national law

‘Areas of Rescue Assistance’ in Buildings – More Bytes ?

2009-03-17:  Pull closer to the screen … we can lower the sound level, and be honest with ourselves for a few minutes …

 

We have enabling legislation spewing out of our ears in the European Union on the subject of ‘fire safety, protection and evacuation for all’ … there is absolutely no shortage whatsoever !

 

The problem is that far too many fire officers (prevention and operations) and building control officers in local authorities, architects, engineers and quantity surveyors do not know and/or do not care about this issue.

 

Rates of compliance with legislation are very low.  Proper compliance is such a rare thing … that you would almost feel like holding a party, in celebration, right there on the spot when it’s discovered !   This applies not only to Ireland and Great Britain … but to the rest of Europe as well.

 

And while many countries have already signed and ratified the 2006 United Nations Convention on the Rights of Persons with Disabilities, which became an International Legal Instrument on 3rd May 2008 … and many more will do likewise during the course of the next year or two, including the United States of America (according to the Whitehouse WebSite !) … I am sure that few individuals in those countries have any understanding of Article 11 (text quoted in an earlier post).

 

 

Accessible Fire Engineering:

On that fateful morning of 11th September, 2001 … at the World Trade Center Complex in Lower Manhattan, New York City … we witnessed a catastrophic failure in common practices and procedures … at all levels …

         Architectural / Conventional (‘Ambient’) Engineering / Fire Engineering ;

         Building Management ;

         Emergency Responders / Firefighters / Rescue Teams ;

         Control Organizations Having Authority (AHJ’s) or Jurisdiction ;

         Fire Safety Objectives in Building Legislation, Codes & Standards.

 

This was a ‘real’ fire incident.  It has been very, very closely examined in the intervening years.  Disability was a major issue at the heart of the tragedy … 6% of WTC building occupants were people with mobility impairments … approximately 8%, in total, were people with disabilities.  The overall number of People with Activity Limitations (2001 WHO ICF), however, was higher.

 

It is for this reason that three vital WTC Components have neatly dovetailed and fused … to realize an essential rational and empirical basis for a transformed fire engineering approach which can deal effectively with ‘fire safety, protection and evacuation for all’ of the people who use buildings … Accessible Fire Engineering … a subset of Sustainable Fire Engineering …

 

1.  2005 NIST(USA) NCSTAR 1 Final Report on 9-11 WTC 1 & 2 Tower Collapses. 

 

2.  2008 NIST NCSTAR 1A Final Report on 9-11 WTC 7 Collapse.

 

3.  Ongoing NYC-ATSDR World Trade Center Health Registry (established 2002).

 

 

Further Information about ‘fire safety, protection and evacuation for all’, the NIST 9-11 Reports and the WTC Health Registry … is available at the FireOx International WebSite

 

www.fireox-international.eu

 

 

 

Picking up, therefore, where I left off a few days ago …

 

 

An ‘Area of Rescue Assistance’ in a Building should:

         adjoin every fire evacuation staircase in a building ;

         be located on every floor (note: fire evacuation routes at ground level should lead directly to the exterior) ;

         include adequate space for the people in wheelchairs, and their assistants, people using crutches, people with visual impairments, etc., who may be expected to use the area of rescue assistance during a fire emergency ;

         have good lighting at all times (note: lighting activation/de-activation by motion detection, for reasons of energy efficiency, should not be used in an area of rescue assistance) ;

         be clearly indicated with good signage ;

         be fitted with an accessible and reliable communication system placed at a height of 900 – 1 200 mm above finished floor level, facilitating direct contact with a person in the main fire and security control centre for the building ;

         be of sufficient size for the storage of a sufficient number of (powered) evacuation chairs, portable fire extinguishers, a fire hose reel and a manual fire alarm call point, a fire evacuation supply kit containing, for example, smoke hoods, suitable gloves to protect a person’s hands from debris when pushing his/her manual wheelchair, patch kits to repair flat tyres, and extra batteries for powered wheelchairs, etc.

 

 

The Size of an Area of Rescue Assistance should:

         relate to expected local usage during a fire emergency.  When the number of people using/occupying/working in/visiting a specific building is considered … calculate how many may have to wait there, if the lifts/elevators cannot be used for evacuation and/or fire safety management procedures fail.

 

For example, if there are only two fire evacuation staircases on a floor in a building (on opposite sides of the building, of course), each area of rescue assistance should be designed to cater for the expected needs of the full floor.

 

Please also see the end of my Post: ‘U.S. Disability Statistics – EU Practical Application ?’, dated 2009-02-25.

 

 

Evacuation Chairs should be capable of:

         being safely and easily handled ;

         carrying people of large weight (up to 150 kg) ;

         going down staircases, which may be narrow and of unusual shape, particularly in existing buildings ;

         travelling long distances horizontally and externally, perhaps over rough ground, in order to reach a ‘place of safety’.

 

When it is necessary to go up an evacuation staircase to reach ground level … for example, from a basement or underground shopping centre … Powered Fire Evacuation Chairs should always be provided.

 

 

A ‘Reliable’ Buddy System:

In buildings with a reasonably stable user profile, e.g. workplaces, a Buddy System should be introduced throughout the building user population.  For reliability and flexibility, e.g. to accommodate absence or holiday leave, a buddy system should always comprise at least 3 or 4 people.

