national law

BS 9999:2008 & BS 8300:2009 – Sleepwalking into Problems ?

Posted 2009-06-14 by CJ Walsh

2009-06-14: Ireland has no national standards or codes of practice of its own covering Building Accessibility or Fire Safety in Buildings. Instead, many people and organizations in this country will just switch to automatic pilot and – without thinking or questioning – adopt the following two standards of another jurisdiction as the default Irish National Standards …

British Standard BS 9999:2008 – Code of Practice for Fire Safety in the Design, Management and Use of Buildings … was published on 31 October 2008.

British Standard BS 8300:2009 – Design of Buildings and Their Approaches to Meet the Needs of Disabled People. This Code of Practice was published on 28 February 2009.

If Ireland does not quickly open its eyes … we will be sleep walking into a very problematic legal environment, as far as building accessibility and fire safety in buildings is concerned.

1. An Immediate Challenge

A Sub-Group (established at a meeting of the NSAI Accessibility-for-All Standards Consultative Committee WG1 held on Tuesday 2009-05-19) was tasked with developing a common position, suitable for application in Ireland and compatible with European Technical Harmonization, on the following issues:

Clear Width of Internal & External Door Openings ;
Turning Circles for Occupied Wheelchairs ;
Car Parking Spaces ;
Fire Safety Issues.

A series of coherent proposals will be presented to the next NSAI AASCC WG1 Meeting, on Friday 19th June 2009 … and, given the absence of Irish National Standards, it will also be suggested how these proposals may be confirmed as best current practice here.

2. Overview of BS 8300:2009 & BS 9999:2008

During the development of the Draft ISO Accessibility-for-All Standard, it has been unanimously agreed that Accessibility encompasses the full range of activity related to buildings: to approach, enter, use, egress from and evacuate a building independently, in an equitable and dignified manner (Introduction, 2nd Paragraph, Page 5). ‘Egress’ under normal, ambient conditions is distinguished from ‘Evacuation’ in the event of a fire emergency. Use of the word ‘Escape’ is discouraged in any circumstance. For the first time, fire safety texts have been fully incorporated into the main body of the Draft ISO Standard.

Accessibility within the British Standards Institution (BSI), on the other hand, is still segregated between BS 8300:2009 – approach, entry and use and BS 9999:2008 – fire evacuation. Conflicts and gaps in content naturally result from such a configuration, which can now be seen as outdated and fundamentally flawed.

This configuration has been replicated, in Irish Building Regulations, with the separate scopes of Part M / Technical Guidance Document M and Part B / Technical Guidance Document B. Integration between these 2 Technical Guidance Documents is very poor. In practice, fire safety for people with activity limitations is widely disregarded within the process of Fire Safety Certification in Ireland.

2.1 BS 8300:2009

BSI has arrogantly gone on a solo run, and decided to deviate from some very widely accepted concepts of accessibility, e.g. ‘clear width’ of a door opening (discussed in more detail later). The ‘Ergonomic Research’ supporting door opening forces of 30 N is at complete variance with earlier research in Britain and must, therefore, be strongly questioned. Perhaps, it is the case that the Fire Services in England & Wales re-asserted their authority, supported by reference to European Fire Product Standards with little if any input from the European Disability Sector, and insisted on a ‘definite’, i.e. high, closing force being exerted on the door leaves in fire resisting doorsets.

2.2 BS 9999:2008

People with disabilities have a right, recognized in international law after 3rd May 2008, to equal opportunity and non-discrimination in matters of building fire safety, protection and evacuation. A minimum response to Article 11 (Situations of Risk) in the 2006 United Nations Convention on the Rights of Persons with Disabilities is required, therefore, from fire regulators and code writers. Such a response is absent in British Standard BS 9999:2008.

A close examination of the fire safety texts relating to ‘disability’ in BS 9999:2008 shows that they have not been properly integrated into the ‘mainstream’ content. In fact, much of the content from the replaced BS 5588:Part 8 has just been grafted onto BS 9999, with very little change or alteration from the first version of Part 8 published in 1988 !

Compare Figure G.1 on Page 360 of BS 9999:2008 … with … Figure 4 on Page 8 of BS 5588:Part 8:1988 … both are exactly the same …

Black and white drawing showing both a token and an inadequate 'area of rescue assistance' in BS 9999:2008 - exactly as shown in the first version of BS 5588:Part 8 published back in 1988 ! — Black and white drawing showing both a token and an inadequate ‘area of rescue assistance’ in BS 9999:2008 – exactly as shown in the first version of BS 5588:Part 8 published back in 1988 ! Click to enlarge.

Two Critical Observations in relation to the ‘area of rescue assistance’ shown above:

– This drawing in BS 9999:2008 is in direct conflict with the text located directly above it … ‘where the wheelchair space is within a protected stairway, access to the wheelchair space should not obstruct the flow of persons escaping’ ;

but, more importantly …

– In BS 9999:2008, fire safety for people with activity limitations receives treatment which is superficial and merely token. Many times in relation to buildings generally, it is stated in Annex G.1, Page 359 …

‘A refuge needs to be of sufficient size both to accommodate a wheelchair and to allow the user to manoeuvre into the wheelchair space without undue difficulty.’

‘ In most premises, it is considered reasonable to have refuges of a size where each one is able to accommodate one wheelchair user. Where it is reasonably foreseeable that the proportion of disabled users in a building will be relatively high, or where the use of the premises is likely to result in groups of wheelchair users being present (e.g. some types of sporting, entertainment, transport or public assembly buildings), consideration should be given to increasing the size and/or number of refuges accordingly.’

‘ NOTE 3 Managers of sporting or other venues where a number of disabled people might be present are advised not to restrict the number of disabled people who can be admitted to that venue on the grounds of the size of refuges, since some disabled people who use mobility aids such as a wheelchair will be able to self-evacuate in the case of a real fire.’

and again in Annex G.2.2 on Page 367 …

‘Where it is reasonably foreseeable that the refuges will be used by more than one user (e.g. some types of sporting, entertainment, transport or public assembly buildings), … ‘

Within such an inadequate and token context, it is understandable that an unduly heavy reliance is placed on the practice of developing Personal Emergency Evacuation Plans (PEEPS) for individuals with activity limitations. See Paragraph #46.7a) on Page 248, which states …

‘ By taking into account the individual needs of a person when preparing a PEEP, management will be able to make any reasonable adjustments to the premises or procedures that are necessary.’

These Plans are flawed and discriminatory because they are:

– person specific ; and

– location specific ;

… with the underlying assumption in the text being that, beyond the specified location(s), the building is not properly accessible, i.e. does not meet the functional requirements of Parts B & M in the Building Regulations for England & Wales – or, in the case of Ireland, Parts B & M of our Building Regulations.

There are silly technical errors in BS 9999:2008, e.g. in Annex G.2.3 on Page 368, it states …

‘Unless a different order has been agreed with the fire authority, evacuation should normally be in the following order:

1) the fire floor ;

2) the floor immediately above the fire floor ; [This should read ‘the floors immediately above and immediately below the fire floor’ !]

3) other floors above the fire floor starting at the top storey ;

4) all remaining floors.’

A Technical Term is used in BS 9999:2008 – Place of Ultimate Safety – which complicates the already widely accepted term: ‘Place of Safety’. The definition provided for the British Term in Section 3: Terms & Definitions (#3.84, Page 17) is so vague that it is of no practical use to fire engineering designers, building managers or building users.

