at different levels. 2. States Parties shall, in accordance with their legal and administrative systems, maintain, strengthen, designate or establish within the State Party, a framework, including one or more independent mechanisms, as appropriate, to promote, protect and monitor implementation of the present Convention. When designating or establishing such a mechanism, States Parties shall take into account the principles relating to the status and functioning of national institutions for protection and promotion of human rights. 3. Civil society, in particular persons with disabilities and their representative organizations, shall be involved and participate fully in the monitoring process.
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The Access Consultants for Dublin Castle were O’Herlihy Access Consultancy.
2014-08-28: Earlier this month … the final straw … as I caught up on a ‘piece’ in McGraw Hill’s Architectural Record … which reproduced an original, intriguing article from designMENA.com, posted on 12 August 2014, by Nick Ames …
Rebel Architects Star In New TV Show
Qatar-based broadcaster Al Jazeera is to show a series of films focusing on radical architects from Pakistan, Brazil, Nigeria, Spain, Palestine and Vietnam. The series – entitled ‘Rebel Architecture’ – focuses on architects using design to confront urban, environmental and social problems in their communities.
Dan Davies, producer of the series, said: “We couldn’t help noticing that despite all the problems afflicting humanity, many of which architecture uniquely has the ability to assist and even solve, most of the mainstream and architectural press celebrates the aesthetics of huge iconic projects, marvelling at insanely complicated ways to fold giant sheets of metal.”
“As we face issues from floods and natural disasters to an explosion of urban populations, soaring inequality and displacement through conflict, architecture seems wholly absent. So we wanted to look beyond the discussion of the aesthetics of Star-chitecture and see what architects outside the mainstream are doing.”
The six-part series, which starts on 18 August, begins with a film documenting the work of Spanish architect Santiago Cirugeda, who uses his knowledge of planning law to occupy abandoned properties and to build structures on unused land.
It also features Pakistani architect Yasmeen Lari, who designs disaster relief shelters and Eyal Weizman, professor of spatial and visual cultures at Goldsmiths University, who explores the way the built environment is used as an instrument of occupation.
In Vietnam, the series follows Vo Trong Nghia, whose projects focus on open spaces and sustainable design, while in Nigeria, Kunlé Adeyemi has designed floating buildings to solve issues of flooding and overcrowding.
The final episode explores Rocinha, the largest favela in Brazil, with builder Ricardo de Oliveira, and master planner Luis Toledo.
“The rebel architects have to push boundaries, but they must also look beyond their own buildings,” said Davies. “They start by looking at the wider context in which they live – be it Spain hit by the financial crisis, or Pakistan ravaged by floods – and work out how they can change the status quo with architecture.”
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I SAY …
Shouldn’t every Architect be concerned about the issues raised in Nick’s article ? And if not … why not ??
Architecture is a wide and complex field of human creative, artistic and scientific endeavour. Yet in the international and national media, both mainstream and architectural … it does appear, as presented, to be narrowly confined to the “aesthetics of huge iconic projects”, and “insanely complicated ways to fold giant sheets of metal”. And the various media continue to focus on and enthusiastically applaud the current, outrageous phallic skyscraper contest in, for example, the Arab Gulf Region, China and South-East Asia … a contest which is actively promoted by such international organizations as the US-based Council on Tall Buildings & Urban Habitat. [ I might add … with entirely insufficient attention being paid to fire safety, resilience and sustainability in those Super-Tall Buildings !! ]
If Santiago Cirugeda, Yasmeen Lari, Eyal Weizman, Vo Trong Nghia, Kunlé Adeyemi, Ricardo de Oliveira, and Luis Toledo are indeed Rebels … [ I would argue that they most definitely are not ] … and each one is working in isolation … then we must urgently instigate a Revolution …
Creative Architecture In Context !!
PRINCIPAL BARRIER …
The Institutional Framework of Today’s Conventional Architecture … typically developed to promote and protect a 19th Century Model of Architectural Practice … exerts a powerful stranglehold over the architectural profession and the schools of architecture in many countries. It is no longer ‘fit for purpose’ in the 21st Century !