 

In the case of a person using a wheelchair, his/her Buddy Unit should never be less than 4 people …

 

Black and white photograph showing the correct technique for assisting the evacuation of a person who uses a wheelchair. U.S. Fire Administration 'Orientation Manual for First Responders on the Evacuation of People with Disabilities'. FA-235/August 2002.
Black and white photograph showing the correct technique for assisting the evacuation of a person who uses a wheelchair. U.S. Fire Administration ‘Orientation Manual for First Responders on the Evacuation of People with Disabilities’. FA-235/August 2002.

 

Fire Safety Management Procedures:

Prior to putting any Management Procedures into operation … and certainly before carving any of these procedures in stone … meaningful consultation should take place with building users and local fire authorities … which, particularly in the case of people with activity limitations, will produce the desired outcome of informed consent.

 

Informed Consent …

Consent freely obtained – without threats or improper inducements – after appropriate disclosure to a person of relevant, adequate and easily assimilated information in a form (e.g. oral, written, braille) and language understood by that person.

 

Personal Representative …

A person charged, under European Union or EU Member State national law, with the duty of representing another person’s interests in any specified respect, or of exercising specified rights on that person’s behalf – and including the parent or legal guardian of a child, i.e. a person under the age of 18 years, unless otherwise provided for by European Union or EU Member State national law.

 

 

Without wishing to be obscure, or to avoid the issue … Fire Safety Management Procedures need to be developed to suit each specific building, with its own building user population.

 

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‘112’ – A Single European Emergency Phone Number ??

2009-03-16:  Wherever you are in the European Union (EU) … and whatever you are doing … there is just one phone number that you need to remember for emergency services – ‘112’.

 

Now that Bulgaria has set up its own 112 Hotline, the single EU Emergency Phone Number works in All EU Member States, without exception …

 

Check out your country … here !

 

 

When you call ‘112’, – from a land line, a public pay phone or a mobile/cell/handy phone – a local operator will either deal with your call directly, or redirect you to the emergency service you need – ambulance, police, or the fire services.

 

There is no charge for a ‘112’ Phone Call.

 

The single EU Emergency Phone Number does not replace existing national emergency phone numbers – it works alongside them.

 

Did you know that this number has been around for almost 20 years … and still only 22% of Europeans know about it ?

 

 

However, one small little problem remains … you can only call this number … that is, if you are physically capable of making a call and having a phone conversation !

 

Article 9 of the 2006 United Nations Convention on the Rights of Persons with Disabilities (text quoted in an earlier post !), which became an International Legal Instrument on 3rd May 2008, requires that the …

 

EU ‘112’ Emergency Phone Number System SHALL be ACCESSIBLE !

 

Get your fingers out Brussels !!!

 

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UPDATE 2013-04-06:   In the interim … there has been no dramatic improvement …

 

Flash EuroBarometer 368 – February 2013 – Summary Report

 

The European Emergency Number ‘112’

Click the Link above to read/download PDF File (1.4 MB)

 

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Fire Evacuation of People with Disabilities – Reality Bites ?

2009-03-10:   Regarding Seán’s Comment, dated 2009-03-06.

 

Yes, the guidance provided in Technical Guidance Document B (Ireland) is inadequate … and the same can equally be said of Approved Document B (England & Wales).

 

And yes, you will find only partial answers in British Standard BS 9999, even though it was only published on 31st October 2008 last.

 

Access Consultants in Ireland and Great Britain rarely deal with any matters relating to fire safety in buildings.

 

 

 

Please allow me, therefore, to fill in some gaps for you.  The following guidance is suitable for application in any European country …

 

People with Activity Limitations (2001 WHO ICF) experience many difficulties when attempting to independently evacuate a fire building.  However, our reasoning is very simple.  If we can get things right for the most vulnerable building users, we get them right for everyone else also.

 

 

The Target Destination … whether evacuation is independent, assisted by other building users or accomplished by means of firefighter rescue … is a ‘Place of Safety’.  This term is not well defined in legislation or codes.

 

Building User ‘Place of Safety’:

Any location beyond a perimeter which is [100] metres from the fire building or a distance of [10] times the height of such building, whichever is the greater … and … where necessary and effective medical care and attention can be provided, or organized, within one hour of injury … and … where people can be identified.

 

Where there is a Risk of Explosion … multiply the numbers in square brackets above by 4 (at least !).

 

 

 

All Fire Evacuation Routes – inside and outside a building – should comply with Accessibility Design Criteria.  This is an entirely alien concept to many Fire Prevention Officers in Local Authorities, and Fire Consultants !

 

Panic Attacks, during evacuation in a ‘real’ fire incident, exist.

 

Standard Movement Times, during evacuation in a ‘real’ fire incident, do not exist.

 

 

 

People should be able to reach an ‘Area of Rescue Assistance’ inside a building with ease.  In practice, few people understand what the word ‘refuge’ means (as in … refuge point, refuge area, area of refuge, etc).  As a result, these spaces are regularly misused and/or abused in buildings.  And there is great difficulty translating a word into other languages which, in English, can have so many meanings.  In Italian fire safety legislation, for example, ‘refuge’ has been translated as ‘spazio calmo’.  How crazy is that ?