3. Comments: i) Clear Width of Door Openings

Paragraph #6.4.1, on Page 36 of BS 8300:2009 introduces a new understanding of ‘clear width’ for door openings, which is illustrated in Figure 11 (Page 37) … and also a new term ‘effective clear width’.

The new understanding of ‘clear width’ is a complete departure from the standard understanding, widely accepted throughout the world, which is shown in the bottom left hand drawing of Figure 11.

The new term ‘effective clear width’ will complicate the already difficult concept of ‘clear width’. Wasn’t the ‘clear width’ of a door opening always supposed to be ‘effective’, i.e. properly permit circulation for wheelchair users ?

However, the issue raised in the top right hand drawing of Figure 11 is valid …

Colour photograph showing the Final Fire Exit from a building (somewhere in Ireland). The 'clear width' of the door opening is seriously compromised - the door leaf cannot be fully opened and the panic bar reduces the 'clear width' still more. — Colour photograph showing the Final Fire Exit from a building (somewhere in Ireland). The ‘clear width’ of the door opening is seriously compromised – the door leaf cannot be fully opened and the panic bar reduces the ‘clear width’ still more. Click to enlarge.

Solution: Retain the current international/European/national understanding of ‘clear width’ for door openings in Ireland … but include text, with supporting drawings, in Revised Technical Guidance Documents B & M to ensure that there is no encroachment on that ‘clear width’ caused by protruding door leaf ironmongery or, more importantly, where the door leaf itself cannot be fully opened to 90^o-100^o.

4. Comments: i) Clear Width of Door Openings in Existing Buildings

Table 2, on Page 37 of BS 8300:2009, permits the ‘clear width’ for door openings in existing buildings to be reduced significantly below 800mm.

If buildings of historical, architectural and cultural importance are properly identified, and proper allowance is made for these specific building types in Revised Technical Guidance Documents B & M … there is no need to permit a general reduction in the ‘clear width’ for door openings in existing buildings.

Solution: Clearly indicate in the Revised Technical Guidance Document M that the last ‘Existing Buildings’ Column on the right of Table 2 in BS 8300 should be disregarded.

5. Comments: ii) Turning Circles for Occupied Wheelchairs

Down through the years, it has been just possible to communicate the concept of the ‘wheelchair turning circle’ to building designers and urban planners … whether it be the older 1.5m diameter circle or the newer 1.8m diameter circle.

The new Figures and Tables in Annexes C.3 and C.4 of BS 8300:2009 will be difficult to communicate … and may be a complication too far ?

6. Comments: iv) Fire Safety Issues

Colour photograph showing people trapped at the top of one of the WTC Towers. This Tower collapsed soon afterwards. Click to enlarge.

The Recommendations contained in the 2005 & 2008 National Institute of Standards & Technology (USA) Reports on the WTC 9-11 Incident in New York provide an invaluable and essential empirical basis for the practice of effective fire engineering design in today’s built environment.

The first of these two reports has special relevance for NSAI AASCC WG1 because the typical problems encountered by people with activity limitations during a ‘real’ building fire incident have been highlighted by NIST and closely investigated. As a result, three important fire engineering keywords have been re-stated with strong emphasis: ‘reality’ – ‘reliability’ – ‘redundancy’. And, a new key phrase in relation to way finding during evacuation has been introduced to the everyday practice of fire engineering design: ‘intuitive and obvious’.

The 2005 NIST Report, particularly, must be given proper consideration during the development of any reputable fire safety related standard or code of practice for the following reasons:

– at the time of the ‘real’ fire incident, approximately 8% of building users were people with disabilities, with 6% having mobility impairments ; [The percentage of ‘building users with activity limitations’ exceeded the 8% quoted above.]

– NIST found that the average surviving occupant in the buildings descended stairwells at about half the slowest speed previously measured for non-emergency/test evacuations. This raises a serious question over the use of standard movement times in fire engineering design calculations for evacuation ;

– NIST strongly recommended that fire-protected and structurally hardened lifts (elevators) should be installed in buildings to facilitate the evacuation of building users with disabilities, and to improve emergency response activities by providing timely emergency access to firefighters ; [In Ireland, building designers have already adopted this approach by constructing cores of reinforced concrete … even in the absence of European/national standards.]

– it was recommended that evacuation routes should have consistent layouts, and be ‘intuitive and obvious’ for all building users, including visitors who may be unfamiliar with the building, during evacuations ;

– NIST recommended that staircase capacity and stair discharge door widths should be adequate to accommodate contraflow in circulation spaces, i.e. the simultaneous emergency access by firefighters into a building and towards a fire, while building users are still moving away from the fire and evacuating the building. This has implications for the minimum clear width of all fire evacuation staircases. Wider staircases facilitate the assisted evacuation and rescue of people with disabilities.

No consideration was given in BS 9999:2008, however, to any of the Recommendations contained in the 2005 & 2008 NIST Reports … there is not even a mention of either Report in the Bibliography (Pages 423-429).

– For such an important national standard in Europe – BS 9999:2008 – there is no understanding demonstrated of the Fundamental Functional Requirement for Public Safety in Buildings …

Buildings shall remain structurally stable and serviceable …

1. while people are waiting in ‘Areas of Rescue Assistance’ ; and

2. until all of these people can be rescued by Firefighters and can reach a ‘Place of Safety’, which is remote from a fire building – with an assurance of individual health, safety & welfare for the people involved ;

– There is a reference to ‘normal movement times’ which are used to calculate evacuation times in Mobility-Impaired People (Paragraph #46.2, Page 247), even though it was found by NIST that the average surviving occupant in the WTC Towers descended stairwells at about half the slowest speed previously measured for non-emergency evacuations. In a ‘real’ fire incident, there is no such thing as ‘normal’ or ‘standard’ evacuation movement times, and the idea that any building must be clear of occupants within a very short timeframe, e.g. 2.5-3.5 minutes, is ludicrous ;

– In the sensitive area of the Resistance to Damage of Enclosing and Separating Partitions (Paragraph #21.2.5 on Page 101) surrounding Firefighting Shafts, it is still permissible in BS 9999:2008 to use non-robust construction, e.g. lightweight plasterboard. Fire-Induced Progressive Collapse is not discussed in the BS 9999 … and neither is Disproportionate Collapse, which is one of the functional requirements – A3 – in Part A of the Building Regulations for England & Wales (and Ireland !) ;

– Although in Wheelchair Users (Paragraph #46.3 on Page 247), it is stated …

‘It should be noted that it can take as many as four people to use an evacuation chair safely and effectively.’

… the dimensions for the minimum width of staircases in Width of Escape Stairs (Table 14 on Page 88) and Firefighting Stairs (Paragraph #21.3.2 on Page 106) disregard the guidance given on Page 247 … and ignore the minimum clear staircase width (1.5m) required to safely assist the evacuation of a person in a manual wheelchair …

Black and white photograph (US FEMA 2002) showing the correct way to assist the fire evacuation of a wheelchair user in an evacuation staircase ... one person at each side, with another person behind. — Black and white photograph (US FEMA 2002) showing the correct way to assist the fire evacuation of a wheelchair user in an evacuation staircase … one person at each side, with another person behind.

