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 !
A few weeks ago … in a post dated 20 October 2010 … Japan in April & May 2010 – Accessibility-for-All ! … I discussed some of the many aspects which, together, facilitate a high level of quality in ‘real’, or actually realized, Built Environment Accessibility Performance in Japan … and I illustrated that quality with a number of photographs.
In time, I will add more photographs from my valuable ‘Accessibility in Japan’ Collection !
Note: Built Environment … Anywhere there is, or has been, a man-made or wrought (worked) intervention by humans in the natural environment, e.g. cities, towns, villages, rural settlements, roads, bridges, tunnels, transport systems, service utilities, and cultivated lands, lakes, rivers, coasts, seas, etc. … including the Virtual Environment.
Note: Social Environment … The complex network of real and virtual human interaction – at a communal or larger group level – which operates for reasons of tradition, culture, business, pleasure, information exchange, institutional organization, legal procedure, governance, human betterment, social progress and spiritual enlightenment, etc.
Note: Virtual Environment … A designed environment, electronically-generated from within the Built Environment, which may have the appearance, form, functionality and impact – to the person perceiving and actually experiencing it – of a real, imagined and/or utopian world.
However … many of these aspects are missing in European Approaches to Accessibility-for-All … and, typically, the level of Accessibility Performance which we are used to experiencing, and accepting, is inadequate, sloppy, poor … and to be direct and honest … BRUTAL !!
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As far back as 2001 … in an Introduction to a Page on our Corporate WebSite illustrating the Inaccessibility of European Union Institutional Buildings … specifically, the European Parliaments in Brussels and Strasbourg … I wrote …
‘ Many times each year, our work takes us to Brussels, Luxembourg and Strasbourg.
In spite of all the rhetoric from European politicians, and the extensive body of European legislation actually in force at national and regional levels in every Member State … the inaccessibility of Institutional Buildings is shockingly and unacceptably bad … in some cases, dangerously so !
Yet, these buildings should represent, in built form, the ideals, values and aspirations of the peoples of Europe – as expressed in the EU Treaties.
What a bitter disappointment ! ‘
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Today … France, in particular, continues to be a depressing experience … where Talk is far, far too cheap … and Good Accessibility Performance is still all too rare !!
Last Thursday, 25 November 2010 … I attended a Paris Meeting of the Editorial Team for the CIB W108 Report: ‘Sustainable Climate Change Adaptation in the Built Environment’. My airline flights from Dublin brought me in and out through Terminal 1 of Roissy Charles de Gaulle (CDG) Airport in Paris.
A spanking new automatically operated Métro (shuttle) … CDGVAL … connects Terminals 1, 2 & 3, various Multi-Storey Car Parks and Train Stations within the Airport Complex …
Colour image showing the Airport Complex Plan of Roissy Charles De Gaulle in Paris. Note the New CDGVAL Métro ... an important interconnecting transportation system. Click to enlarge.
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Colour photograph showing the new, automatically operated CDGVAL Métro at Roissy Charles De Gaulle Airport in Paris. Yet another magnificent example of Sloppy French Accessibility Implementation ! Photograph taken by CJ Walsh. 2010-11-26. Click to enlarge.
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IF … you search hard enough on the CDG Airport WebSite, you will find these three highlighted short sentences under content with the title ‘Personne à Mobilité Réduite’ … total rubbish and complete bullshit when you actually see the airport’s buildings and many facilities. And … as usual, in French, the disability-related terminology is evil … and sucks !
‘Aéroports de Paris assure l’assistance des passagers handicapés et à mobilité réduite dés leur arrivée, et tout au long de leur parcours dans le terminal.
Aéroports de Paris a depuis longtemps entamé une démarche d’équipement et d’adaptation de ses terminaux pour faciliter les déplacements de tous.
Aujourd’hui, les problématiques d’accessibilités sont systématiquement prises en compte dans l’aménagement de nos infrastructures.’
Colour photograph showing the Door Threshold Detail of the new, automatically operated CDGVAL Métro at Roissy Charles De Gaulle Airport in Paris. In totally new construction ... an unacceptably huge difference between platform height and the shuttle's floor ! This is also now a trip hazard for everyone !! Photograph taken by CJ Walsh. 2010-11-26. Click to enlarge.
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Why is this relevant for us now … here in Ireland ?
The new scheme of Disability Access Certification, closely modelled on the existing highly problematic scheme of Fire Safety Certification … is undergoing a normal, introductory ‘teething’ process within this jurisdiction … and many questions about interpretation of the law and its operation are being asked.
Important Clarification: The Guidance Text contained in Technical Guidance Document M … is not Law … is not Prescriptive Regulation … is not ‘Deemed to Satisfy’ … and … because the guidance is so incomplete, incoherent and inadequate … does not even indicate Minimum Accessibility Performance !
Part M Functional Requirements – Access for People with Disabilities Second Schedule of the 1997 Building Regulations – As Amended by the Building Regulations (Amendment) Regulations, 2000 – Statutory Instrument No.179 of 2000
Access and UseM1 Adequate provision shall be made to enable people with disabilities to safely and independently access and use a building.
Sanitary ConveniencesM2 If sanitary conveniences are provided in a building, adequate provision shall be made for people with disabilities.
Audience or Spectator FacilitiesM3 If a building contains fixed seating for audience or spectators, adequate provision shall be made for people with disabilities.
Definition for This PartM4 In this Part, ‘people with disabilities’ means people who have an impairment of hearing or sight or an impairment which limits their ability to walk, or which restricts them to a wheelchair.
Application of This PartM5 Part M does not apply to works in connection with extensions to and the material alterations of existing dwellings, provided that such works do not create a new dwelling.
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Today in Ireland … Talk IS too cheap … and Good Accessibility Performance IS almost non-existent !!! Yes … and that even includes the work of those mighty superheroes in the Office of Public Works (OPW).
Furthermore … the big fun will really start when the New Part M Requirements come into operation on 1 January 2012 … and we will enter a surreal Alice’s Wonderland of Accessibility Ambiguity …
Part M Functional Requirements – Access and Use Second Schedule of the 1997 Building Regulations – As Amended by the Building Regulations (Part M Amendment) Regulations, 2010 – Statutory Instrument No.513 of 2010
Access and UseM1 Adequate provision shall be made for people to access and use a building, its facilities and its environs.
Application of The PartM2 Adequate provision shall be made for people to approach and access an extension to a building.
M3 If sanitary facilities are provided in a building that is to be extended, adequate sanitary facilities shall be provided for people within the extension.
M4 Part M does not apply to works in connection with extensions to and material alterations of existing dwellings, provided that such works do not create anew dwelling.
On Tuesday last … 9 November 2010 … Ireland’s Office of the Ombudsman issued a Report to the Irish Oireachtas (the Dáil and Seanad) … in accordance with Section 6(7) of the 1980 Ombudsman Act … concerning an Investigation based on more than 1,000 individual complaints made, since 1985, on behalf of older people who were unable to get long-term nursing home care from their health boards … now the Health Service Executive (HSE).