 

So … what is an ‘Area of Rescue Assistance’ ?

A building space directly adjoining, and visible from, a main vertical evacuation route – robustly and reliably protected from heat, smoke and flame during and after a fire – where people may temporarily wait with confidence for further information, instructions, and/or rescue assistance, without obstructing or interfering with the evacuation travel of other building users.

 

 

This is a notional Area of Rescue Assistance …

 

A Clear Evacuation Width of 1.5 metres on the Evacuation Staircase facilitates ‘contraflow’ in a fire emergency (shown on the lower flight of stairs), i.e. emergency access by firefighters entering a building and moving towards a fire, while building users are moving away from the fire and evacuating the building … as well as allowing sufficient space to safely carry an occupied wheelchair down the staircase (shown on the upper flight of stairs).

 

Drawing showing a notional Area of Rescue Assistance in a Building. Click to enlarge. Based on a design by CJ Walsh. Drawn by S Ginnerup, Denmark.
Drawing showing a notional Area of Rescue Assistance in a Building. Click to enlarge. Based on a design by CJ Walsh. Drawn by S Ginnerup, Denmark.

 

 

Evacuation Skills & Self-Protection from Fire in Buildings …

A ‘skill’ is the ability of a person – resulting from adequate training and regular practice – to carry out complex, well-organized patterns of behaviour efficiently and adaptively, in order to achieve some end or goal.

 

Building users should be skilled for evacuation to a ‘place of safety’, and test/drill/non-emergency evacuations should be carried out sufficiently often to equip building users with that skill.  Consideration should be given to practicing evacuation once every month or, at most, every two months; once a year is inadequate.  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 incident.

 

Since Fire Protection Measures and Human Management Systems are never 100% reliable … it is necessary for frail older people and building users with disabilities to be familiar with necessary guidelines for self-protection in the event of a fire emergency.

 

 

Assisted Evacuation & Rescue Techniques …

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.

 

People with disabilities are participating more and more, and in ever increasing numbers, in mainstream society.  It is necessary, particularly for firefighters, to become skilled in how best to rescue a person with a disability from a building, using procedures and equipment which will not cause further harm or injury to that person.

 

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.

 

Generally … Powered Wheelchairs are too heavy for manual handling in any situation.

 

For these reasons, all lifts/elevators in new buildings should be capable of being used for fire evacuation.  Lifts/elevators in existing buildings, when being replaced or undergoing major overhaul, should then be made capable of being used for fire evacuation.

 

Local Fire Authorities should ensure that they possess the necessary equipment to rescue people with a wide range of impairments, and that specialized rescue equipment is regularly serviced and maintained.  Every Fire Authority should have an ‘accessible’ and ‘reliable’ Emergency Call System which is available, at all times, to the public within its functional area.

 

It is essential that every Firefighter is fully aware of this important public safety issue, and is regularly trained in the necessary rescue procedures involving people with a wide range of impairments.

 

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BER Certificates & Poor Indoor Air Quality (III)

2009-02-27:  Energy Labelling of Industrial Products is an essential means of raising consumer awareness about energy efficiency and conservation.  I like being able to wander into an electrical shop anywhere in Ireland, Italy or Turkey, for example … and to compare the energy performance of different makes of washing machines, dishwashers or fridges … and even of apparently similar products in the different countries.

 

I can easily visualize these small industrial products being brought into a test laboratory, and then being put through their paces.  It is a credible system.

 

This is NOT possible, however, with a building.

 

 

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 short document of 7 Pages.  Its Preamble takes up slightly more than the first 2 Pages, and there is a 1 Page Annex at the rear.  Its language is clear and straightforward (see the example of Article 4 below).

 

[What I fail to understand is how and why the Irish National Legislation which implements the Directive … Statutory Instrument No. 666 of 2006: European Communities (Energy Performance of Buildings) Regulations 2006 … is so clumsy, awkward and full of flaws … offering us yet another example of failed ‘light-touch regulation’.  It may also be unconstitutional.]

 

 

 

The EU Directive has something important to say about Indoor Air Quality

 

Article 4 – Setting of Energy Performance Requirements

 

1. Member States shall take the necessary measures to ensure that minimum energy performance requirements for buildings are set, based on the methodology referred to in Article 3.  When setting requirements, Member States may differentiate between new and existing buildings and different categories of buildings.  These requirements shall take account of general indoor climate conditions, in order to avoid possible negative effects such as inadequate ventilation, as well as local conditions and the designated function and the age of the building.

 

[Quick flashback to a generation ago … the panic, throughout Europe, to conserve energy in the late 1970’s and early 1980’s led to a dramatic reduction in rates and quantities of direct, natural ventilation to the habitable spaces of buildings.  This, in turn, had an adverse impact on Indoor Air Quality, and led to a sharp rise in Asthma among building occupants.]

 

 

 

In Ireland, today, problems concerning Poor Indoor Air Quality continue to occur … typically during the Winter Heating Season.  There is a natural tendency to keep windows closed and to seal permanent ventilation openings.  Accidental indoor air seepage to the exterior is also being reduced in our newer building stock.