And … for some unexplained reason, handrails are permitted to intrude into the ‘clear width’ of a firefighting staircase in BS 9999:2008 (Paragraph #21.3.2, Page 106).

Please note well … this method (shown below) of assisting the evacuation of a person in a manual wheelchair is NOT correct. It is not possible to support any weight by holding the foot rests on a manual wheelchair, or by grasping the wheelchair by the front wheels …

Black & white sketch showing how definitely NOT to assist the fire evacuation of a wheelchair user in an evacuation staircase.

Manual handling of occupied wheelchairs in a fire evacuation staircase, even with adequate training for everyone directly and indirectly involved, is hazardous for the person in the wheelchair and those people – minimum three – giving assistance.

The weight of an average unoccupied powered wheelchair, alone, makes manual handling impractical. All lifts (elevators) in new buildings should, therefore, be capable of being used for evacuation in a fire situation. Lifts (elevators) in existing buildings, when being replaced or undergoing a major overhaul, should then be made capable of use for this purpose.

Contraflow Circulation, i.e. the simultaneous emergency access by firefighters into a building and towards a fire, while building users are still moving away from the fire and evacuating the building, has not been considered at all in BS 9999:2008.

A clear staircase width of 1.5m provides sufficient space for a mobile person to evacuate (700 mm) and a heavily protected and equipped firefighter to simultaneously move in the opposite direction (800 mm) …

Colour drawing, with photograph insets, showing the symbiotic relationship between Contraflow Circulation and Proper Assisted Evacuation in a building. Click to enlarge.

Human Behaviour in Fires should have been discussed in far more detail in BS 9999:2008 … but wasn’t. It is important for fire engineering designers to understand that the ‘real’ people who use ‘real’ buildings every day of every week, in all parts of the world, have widely differing ranges of human abilities and activity limitations … they are different from each other, and they will react differently in a fire emergency.

Building users need to be Skilled for Evacuation to a place, or places, of safety remote from a fire building. In the case of people with a mental or cognitive impairment, there is a particular need to encourage, foster and regularly practice the adaptive thinking which will be necessary during a ‘real’ fire evacuation.

Meaningful Consultation with every person known to occupy or use a building, for the purposes of receiving his/her active co-operation and obtaining his/her informed consent (involving a personal representative, if necessary), is an essential component of adequate pre-planning and preparation for a fire emergency.

Adequate Warning of a fire incident in a building should be communicated well in advance of the time when it is necessary to act and should continue for the full duration of the incident. Warnings should be informative, and easily assimilated in a form (e.g. oral, written, braille) and language understood by the people using the building.

Panic attacks, during evacuation in a ‘real’ fire incident, exist. The 2005 National Building Code of India refers extensively to this issue.

Solution: To resolve the technical inadequacies, inconsistencies and content gaps in BS 9999:2008 … it will be necessary to revise Technical Guidance Document B in Ireland. Fire safety, protection and evacuation from buildings for people with disabilities must be comprehensively included in the process of Fire Safety Certification.

7. Conclusions – BS 9999:2008 & BS 8300:2009

There are many gaps and conflicts between these two British Standards, principally because … they are two separate standards … drafted by two different Technical Committees within the British Standards Institution (BSI).

Because of its deviation from widely accepted concepts of accessibility and its tortuous use of terminology, BS 8003:2009 will have an adverse impact on the practice of Accessibility Design in Ireland … and has already complicated the development of the ISO Accessibility-for-All Standard (DIS ISO 21542).

Arrogance within BSI is not the only reason for such deviations. Distorting the European Union Single Market, for the purpose of introducing technical barriers to trade, is common in Britain … refer to the ‘deemed-to-satisfy’ status of the Approved Documents in the Building Regulations for England & Wales … and the Fire Protection Association’s ‘LPC Sprinkler Rules’.

Input from the Disability Sector during the drafting of BS 9999:2008 was not at all sufficient to ensure that there was a meaningful consideration of the problems encountered by people with activity limitations during a ‘real’ building fire incident. The necessary range of available and effective fire engineering solutions has not, therefore, been presented in the standard.

In addition … the complete and abject failure to consider the important Recommendations contained in the 2005 & 2008 National Institute of Standards & Technology (USA) Reports on the WTC 9-11 Incident in New York was an inexcusable and unforgivable technical oversight.

The result is a crassly inadequate, discriminatory and deeply flawed national fire safety standard in Great Britain & Northern Ireland. BS 9999:2008 became obsolete on the very day of its publication !

Postscript

Please refer to our 1999 Submission to the Department of the Environment & Local Government, in Dublin, concerning the use of British Standard BS 5588:Part 8 in Ireland …

http://www.sustainable-design.ie/arch/submissions.htm

Following this Submission, our understanding is that an ‘Internal’ Working Party was established within the Department. However, the Working Party never reported. No proper response to this Submission has ever been received from the Minister or the Department.

On 29th November 2006, similar and very polite comments were sent directly to the British Standards Institution (BSI) by e-mail. Receipt of this e-mail was never acknowledged by anyone in BSI.

The contents of the e-mail were ignored.

END

BER Certificates – A Proposal for What’s Next ! (VI)

Posted 2009-06-8 by CJ Walsh

2009-06-08: The other day, I received an impassioned e-mail … an extract …

” We are an energy rating company involved in a campaign for enforcement. Yesterday, we made a presentation to SEI (see attached). It was the result of a 2-month attempt to meet with the DEHLG and SEI. You are right in your article about them ‘not WANTING to know’.

My only question is: do you have any ideas on what’s next ? ”

The BER Gold Rush Soap Opera so far …

There are thousands of BER Assessors out there around the country … each having paid a ‘pretty penny’ for training, for exams, and for registration … and work on the ground is very scarce. A significant number of those Assessors have an inadequate understanding of building construction … while some of the people who are involved in providing Validated BER Training Courses are, to put it mildly, similarly unendowed.

Energy Ireland (SEI) is the Issuing Authority, but it has absolutely no experience as a Control Authority. And has anyone bothered to read the relevant Legal Disclaimer on the SEI WebSite ? It does, however, have a large marketing budget … those smarmy, wall-to-wall radio advertisements, which refer to the ‘property game’, continue to irritate my sensitive ear drums !

Apparently … 20% of BER Assessments are turning out to be faulty, i.e. they have not been properly carried out by Registered BER Assessors. In other words, 1 out of every 5 BER Certificates needs to be thrown in the paper recycling bin. Furthermore … I have discussed in one of my first posts how there is only a very tenuous relationship between a BER Certificate and the ‘real’ energy performance of a specific building. And in relation to ‘real’ buildings … there is a general non-compliance rate of 70% on Irish Building Sites with the minimal energy performance requirements in Part L of the Irish Building Regulations.

SEI’s Register of BER Assessors is unreliable.

What a magnificent waste of time, energy and money !

Some Comments on a Recent BER Certificate …

Sitting on the desk to the left of my computer keyboard is a recent Building Energy Rating (BER) Certificate and its accompanying Advisory Report … issued sometime during the second half of May 2009 … for a private, single-occupation dwelling house somewhere in Leinster … and using the DEAP Version 3.0.0 computer software. I do not wish to identify the specific Certificate.

This particular BER Certificate Documentation comprises:

– the actual BER Certificate ;

Can I be sure that the correct choices were made with regard to the software input information/data ? No.