Here in Ireland … a few days before reading the Nick Ames article … I attended a long Extraordinary General Meeting of the Royal Institute of the Architects of Ireland (RIAI) … called by 10 Institute Members to demand urgent, concerted action from the Institute’s Council in response to the new and very flawed Building Control Amendment Regulations (Statutory Instruments Nos.9 & 105 of 2014), which came into effect from 1 March 2014.
Far from being an enlightening and pleasurable occasion … for many small reasons, it was annoying and frustrating. The biggest reason of all, however, was that I saw no evidence whatever that either Council or the Membership understands the simple, fundamental truth that … self-regulation/self-certification does NOT work !
Refer back to my previous post.
The General Public in Ireland … also known as ‘The Long-Suffering Consumer’ … does not trust the Medical and Legal Professions to self-regulate, despite the vociferous protestations from both that their internal regulatory systems are packed-packed-packed with civilians. Yes … ‘selected’ civilians !
That particular evening in the Davenport Hotel, Dublin … the RIAI’s Extraordinary General Meeting (EGM) went nowhere … aided and abetted by Council Members at the head table. It was interesting to note that none of the 10 Institute Members who had called the meeting had a seat at that same table.
As we exit the Profound Economic Crisis following the Extravagant Celtic Tiger Years … and coldly look around us … we witness an architectural profession lost in a contextual wilderness – urban, environmental and social – while fumbling around in a legal and political maze. And, every day, we experience a sprawling, ugly, depressing and unsustainable built environment which is engaged in a sad and brutal conflict with nature.
It has taken at least a generation … but the RIAI has directly overseen the slow and progressive dilution of what it means to be an Architect in Ireland.
2013-07-19: Once upon a time, back in 1979, when I was flying to Sydney, Australia … one of the scheduled stops on the route was Bahrain and the New International Airport Terminal there. In spite of the flashy and expensive building, I noticed how obsolete looking (and functioning) were the fittings in the toilet area. Could it possibly be, I wondered, that the Arab Gulf Region was being supplied with shoddy, second rate construction products from you-know-where ??
Fast forward to a few years ago … in Riyadh, Saudi Arabia … and I encountered one building – the same building – where one half had a 110 Volt electrical supply, and the other half had a 220 Volt supply. Amazing !?! Two different consultants, or contractors, or whatever … one from North America, and the other from Europe … with the Saudis in the middle, having to tolerate this nonsense !!
Photograph taken by Brian Candy. 2012-05-28. Click to enlarge.
DOHA City Fire – Monday, 28 May 2012 …
I distinctly remember that some Irish people who had actually witnessed the Fatal Fire Incident at the ‘Villaggio’ Shopping Mall (www.villaggioqatar.com), in Doha (capital city of Qatar) … were afterwards talking to Mr. Joe Duffy, on the lunchtime ‘Liveline’ Programme (Ireland’s RTE Radio 1 Station).
19 People were killed on that Monday morning in Doha … 13 Children, 4 Teachers, and 2 Firefighters. Many more were injured from inhaling toxic smoke.
According to various news reports … an electrical fire, caused by a light fitting (which was not ‘fit for its intended use’) in a Nike Shop, engulfed a section of the shopping centre … spreading to the Gympanzee Drop-and-Shop Childcare Centre on the first floor.
The staircase leading to the Childcare Centre collapsed … trapping victims inside. One of their fire exits led directly to the seat of the fire, while the other fire exit was locked from the outside.
In addition, the ‘Villaggio’ – a luxury mock-Italian shopping centre (one of the most popular in the country !) where customers could ride around Venetian-style Canals, in Venetian-style Gondolas – was later found to be in breach of legislation because Essential Fire Safety Measures were either inadequate or missing, at the time of the fire: the fire sprinkler system was not working properly; inflammable paint and decorative mouldings were used in the construction; the building did not have effective fire evacuation procedures in place; the building was not equipped with proper fire-fighting equipment; and the fire alarm wasn’t loud enough.
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A Qatari Court – Thursday, 20 June 2013 …
The recent outcome from this Qatari Court Case has been nagging at me ever since I saw the news on Al Jazeera (English) … www.aljazeera.com
Only Some of the People having Control / Responsibility were convicted for the Negligence which resulted in the 19 Deaths, and many injuries, at the 2012 ‘Villaggio’ Fatal Fire Incident.
Four people received six-year jail terms, while the fifth received a five-year term. All five are currently out on appeal, and will remain out of custody until the appeals process is completed.