 

Poor Indoor Air Quality, an important factor in relation to building related ill-health (also known as ‘sick building syndrome’), can cause serious health impairments and severely restrict a person’s participation in everyday activities, e.g. work.

 

Symptoms and Signs may include:

         irritation of eyes, nose and throat ;

         respiratory infections and cough ;

         voice hoarseness and wheezing ;

         asthma ;

         dry mucous membrane and skin ;

         erythema (reddening or inflammation of the skin) ;

         lethargy ;

         mental fatigue and poor concentration ;

         headache ;

         stress ;

         hypersensitivity reactions, i.e. allergies ;

         nausea and dizziness ;

         cancers.

 

 

 

The following 2 Performance Indicators of Good Indoor Air Quality, developed with the aim of protecting human health, are recommended:

 

         Carbon Dioxide (CO2) concentrations in a building should not significantly exceed average external levels – typically within the range of 300 to 500 parts per million – but should at no time exceed 800 parts per million ;

 

         Radon Activity (including Rn-222, Rn-220, RnD) in a building should, on average, fall within the range of 10 to 40 Bq/m3 … but should at no time exceed 60 Bq/m3.

 

 

NOTES:

 

The concept of Protecting Human Health is altogether different from the concept of Assessing Risk to Safety.

 

In Ireland, testing for Radon Activity in buildings must take place during the Heating Season, i.e. the months of November through to March.  What is the use of testing during July, for example, when windows will be wide open ?   Who would even think of doing that ?   I wonder.

 

Measurement Uncertainty of the standard Alpha Particle Etched-Track Detector distributed by the Radiological Protection Institute of Ireland (RPII) is as follows:

         under laboratory conditions: …………………… in the order of …… +/- 10%

         under tightly controlled site conditions: …. in the order of …… +/- 20%

         under typical conditions of use: …………….. well in excess of … +/- 30%

 

Unfortunately, until the RPII includes proper statements of Measurement Uncertainty in its Test Reports … our Organization cannot recommend RPII Radon Testing Services, and we will not accept RPII Test Reports as proper evidence of Radon Test Results.

 

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BER Certificates, Energy Efficiency & Climate Change (II)

2009-02-23:  The World Business Council for Sustainable Development (WBCSD) has identified buildings as one of the five main users of energy where ‘megatrends’ are needed to transform global energy efficiency in the immediate short term, and so meet the daunting challenge of Climate Change Adaptation.  They account for 40% of primary energy (primary energy includes the energy required to generate, transmit and distribute electricity, as well as energy directly consumed on site) in most developed countries, and consumption is rising. 

                         … 2007 WBCSD Energy Efficiency in Buildings (EEB) Project

 

 

If you find that you are not responding emotionally to that … please leave your computer immediately and take a cold shower !   When you return, check out how far adrift Ireland is – even on paper – in meeting its legally binding 1997 Kyoto Protocol (UNFCCC) responsibilities.  After 2012, the European Union’s 2020 Targets will be in a different league altogether.

 

Let there be do doubt, therefore, that over the next few years … nothing less than a complete cultural shift will be necessary throughout the European Construction Sector – and this very much includes Ireland – beginning with all research and design disciplines and extending right across to any person who works on a construction site or has any part to play in managing, maintaining or servicing a building.

 

 

 

Burden Sharing in the Built Environment

 

Separate Energy Efficiency Strategies will be required to vastly improve the energy performance of:

         existing buildings … onto which many energy efficiency measures can be successfully grafted … but they will not be cheap, and they will not be 100% effective ;

         buildings of historical, architectural or cultural importance … the integrity of which must be protected ;   and

         new buildings, which must therefore carry the major burden.

 

In addition … if we fully value the Agricultural Industry in Ireland, the burden to be carried by New Buildings may have to be far heavier.

 

 

 

Suggested Building Energy Efficiency Targets in Ireland to 2020

 

From the Beginning of 2012, i.e. after an Essential Transition Period involving extensive re-education and up-skilling, accompanied by ‘attractive’ incentives …

         Require all New Buildings to achieve a Minimum Building Energy Rating (BER) of ‘A1’ … indicating a Primary Energy Consumption less than or equal to 25 kWh/m2/yr.  And require 40% of Primary Energy Consumed to be, directly or indirectly, from Renewable Energy Sources ;

         Require all Existing Buildings to achieve a Minimum Building Energy Rating (BER) of ‘B1’ … indicating a Primary Energy Consumption less than or equal to 100 kWh/m2/yr.  And require 15% of Primary Energy Consumed to be, directly or indirectly, from Renewable Energy Sources.  Retain Incentive Measures to achieve better performance with regard to energy efficiency and/or renewable energies ;

         Require Buildings of Historical, Architectural or Cultural Importance to achieve a Minimum Building Energy Rating (BER) of ‘C1’ … indicating a Primary Energy Consumption less than or equal to 175 kWh/m2/yr.  Retain Incentive Measures to achieve better energy efficiency performance.  No legal requirements or incentives with regard to Renewable Energies should apply to Buildings of Historical, Architectural or Cultural Importance.