– its accompanying BER Advisory Report.

Not missing any marketing trick, and in stark contrast to the actual BER Certificate … there is an Energy Ireland (SEI) Logo at the top of the first page of the Advisory Report … and an elaborate footer with SEI contact information on the last page.

Meanwhile, there is not one single mention of Statutory Instrument No. 666 of 2006: European Communities (Energy Performance of Buildings) Regulations 2006 anywhere in the Report … nothing to explain that SEI is the Issuing Authority for the purposes of this national legislation … or that there is such a thing as a BER Register … etc, etc, etc.

The Advisory Information provided in the Report is too vague to be useable … and there are silly typographical errors.

Did the BER Assessor request any information from the owner about the house ? It is impossible to tell whether he/she made any such request.

Am I assured that the BER Assessor had an adequate understanding of building construction ? Definitely not.

[ Specific comments about other issues might identify the actual BER Certificate. ]

What’s Next ?

The following remarks are directed at those BER Assessors, building owners, landlords, building professionals and general punters who do wish to spend their money on something worthwhile … something which has meaning, and is useful.

Energy Labelling of Buildings, just as in the case of other energy using/consuming industrial products … is positive and very worthwhile.

The legal basis established by European Union (EU) Directive 2002/91/EC of the European Parliament and of the Council, of 16 December 2002, on the Energy Performance of Buildings … is a good start.

I would much prefer if this Directive were linked in more directly to the Extensive Framework of the Construction Product Directive … EU Council Directive 89/106/EEC, of 21 December 1988, on the Approximation of Laws, Regulations and Administrative Provisions of the Member States relating to Construction Products. The reason that this has not already happened is because of a startling lack of horizontal integration between the different Directorates-General in the European Commission.

If there are problems with how the BER Legislation is operating at national level in Ireland, it is not the fault of Brussels or Directive 2002/91/EC … it is our problem … and it is up to us to remedy the situation.

There are 3 Immediate Priorities for Building Energy Rating in Ireland:

– increase accuracy ;

– reduce uncertainty ;

– improve reliability.

An Initial Proposal …

Without amending any legislation … and without reference to the Department of the Environment, Heritage & Local Government (DEHLG), Energy Ireland (SEI) and the Construction Industry Federation (CIF) … none of which have shown any proper leadership in relation to these issues, but seem interested only in playing games …

1. The BER Certificate

Attach a Single-Page Appendix to the actual BER Certificate which clearly shows the Input Information/Data selected by the Registered BER Assessor. Include a Statement of Measurement/Calculation Uncertainty concerning the Energy Rating Process … and a Statement of Competence in Building Construction, with the Assessor’s Signature … at the bottom of the page.

Show the Page Number on the Certificate as Page No.1 of 2 … and on the Appendix as Page No.2 of 2.

A BER Certificate should not be valid without this Appendix.

2. The Accompanying BER Advisory Report

Generally … tighten up the information provided in the Report, make it easier to understand … and make it more useable ! DO NOT TIE energy performance, or any other aspects of building performance, to the minimal – ‘abysmal’ – performance targets described in the guidance texts of Technical Guidance Documents A-M in the Irish Building Regulations. We have to aim much, much higher !! The European Union’s 2020 Climate Change Targets will be heavy going for Ireland, even if there is no agreement in Copenhagen at the end of 2009. And … insert Page Numbers !!!

Include Additional Components in the BER Advisory Report:

– Findings of a Formal Interview/Questionnaire Survey with the building owner, landlord or manager – some questions should have an open format ;

– Results of Infra-Red Thermography and Air Seepage Testing – discussed at length in previous posts ;

– Results of a Radon Test – as already discussed, an important indicator of Indoor Air Quality and whether or not there is adequate Ventilation in the building.

END

www.Recovery.gov … Pro-Active Political Accountability ?

Posted 2009-05-29 by CJ Walsh

2009-05-29: In Ireland, we are far too accepting and comfortable with our politicians, civil and public service employees, semi-state and qwango employees guarding all information … our information … as if their lives depended on it … and transforming any of our ‘Freedom of Information’ Requests into marathon obstacle courses which require a substantial entrance fee !

This is abnormal behaviour … and we cannot – must not – tolerate it any more !!!

Relax, chill-out … and please compare and contrast with …

http://www.recovery.gov/

… an Official United States Government WebSite which contains up-to-date information on how the American Recovery & Reinvestment Act (ARRA) of 2009 is working, including how funding is being distributed at federal, state, tribal and local levels … and (be sure to sit down for this !) … tools for people to hold the government accountable.

Established under Section 1526 of Division A (Appropriations Provisions), Title XV (Accountability & Transparency) of the American Recovery and Reinvestment Act of 2009, this WebSite has a precise job to do …

1. The website shall provide materials explaining what this Act means for citizens. The materials shall be easy to understand and regularly updated.

2. The website shall provide accountability information, including findings from audits, inspectors general, and the Government Accountability Office.

3. The website shall provide data on relevant economic, financial, grant, and contract information in user-friendly visual presentations to enhance public awareness of the use of covered funds.

4. The website shall provide detailed data on contracts awarded by the Federal Government that expend covered funds, including information about the competitiveness of the contracting process, information about the process that was used for the award of contracts, and for contracts over $500,000 a summary of the contract.

5. The website shall include printable reports on covered funds obligated by month to each State and congressional district.

6. The website shall provide a means for the public to give feedback on the performance of contracts that expend covered funds.

7. The website shall include detailed information on Federal Government contracts and grants that expend covered funds, to include the data elements required to comply with the Federal Funding Accountability and Transparency Act of 2006 (Public Law 109–282), allowing aggregate reporting on awards below $25,000 or to individuals, as prescribed by the Director of the Office of Management and Budget.

8. The website shall provide a link to estimates of the jobs sustained or created by the Act.

9. The website shall provide a link to information about announcements of grant competitions and solicitations for contracts to be awarded.

10. The website shall include appropriate links to other government websites with information concerning covered funds, including Federal agency and State websites.

11. The website shall include a plan from each Federal agency for using funds made available in this Act to the agency.

12. The website shall provide information on Federal allocations of formula grants and awards of competitive grants using covered funds.

13. The website shall provide information on Federal allocations of mandatory and other entitlement programs by State, county, or other appropriate geographical unit.

14. To the extent practical, the website shall provide, organized by the location of the job opportunities involved, links to and information about how to access job opportunities, including, if possible, links to or information about local employment agencies, job banks operated by State workforce agencies, the Department of Labor’s CareerOneStop website, State, local and other public agencies receiving Federal funding, and private firms contracted to perform work with Federal funding, in order to direct job seekers to job opportunities created by this Act.

15. The website shall be enhanced and updated as necessary to carry out the purposes of this subtitle.

On-line … the following boxed (and linked) texts can be viewed on every Page …

Accountability & Transparency

This is your money. You have a right to know where it’s going and how it’s being spent. Learn what steps we’re taking to conduct oversight of funds distributed under this law in order to prevent fraud, waste and abuse.

Fraud, Waste & Abuse

Large amounts of cash can attract fraud. Learn how to report any suspected waste and misuse of the recovery money.

Importantly … there also is a specific Page dealing with the Whistleblower Protection provided by Section 1553 of Division A (Appropriations Provisions), Title XV (Accountability & Transparency) of the ARRA. There is even information included about making a Whistleblower Reprisal Complaint !