Those convicted include Two Co-Owners of the Childcare Centre, and Members of the Mall’s Management Team. Sheikh Ali Bin Jassim Al Thani, one of the co-owners, is also currently Qatar’s Ambassador to Belgium … while Iman Al-Kuwari, the other co-owner, is the daughter of Qatar’s Culture Minister.
Two other defendants, including the Mall’s Assistant Manager and Head of Security, were cleared of all charges.
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Other People having Control / Responsibility were also Careless, Incompetent, and Negligent …
Submissions on India’s Draft Amendment No.1 to the 2005 National Building Code (SP 7:2005) concerning the Proposed Incorporation of a New Part 11: ‘Approach to Sustainability’ had to arrive at the Bureau of Indian Standards (BIS), in Dilli … by e-mail … no later than Friday last, 15 March 2013 …
Click to enlarge.
Indian NBC, Proposed Part 11 on ‘Sustainability’ – December 2012 Consultation
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Extract From Foreword (Page 7):
‘ Developed nations’ approach to sustainability generally concentrates on energy conservation through high technology innovations, and use of products, materials and designs with lower embodied energy. Their green ratings are based on intent, which implies expert inputs and simulation. The Indian construction industry will do better using our traditional wisdom and practices, building in harmony with nature through regional common knowledge, consuming as little as necessary, applying low cost technology innovations, using recycled materials, and recognizing performance (not intent) through easily measurable parameters wherever feasible.’
How Right They Are About Prioritizing ‘Real’ Performance !!
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And Just Before That Extract Above:
‘ The authentic (my insert !) Indian way of life is aparigraha (minimum possessions), conservation (minimum consumption), and recycling (minimum waste). These three attributes are the guiding principles for sustainable buildings as well. With these attributes and its rich heritage, India can make a substantial contribution in this field and eventually lead the world on the path of sustainability.’
An Overly Ambitious Target ? Perhaps Not.
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SDI Supporting India’s National Sustainable Buildings Strategy …
We very much welcome this opportunity to make a Submission on India’s Draft Amendment No.1 to the 2005 National Building Code (SP 7:2005) concerning the Proposed Inclusion of a New Part 11 ‘Approach to Sustainability’.
This IS an important development for India … and it DOES mark a substantial contribution to this field, at international level. We wish that other countries would follow your example … particularly China, the other mushrooming economies in South-East Asia, and the Arab Gulf States.
You may not be aware that Sustainable Design International (SDI) has been specializing in the theory and implementation of a Sustainable Human Environment (social, built, virtual, and economic) since the mid-1990’s.
And, for example … in September 2007, we were invited to make a series of Keynote Presentations to 20 Senior National Decision-Makers, from both the public and private sectors, at a 2-Day Workshop which was organized for us in Lisboa, Portugal. If invited, we would be delighted to repeat this valuable exercise in Dilli, Bengaluru, and other suitable venues in India.
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IF India is to lead the world on this particular track, i.e. Sustainable Buildings, a coherent philosophy must be outlined in the Proposed New Part 11 of the National Building Code, and a clear direction must also be given there to decision-makers, e.g. clients/client organizations, and designers.
Certain essential content must be included in Part 11. With regard to an improved layout of Part 11, please review the attached SDI Document: ‘SEED Building Life Cycle’ (PDF File, 55 Kb) .
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Because you have prioritized ‘real’ building performance over pre-construction design ‘intent’, it is appropriate to begin our comments here …
1. Sustainability Performance Indicators
In order to prioritize ‘real’ performance, the monitoring of actual sustainability performance in completed and occupied buildings must be comprehensive, accurate and reliable. Indicators of sustainability performance must, therefore, be included in all sections of the Proposed New Part 11.
Sustainability Performance Indicators provide important signposts for decision-making and design in many ways. They can translate physical and social science knowledge into manageable units of information which facilitate the decision-making and design processes. They can help to measure and calibrate progress towards sustainable development goals, and sectoral sustainability targets. They can provide an early warning to prevent economic, social and environmental damage and harm. They are also important tools to communicate ideas, thoughts and values because, as statisticians say: “We measure what we value, and value what we measure”.