Please Note Well … this Report is not just about Older People !
This document raises a number of very serious and fundamental issues concerning our current system of Dysfunctional National Governance in Ireland. Every Irish person should, therefore, expend a small bit of time and effort in making themselves familiar with these problems … especially in the run-up to any by-elections … or, perhaps, even a general election … and certainly before we enter a prolonged period of being hammered in a Draconian Series of 4 Budgets !
This Report places a major question mark over the positions of Ms. Mary Harney T.D., Minister for Health & Children (a woman of strong ‘Boston-esque’, neo-liberal and anti-social convictions) … and the Senior Civil Servants (plural !) in Her Department.
And don’t be fooled into thinking, either, that the Department of Health & Children is our only dysfunctional national ministry ! See my previous Posts.
Ms. Emily O’Reilly, Ireland’s Ombudsman, deserves our full support !
Click the Link Above to read and/or download PDF File (621kb)
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Conclusions (Executive Summary)
The conclusions of this investigation are easily stated:
The Health Act 1970 has required the State to provide nursing home care for those who need it.
It is an open question as to whether that obligation continues in place, notwithstanding recent amendments to the Health Act 1970.
The State has failed consistently to meet this obligation over four decades.
The State has failed over that same period, and despite repeated commitments (especially since 2001), to amend the law so as to bring actual practice and legal obligations into harmony.
Very many people over these decades have been deprived of their legal entitlement.
Access to nursing home care over this period has been marked by confusion, uncertainty, misinformation, inconsistency and inequity.
Very many people over this period have suffered significant adverse affect.
This situation has been allowed to continue with the full knowledge and consent of the responsible State agencies.
Arising from these failures, the State is now facing several hundred legal actions from, or on behalf of, people seeking compensation for the costs incurred in having to avail of private nursing home care.
These particular failures, which have been allowed to continue for decades, point inevitably to wider failures in government.
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The conduct of the investigation and the preparation of this report for the Oireachtas have been marked by an unprecedented level of rancour and disagreement.
The Department, in particular, has laid a multiplicity of charges against the Ombudsman regarding the manner in which the investigation has been conducted. Amongst its charges are:
that the Ombudsman exceeded her jurisdiction in undertaking this investigation ;
that the Ombudsman failed to abide by fair procedures particularly in relation to the provision of a draft version of the investigation report ;
that the Ombudsman displayed prejudice and objective bias in the course of the investigation ;
that the Ombudsman displayed arrogance in purporting to interpret the law ;
that the Ombudsman has purported to deny the State bodies concerned their right to have the litigation (detailed in this report) determined by the Courts.
The Minister, acting on behalf of the Government, has informed the Ombudsman that the Government supports the submission of her Department in which these charges are made. While the HSE, in general, has been more temperate, it has specifically charged the Ombudsman with attempting to influence the outcome of court proceedings. In effect, the Department and the HSE are saying that the Ombudsman undertook this investigation in bad faith.
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In fact, the Ombudsman’s motivation in producing this report was five-fold:
1. To highlight the very significant difficulties faced over several decades by families seeking to make arrangements for long-term nursing home care for a family member.
2. To represent, in many instances through their own words, the distress and upset (including financial) of people who complained to the Ombudsman’s Office over the years in relation to nursing home care.
3. To highlight the inadequacy and the tardiness of the State’s responses to these problems.
4. To raise the issue of whether and, if so how, people adversely affected should have some recognition of having been failed by the State.
5. To raise wider questions of governance prompted by the practices highlighted in this report.
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In the 2001 Report: ‘Nursing Home Subventions’, the then Ombudsman expressed the view that the issues of bad administration dealt with in that report reflected significant dysfunction in our system of government. That view could, with only minor contextual amendments, be reproduced in full here with the same validity as in 2001.
The then Ombudsman identified deficits in three sets of relationships which, in his view, contribute significantly to this dysfunction.
These relationships are:
The Relationship between the Oireachtas and the Executive – the Constitutional model whereby the Legislature makes the laws and the Executive implements them has become a fiction; in fact, it is the Executive (Government) ‘which decides policy; which proposes legislation and ensures its passage through the Oireachtas and, subsequently, in its executive capacity ensures that the laws are implemented’. Parliament is relatively powerless and not in a position to exercise the role (including that of calling the Executive to account) envisaged in the Constitution.
Relationships within the Executive – in the past, there was a clear division of functions as between the political (Ministerial) side and the official side. The integrity of the governmental process depended, to a large extent, on the official side being seen to be non-political; the tension inevitably generated by this division was regarded as necessary and healthy. “Good government”, as Professor Séamus Ó Cinnéide put it, “depended on a certain distance and balance between the two sides”. This distance and balance no longer applies and, again to quote Professor Ó Cinnéide, this change is part of “an unspoken revolution in our system of governance”. Again, another key element in the overall model of government has been discarded or, at the very least, diluted considerably.
Relationship between Department and Health Boards – similar to the relationships within the Executive, the relationship between the Department and the health boards is most effective where the latter are prepared to keep a certain distance from the former and to exercise, as necessary, their status as independent, statutory bodies. But the health boards, for the greater part, failed to act independently; to ‘a large extent, health boards appear to act in relation to the Department as if they are satellites rather than independent bodies […] The majority of the health boards were prepared to continue with a scheme, about which they increasingly had doubts, for as long as the Department told them they should.’
The present Ombudsman comments on these three areas from the perspective of today and concludes that, if anything, matters have disimproved rather than improved. In relation to the role of the Oireachtas, the Ombudsman observes that parliament has been sidelined and exercises only a limited role. Reflecting the views of many commentators, the Ombudsman observes that our governmental arrangements are undermined significantly by virtue of having an Executive which is too powerful and a Legislature which is too weak.
As regards relationships within the Executive, and taking the example of the Department of Health & Children, the Ombudsman observes that the distance between Ministers and senior civil servants – which was a necessary feature of our model of government – no longer exists. In the wider context of the health service, the Ombudsman draws attention to a continuing confusion as to the respective roles of the HSE and of the Department.
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Findings (Executive Summary)
The Ombudsman finds, in relation to the type of complaints dealt with in this investigation, that the health boards (HSE) failed to fulfil their obligations to older people under section 52 of the Health Act 1970 and that this failure came about with the full knowledge and agreement of the Department. As a result of these failures, very many older people (and their families) suffered significant adverse affect over several decades. The Ombudsman finds that these failures of the health boards (HSE) and of the Department constitute (to use the language of the Ombudsman Act) actions “based on an undesirable administrative practice” and also actions “contrary to fair or sound administration”. These findings are at a level of generality as this investigation is an ‘own initiative’ one rather than one linked to specific, named complainants.
The Ombudsman takes the view that the HSE and the Department should acknowledge formally that the State, in the case of older people needing long-term nursing home care, has not been meeting its obligations under section 52 of the Health Act 1970. This acknowledgment could be in the form of a public statement from the two bodies and could be made on a ‘without prejudice’ basis.