Does this blow your mind … or does this blow your mind ?!?!

END

Institutions of National Governance – Criminally Dysfunctional ?

Posted 2009-05-28 by CJ Walsh

2009-05-28: A week can be a long time in Ireland … during this last seven days, in particular, a time of harrowing emotions … horror, shame, disbelief, anger, pain, embarrassment … and relief that the truth has finally been revealed …

On Wednesday, 20th May 2009, at 14.30 hrs … the Report of the Commission to Inquire into Child Abuse was published at a launch, before a select audience, in Dublin’s Conrad Hotel. Victims of that child abuse and representative groups were barred, with the support of Gardaí, from attending.

Has anything really changed ?

The Commission was established on 23rd May 2000 … under the 2000 Commission to Inquire into Child Abuse Act (No.7 of 2000) … and given three primary functions:

– to hear evidence of abuse from persons who allege they suffered abuse in childhood, in institutions, during the period from 1940 or earlier, to the present day ;

– to conduct an inquiry into abuse of children in institutions during that period and, where satisfied that abuse occurred, to determine the causes, nature, circumstances and extent of such abuse ; and

– to prepare and publish reports on the results of the inquiry and on its recommendations in relation to dealing with the effects of such abuse.

The Chairperson of the Commission, Mr. Justice Seán Ryan, is a judge of the High Court.

The full Ryan Commission Report can be downloaded here … www.childabusecommission.com/rpt/pdfs/

Although Commission Recommendation No.5 (Volume IV, Chapter 7, Paragraph 7.06) states …

Childcare policy should be child-centred. The needs of the child should be paramount.

The overall policy of childcare should respect the rights and dignity of the child and have as its primary focus their safe care and welfare. Services should be tailored to the developmental, educational and health needs of the particular child. Adults entrusted with the care of children must prioritise the wellbeing and protection of those children above personal, professional or institutional loyalty.

[ Why is this critical Recommendation only in position ‘5’ ? Concerning the rights and dignity of children, why is the word ‘should’ used instead of ‘must’ ? ]

… none of the 20 Commission Recommendations refer directly to the 1989 United Nations (OHCHR) Convention on the Rights of the Child, which became an International Legal Instrument on 2nd September 1990 … and which Ireland signed on 30th September 1990, and later ratified on 28th September 1992.

The Convention has not yet been fully incorporated into Irish National Law. Why not ?

In relation to Ireland, the UN (OHCHR) Committee on the Rights of the Child observed the following in late 2006 …

” … the Committee regrets that some of the concerns expressed and recommendations made have not yet been fully addressed, in particular those related to the status of the child as a rights-holder and the adoption of a child rights-based approach in policies and practices.”

Some Comments & Questions …

1. The Hierarchy of the Roman Catholic Church in Ireland (with the notable exception of Dublin Archbishop, Dr. Diarmuid Martin), the Catholic Religious Orders and the Catholic Church generally … have lost their moral authority … and all credibility. If child abuse was deeply in-grained and systemic in Ireland’s institutions … what was happening in institutions run by the 18(?) Irish Religious Congregations in other countries ? What assets have been transferred out of Ireland by the 18(?) Irish Religious Orders since the year 2000 ?

2. The Irish Government Ministry having jurisdiction … the Department of Education … has been clearly shown to be criminally dysfunctional. What radical changes in its organization, policies, practices and procedures will be put in place following the Ryan Commission Report ? We also ask the same question of the Department of Health & Children !

Perhaps Unnoticed … Another Institution …

Reported in an article on Page 4 of The Irish Times (2009-05-21) … on the same day that the Commission to Inquire into Child Abuse published its findings … 20th May 2009 … the family of a six-year-old girl, Sarah Jinks, who died in a fire on 10th January 1999 at a local authority house in Sligo, secured €115,000 in settlement of their High Court Action alleging that Sligo County Council had negligently failed to maintain a safe electrical system in the house. During the Action, Sarah’s mother, Ms. Philomena Jinks, had claimed that the Council failed to respond with sufficient thoroughness to complaints about dangers in the house.

The ‘Real’ Institution Involved …

Let me place in the public domain some revealing background to a series of fatal fires at a local authority housing estate on the far side of the country from Sligo … and a Letter, dated 22nd September 2005, which we were forced to write to Bray Town Council, in County Wicklow …

Colour photograph showing the scene after a fire in a terraced house at Oldcourt Housing Estate, Bray, Co. Wicklow. Click to enlarge. Photograph taken by CJ Walsh. 2005-08-18.

Mr. Seán O’Neill,

Town Engineer,

Comhairle Baile Bhré,

Civic Offices,

Main Street,

Bray,

Co. Wicklow.

Re: Fire Safety Survey of Oldcourt Estate, Bray.

Mr. O’Neill,

In good faith, we submitted a Tender Proposal (copy enclosed with the original letter) for a Fire Safety Survey of the Oldcourt Housing Estate to you. As of today, we have had no communication, written or oral, from Bray Town Council.

We fully understood the critical need for this to be an authoritative, competent, comprehensive and entirely independent Fire Safety Survey. Our principal concern was that this must be shown to be so, especially to local residents. We remain uniquely qualified, in Ireland and Europe, to complete the special and unique task involved.

It was with complete shock, dismay and alarm, however, that we saw our Organization actually named in Media Reports of discussions which took place at the September Council Meeting in Bray.

As a matter of public record, we now wish to clarify a few issues …

1. We commenced our work on the basis that the Tender Documentation issued by Bray Town Council was unreliable. This we were only able to do because of our extensive experience with Local Authority Housing, and the ‘ways’ and ‘means’ of Local Authorities in Ireland.

2. The Department of the Environment, Heritage & Local Government (DEHLG) has been intimately involved – at every level – with the planning, costing, design and construction of Local Authority Housing in every part of Ireland – from our direct experience, since the mid-1980’s. The Department is, therefore, very far from being a Disinterested Party in the serious matters under examination at the Oldcourt Housing Estate. It was extraordinary to see a representative of the DEHLG on the Interview Panel.

3. The Members of the Tender Interview Panel may have been ‘experts’, but we are not sure in which field. They showed little interest in our extensive practical experience of the complex area of fire engineering and its dynamic interaction with other aspects of performance in buildings and the built environment. It was necessary to explain some fundamental facts about the limited safety objectives of the Building Regulations to one Member. Some of the working methods necessary to effectively complete the Fire Safety Survey, of which we have direct and extensive experience, were unknown to all Members. It was clear that the Panels Members did not fully read our Tender Proposal.

4. At one stage in the Tender Interview, it was strongly ‘suggested’ to us that the Survey was to be a purely technical exercise, with no involvement whatever by the residents. At approximately the ‘two-thirds’ stage in the short interview, we realized that there was some ‘agenda’ in the background. We did not, therefore, make any final comments to the Panel.

We must now conclude that the Tender Process, organized by Bray Town Council, for a Fire Safety Survey of the Oldcourt Housing Estate appears to be corrupt. With deep regret, we hereby withdraw our Tender Proposal.

We require a full explanation as to why we have received no communication from you, or anybody else associated with Bray Town Council. We demand a full apology from the Council, and this must be published widely in the local and national media.