Performance Indicators may be both quantitative and qualitative … but must cover all stages of the building process, i.e. project feasibility and performance specification, spatial planning, design, construction, management, operation, maintenance and servicing, de-construction, disposal, final site clean-up and sustainable repair.
While many, though not all, types of building performance can be successfully monitored using lightweight portable equipment … a certain number of monitoring devices must also be permanently installed in the building during construction. A facility to reliably feed the output from these devices back to data collection points, on site and remote, must also be incorporated in the Building’s Intelligent Management System.
Management and collation of sustainability performance data must be reliable. Uncertainty is always present. Therefore, Statements of Uncertainty should always be attached to ‘reliable’ data.
Safety Factors should always be included when targeting critical ‘health and safety’ related types of performance.
Sustainability Performance Indicators must be directly comparable across different Global Regions … within Asia, across different countries … and within India, across different States. A Balanced, Harmonized Core Set of Indian Performance Indicators should be quickly developed. A Balanced ‘Local’ Set of Performance Indicators will always be necessary.
People tasked with monitoring sustainable building performance must be competent … and independent, i.e. be unconnected to client, design and construction organizations.
Specifically in relation to Energy Performance, the targets to be achieved in new buildings must be far more ambitious. Please review the attached SDI Document: ‘SEED Positive Energy Buildings’ (PDF File, 29 Kb) .
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2. Properly Defining ‘Sustainable Development’
As currently drafted … Definition 2.26 Sustainable Development, on Page 13 of the Proposed New Part 11, is not only ambiguous, it is inadequate for India’s needs … and it is barely the first half of the full, correct definition …
Sustainable Development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs. It contains within it two key concepts:
the concept of ‘needs’, in particular the essential needs of the world’s poor, to which overriding priority should be given ; and
the idea of limitations imposed by the state of technology and social organization on the environment’s ability to meet present and future needs.
[ Please refer to the 1987 Report of the World Commission on Environment & Development (WCED): ‘Our Common Future’ – Chapter 2, Paragraph 1.]
This original definition in the 1987 WCED Report IS appropriate for India … and it must become the core definition at the heart of India’s National Sustainable Buildings Strategy !
A careful reading of the full definition makes it clear that there are Many Aspects to this intricate, open, dynamic and still evolving concept … the most important of which are: Social, Economic, Environmental, Institutional, Political, and Legal.
It is a Fundamental Principle of Sustainability, and one of its Primary Values … that Implementation must be Synchronous, Balanced and Equitable across All Aspects of Sustainability.
The ‘Green Agenda’ merely considers Environmental Aspects of Sustainability … in isolation from all of the other Aspects ! This is a fatal flaw which must be avoided in the Proposed New Part 11 !!
[ I made many references to this issue during the FSAI Conferences in India ! ]
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3. Sustainability Impact Assessment (SIA) for India !
Rather than Environmental Impact Assessment … surely the Proposed New Part 11: ‘Approach to Sustainability’ must now use, explain and discuss Sustainability Impact Assessment instead !?!
Sustainability Impact Assessment (SIA)
A continual evaluation and optimization assessment – informing initial decision-making, or design, and shaping activity/product/service realization, useful life and termination, or final disposal – of the interrelated positive and negative social, economic, environmental, institutional, political and legal impacts on the synchronous, balanced and equitable implementation of Sustainable Human & Social Development.
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4. A Robust Legal Foundation for ‘Sustainable Human & Social Development’
Paragraph 4 (Chapter 2, 1987 WCED Report) states …
‘ The satisfaction of human needs and aspirations is the major objective of development. The essential needs of vast numbers of people in developing countries – for food, clothing, shelter, jobs – are not being met, and beyond their basic needs these people have legitimate aspirations for an improved quality of life. A world in which poverty and inequity are endemic will always be prone to ecological and other crises. Sustainable development requires meeting the basic needs of all and extending to all the opportunity to satisfy their aspirations for a better life.’
Trying to list the essential needs of people / the basic needs of all is a very difficult task … but it is work which has been on-going, at international level, since just after the Second World War.
The essential needs of people / the basic needs of all … are specified as being Human Rights and Fundamental Freedoms, and are already fully described within the extensive framework of International Legal Rights Instruments.
Which is why, many years ago, SDI developed this definition for Sustainable Human & Social Development … in order:
to give this concept a robust legal foundation ; and
(because of widespread confusion in media, political and academic circles) … to clearly establish that we are talking about sustainable human and social development, and not sustainable economic development, or any other type of development !