There is no satisfactory solution to the issue of whether there should be financial redress for those who have been adversely affected by the State’s failure to provide long-stay care. The financial consequences for the State, in meeting a recommendation to compensate all those adversely affected, would be enormous, potentially running to several billion euros. In present circumstances, it appears this is not a cost which the State can meet. Nor is it likely that the State will be in a position to meet this type of charge for many years to come. On the other hand, not to recommend financial redress, might be seen as condoning maladministration and allowing bad practice to go unchecked. It would also mean that individual people and their families are being left with nowhere to turn and with a financial burden to bear which, as the Ombudsman understands the law, should have been borne by the State.
With considerable reluctance, the Ombudsman takes the view that in present circumstances the public interest is best served in not recommending any specific redress in the sense of financial compensation for those affected adversely. The Ombudsman suggests that some thought be given within the Department to devising some limited scheme under which families which have suffered serious financial hardship might be assisted. One possibility, in this regard, is that the existing Supplementary Welfare Allowance scheme might provide the statutory mechanism for the making of one-off payments, based on exceptional need, for such people affected adversely by the State’s failure to provide nursing home care for a family member.
The Ombudsman feels it is vital that steps be taken to prevent situations, such as described in this report, coming about in the future; or, where they do come about, there should be mechanisms in place to deal with them at an early stage. The Ombudsman proposes that, in future, measures to deal with such instances should be conducted with full transparency and in the public domain. The Ombudsman proposes the creation of an independent group whose function would be to advise Government on how best to handle legal actions, or threatened legal actions, which involve numbers of people and which arise from a contended failure of a State agency to meet statutory obligations particularly in instances where those claimed to be affected belong to a vulnerable group in society. Past examples of situations where such an approach might have been helpful include:
– the army deafness claims ;
– the contaminated blood claims ;
– education rights of autistic children ;
– provision of secure care for children ; and
– the right of older people to long stay nursing home care.
This proposal is based on the premise that the State should react to such situations, not simply in legalistic terms, but in terms which have regard both to legal rights (including human rights), to the State’s finances and the overall public interest. The proposal envisages that, while ultimate legal responsibility for dealing with such claims will continue to rest with the State (and its relevant agency), the direction of the State’s response should have regard to the advice of this group. Amongst the options for this group would be that of stating a case to the High Court, perhaps at an early stage, in order to get legal clarity where that is needed. The overall thrust of this proposal is that the State’s response to situations of this kind should be speedy, be made at an early stage, and be based on considerations of fairness and the public good rather than, as tends to happen at present, being defensive, combative and legalistic.
Some thought might be given to the possibility of such a group acting as adviser to the Attorney General in fulfilling the role of guardian of the public interest or, alternatively, that this group would replace the Attorney General in fulfilling that role. In any case, there is certainly considerable scope for improving our governmental mechanisms with a view to ensuring that, where these major issues arise, they will be handled always with a view to securing the public interest.
It’s all happening here ! From trawling the depths of European Union (EU) Legislation in my last Post … to the heights of Attic Roof Spaces in Ireland … what a magnificent contrast !!
This Post has nothing to do with this law, or that law … or the proper technical control of these sorts of troubling situations. It has everything to do with a strong dose of ‘Reality’ … and the typical sorts of Serious Hazards which lurk quietly, unannounced and generally unheeded in most houses … houses which are occupied by ordinary, average people.
The following photographs could have been taken in almost any house, anywhere in the country ! These particular photographs, however, were taken during a House Inspection for a good friend, somewhere in County Wicklow, during May 2010 …
Colour photograph showing the typical clutter which can accumulate, over time, in an Attic Roof Space. Wait and see, however, what else is happening underneath and around this clutter. Smoke Detectors should always be fitted in these Spaces as a matter of routine. Also ... notice that this is a trussed timber roof. Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
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Colour photograph showing fire scorched thermal insulation. Careless Hot Works are a major cause of fires in ALL building types! Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
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Colour photograph showing that there is NO fire separation between this house and the neighbouring house at the junction between the party wall and the roof covering. And ... once fire enters this Attic Roof Space, those thin metal connecting plates in the roof trusses will rapidly lose strength, and the entire roof will then collapse. Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
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Colour photograph showing a very badly constructed party wall ... see the many gaps in the joints between the concrete blocks. Just because a wall is made of masonry ... do not, for a single moment, assume that it is either smoke resisting or sound resisting. Also ... notice the sloppy DIY electrics. Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
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Colour photograph showing, after I had pulled back a portion of thermal insulation, where the insulation had completely covered a downlighter. In other parts of this Attic Roof Space chipboard, to hold all of the clutter, covers the transformers as well. Downlighters need direct ventilation to facilitate the escape of heat. Also ... note the trap doorset is not fire and smoke resisting. Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
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Colour photograph showing thermal insulation packed tightly into the roof eaves ... choking off essential ventilation pathways. Thermal insulation was also placed under the water storage tanks ... exposing them to freezing external conditions during cold winter nights. Thick, multi-layered thermal insulation will also conceal the bottom horizontal members in all types of timber roof construction ... expect more fall accidents through ceilings in the future! Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
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There are simple Design and Construction Solutions to all of these problems … and Competent, Independent Technical Control over the works being carried out is absolutely essential.
BUT … Dysfunctional Government Departments and State Agencies are still … to this day … directly sponsoring and knowingly contributing to these hazardous situations in our homes !
2010-11-02: For a long, long time … too long … I have been bleating on about the major and substantial difference between Sustainable Design and Green Design … or ‘Sustainability’ and ‘Green-ness’. See my previous Posts.
This bores me no end !
HOWEVER … there are some serious implications if this difference is not properly understood … particularly by individuals, groups or organizations attempting to advance the Application of Criteria which address Social and/or Ethical Concerns within, for example, the European Union’s Public Procurement Framework … or the EU’s Construction Product Framework.
The following is a nice little example of exactly what I am talking about … explained by no less an authority than the Directorate General for Environment in the European Commission itself … on its very own Public Procurement WebPage at http://ec.europa.eu/environment/gpp/index_en.htm … as viewed, by me, on 2010-09-12 …
[ For a moment, let’s just overlook the simplistic and crude ‘three pillars’ understanding of Sustainable Development. See my previous Posts.]
Sustainable Public Procurement (SPP) … means that public authorities seek to achieve the appropriate balance between the three pillars of sustainable development – economic, social and environmental – when procuring goods, services or works at all stages of the project.
Green Public Procurement (GPP) … means that public authorities seek to procure goods, services and works with a reduced environmental impact throughout their life cycle compared to goods, services and works with the same primary function that would otherwise be procured.
Practical Differences Between SPP & GPP !
GPP is often more easily accommodated than SPP within the existing legal and practical framework of procurement. Green requirements can be included in technical or performance-based specifications for products, services and works. Provided the conditions set out in the ‘Helsinki Bus’ and ‘Wienstrom’ Cases, and Evropaïki Dynamiki vs. European Environment Agency (EEA) … are met, green award criteria can also be applied (further information on these cases is available at http://ec.europa.eu/environment/gpp/case_law_en.htm).