We are consulting with our legal advisors.

Signed: C. J. Walsh, Chief Technical Officer, FireOx International.

Copy: Ms. Deirdre deBurca, Chairperson, Bray Town Council.

[ No response has ever been received to this letter … from any party. ]

And … we have not forgotten the deep corruption which went to the core of the Tribunal of Inquiry into the Stardust Fire Disaster.

END

Part B – Careless Disregard for Firefighter Safety ?

Posted 2009-05-15 by CJ Walsh

2009-05-15: Firefighters have two functions:

– fighting fires ; and

– rescuing people who are trapped in buildings, or for some reason, cannot independently evacuate a building which is on fire.

Compare for a moment, therefore, Part B5 in the Irish Building Regulations …

B5 Access & Facilities for the Fire Service

A building shall be so designed and constructed that there is adequate provision for access for fire appliances and such other facilities as may be reasonably required to assist the fire service in the protection of life and property.

… with Essential Requirement 2 of the European Union (EU) Construction Products Directive 89/106/EEC …

2. Safety in Case of Fire

The construction works must be designed and built in such a way that in the event of an outbreak of fire:

– the load-bearing capacity of the construction can be assumed for a specific period of time ;

– the generation and spread of fire and smoke within the works are limited ;

– the spread of the fire to neighbouring construction works is limited ;

– occupants can leave the works or be rescued by other means ;

– the safety of rescue teams is taken into consideration.

Can you spot the difference ? Go to the last indent in Essential Requirement 2.

There is a complete and careless disregard for Firefighter Safety in the Irish Building Regulations … it isn’t even mentioned. And forget about any references to ‘firefighter safety’ in the guidance text of Technical Guidance Document B … there are none.

In July 2003 … the results of a U.S. Firefighter Disorientation Study, examining firefighter fatalities in the years 1979-2001, were released. This important Study was prepared by Captain William R. Mora of the San Antonio Fire Department in Texas.

Firefighter Disorientation – loss of direction due to the lack of vision in a building fire – is one of the oldest, least understood and deadliest hazards of firefighting inside a building. And according to the U.S. National Institute of Occupational Safety & Health (NIOSH) … disorientation usually precedes firefighter fatality.

Capt. Mora’s Study focused on 17 building fires in which disorientation played a major part in 23 firefighter fatalities.

In the cases studied, the typical Disorientation Sequence was as follows:

A fire in an enclosed building with smoke showing occurs. The arriving fire services immediately initiate an aggressive interior attack to search for the source of the fire. During the search, the source cannot be located and conditions deteriorate with the production of heat, smoke and prolonged zero visibility. As firefighters perform an emergency evacuation due to deteriorating conditions, hoseline separation occurs or tangled hoselines are encountered. Disorientation then occurs as firefighters exceed their air supply, are caught in flashovers or backdrafts, or are trapped by a collapsing floor or roof. When a firefighter is not located quickly enough, the outcome is a fatality or serious injury. The disorientation sequence usually unfolds in a building that does not have a sprinkler system or one that is inoperable.

The 17 Buildings displayed a wide range of architectural features … including differences in size, height and type of construction. In 100% of the fire incidents, however, the buildings had an ‘enclosed’ design with very few windows or doors (necessary for prompt ventilation and emergency evacuation by firefighters) in relation to the size of the building. They also included basements.

This ‘enclosed’ form was the result of Architectural Design or alteration after construction was completed. When owners altered a building, pre-existing windows or doors were closed up using materials such as plywood sheeting or brickwork.

Another Issue … a Fundamental Principle of Fire Engineering Design … after the WTC 9-11 Incident in New York … is to always ensure the provision of Alternative, Safe & ‘Intuitive’ Evacuation Routes for ALL building users.

Fully understanding the different functions of firefighters … and giving proper consideration to their safety … why aren’t Alternative, Safe and ‘Intuitive’ Fire Attack Routes for Firefighters provided, as the norm, in buildings ?

What is ‘Intuitive and Obvious’ Design for Fire Evacuation, anyway ?

Are Architects and Fire Engineers given any education or training about …

– Visuo-Spatial Learning ?

– Proprioception ?

– Cognitive Psychology ?

END

PEEPS – Fundamentally Flawed & Discriminatory ?

Posted 2009-05-13 by CJ Walsh

2009-05-13: The other day, I thought it might be interesting to google ‘PEEPS’. The surprising results … page after page about the marshmallow candies (in English: sweets) which are sold in Canada and the USA. I have learned something new !

What I was trying to find, however, was information relating to Personal Emergency Egress PlanS (PEEPS) for building users with disabilities. PEEPS is widely referenced in British literature … and because certain people (who should know better) believe that the sun, moon and stars rise over London … it has also seeped into the Irish literature by some process of ‘preverted’ osmosis. Most regrettable !

Yesterday, I discussed the inadequacy of developing Fire Safety Management Procedures … or, in fact, designing buildings … with the sole concern being people with disabilities.

Taking account of all the relevant, and different, types of European and National Legislation … the Rule of Thumb should always be People with Activity Limitations and Accessibility for All.

While fully understanding the need for a catchy acronym … ‘PEEPS’ does not respond well to internet searches on Google.

The next unfortunate feature of Personal Emergency Egress PlanS is the misguided use of Fire Engineering Terminology in English …

Evacuation from a Fire Building

To withdraw, or cause to withdraw, all users from a fire building in planned and orderly phased movements to a Place of Safety remote from the building.

Egress

Independent emergence of user(s) from a building, under normal ambient conditions, and removal from its immediate vicinity.

Escape

Avoidance of injury or harm which is threatened by imminent danger.

Instrumental Aggression

Aggression which is a means to another end, e.g. pushing someone aside to escape from danger.

Whenever, therefore, the terms ‘evacuation’, ‘egress’ and ‘escape’ are used interchangeably … on the same occasion … and without apparent rhyme or reason … it is time to call a halt to proceedings … and to scream “bullshit – moráns at work” ! Furthermore … the word ‘escape’ should never be used in connection with fire evacuation from a building. BSI, CEN and ISO … please take careful note !!!

A Personal Emergency Egress Plan (PEEP) is fundamentally flawed and discriminatory because it is …

– person-specific ; and

– location-specific.

Would any able-bodied building user tolerate being told that a document would have to be prepared before he/she could enter and use a building … and that this document would discuss only his/her use of the building … and that use only in specified parts of the building ??? No way ! Are you serious !! What a joke !!!

The relevant, and different, types of European and Irish National Legislation require that buildings be accessible … covering approach to, entry, use, egress (under normal conditions), evacuation (in the event of a fire emergency) and removal from their immediate vicinity.

Within this legal environment … PEEPS is fundamentally flawed. And … because building use is limited for specified individuals to specified areas only … PEEPS is also discriminatory.

If there is to be recourse to PEEPS, it should be in very exceptional circumstances only ! And, I can certainly think of one possible situation … existing buildings of historical, architectural and cultural importance … where anything more than moderate interference with the building fabric is both ill-advised and restricted … and everyone’s use of the building must be curtailed to some extent.

END

People with Activity Limitations (2001 WHO ICF) ?

Posted 2009-05-12 by CJ Walsh

2009-05-12: Or … in French: Personnes à Performances Réduites … a term which should be used much more often !

