Accessibility-for-All

Disability Access Certificates (DAC’s) – Acceptable Accessibility ?

Posted by CJ Walsh

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.
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.
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.
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 Use     M1     Adequate provision shall be made to enable people with disabilities to safely and independently access and use a building.

Sanitary Conveniences     M2     If sanitary conveniences are provided in a building, adequate provision shall be made for people with disabilities.

Audience or Spectator Facilities     M3     If a building contains fixed seating for audience or spectators, adequate provision shall be made for people with disabilities.

Definition for This Part     M4     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 Part     M5     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 Use     M1     Adequate provision shall be made for people to access and use a building, its facilities and its environs.

Application of The Part     M2     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.

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EU Sustainable vs. Green Public Procurement – Beware !

Posted by CJ Walsh

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.

Beware !!

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Ireland’s Mental Health Services – In Serious & Rapid Decay !

Posted by CJ Walsh

2010-10-29:  For those of you who are not fully up to speed with Ireland’s Current Economic Disaster … very painful for some people, but not for all (!) … in the next few weeks, we will be presented with a 4 Year Budget Strategy Plan, which will be verified by the European Commission, in Brussels, and the European Central Bank, in Frankfurt … and also be presented with a Draconian First in a Series of 4 Budgets.  The track record of our Government shows that the most vulnerable groups in our society will be the Primary Targets for fiscal cutting, slashing, pillage and burning.

Which is why I am pleased to align our Organization … Sustainable Design International Ltd … with the following Open Letter to …

  • An Taoiseach (Ireland’s Prime Minister), Mr. Brian Cowan T.D. ;
  • Minister for Finance, Mr. Brian Lenihan T.D. ;
  • Minister for Health & Children, Ms. Mary Harney T.D. ;   and
  • Minister of State for Disability & Mental Health, Mr. John Moloney T.D.

Dear Ministers,

We call on the Irish Government to respond to the Crisis in our Mental Health Services !

Mental Health Services simply cannot be maintained at acceptable levels in a civilized society if there are further cuts in Ireland’s Budget 2011.  They have already been cut unfairly and disproportionately.  Spending is down 9.2% since 2006, and is at 5.3% of the Overall Health Budget – now at its lowest share in modern history.  More than half of all the staff cut from the HSE (Health Service Executive … http://www.hse.ie) in 2009 came from the Mental Health Services, despite the fact that they only represent 9% of the HSE’s workforce.

In 2006, the Government’s National Mental Health Policy, ‘A Vision for Change’, promised to end institutionalization and provide modern community-based services.  Yet, progress in developing community services has ground to a halt.  We still have the shameful situation of people living in conditions described by the Inspector of Mental Health Services as “entirely unacceptable and inhumane”; hundreds of children being admitted to adult inpatient mental health units; and large numbers of people with a mild mental or cognitive impairment in Psychiatric Institutions who should not be there in the first place.

We know that there is a financial debacle – but, it is making the mental health crisis worse.  Financial stress, debt and unemployment are putting a massive burden on people’s mental health.  Waiting lists for services are growing as people look for support – rates of suicide and self-harm rose sharply last year !

Any further cuts in Budget 2011 will signal the death knell for ‘A Vision for Change’, and condemn another generation of Irish People to a Mental Health System which is a remnant from the Age of Victorian Asylums.

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I have also signed up to support this Campaign at … http://www.healthrisk.ie/

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Japan in April and May 2010 … Accessibility-for-All !

Posted by CJ Walsh

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’.

The following European Guideline Framework … which I drafted in 2003, and later incorporated into the 2004 Rio de Janeiro Declaration on Sustainable Social Development, Disability & Ageing … is useful …

C.J. Walsh

Guideline Framework on EU Equal Opportunity & Social Inclusion for All

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.
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.
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.
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.
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.
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.
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.
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.
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.
Colour photograph showing Accessibility-for-All in Kanazawa, Japan. Photograph taken by CJ Walsh. 2010-04-27. Click to enlarge.

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Evacuation Chair Devices – Fire Engineering for All in Buildings ?

Posted by CJ Walsh

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 … 

  1. Evacuation for All Building Users … with an assurance of health, safety and welfare protection during the course of that evacuation.
  2. 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.
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.
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.
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.
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.
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.
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.

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ISO/IEC Guide 71 & CEN/CENELEC Guide 6 – Flawed ?

Posted by CJ Walsh

International Guidance Document … ISO/IEC Guide 71 : Guidelines for Standards Developers to Address the Needs of Older Persons and Persons with Disabilities was issued in November 2001.

European Guidance Document … CEN/CENELEC Guide 6 : Guidelines for Standards Developers to Address the Needs of Older Persons and Persons with Disabilities … a similar document … was issued a little later, in January 2002.

These Guides provide basic guidance to people drafting International & European Standards on how to take into account the needs of people with activity limitations, particularly older persons and people with disabilities.  While recognizing that some people with very extensive and complex impairments may have requirements beyond the level addressed in these documents, a very large number of people have minor impairments which can easily be addressed with a very small change of approach by people writing the Standards.  Typically, the problem is solely a lack of awareness.

Unfortunately, few Standards Developers … in either organization … are paying the slightest bit of attention to these Guides.