Sustainable Human & Social Development
Development which meets the responsible needs, i.e. the Human & Social Rights*, of this generation – without stealing the life and living resources from future generations … especially our children, and their children … and the next five generations of children.
*As defined in the 1948 Universal Declaration of Human Rights.
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5. Climate Change Adaptation & Resilient Buildings in India ?
Atmospheric Ozone Depletion and Climate Change are mentioned, here and there, in the Proposed New Part 11. The important implications of these phenomena for Sustainable Building Design in India are not explained … at all. Why not ?
To properly respond to these phenomena, both must be integrated into India’s National Sustainability Strategies & Policies.
At the very least … we strongly recommend that Design Guidance on Climate Resilient Buildings be immediately drafted. This guidance must be appropriate for implementation in each of the different climatic regions of India.
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6. A Sustainable Indian Built Environment which is Accessible for All !
Barrier Free is mentioned, here and there, in the Proposed New Part 11. This is to be warmly welcomed and congratulated. Under Social Aspects of Sustainable Human & Social Development … this is an essential attribute of a Sustainable Built Environment ! However, no guidance on this subject is given to decision-makers or designers. Why not ?
However, you should be aware that India ratified the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) on 1 October 2007. For your convenience, I have attached copies of the Convention in English, Hindi and Tamil.
You should also be aware that, in December 2011, the International Standards Organization (ISO) published ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’. In its Introduction, ISO 21542 is directly linked to the U.N. Convention … almost like an umbilical cord. The scope of this Standard currently covers public buildings. As the Accessibility Agenda in the U.N. Convention is very broad … much standardization work remains to be finished at international level.
The correct term … Accessibility for All … has been defined in ISO 21542 as including … ‘access to buildings, circulation within buildings and their use, egress from buildings in the normal course of events, and evacuation in the event of an emergency’.
A note at the beginning of the standard also clarifies that Accessibility is an independent activity, i.e. assistance from another person should not be necessary … and that there should be an assurance of individual health, safety and welfare during the course of those (accessibility-related) activities.
In order to fulfil India’s legal obligations as a State Party to the U.N. Convention on the Rights of Persons with Disabilities … adequate Design Guidance on Accessibility must be included in the Proposed New Part 11, supported by ISO 21542.
In addition, the Bureau of Indian Standards (BIS) should immediately adopt ISO 21542 as the Indian National Standard on Accessibility for All … IS / ISO 21542.
[ I made many references to this issue during the FSAI Conferences in India ! ]
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7. Fire Safety & Protection for All in Sustainable Indian Buildings ?
Yes … there is 1 mention of ‘fire safety’ and 40 other references to ‘fire’ in the Proposed New Part 11 … but no design guidance. Why not ?
You should be aware that there is a fundamental conflict between Sustainable Building Design Strategies and the current state-of-the-art in Fire Engineering Design. As a good example … for cooling, heating and/or ventilation purposes in a sustainable building, it is necessary to take advantage of natural patterns of air movement in that building. On the other hand, fire engineers in private practice, and fire prevention officers in Authorities Having Jurisdiction (AHJ’s), will demand that building spaces be strictly compartmented in order to limit the spread of fire and smoke … thereby dramatically interfering with those natural patterns of air movement.
In everyday practice, there is a vast chasm in understanding and communication between these two very different design disciplines. As a result, serious compromises are being enforced on Sustainability Building Performance. If, on the other hand, adequate independent technical control is absent on the site of a Sustainable Building … it is the fire safety and protection which is being seriously compromised.
A range of critical fire safety issues (fatal, in the case of firefighters) are also arising with the Innovative Building Products and Systems being installed in Sustainable Buildings.
Because the emphasis is on pre-construction design ‘intent’ rather than the ‘real’ performance of the completed and occupied building … all of these problems are being conveniently ignored, and they remain hidden from everybody’s view.
This must be addressed in the Proposed New Part 11.
[ I made many references to this issue during the FSAI Conferences in India ! ]
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C. J. Walsh – Consultant Architect, Fire Engineer & Technical Controller – Managing Director, Sustainable Design International Ltd. – Ireland, Italy & Turkey.