The application of Criteria aimed at addressing Social or Ethical Concerns can be more difficult in the context of regulated public procurement procedures. Public authorities are specifically empowered to include social requirements in their conditions for the performance of contracts or to reserve certain contracts for performance by sheltered workshops or employment programmes (Articles 26 and 19 of Directive 2004/18/EC respectively).
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My Note:DIRECTIVE 2004/18/EC of the European Parliament and of the Council, of 31 March 2004, on the co-ordination of procedures for the award of public works contracts, public supply contracts and public service contracts.
[ For another moment, let’s just overlook the unfortunate use of disability-related language … which fails, utterly, to take account of the 2001 World Health Organization’s International Classification of Functioning, Disability & Health (ICF). See my previous Posts.]
Article 19 – Reserved Contracts
Member States may reserve the right to participate in public contract award procedures to sheltered workshops or provide for such contracts to be performed in the context of sheltered employment programmes where most of the employees concerned are handicapped persons who, by reason of the nature or the seriousness of their disabilities, cannot carry on occupations under normal conditions.
The contract notice shall make reference to this provision.
Article 26 – Conditions for Performance of Contracts
Contracting authorities may lay down special conditions relating to the performance of a contract, provided that these are compatible with Community law and are indicated in the contract notice or in the specifications. The conditions governing the performance of a contract may, in particular, concern social and environmental considerations.
ANNEX VI – Definition of Certain Technical Specifications
For the purposes of this Directive:
1. (a) ‘technical specification’, in the case of public works contracts, means the totality of the technical prescriptions contained in particular in the tender documents, defining the characteristics required of a material, product or supply, which permits a material, a product or a supply to be described in a manner such that it fulfils the use for which it is intended by the contracting authority. These characteristics shall include levels of environmental performance, design for all requirements (including accessibility for disabled persons) and conformity assessment, performance, safety or dimensions, including the procedures concerning quality assurance, terminology, symbols, testing and test methods, packaging, marking and labelling and production processes and methods. They shall also include rules relating to design and costing, the test, inspection and acceptance conditions for works and methods or techniques of construction and all other technical conditions which the contracting authority is in a position to prescribe, under general or specific regulations, in relation to the finished works and to the materials or parts which they involve ;
(b) ‘technical specification’, in the case of public supply or service contracts, means a specification in a document defining the required characteristics of a product or a service, such as quality levels, environmental performance levels, design for all requirements (including accessibility for disabled persons) and conformity assessment, performance, use of the product, safety or dimensions, including requirements relevant to the product as regards the name under which the product is sold, terminology, symbols, testing and test methods, packaging, marking and labelling, user instructions, production processes and methods and conformity assessment procedures ;
2. ‘standard’ means a technical specification approved by a recognised standardising body for repeated or continuous application, compliance with which is not compulsory and which falls into one of the following categories:
– International Standard: a standard adopted by an international standards organisation and made available to the general public ;
– European Standard: a standard adopted by a European standards organisation and made available to the general public ;
– National Standard: a standard adopted by a national standards organisation and made available to the general public.
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In order for a Criterion … any Criterion … to be acceptable within the European Union’s Public Procurement Framework, it should be expressly linked to the subject matter of the Contract … should be specific … and should be capable of objective verification.
2010-10-20:In Europe … we are experts at talking about an Accessible Built Environment … and hopeless when it comes to effective implementation …
Built Environment: Anywhere there is, or has been, a man-made or wrought (worked) intervention by humans in the natural environment, e.g. cities, towns, villages, rural settlements, roads, bridges, tunnels, transport systems, service utilities, and cultivated lands, lakes, rivers, coasts, seas, etc. … including the Virtual Environment.
Virtual Environment: A designed environment, electronically-generated from within the Built Environment, which may have the appearance, form, functionality and impact – to the person perceiving and actually experiencing it – of a real, imagined and/or utopian world.
However, I would like to share not just one single moment in Japan, but a Series of Special Moments … where I was observing and studying, up close and personal, the ‘real’ implementation of Accessibility-for-All in Public Places … including some discrete detailing at the Main Gate to Kanazawa Castle … Ishikawa-mon.
When I say Accessibility-for-All … I mean Accessibility Design, with all of the rambling philosophical bullshit removed. The emphasis can then properly be placed on a high level of quality in Actual Accessibility Performance provided for users of the built environment … all users, because many of the details shown in the photographs below make movement in and around public places safer and more convenient for everybody.
Some of the many Aspects in Japan which, together, facilitate this high level of quality in Actual Accessibility Performance …
A robust legal base mandating the provision of Accessibility-for-All ;
Determined political will ;
Sufficient financial resources ;
A compassionate and understanding bureaucracy – at all levels in society ;
Competence, i.e. education, training and experience, of spatial planners, architects, engineers, quantity surveyors, etc … and members of construction organizations ;
Innovative, well-designed accessibility-related products which can be shown to be ‘fit for their intended use’.
Click the Link Above to read and/or download PDF File (82kb)
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Much of the Accessibility Detailing in Japan far exceeds, in quality of performance, what is described in the Proposed International Standards Organization (ISO) Accessibility-for-All Standard … to be published, hopefully(!), in 2011 … and here is a small taste …
Colour photograph showing Accessibility-for-All in Kyoto, Japan. Photograph taken by CJ Walsh. 2010-04-27. Click to enlarge.
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Colour photograph showing Accessibility-for-All in Kyoto, Japan. Photograph taken by CJ Walsh. 2010-04-27. Click to enlarge.
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Colour photograph showing Accessibility-for-All in Kyoto, Japan. Photograph taken by CJ Walsh. 2010-04-27. Click to enlarge.
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Colour photograph showing Accessibility-for-All in Kyoto, Japan. Photograph taken by CJ Walsh. 2010-04-27. Click to enlarge.
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It is important to link one activity/task/function with the next … (please ignore the awkward step up at the entrance to the train carriage … instead, look at the wonderful entrance detail in the next photograph below) …
Colour photograph showing Accessibility-for-All in Nara, Japan. Photograph taken by CJ Walsh. 2010-04-23. Click to enlarge.
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What a beauty !
Colour photograph showing Accessibility-for-All in Kyoto, Japan. Photograph taken by CJ Walsh. 2010-04-24. Click to enlarge.
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Common everywhere … a closer look at the information which can very easily be provided on all handrails …
Colour photograph showing Accessibility-for-All in Osafune, Japan. Photograph taken by CJ Walsh. 2010-04-21. Click to enlarge.
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The Main Gate to Kanazawa Castle … Ishikawa-mon …
Colour photograph showing Accessibility-for-All in Kanazawa, Japan. Photograph taken by CJ Walsh. 2010-04-27. Click to enlarge.
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Colour photograph showing Accessibility-for-All in Kanazawa, Japan. Photograph taken by CJ Walsh. 2010-04-27. Click to enlarge.
2010-06-06: This post has been running around in the back of my mind for quite some time … and I know now, for far too long ! But recently, my patience with certain manufacturers and suppliers of evacuation chair devices has reached its limit.