 

From the Beginning of 2015

         Require all New Buildings to be ‘Positive Energy Buildings’ (see below) ;

         Require all Existing Buildings to achieve a Minimum Building Energy Rating (BER) of ‘A2’ … indicating a Primary Energy Consumption less than or equal to 50 kWh/m2/yr.  And require a Positive Energy Contribution of 25 kWh/m2/yr to be from renewable Energy Systems installed in the building ;

         Require Buildings of Historical, Architectural or Cultural Importance to achieve  a Minimum Building Energy Rating (BER) of ‘B1’ … indicating a Primary Energy Consumption less than or equal to 100 kWh/m2/yr.  Retain Incentive Measures to achieve better energy efficiency performance.  No legal requirements or incentives with regard to Renewable Energies shall apply to Buildings of Historical, Architectural or Cultural Importance.

 

 

 

‘Effective’ Technical Control of Construction & Post-Occupation Buildings

 

Any proposed Building Energy Efficiency/Conservation and Renewable Energy Improvements must take place in a legal environment of stringent control during construction (by competent Local Authority Building Controllers and/or Independent Technical Controllers) and rigorous post-construction energy performance monitoring (using Long Wave Infra-Red Thermal Imagery, in conjunction with building roof and external wall Air Seepage Tests).  Observation of post-occupation building energy performance will also be necessary.  Introduce mandatory 5-Yearly Energy Surveying of Buildings.

 

 

 

The Paradigm for New Buildings – A ‘Positive Energy’ Return

 

Primary Energy Consumption is less than or equal to 15 kWh/m2/yr.  Renewable Energy & Heating Systems then contribute a reliable quantity of energy, per year, which covers the following:

         the Building’s Primary Energy Consumption ;

         an Energy Efficiency Degradation Factor which takes account of the degradation in energy efficiency normally expected during the life cycle of renewable energy and heating systems installed in the building (the rate of degradation will depend on the quality of maintenance and servicing) … and caused by wasteful patterns of building management and/or use ;

         the energy consumed by Private Transport associated with the building ;

         an Energy Return to an Intelligent District or Regional Grid exceeding, by a whole number multiple determined by reference to local conditions, the total energy consumed by the Building (including its Energy Efficiency Degradation Factor) and any associated Private Transport.

 

Uniquely, this more practical elaboration of the innovative concept of Positive Energy Buildings considers life cycle energy efficiency degradation.

 

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BER Certificates, Legislation & Thermal Comfort (I)

2009-02-20:  The recent comment submitted by Mr. Robin Evans regarding the use of Infra-Red Thermography as an aid to BER Assessment … and the high level of confusion and misinformation in the marketplace, which I have now had an opportunity to examine more closely … have forced me to conclude that a series of posts on BER Certificates would be good for the system – ‘my’ system !

 

There are many pieces in this jig-saw puzzle, but the final picture is wonderful … please believe me.

 

 

Before I start to assemble anything, however, a few small details …

 

         Infra-Red Thermography.  This is a valuable technical aid during any Energy Survey of any Building.  It is remarkable how much information can be gathered by a good, high-resolution Infra-Red Camera.  But, it must be used competently …  Because we are working in ambient temperature conditions, i.e. between -10OC and +30 OC, it should be a Long Wave Infra-Red Camera (≈ 8-12 microns).  The temperature difference between the inside of the building and the exterior should be at least 10 degrees C … it would be better with 15 degrees C.  The Camera Operator should be fully familiar with the operation of the Camera and its associated computer software, etc … and he/she should know what they are looking at.  In other words, some sort of architectural background is essential … not only are images taken outside the building, but they are also taken inside the building !   Any Camera Work should be done after dark.  It is not necessary to do a midnight to 4 o’clock in the morning shift … 8 o’clock in the evening until midnight is perfectly fine.  By the way, none of this work can be done in just 30 minutes.  Finally, Infra-Red Work is best carried out, in Ireland, during the Heating Season, i.e. the months of November through to March.  Depending on the year, it may be possible to squeeze in the end of October and the beginning of April.

 

In the old days, I used to work as part of a Multi-Disciplinary Team of 4 People (not all males !), comprising a Civil Engineer, a Physicist/Expert in Measurement, an Engineering Technician with a background in Social Science, and myself as Architect/Fire Engineer/Technical Controller.  They were great days !

 

 

Robin … in order to provide this service for the owner of a typical suburban, semi-detached house … €100 (Euros) is a little on the low side, even as a ‘lost leader’.

 

And … the Irish Public are indeed blissfully unaware of the efficacy of Infra-Red Thermography.  The ‘powers that be’ in Ireland, i.e. the Department of the Environment, Heritage & Local Government (DEHLG), Energy Ireland (SEI) and the Construction Industry Federation (CIF), are not at all interested in the ‘real’ energy performance of buildings.  They have a vested interest in not being interested.  Suddenly … the image of an ostrich, with head deeply embedded in sand, floods my mind …

 
Colour Clip Art Image of an Ostrich, with head deeply embedded in sand. Meanwhile, in the background, an hourglass signals that time is running out !
Colour Clip Art Image of an Ostrich, with head deeply embedded in sand. Meanwhile, in the background, an hourglass signals that time is running out !