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

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1.  A full six months before the appearance of ISO/IEC Guide 71 … all of the 191 Member States of the World Health Organization endorsed, and officially adopted, the International Classification of Functioning, Disability & Health (ICF) on 22nd May 2001 … which replaced the earlier International Classification of Impairment, Disability & Handicap (ICIDH), dating from 1980.

While the previous health indicators had been based on the mortality (i.e. death) rates of populations … the new 2001 WHO ICF dramatically shifted the focus to ‘life’ and ‘living’ … in other words, how everyone is living with his/her health condition(s) and how improvements can be made to ensure a productive, fulfilling life in society.

This had important implications for medical practice; for legal, social, economic, institutional, design and spatial planning policies to improve accessibility, equal opportunity for all and inclusion; and for the protection of the rights of all individuals and groups.

Of special interest for people involved in any of the technical fields mentioned above … the 2001 WHO ICF also introduced a new disability-related language and terminology.

BUT … But … but … ISO/IEC Guide 71 and CEN/CENELEC Guide 6 do not use the 2001 WHO ICF’s innovative language and terminology.  Consequently, these International & European Guides are flawed.

For a very good example of WHAT MUST BE AVOIDED (!) in the drafting of International & European Standards … please examine the following text …

ISO DIS (Draft International Standard) 21542 : Building Construction – Accessibility and Usability of the Built Environment … dated November 2009 …

Section 3   Terms & Definitions

‘ #3.36  Impairment

Limitation in body function or structure such as a significant deviation or loss which can be temporary due, for example, to injury, or permanent, slight or severe and can fluctuate over time, in particular, deterioration due to ageing.

[ISO/TR 22411:2008]

NOTE 1   Body function can be a physiological or psychological function of a body system; body structure refers to an anatomic part of the body such as organs, limbs and their components (as defined in ICIDH-2 of July 1999).

NOTE 2   This definition differs from that in ISO 9999:2002 and, slightly, from ICIDH-2/ICF: May 2001, WHO: ‘any loss or abnormality of a body function, or body structure’.

NOTE 3   The word ‘abnormality’ is strictly used here to refer to a significant deviation from an established population mean, within measured statistical norms. Impairments can be physical, mental, cognitive or psychological.’

As clear as mud … what a mess !   This does nothing only sow needless confusion in the mind of a reader.

Unless and Until … we properly harmonize, at a technical level, disability-related language and terminology … in order to improve communication … we will all continue to run around in circles and make little forward progress !!!

[ At the level of the individual, people should always be free to use whatever language they wish. ]

Our Guidance to All Standards Developers is … whether working within the International Standards Organizations (ISO & IEC) or the European Standards Organizations (CEN & CENELEC) … or both …

‘ People with Activity Limitations must be properly considered at all stages in the development of a Standard … and any disability-related terminology used … should be fully consistent with the World Health Organization’s 2001 International Classification of Functioning, Disability & Health (ICF).  Confusing and contradictory texts should be avoided.’

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2.  In relation to ISO/IEC Guide 71 & CEN/CENELEC Guide 6 – Table 7 (Page 13 in both Guides) … #8.23 Fire Resistance requires a complete re-assessment.  On Page 21 of ISO/IEC Guide 71 and Page 22 of CEN/CENELEC Guide 6 … the supporting text for #8.23 has the different heading of ‘Fire Safety of Materials’ ?!?   Confusing, isn’t it ?

The Revised Title in Table 7 and the supporting text should read … Fire Safety.  ‘Fire Resistance’ is but one of many passive fire protection concepts … a very small sub-set in the wide technical field of ‘fire safety’ in buildings.  ‘Fire Resistance’ is not used in connection with the ignition and fire development behaviour of materials or fabrics.

Relevant Factors for #8.23 are not properly indicated, in Table 7, under Columns #9.2, #9.3, #9.4 (a glaring omission !) & #9.5.

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3.  Pertinent to ‘fire safety’ in buildings … this text was removed from ISO CD (Committee Draft) 21542 … the previous version of the ISO Standard, dating from December 2008 …

ISO CD 21542 – Annex A.1.2 – 2nd Paragraph

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

The Definition for the Term Skill (#3.60) is still retained in the later ISO DIS 21542 version of the Standard …

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

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4.  While there are eight references to ‘Cognitive Impairment’ in both Guides … nowhere is this term defined … or distinguished from ‘Mental Impairment’ …

Cognitive Impairment:  A deficiency of neuropsychological function which can be related to injury or degeneration in specific area(s) of the brain.

Mental Impairment:  A general term describing a slower than normal rate in a person’s cognitive developmental maturation, or where the cognitive processes themselves appear to be slower than normal – with an associated implication of reduced, overall mental potential. 

A deeper understanding, at a technical level, of the many different types of health conditions and impairments (physical/mental/cognitive/psychological) … can only result in a better designed, more facilitating Human Environment.

One final important term … when considering Fire Safety in Buildings …

Panic Attack:  A momentary period of intense fear or discomfort, accompanied by various symptoms which may include shortness of breath, dizziness, palpitations, trembling, sweating, nausea, and often a fear by a person that he/she is going mad.

I have long held the view that, in Fire Engineering, dramatic breakthroughs will result from a closer study of Cognitive Psychology.

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