In relation to Building Users … previous posts have examined the technical term: Place of Safety (see the post dated 2009-10-24) … and why this concept is an essential starting point in the development of any practical … and comprehensive … fire engineering strategy for a building.
Previous posts have also explored the complex issue of Areas of Rescue Assistance in a building (see posts dated 2009-03-10 & 2009-03-17).
For the purposes of this discussion, now, a clear statement of Fire Engineering Design Objectives is required …
Evacuation for All Building Users … with an assurance of health, safety and welfare protection during the course of that evacuation.
Sustain Building Serviceability during Evacuation … at the very least, while people are waiting in Areas of Rescue Assistance … and, until all of those people can be rescued by Firefighters and can reach a Place of Safety.
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We are rapidly approaching the day when all lifts/elevators in a building must be capable of being used during the course of a fire incident. AND … these lifts/elevators must be situated so that … alternative, safe and intuitive means of evacuation … are effectively presented to all building users.
Greedy vested interests continue to impede the onset of that inevitable day.
Another surprising barrier to the implementation of this goal, however, is the sloppy and incompetent drafting of fire engineering design standards and codes of practice. Previous posts have discussed … and shown … some of the serious problems with British Standard BS 9999 – Code of Practice for Fire Safety in the Design, Management and Use of Buildings (2008).
A ‘Restricted’ Architectural Vocabulary is yet another barrier to implementation. High-Rise and/or Complex Buildings are still typically being designed for Access … not Evacuation ! This fault very definitely lies with the architectural and engineering schools throughout Europe.
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Until all lifts/elevators in a building are capable of being used during the course of a fire incident … there is an obvious and pressing need for a fire engineering design solution which involves the installation, maintenance and proper use of Approved Fire Evacuation Chair Devices … which need to be powered or manual depending upon the particular circumstances in a building !
AND, even when all lifts/elevators are capable of being used during the course of a fire incident … because lifts/elevators must always undergo routine servicing and maintenance and they will not, therefore, be in operation for short periods of time … there will still be an obvious need for Approved Fire Evacuation Chair Devices. So, these fire-evacuation related products should never be regarded as a wasted investment !
I have repeated the word ‘Approved’ because, unfortunately, since these are also disability related products … insufficient attention, and emphasis, is given to Product Approval in this Market Sector, i.e. showing that the product is ‘fit for its intended use, in the location of use’.
At the most basic level imaginable … National Building Regulations in the European Union Member States, and E.U. Safety at Work and Product Liability Legislation … all demand Product Approval.
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Performance Requirements for Fire Evacuation Chair Devices: Fire Evacuation Chair Devices, powered or manual, must be capable of …
being safely and easily operated ;
carrying people of large weight (150 Kg minimum) ;
going down staircases which, in existing buildings of historical, architectural and cultural importance, may be narrow and of unusual shape ;
travelling long distances horizontally … in a robust and stable manner … both within a building … and externally, perhaps over rough ground … in order to reach a Place of Safety.
When going up a staircase is necessary in order to reach a Place of Safety, a powered evacuation chair device must be provided !
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Fire Evacuation Staircases: A vivid image, with a few accompanying words, are necessary …
Unlike the incredible scene shown in the colour photograph above ... Fire Evacuation Staircases must be suitable for Safe, Intuitive and Unhampered Building User Evacuation, Firefighter Contraflow and the Assisted Evacuation of People with Activity Limitations. A Minimum Clear Width of 1.5 Metres (from edge of handrail to edge of handrail !) is required. Click to enlarge.
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Fire Evacuation Chair Devices & What To Avoid: Can you spot the Evacuation Chair Device in the first photograph below ?
Colour photograph showing a Fire Evacuation Chair Device Installation at Dublin Airport, Ireland. On so many levels and in so many ways, this 'decorative' installation ... intended to demonstrate that an organization is complying with legislation ... will prove to be, in the event of a real fire emergency, SO wrong and unworkable. Photograph taken by CJ Walsh. 2008-04-04. Click to enlarge.
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Colour photograph showing a Manual/Gravity Fire Evacuation Chair Device in operation. Transfer from a wheelchair to this type of device at the top of a staircase can be difficult and hazardous ... it can only travel down a staircase, using gravity (never up, against gravity !) ... and during horizontal travel, it is shaky and unstable. Click to enlarge.
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Fire Evacuation Chair Devices & Issues To Carefully Consider: Modern wheelchairs come in all shapes, sizes and styles … are highly adapted by their owners … and can be very expensive. Why is it a surprise, therefore, to learn that most wheelchair users will not want to abandon their expensive personal property, i.e. the wheelchair, in the event of a real fire emergency.
The answer, of course, is PROPER CONSULTATION with All Building Users (where these are known !) during the preparation of a Fire Defence Plan for a Building.
The following photographs illustrate different aspects of the capability of Powered Fire Evacuation Chair Devices …
Colour photograph showing a Powered Fire Evacuation Chair Device in operation. This particular device facilitates evacuation, down and up a staircase, using the person's own manual wheelchair. Having completed its task at the bottom (or top !) of a staircase ... the device can be quickly released for use by another person who needs assistance on the staircase. Throughout this process, wheelchair users move independently to a Place of Safety. Click to enlarge.
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Colour photograph showing another Powered Fire Evacuation Chair Device. This particular device facilitates evacuation of an adapted manual wheelchair, which may (or may not !) be the person's own wheelchair. It also facilitates travel on narrow or unusually shaped staircases. Click to enlarge.
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Colour photograph showing a Powered Fire Evacuation Chair Device in operation. This particular device facilitates evacuation, down and up a staircase. It is also robust and stable while travelling horizontally ... both within a building ... and externally, perhaps over rough ground ... in order to reach a Place of Safety. Click to enlarge.
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Product Approval in the European Union Single Market: Fire Evacuation Chair Devices must be permanently CE Marked … including the product itself, any cover (such as that shown in the Dublin Airport photograph above), all product literature, and any product packaging.
It is not acceptable to print the CE Mark on an adhesive label … and then stick the label to the product ! Correct informative text must always accompany a CE Mark !
Please note that the CE Mark is not a Safety Mark. A CE Mark denotes conformity with the Essential Requirements of a single, specific European Union Directive.
2010-04-01: The Inter-Basin Water Transfer Project from Lough Ree, on the River Shannon, to Dublin City, in Ireland, has been described as a Pilot Adaptation Project on the United Nations Framework Convention on Climate Change (UNFCCC) WebSite Database relating to the Nairobi Work Programme (2005-2010).
Detailed information concerning the Project can be accessed and downloaded at this Irish Address: www.watersupplyproject-dublinregion.ie It will cost approximately €600 million (probably much more !) … devour many material resources and have an adverse environmental impact … the objective being to divert water from the Shannon, a large river in the mid-west of the country … to Dublin, the capital city, which is located over 100 kilometres away on the east coast … in order to deal with the expected shortage of water which will be caused, among other relevant factors, by future climate change.