  

         BER Certificates & EU/National Legislation.  Mr. Charlie McCreevy, Ireland’s EU Commissioner, during one of his many ‘direct, pragmatic and neo-liberal’ talks in Dublin, used the following magnificent phrase in relation to the national implementation of European Union Legislation in the different EU Member States … ‘National Gold Plating and Divergent Implementation’ … some important words to remember !   However, I learned this valuable lesson myself a long, long time ago.

 

Irish National Legislation:  Statutory Instrument No. 666 of 2006: European Communities (Energy Performance of Buildings) Regulations 2006.

 

These Regulations may be unconstitutional.  A prime example … Section 23 (1) states that a person authorised by Energy Ireland (SEI) under the Regulations … ‘may enter, inspect and examine a building or any part of a building for the purpose of forming an opinion as to whether or not a BER Data File or BER Certificate issued for the building, or part of the building, is warranted’.  In relation to a private, single-occupation dwelling house … this provision is entirely unacceptable !

 

The Register of BER Assessors on the SEI WebSite is not reliable.

 

Because of ‘national gold plating and divergent implementation’ in Ireland, it is necessary to be familiar, also, with the originating EU Secondary Legislation.

 

European Union Legislation:  EU Directive 2002/91/EC of the European Parliament and of the Council, of 16 December 2002, on the Energy Performance of Buildings.

 

Both pieces of legislation can be downloaded from the SDI WebSite … here.

 

 

         Thermal Comfort in Buildings.  The starting point for any discussion about this subject should be an International Standard, which is also the European Standard and the Irish National Standard … ISO 7730  Moderate Thermal Environments – Determination of the PMV and PPD Indices and Specification of the Conditions for Thermal Comfort.

 

This Standard establishes the following important general principle … and is also critical in relation to people with activity limitations who use/occupy/visit buildings: Man’s/Woman’s Thermal Sensation is mainly related to the thermal balance of his/her body as a whole.  This balance is influenced by his/her physical activity and clothing, as well as the environmental parameters: air temperature, mean radiant temperature, air velocity (i.e. draughts) and air humidity.

 

Air Temperature, alone, is definitely not an Indicator of Thermal Comfort in a building.

 

 

         Technical Control of Construction.  The 2005 & 2008 NIST Reports on the 9-11 WTC Incident have presented us with some stark language … ‘NIST urges state and local agencies to rigorously enforce building codes and standards since such enforcement is critical to ensure the expected level of safety … unless they are complied with, the best codes and standards cannot protect occupants, emergency responders, or buildings.’

 

With regard to Private Construction in Ireland … Building Control Authorities in Ireland are, purposefully, not sufficiently resourced to be ‘effective’.  See my earlier Post, dated 2009-02-12.

 

With regard to Public Construction in Ireland … self-regulation is no regulation !  Government Departments, the Office of Public Works and Local Authorities can, far too often, be complacent, careless and/or stubborn concerning compliance with even the minimal performance levels specified in building regulations, codes and standards.

 

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‘Accessible’ Emergency Services in Ireland ? … Action Now !

2009-02-17:  Mr. Joe Duffy, presenter of the popular phone-in RTÉ Radio 1 Programme: ‘Liveline (13.45-15.00 hrs. local time in Ireland), covered an item of major importance today … the complete lack, in our country, of ‘accessible’ emergency services for people with a hearing impairment (2001 WHO ICF).

 

To place this issue in a necessary wider context … back in December 2006, the United Nations adopted the Convention on the Rights of Persons with Disabilities.  After various procedural ‘jigs and reels’, the Convention became an International Legal Instrument on 3rd May 2008.  This is now International Law !

 

 

It is worth quoting from some of the UN Convention’s Text

 

Article 9 – Accessibility

1. To enable persons with disabilities to live independently and participate fully in all aspects of life, States Parties shall take appropriate measures to ensure to persons with disabilities access, on an equal basis with others, to the physical environment, to transportation, to information and communications, including information and communications technologies and systems, and to other facilities and services open or provided to the public, both in urban and in rural areas.  These measures, which shall include the identification and elimination of obstacles and barriers to accessibility, shall apply to, inter alia:

(a)  Buildings, roads, transportation and other indoor and outdoor facilities, including schools, housing, medical facilities and workplaces ;

(b)  Information, communications and other services, including electronic services and emergency services.

 

Article 11 – Situations of Risk & Humanitarian Emergencies

States Parties shall take, in accordance with their obligations under international law, including international humanitarian law and international human rights law, all necessary measures to ensure the protection and safety of persons with disabilities in situations of risk, including situations of armed conflict, humanitarian emergencies and the occurrence of natural disasters.

 

[Note: Article 11 covers risk situations such as … fires in buildings.]

 

 

Progress with regard to the continuing Ratification of this United Nations Convention can be viewed here.

 

Although Ireland signed the Convention on 30th March 2007, amidst much publicity, this country has still not ratified it.  Why is that ?   Other European Union Member States have ratified it without any problem.

 

Yet again, why haven’t the National Disability Authority … and particularly Ms. Angela Kerins, NDA & Equality Authority Chairperson – ‘valiant protector, against all odds and foes, of disability & equal rights’ … screamed and protested loudly about Ireland’s disgraceful tardy ratification of the UN Disability Convention ?   Did we even hear a whimper from them ?   Definitely not.