For many decades, the language of ‘disability’ has been all over the place, to put it mildly … others might suggest, however, that it lacks coherence, and is fragmented and chaotic ! As a result, it has been difficult to make any sort of solid progress on harmonization … at a technical level … in Europe.

Adopted on the 22nd May 2001, the World Health Organization’s International Classification of Functioning, Disability & Health (ICF), changed that situation for the better. It is important to emphasise that the ICF is a classification of ‘Health’ … not of ‘Disability’.

People with Activity Limitations (English) /

Personnes à Performances Réduites (French):

Those people, of all ages, who are unable to perform, independently and without aid, basic human activities or tasks – because of a health condition or physical/mental/cognitive/psychological impairment of a permanent or temporary nature.

This term includes …

– wheelchair users ;

– people who experience difficulty in walking, with or without aid, e.g. stick, crutch, calliper or walking frame ;

– frail, older people ;

– the very young (people under the age of 5 years) ;

– people who suffer from arthritis, asthma, or a heart condition ;

– the visually and/or hearing impaired ;

– people who have a cognitive impairment disorder, including dementia, amnesia, brain injury, or delirium ;

– women in the later stages of pregnancy ;

– people impaired following the use of alcohol, other ‘social’ drugs, e.g. cocaine and heroin, and some medicines, e.g. psychotropic drugs ;

– people who suffer any partial or complete loss of language related abilities, i.e. aphasia ;

– people impaired following exposure to environmental pollution and/or irresponsible human activity ;

and

– people who experience a panic attack in a fire situation or other emergency ;

– people, including firefighters, who suffer incapacitation as a result of exposure, during a fire, to poisonous or toxic substances, and/or elevated temperatures.

Anosognosia:

A neurological disorder marked by the inability of a person to recognize that he/she has an activity limitation or a health condition.

What is the big deal here ?

Because of the stigma which still attaches to ‘disability’ … and because some people are unable to recognise that they have an activity limitation or a health condition … depending on self-declaration, alone, for the purposes of developing suitable Fire Safety Management Procedures in a building (of any type) is a recipe for certain failure of those procedures.

And … of very direct relevance to design practice generally … compare the weak and inadequate definition of people with disabilities in Part M4 of the Irish Building Regulations (there is no reason to suspect that there will be an earth shattering improvement to this definition in the Revised Technical Guidance Document M … whenever it eventually sees the light of day !) … with the definition of disability in Irish Equality Legislation.

Chalk and Cheese ! Or … from the ridiculous to the sublime ! Check it out for yourself.

The consequence of this remarkable difference in definitions for anyone involved in the design and/or construction of a building is that … while they might very well be satisfying the Functional Requirements of Parts M and B in the Building Regulations … they will, more than likely, be still leaving the owner and the person who controls or manages the new building open to a complaint under our Equality Legislation.

In the case of Workplaces … truly brave is the person who will design a ‘place of work’ just to meet the minimal performance requirements of Building Regulations !

As a Rule of Thumb, therefore … architects, engineers, facility managers, construction organizations, etc, etc … should become more comfortable working with the concept of People with Activity Limitations.

This practical Rule of Thumb is also what lies behind the concept of Maximum Credible User Scenario, i.e. building user conditions which are severe, but reasonable to anticipate …

– the number of people using a building may increase, on occasions which cannot be specified, to 120% of calculated maximum building capacity ; and

– 10% of people using the building (occupants, visitors and other users) may have an impairment (visual or hearing, physical function, mental, cognitive or psychological, with some impairments not being identifiable, e.g. in the case of anosognosia).

[ Please note well … that miserable piece of legislation … or, bureaucrats’ charter .. the 2005 Disability Act (Number 14 of 2005) … is irrelevant to the above discussion. But … when Irish Politicians, Senior Civil Servants and the National Disability Authority begin to take seriously the 2006 United Nations Charter on the Rights of Persons with Disabilities … the 2005 Act will have to be scrapped altogether and/or dramatically re-drafted ! ]

END

BER Certificates & ‘Big Brother’ – 1984 Style ? (V)

Posted 2009-04-14 by CJ Walsh

2009-04-14: ‘Big Brother’ has arrived on our doorsteps … not in the style of today’s reality television … but in the George Orwell 1984 style of a generation ago … when 1984 used to be far into the distant future.

I wasn’t quite sure, but I thought that some readers … avid followers of Ireland’s BER Soap Opera … might be interested in the contents of a certain Important Notice Regarding BER Certificates (on official headed notepaper) … with the name of Mr. Steven Manek MIAVI, Partner, Douglas Newman Good (estate agents) at the bottom of the page … and dated March 2009 … which was circulated to DNG’s client vendors …

” We have now been advised by the Irish Auctioneers and Valuers Institute (IAVI) to contact all our vendor clients and advise them that an officer from one of the local authorities has started visiting estate agents’ offices in the greater Dublin area to inspect BER certificates for properties currently for sale/rent.

The IAVI have further advised us that if a certificate is not available the inspector is currently allowing a short grace period for provision of a certificate (even though there is no legal reason for them to do so). If a certificate is not available within that time frame there is a risk of prosecution thereafter as it is a legal requirement to provide a BER certificate. The maximum fine for a vendor under the legislation is €5,000.

In view of this we wish to formally notify you of your legal obligations and recommend that you obtain a BER certificate for your property as soon as possible.

The energy rating of a property must be carried out by a trained and registered SEI Building Energy Rating Assessor (BER Assessor). We have a panel of assessors that can undertake this certification for you and should you wish us to handle this for you please do not hesitate to contact me.”

Like too many other people … Steven does not seem to have taken the time to read the actual legislation. Or, maybe he has … which is worse … whatever !

The clear intention of this nasty piece of DNG propaganda, however, is to scare the living daylights out of their own client vendors … and to drive them, like lost little sheep into the long spindly arms of their own in-house BER Assessors.

Hold onto your liathróidí folks !

END

Barcelona Accessibility Conference – European Issues ?

Posted 2009-03-24 by CJ Walsh

2009-03-24: Permit me, first of all, to vigorously reclaim the word ‘accessibility’ back from the Transport Sector. This important conference in Barcelona was not about transport networks or distances from the nearest transportation node … but about Accessibility of the Human Environment for People with Activity Limitations (2001 WHO ICF), i.e. Accessibility-for-All.

A 2-Day Conference organized by EuCAN – the European Concept for Accessibility Network co-ordinated from Luxembourg – it was held in the TRYP APOLO Hotel (Av. Paral-lel, 57-59), on the 19-20th March 2009 … an impressive start-up event for the next EuCAN Project … a publication elaborating the business opportunities being created by Design-for-All for manufacturers and service providers across Europe.

I was very pleased to make a presentation on the exciting business potential of Accessible Fire Engineering … a subset of Sustainable Fire Engineering …

Colour image showing the Title Page (only) of CJ Walsh's Presentation: 'Accessible Fire Engineering', at the recent 2-Day EuCAN Conference in Barcelona, Spain. Held on 19-20th March, 2009. — Colour image showing the Title Page (only) of CJ Walsh’s Presentation: ‘Accessible Fire Engineering’, at the recent 2-Day EuCAN Conference in Barcelona, Spain. Held on 19-20th March, 2009. Click to enlarge.