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Colour image showing the many options for a future Dublin Region Water Supply Project ... linking the River Shannon, and its lakes ... to the Capital City, which is over 100 kilometres away on the east coast. Click to enlarge.
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BUT … just how Sustainable is this Climate Change Adaptation Project … if the following other relevant factors are considered ?????
1. Since the 1960’s … a dysfunctional and corrupt Spatial Planning System in the Dublin City Region has actively encouraged an uncontrolled, urban and suburban horizontal sprawl to take place. Today, this pattern of development remains unchecked.
2. At this time, there are still no Residential Water Charges in Dublin. The concept of water conservation is, therefore, almost unknown among householders. National and local politicians are terrified by any prospect of having to vote in favour of imposing these necessary charges.
3. There are enormous un-intended losses, i.e. Leaks, from the public mains potable/drinking water distribution system … approximately 40% even in the good times, and recently, well in excess of 60% following the National Snow Emergency in Ireland.
4. Potable/drinking water supplied to houses in the Dublin City Region is not yet Metered. There is no urgency, therefore, in locating and repairing water leaks which occur between the private property boundary of a house and the house itself.
5. There is no existing legal requirement in Ireland’s National Building Regulations to Harvest Rainwater in any buildings, or on any hard surfaces in the vicinity of those buildings. A current proposal to amend Technical Guidance Document H: ‘Drainage & Waste Water Disposal’ will merely present relevant guidance text to building designers concerning this option.
Furthermore, there is no effective System of Technical Control operated by the Local Authorities in the City Region … to enforce a legal requirement concerning rainwater harvesting … even if such a legal requirement were to be introduced !
Overloading of the existing drainage systems was evident from a marked deterioration in water quality, increased risks of flooding and pollution, and concerns that the drainage system and sewage treatment plants had insufficient capacity to cater for future development.
7.Sustainability Impact Assessment (SIA) …
‘ a continual evaluation and optimization assessment – informing initial decision-making, or design, and shaping activity/product/service realization, useful life and termination, or final disposal – of the interrelated positive and negative social, economic, environmental, institutional, political and legal impacts on balanced and equitable implementation of Sustainable Human & Social Development ‘
… is not yet a standard procedure, at any level, within national, regional and local Authorities Having Jurisdiction (AHJ’s). If it were, the most glaring flaw in this project would rapidly be identified. There is no comprehension at all, in the minds of Dublin City’s decision-makers, that water is a very valuable, but limited, resource !
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Although today is 1st April 2010 … far too many people in senior policy and decision-making roles are giving solemn, unquestioning consideration to this Project.
To be successful, however, National Adaptation Strategies, Programmes and Projects must be informed, in a meaningful way, by the concept of Sustainable Human and Social Development … and, prior to implementation, must be filtered through the lens of a comprehensive Sustainability Impact Assessment (SIA) !
22.11 Funding for the provision of infrastructure for the supply of drinking water is provided by the Department of the Environment, Community and Local Government under two programmes. Major water supply schemes are included in the rolling three-year Water Services Investment Programme (WSIP). These schemes focus on the larger concentrations of population in urban areas. Annual Rural Water Programmes (RWP) provide the bulk of funding for the construction of group water schemes and small public schemes in rural areas.
22.12 Over the period 2000-2010, €5.2 Billion of Exchequer resources have been invested in the upgrading and provision of new water services infrastructure, of which €4.2 Billion was spent on WSIP and €0.99 Billion was spent on RWP. Overall expenditure includes investment of over €1 Billion on public water supply and networks and €168 Million on water conservation. [The WSIP expenditure also includes €889 million relating mainly to the group water sector under the rural water programme.] There are two key indicators of the effectiveness of expenditure on water supply and conservation:
the quality of drinking water;
the extent to which treated water reaches the consumer.
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Effectiveness of Water Supply System
22.17 Loss of output is a feature of all water distribution systems. Unaccounted for Water (UFW) is a measure that is used to track this loss. It is the difference between ‘net production’ which is the volume of water delivered into a network and ‘consumption’ measured in terms of the volume of water that can be accounted for by legitimate consumption.
22.18Figure 109 shows UFW as a percentage of the net volume of water supplied for 2008 and 2009. It sets out the national average performance and the range across local authorities. Annex A contains the data on UFW for these two years for all county and city councils.
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Black and white image showing Figure 109: 'Unaccounted for Water (UFW) as a Percentage of Water Supplied, 2008-2009' ... from the 2010 Annual Report of the Irish Comptroller and Auditor General - Volume 2. Click to enlarge.
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Black and white image showing Annex A: 'Unaccounted for Water (UFW) as a Percentage of Total Volume of Water Supplied, 2008 and 2009' ... from the 2010 Annual Report of the Irish Comptroller and Auditor General - Volume 2. Click to enlarge.
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22.19 Overall, the average percentage of UFW was approximately 41.48% in 2009, which showed a marginal increase over 2008 (41.20%). Some 17 of the 34 authorities have seen an improvement in 2009, the most noticeable being a reduction in the percentage of water lost in Monaghan which was down by 27%, Cavan by 18% and Kilkenny by 15%. The other 17 local authorities reported a disimprovement in the amount of UFW for 2009, with Limerick County Council reporting losses of 35%, up from 17% in 2008. Fingal County Council, Limerick City Council, and Dublin City Council reported substantial increased leakage in 2009 over 2008 at 27%, 22% and 20% respectively.
Cost of Unaccounted for Water (UFW)
22.20 The cost of UFW is considerable for local authorities. However, since the LGMSB does not collate information on water production and associated costs the data is not available in the Department of the Environment, Community and Local Government. As a result, it is not possible in this report to provide an up-to-date estimate of the cost of UFW being experienced.
22.21 A value for money examination carried out in the mid-1990’s on water production and distribution showed that the cost per cubic metre of water produced varied between €0.14 to €0.39. The study found that overall water leakage level in the authorities surveyed at that time ranged from 27% to 40% of total water produced.
22.22 The results of the study were based on estimates since none of the authorities that were the subject of the value for money examination had the means to measure accurately the level of overall leakage.
22.23 Based on its results, the examination reported that, for five local authorities reviewed at that time, the estimated annual production cost of the water lost due to leakages was in the order of €3.5 million. Applying the Consumer Price Index to this value brings the cost to approximately €5.3 million in present-day terms.
22.24 As leakage is just one factor contributing to UFW, it appears from the losses now being recorded by local authorities that there has been little, if any, improvement in the situation despite the considerable State investment in water services in the interim.
Views of the Accounting Officer
22.25 The Accounting Officer informed me that under the National Water Conservation Sub-Programme, which commenced in 1996, the National Water Study undertook a comprehensive national water audit of all urban centres with populations exceeding 5,000 to determine the extent of UFW and leakage problems nationally. The National Water Study examined the reasons for UFW and set out recommendations to reduce the levels of UFW.
22.26 Arising from the findings of the National Water Study and pilot water conservation schemes undertaken in the main urban centres of Dublin, Cork, Galway, Waterford and Limerick, water conservation strategies and operational programmes were adopted which have been rolled out nationally since 2003.