 

This is an issue where an essential leadership role must be taken up – enthusiastically – by our politicians and senior civil servants.  The correct signals must be given to society as a whole.

 

What Mr. Joe Duffy does not understand, unfortunately, is that Irish Politicians and Senior Civil Servants would all rather commit ritual suicide on Merrion Street (outside the Dáil and Government Buildings) than give people with disabilities their rights.

 

 

There is no longer any acceptable reason whatsoever … why ‘accessible’ emergency services cannot be introduced immediately in this country … or throughout the rest of Europe.

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Quality of Irish Construction – Unacceptable ?

2009-02-12:   So … Anglo-Irish Bank has been caught – finally – playing with numbers and cooking the books.  And … because of inadequate (i.e. a complete lack of effective) control by the National Financial Regulator, this was regarded as a routine, ‘smart’ transaction by privileged individuals.  “What is the problem ?” … they ask … “no laws were being broken”.

 

Holding firmly onto those thoughts, let us briefly turn our attention to the Construction Sector … and the Energy Performance of Buildings …

 

A new Home Energy Savings (HES) Scheme was recently announced by Mr. Eamon Ryan T.D., Minister of Communications, Energy & Natural Resources … €100 million Insulation Scheme to Benefit 50,000 Homes – Programme Will Create 4,000 Jobs … according to an article in The Irish Times, on Monday 9th February 2009, by Mr. Harry McGee.

 

Reading the Department of Energy’s own Press Release for the Scheme Launch, dated 2009-02-08 … it is evident that public relations consultants, marketing gurus, senior academics (who should know better) and civil servants were involved in producing ‘paper’ numbers to justify and support the miserable grants being offered in the HES Scheme.  Numbers were even presented for ‘Typical Net BER Improvement’ ?!?

 

When the Scheme is eventually up and running, Thermal Insulation Contractors will be required to comply with a voluntary Energy Ireland (SEI) ‘Contractors Code of Practice & Standards and Specifications Guidelines’ (version 1, 2009-02-03) … and SEI may or may not carry out control inspections in order to monitor the quality of their work.  Does all this sound familiar ?

 

 

But … are these paper energy numbers ‘real’ ?   If he thinks so, Mr. Eamon Ryan is living in Alice’s Wonderland !

 

This is a photograph, taken back in 2000, of expanded polystyrene insulation which was badly installed in an external cavity wall … very badly installed !   When the Irish Construction Industry would later enter extreme ‘over-heat’ mode, the quality of typical construction would deteriorate sharply.

 

Colour Photograph of an External Cavity Wall, showing 'Floating' Thermal Insulation (and, in the background, an Inclined Steel Wall Tie which will later facilitate water ingress). Click to enlarge. Photograph taken by CJ Walsh. 2000-01-19.
Colour Photograph of an External Cavity Wall, showing ‘Floating’ Thermal Insulation (and, in the background, an Inclined Steel Wall Tie which will later facilitate water ingress). Click to enlarge. Photograph taken by CJ Walsh. 2000-01-19.

Who can know what is happening inside that cavity when it is all finished and covered up from view ?   Nobody.  Unless, that is, you manage to take an Infra-Red Thermal Image during the next winter heating season – which is far too late to remedy the problem.

 

This is an example of an Infra-Red Thermal Image, taken back in 1998 …

 

Colour Image, with explanatory Text and Horizontal Temperature Bar below, showing the 'Real' Energy Performance of a Building. Click to enlarge. Project Architect: CJ Walsh. Image taken by sub-contractor in 1998.
Colour Image, with explanatory Text and Horizontal Temperature Bar below, showing the ‘Real’ Energy Performance of a Building. Click to enlarge. Project Architect: CJ Walsh. Image taken by sub-contractor in 1998.

 

 

Explaining the Current Context in Ireland …

 

It was 10 Years after the Dublin Stardust Fire Tragedy (February 1981) … before the first legal, National Building Regulations were introduced (December 1991); they became operational during the following summer of 1992.  Around the same time, Building Control Authorities were being established in every Local Authority.

 

Prior to this, legal Building Bye-Laws were operated in just a small number of our major urban centres.

 

Dublin Corporation’s Bye-Laws with respect to the Construction of Buildings, adopted by Dublin City Council on 27th June 1949, were an interesting mix of functional, performance and prescriptive requirements.  An Application, containing detailed construction information, for Building Bye-Law Approval had to be made for every construction project … and I mean ‘every’ project … prior to any construction commencing.  And, ‘every’ project was inspected at the foundation and drainage stages of construction … no exceptions.  The more complex projects were inspected as they progressed further, with special attention being paid, for example, to fire safety related construction.  I know, first-hand, that the surveyors and inspectors in Dublin Corporation’s (as it was then called) Building Control Section had built up a considerable wealth of knowledge and understanding about construction conditions and practices right around the city and suburbs.

 

Anyway … after the introduction of the National Building Regulations, an unwritten national policy was put into action … having as an aim the winding down, and general ‘castration’, of the large, well-established Building Control Sections in Dublin City and County, and Cork.  Meanwhile … in the rush to establish the new Building Control Authorities throughout the rest of the country, it was common to hear of Road Engineers being transferred into the new Control Authorities … usually having little or no experience in dealing with the construction of buildings.