There were, however, some developments at the conference which should be brought to wider public attention for consideration and discussion … here in Ireland, but also in other European countries …

Colour photograph showing the West/'Passion' Elevation of the Templo Expiatorio de la Sagrada Familia in Barcelona, Spain. An architectural wonder designed by Catalan Architect, Antoni Gaudí i Cornet (1852-1926), and still under construction. Click to enlarge. Photograph taken by CJ Walsh. 2009-03-20. — Colour photograph showing the West/’Passion’ Elevation of the Templo Expiatorio de la Sagrada Familia in Barcelona, Spain. An architectural wonder designed by Catalan Architect, Antoni Gaudí i Cornet (1852-1926), and still under construction. Click to enlarge. Photograph taken by CJ Walsh. 2009-03-20.

1. News was announced at the conference that the Proposed International Accessibility-for-All Standard (at present ISO CD 21542.3) has been overwhelmingly supported (mid-March 2009) for progress to the Draft International Standard (DIS) stage in its development. If everything goes well, we should see this International Standard being published sometime during the first half of 2010.

The ISO Accessibility-for-All Standard, which will be an essential implementation tool for Articles 9 & 11 of the 2006 United Nations Convention on the Rights of Persons with Disabilities in relation to Buildings, is particularly important for 2 Reasons:

– ‘Fire Safety’ Texts are now included in the Main Body of the Standard ;

– ‘Fire Evacuation’ is fully integrated into the definition and meaning of ‘Accessibility’.

Colour photograph showing the Interior of the Templo Expiatorio de la Sagrada Familia in Barcelona, Spain. Current state of progress with the Nave. An architectural wonder designed by Catalan Architect, Antoni Gaudí i Cornet (1852-1926), and still under construction. Click to enlarge. Photograph taken by CJ Walsh. 2009-03-20.

2. A conversation during the conference morning coffee break, on Friday 20th March, with Bojana Rudić and Miodrag Počuč of the Centar Živeti Uspravno in Serbia, has finally convinced me that all of the various Accessibility Design Philosophies …

– design-for-all (some attempts have been made to develop 6 Principles for this rather vague philosophy) … used by EU Institutions, and more widely throughout Europe in reaction to universal design ;

– universal design (with its 7 Principles/Commandments) … preached from the USA … but in Japan, for example, a more practical application can be seen. Strangest of all is the relatively recent establishment in Ireland of the Centre for Universal Design, within the lumbering qwango that is the National Disability Authority (NDA) ;

– inclusive design (with its 5 Principles) … originating from Great Britain ;

– barrier-free design (a philosophy long out of date) … still widely referred to in Germany and other parts of Central Europe ;

– facilitation design (a newer philosophy based on 2 WHO ICF Terms: ‘Facilitator’ and ‘Environmental Factors’ and intended to update barrier-free design) … not yet well known ;

… are not only causing enormous confusion about accessibility among the ‘un-initiated’ and architectural students, to take just two examples … but are diverting scarce resources away from the process of ‘real’ accessibility implementation.

In some cases, devotion to these philosophies is so consuming that I have experienced, first-hand, a general tendency to discourage any talk about rights … with some prominent members of the International Accessibility Community (who shall remain nameless !) not even bothering to read the actual text of the 2006 UN Disability Rights Convention !

Colour photograph showing a General View, from within, of the 1929 Barcelona Pavilion - a Master Statement of Modern Architecture - designed by German Architect, Ludwig Mies van der Rohe (1886-1969). De-constructed in early 1930 after the Barcelona International Exposition, it was constructed again in 1986. Click to enlarge. Photograph taken by CJ Walsh. 2009-03-20. — Colour photograph showing a General View, from within, of the 1929 Barcelona Pavilion – a Master Statement of Modern Architecture – designed by German Architect, Ludwig Mies van der Rohe (1886-1969). De-constructed in early 1930 after the Barcelona International Exposition, it was constructed again in 1986. Click to enlarge. Photograph taken by CJ Walsh. 2009-03-20.

3. Concerning the development of a European Accessibility Business Strategy …

– 2006 UN Convention on the Rights of Persons with Disabilities

Yes … Accessibility-for-All is about much more than making life and living easier for people with disabilities. Children, frail older people (not all older people !), women in the later stages of pregnancy, people who have a health condition, etc., all now need to be included in a more Person-Centred Approach to the design and sustainable transformation of our Human Environment. This is absolutely essential.

But … the 2006 UN Convention must be used as a Product & Service Checklist which covers the basic, i.e. minimum, responsible needs of people with disabilities … a sizeable social group in all of our societies. Failure to complete this simple task is a fundamental strategic error !

The 2006 UN Convention on the Rights of Persons with Disabilities is also their sole route of access to the human and social rights set down in the 1948 Universal Declaration of Human Rights.

– Integration of Accessibility-for-All Performance

Building Accessibility, to take a specific example, is now more complex … and includes …

– Approach to the building from the site boundary ;

– Entry through principal entrance(s) ;

– Health, Safety, Convenience & Comfort In Use, including thermal and acoustic comfort, good indoor air quality, protection from fire, etc ;

– Egress under normal conditions ;

– Evacuation in the Event of a Fire, or other emergency ;

– Removal from the vicinity of the building back to the site boundary ;

and …

– Each stage of a Work Process, at every level, in places of work ;

– Use of Electronic, Information & Communication Technologies (EICT’s) – at minimum, those permanently fixed in/to the building ;

and …

– Management, Services & Attitudes of People in the organization using the building ;

– Recruitment, Employment, Promotion & Training Practices within the same organization.

Performance in all of these different, and up until now separate, components must be brought together and properly integrated.

– Accessibility-related Products

In Ireland, we suffer from an over-supply of British manufactured accessibility-related products which are badly-designed and inadequately tested … or not tested at all. Inability to show compliance with Part D of the Irish Building Regulations is a big issue … that is, if those manufacturers even realize that we have our own separate building legislation over here.

By the way, failure to be able to show compliance with Regulation 7 of the Building Regulations for England & Wales is an issue across the water as well !

The situation isn’t much better in the rest of Europe. Yes … the quality of design is much, much better, but there is still enormous confusion about CE Marking.

Accessibility-related Products are still, and always have been, industrial products which are being placed on the Single European Market. Normal rules apply !

– Accessibility-related Services

Hopefully, we will soon see the demise of the Access Consultant … a plentiful species, particularly in Great Britain … an individual who only deals with ‘approach to’, ‘entry’ and ‘use’ of a building or facility … and nothing about ‘fire evacuation’. Their days are slowly numbered !

The rest of us, however, need to familiarize ourselves with necessary new services …

– Accessibility Impact Assessment ;

– Accessibility Performance Indicators ;

– Accessibility Benchmarking, Target Setting and Progress Evaluation ;

– Independent Accessibility Verification ;

– Etc.

Accessibility-related Services must be dragged out of prehistoric caves … screaming, if necessary. Services must become much more professional !

END

Ar C.J. Walsh Technical Blog – Registered Architect, Fire Engineer & Independent Technical/Building Controller …… International Expert on Accessibility for All (including Fire Safety) + 'Real' Sustainability Implementation !

national law

BER Certificates – A Proposal for What’s Next ! (VI)

www.Recovery.gov … Pro-Active Political Accountability ?

Part B – Careless Disregard for Firefighter Safety ?

BER Certificates & ‘Big Brother’ – 1984 Style ? (V)

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