22.27The Dublin Region Water Conservation Programme, which was carried out between 1998 and 2002 as one of the pilot schemes under the National Water Conservation Sub-Programme, reduced regional leakage from 47% to 28%. UFW in the Dublin region now averages 30% which is amongst the lowest in the country.
22.28 Since the commencement of the water conservation sub-programme, substantial investment has been made in the fundamental infrastructure for water management, including the metering of supply input. Also, the methodology has been standardised. Arising from this, the reported figures now have an accuracy that the figures from earlier times could not have had.
22.29 By way of example, the Greater Dublin Water Supply Strategic Study (1996) estimated losses of 44% of total input, of which 39% was allocated to distribution losses and 5% allocated to customer losses. When the metering infrastructure was checked and upgraded during the water conservation project (around 2000), it was found that the original meter readings for flow into supply were incorrect, and that losses were actually higher than originally thought (giving the corrected estimate for that time of 42% distribution losses and 47% in total). Notwithstanding that the Dublin Region bulk metering infrastructure was considered reliable at the time, it was found to have inaccuracies that were subsequently corrected.
22.30 In terms of comparisons, the Accounting Officer pointed out that the Dublin supply is hugely significant, serving approximately one third of the population of the country. Consequently, the Dublin supply region reduction of distribution loss from 42% to 30% currently must reflect positively on the national average (and it is the corrected Dublin Region figure from 1995/96 that is most reliably reflective of the situation at that time).
22.31 A further observation by the Accounting Officer was that without investment the leakage situation will deteriorate as assets age. It follows that a certain level of investment is required even just to maintain the status quo.
22.32 The Accounting Officer stated that, outside of Dublin, most of the investment had been in water management systems, which while they had made a contribution to tackling leakage, were really the platform for the more intensive investment being rolled out for mains rehabilitation in the WSIP 2010-2012. She said that this investment in water management systems had contributed to greater efficiency in the supply system, which had been demonstrated during the two severe winters and flooding in Cork, when authorities had been better able to manage the rationing of supply and restoration of supply than they would have been a decade ago.
22.33 Finally, the Accounting Officer said that the need to focus on water conservation had been demonstrated through the development of service indicators, training in water conservation, development of guidance and work with the County and City Managers Association to streamline the approaches and accelerate work in this area.
CONCLUSION – Effectiveness of Water Supply System
UFW arises from factors such as leakage, poor service connections and metering errors. Average UFW levels in Ireland appear to be at levels twice the OECD average of 20%. While some caution needs to be applied in interpreting the results of a limited examination of water leakage carried out over 15 years ago, present-day losses may be, in many local authorities, as high as those found in the mid-1990’s, notwithstanding an investment of over €1 Billion in water supply and conservation in the last ten years.
In the light of the potential cost of UFW it is necessary that the factors that give rise to UFW be reviewed and strategies and operational programmes to address the underlying issues contributing to the problem be re-evaluated.
Attention anybody who is screaming, struggling, protesting … being forced to revolt against an unjust and uncaring ‘system’ … so that Vulnerable Individuals and Groups … older people, children, people with disabilities, the homeless, etc., etc., etc … will be treated with dignity, equality and respect in our society … Ireland and the European Union. Pinch yourselves … we are Irish and Europeans !
It is helpful, as an introduction, if a distinction is made between human rights and social rights …
Social Rights: Rights to which an individual person is legally entitled, e.g. the right to free elementary education [Art.26(1), 1948 Universal Declaration of Human Rights], but which are only exercised in a social context with other people, and with the active support of a competent legal authority, e.g. a Nation State.
Commentary: In contrast to Human Rights, it is not protection from the State which is desired or achieved, but freedom with the State’s help.
Social Rights, as distinguished here, include and extend beyond current understandings of civil, political, economic, social and cultural rights.
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Early in the year 2000 … the European Parliament issued a Working Paper (reference PE 168.629) with the title: ‘Fundamental Social Rights in Europe’. The authors were Mark Eric Butt, Julia Kübert and Christiane Anne Schultz. The manuscript was completed in November 1999.
Without getting into the fine detail of the Working Paper … the following Table, on Page 31, is very enlightening …
Click to enlarge this Table.
In the Working Paper, the Table is explained …
‘ The following Table is an overview of the contents of the Member States’ constitutions. It shows what fundamental social rights are enshrined in the constitutions. It is impossible, however, to forge a link between the existence of fundamental social rights and the existence and level of social benefits and institutions in the Member States concerned. This is clear, primarily, from Austria and Great Britain, their columns being empty – whereas they do, of course, have social rights.
The symbol … simple black box … in the table means that the right concerned is referred to in the constitution. The other symbol … shadowed white box … means that, though not explicitly enshrined in the constitution, it is recognised.’
The Countries are listed in the order … Belgium (B), Denmark (DK), Germany (D), Greece (GR), Spain (E), France (F), Ireland (IRL), Italy (I), Luxembourg (L), The Netherlands (NL), Austria (A), Portugal (P), Finland (FIN), Sweden (S) and Great Britain (UK).
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Now … compare and contrast … paying particular attention to Ireland …
In Ireland, it is rarely the case that there is an opportunity to practice Rational, Evidence-Based Fire Engineering … and to apply its Principles in a manner which is both professional and project-specific. The grim reality of everyday fire consultancy revolves around playing ‘cat and mouse’ with current national building and fire regulations/codes … with ‘cost effectiveness’, i.e. to achieve a defined objective at the lowest cost, or to achieve the greatest benefit at a given cost … being the real, hidden driver behind such dangerous games ! Who wants to hear that the Irish Fire Safety Certification System is little more than a charade … an elaborate, resource consuming paper exercise … made all the more meaningless because Part B: ‘Fire Safety’ (of the Second Schedule to the 1997 Building Regulations, as amended) is isolated from a necessary and vital consideration of the other Parts, particularly Parts A: ‘Structure’; D: ‘Materials & Workmanship’; K: ‘Stairways, Ladders, Ramps & Guards’; and M: ‘Access for People with Disabilities’ ?
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Colour photograph showing an external view of Lakanal House, Sceaux Estate, Camberwell, London (GB) ... after the Fatal Fire which occurred at 16.19 hrs, on 3rd July 2009. The fire was caused by a faulty television set, and resulted in the loss of 6 lives, with 15 residents and 1 firefighter left injured. London Fire Brigade was required to assist the evacuation of a further 40 building occupants to safety. Along with the serious loss of life, and the large number of injured people ... over 90 families had to vacate their flats.
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Discussing the Principles of Fire Engineering … and elaborating on the significant differences between the limited Fire Safety Objectives of legal regulations/codes … and the much broader range of Fire Engineering Design Objectives intended to fully protect social wellbeing and the interests of clients/client organizations, i.e. to properly protect their asses and their assets, in the event of a fire … is a constant, tortuous, but rewarding, struggle. Masochism does help !