 

Site Inspections under our current system of National Building Regulations are random.  Inspection Statistics produced by the Department of the Environment, Heritage & Local Government (DEHLG) are not reliable.  Building Control Authorities are, purposefully, not sufficiently resourced to be ‘effective’.

 

Commencement Notices, under the National Building Control Regulations, do not have to be accompanied by detailed construction information when being submitted to a Building Control Authority.

 

Fire Safety Certificates, under the National Building Control Regulations, do not involve any Site Inspections – at any stage – by Fire Authorities.

 

 

 

Some Conclusions …

 

The above is a rather long, but simplified, explanation as to why a large number of privileged property developers and shoddy building contractors have been allowed to flourish on Irish Construction Sites without ever understanding the concept of ‘effective’ technical control.  When they do eventually meet this concept, head-on, the level of their resentment can be without limit.

 

Before the recent property crash, did you ever try to present a builder with a Snag List on a new house ?

 

This will also put SEI’s 70% rate of non-compliance into an understandable context.  See my earlier Post, dated 2008-12-12.

 

With regard to BER Certificates … BER Assessors without any sort of architectural background are not competent to assess the construction of existing buildings … and those BER Assessors with an architectural background cannot possibly evaluate, with reliability, the construction of existing buildings without the use, for example, of Infra-Red Thermography and Air Seepage Testing.

 

BER Assessment of Historical Buildings is unsuitable, and not appropriate.

 

An Energy Survey of a Building is an entirely different concept to a BER Assessment.  See our Technical Guidance Note No.95/101(a).

 

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Dublin Stardust Fire Tragedy – The End ?

2009-02-05 (2021-08-04):  ‘In the early hours of the 14th February 1981, a catastrophic fire swept through the Stardust Ballroom in Artane, Dublin, killing forty eight people and causing serious injury to one hundred and twenty eight others.  The overwhelming majority of the victims were in the age group of eighteen to twenty five and came from the neighbouring areas of Artane, Kilmore and Greater Coolock.  The scale and horror of the tragedy was such that it was, and remains, the greatest disaster to have occurred in the history of the State.’

 

Paragraph 1.2, Report of the Independent Examination of the Stardust Victims Committee’s Case for a Reopened Inquiry into the Stardust Fire Disaster.

 

In the middle of January 2009, relatives of Stardust Disco Fire Victims were forced to hold a lengthy sit-in protest at Government Buildings, in Dublin … in order to gain access to this recent Report by Mr. Paul Coffey, Senior Counsel.  See the Photograph of four forlorn relatives, by Mr. Dara Mac Dónaill, on the Front Page of The Irish Times (2009-01-15).

 

 

In Paragraph 5.15(1) of the Report (no reference number, no publication date) … Mr. Coffey recommended:

 

         that the Government should consider whether it can … place on the public record an acknowledgement of the (Stardust) Tribunal’s findings that there is no evidence that the fire was started deliberately and that its cause is unknown ;

 

Paragraph 5.15(2) continued:

 

         in the event that this cannot be done, there should be a further inquiry … ;

 

 

On Tuesday evening, 3rd February 2009, in the Dáil (Irish Parliament) … the Irish Government moved, with haste, to formally correct the public record in accordance with Mr. Coffey’s recommendation in Paragraph 5.15(1).  See the Dáil Report on the Stardust Tragedy, by Ms. Marie O’Halloran, in The Irish Times (2009-02-04).

 

Should this be the end of the matter ?   No.

 

From the beginning, have the events surrounding this tragedy been well ‘managed’ ?   Yes.

 

 

 

In Separate Letters, dated 4th April 2006, sent by registered post to the Editors of The Irish Times (Dublin), The Irish Independent (Dublin) and The Irish Examiner (Cork), I wrote the following …

 

Re:  Stardust Fire Re-Examination Now Due !

 

As a young architect in private practice, I saw the Dublin Fire ‘Establishment’ disappear from public view, without trace, after the 1981 Stardust Fire;  it was almost impossible, for at least a year after, to have a meeting with a Fire Prevention Officer.

 

Would it not be reasonable to expect that, in 25 years, our understanding of fire behaviour in buildings, and of the practices and procedures associated with serious fire incidents, has improved ?

 

On 26th October 2005, the  NIST Final Report on the 9-11 WTC 1 & 2 Tower Collapses  was presented to Congress in the United States.  Chapter 9 of that Report contains 30 important Recommendations which must radically alter professional fire engineering practice in the case of all building types, of all sizes … even in Dublin, Ireland !

 

The time is now due for an Independent and Impartial Technical Re-Examination of the Stardust Fire Incident, and any relevant events which occurred during a period of time beginning 6 Months before 14th February 1981 and terminating approximately 18 Months after that day.

 

Such a Re-Examination must exclude any involvement by the Department of the Environment, Heritage and Local Government (DEHLG).

 

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

 

 

 

A Similar ‘Management’ Exercise is taking place in relation to the series of Fatal Fire Incidents at the Oldcourt Local Authority Housing Estate in Bray, County Wicklow, Ireland.

 

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