However, the 2009 Fire in a High-Rise Flat Complex at Camberwell, London (GB) … from just looking at the photograph above and reading available information about the spread of fire internally … raises some challenging fire engineering issues for building designers, property managers and construction organizations.
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1. Reliability of People Strategies in a Fire Emergency ?
In spite of the People Strategies elaborated in current Fire Codes/Regulations/Standards … it is totally and utterly irresponsible to advise people to wait in their own flats/apartments during a fire incident, or to develop fire safety strategies based on this approach … unless the confidence level (of ‘Competent Persons’ in Control … managers, designers and builders … of the flat/apartment complex) with regard to the following aspects of construction is very high …
reliability of both passive and active fire protection measures ;
reliability of fire compartmentation (see below) ;
reliability of not just the building’s structural stability, but also its serviceability, during the fire and for a minimum period of time afterwards, i.e. the ‘cooling’ phase.
Competent Person: A person capable of making sound value judgements in the area of professional endeavour in which he/she possesses profound knowledge, understanding and practical experience.
Fire Codes/Regulations/Standards, wherever or whatever their origin, are NOT Infallible … and it is unbelievably mind-boggling, and sad, to witness a blind and unquestioning faith in such documents !
Looking beyond the headline figure of 6 Fatalities in the 2009 Camberwell Fire … adequate attention should also be focused on the 16 Injured … comprising building occupants and firefighters … the lengthy disruption of community wellbeing resulting from the fire … 90 Families had to be re-located … and, of course, the tremendous amount of direct and indirect damage to property and the environment. And, I wonder … how did the more vulnerable occupants … and there may also have been visitors present in the complex at the time … cope in this emergency situation ?
This is why Fire Safety, Protection and Evacuation for All must be a Priority on any ‘Sustainability’ Agenda.
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2. Independent Technical Control of AHJ Construction ?
I have said this before, but it is worth repeating here again … Self-Regulation Is No Regulation ! Surely this lesson has been burnt into our souls, following the recent scandals, financial and otherwise, in Ireland ? National and Local Authorities Having Jurisdiction (AHJ’s) … Government Departments & Agencies, Semi-State Organizations, a myriad of Qwangos, the Office of Public Works and Local Authorities are complacent, careless and stubborn concerning proper compliance with even the minimal performance requirements specified in fire regulations, codes and standards.
The 2005 & 2008 National Institute of Standards & Technology (USA) Reports on the 9-11 WTC Incident in New York presented us with some stark language … and a set of important Recommendations which must be heeded …
‘ NIST recommends that such entities be encouraged to provide a level of safety that equals or exceeds the level of safety that would be provided by strict compliance with the code requirements of an appropriate governmental jurisdiction.
To gain broad public confidence … NIST further recommends that as-designed and as-built safety be certified by a qualified third party, independent of the building owner(s). The process should not use self-approval for code enforcement in areas including interpretation of code provisions, design approval, product acceptance, certification of the final construction, and post-occupancy inspections over the life of the buildings.’
[2005 NIST Final Report on WTC 1 & 2 Collapses – Recommendation No. 25]
Later posts, here, will examine the individual NIST Recommendations in more detail.
However … many individuals and organizations, with vested interests, are still trying to discredit and/or ignore the Recommendations contained in the 2005 & 2008 NIST Reports on the WTC 9-11 Incident. British Standard BS 9999:2008 is a typical case in point … a document which is slowly seeping into the marrow of the Irish Fire Establishment. The complete and abject failure to consider any of the NIST Recommendations during the long development of this British Standard, or even to reference the Reports in the Standard’s Bibliography … was an inexcusable and unforgivable technical oversight. The result was … and remains … a sloppy, crassly inadequate, deeply flawed and discriminatory national fire safety standard. The British Public deserves far better !
At this stage … reluctantly … I must invite the Chair of British Standards Institution Committee FSH/14, Mr. David B. Smith, to seriously re-consider his position.
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3. Fire Resistance, Compartmentation & Fire-Induced Progressive Collapse ?
Every person participating in the design, construction, management or operation of a building, no matter how simple or complex, must have a working knowledge and proper understanding of the Fire Engineering Principle of Fire Compartmentation:
The division of a building into fire-tight compartments, by fire and smoke resisting elements of construction, in order …
– to contain an outbreak of fire ;
– to prevent damage, within the building, to other adjoining compartments and/or spaces ;
– to protect a compartment interior from external fire attack, e.g. fire spread across the building’s facade or from an adjacent building ;
– to minimize adverse, or harmful, environmental impacts outside the building.
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BUT … But … but … buildings are no longer designed and constructed, today, as they were in the 18th or 19th Centuries …
In a fire situation, Fire-Induced Progressive Collapse may commence before any breach of ‘integrity’ occurs in the boundary of such a Fire Compartment, i.e. the building compartment of fire origin.
Fire-Induced Progressive Collapse: The sequential growth and intensification of distortion, displacement and failure of elements of construction in a building – during a fire and the ‘cooling phase’ afterwards – which, if unchecked, will result in disproportionate damage, and may lead to total building collapse.
… which is related to, but distinguishable from …
Disproportionate Damage: The failure of a building’s structural system … (i) remote from the scene of an isolated overloading action ; and (ii) to an extent which is not in reasonable proportion to that action.
Structural Fire Engineering: Those aspects of fire engineering concerned with structural design for fire, and the complex architectural interaction between a building’s structure and fabric, i.e. non-structure, under conditions of fire and its aftermath.
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AND … And … and … a designer of a Sustainable Building will want to utilize … in order to conserve energy … natural patterns of air movement for heating or cooling. This means that it will be necessary to have gaps between elements of construction which are continuously open … in direct conflict with the Principle of Fire Engineering just quoted above !
What happens when this sort of conflict … or lack of resolution (!) … occurs in modern, highly energy-efficient construction projects ? At the final stages of approval/certification … the Fire Prevention Officer will insist on following the outdated prescriptive approach in his/her rulebook. In other words, he/she will illegally apply the guidance text of Technical Guidance Document B as if it were prescriptive regulation. Fire Compartmentation will be uncompromisingly slapped onto ‘unresolved’ areas of a completed building design … to achieve the limited Fire Safety Objectives of Building Regulations … and the fire safety related construction will probably be badly executed, anyway, because the un-supervised sub-contractors of sub-contractors of sub-contractors couldn’t care less if it goes one way or the other ! The outcome is … nobody wins !!!
In Sustainable Building Design, therefore, Fire Resistance (a ‘passive’ protection concept) must not only be extended to consider a complementary relationship with ‘active’ fire protection concepts, but be stretched … ‘intelligently’ … to embrace the concept of ‘non-construction’ …
Building Sterile Space (Fire): An open space of sufficient and appropriate extent which is designed to retain an exceptionally low level of fire hazard and risk, and is ‘intelligently’ fitted with a suitable fire suppression system – in order to resist and control, for a specified time during a fire, the advance of heat, smoke and flame.
Fire Resistance: The inherent capability of a building assembly, or an element of construction, to resist the passage of heat, smoke and flame for a specified time during a fire.