Accessibility-for-All

2010 ACRECONF in Delhi (Dilli), India – 8th & 9th January

It was a great pleasure to be invited to speak on the subject of Sustainable Fire Engineering at the 2010 ACRECONF in Delhi (Dilli), India.  This ground breaking conference in Asia took place at the India Habitat Centre, Lodhi Road, Delhi … on the 8th & 9th January last.  Back during August (2009) in Bengaluru … the ACRECONF Chairman, Mr. Ashish Rakheja, told me that he expected an attendance of somewhere between 500-600 people at the Delhi Conference.  Over the two days of the actual conference, approximately 1800 delegates participated … an enormous response by architects, civil and service engineers, developers, client and construction organizations, etc., etc., from right across the country … and from the deep south.

Colour photograph showing some of the many participants at the 2010 ACRECONF in Delhi, as they enjoy talking and networking during the morning coffee break of the second day at the conference. The venue was the India Habitat Centre on Lodhi Road. The weather was chilly for the time of year, and there had been a heavy fog earlier in the morning. Click to enlarge. Photograph taken by CJ Walsh. 2010-01-09.
Colour photograph showing some of the many participants at the 2010 ACRECONF in Delhi, as they enjoy talking and networking during the morning coffee break of the second day at the conference. The venue was the India Habitat Centre on Lodhi Road. The weather was chilly for the time of year, and there had been a heavy fog earlier in the morning. Click to enlarge. Photograph taken by CJ Walsh. 2010-01-09.

For me … refreshing, extremely impressive, and certainly the highlight of the conference … was a multi-media presentation … on the second morning, just after the coffee break … by Mr. Karan Grover, the renowned Indian Architect.  He is quite an individual !

Before the break, delegates had been treated to an elaboration of the Environmental Design Innovations incorporated into the 71 storey Pearl River Tower (Guangzhou, China), by Mr. Varun Kohli of Skidmore, Owings & Merrill (SOM) in New York.  Construction of the Tower is now well under way.  Afterwards, however, an important discussion took place concerning the issue of fire safety, and fire engineering generally, in Sustainable Buildings.  It became clear to all of the participants that this issue is a major oversight … an intentional gap … in the design of these buildings.  I made the point, forcibly, that Sustainable Fire Engineering is open to innovation and design creativity. There will be an important follow-up to this discussion.

Colour photograph showing a silly tourist on a bicycle rickshaw, as he is brought sightseeing around the Bazaar District in Old Delhi. Click to enlarge. Photograph taken by Mr. Daljeet Singh, Ministry of Tourism, with CJ Walsh's camera. 2010-01-09.
Colour photograph showing a silly tourist on a bicycle rickshaw, as he is brought sightseeing around the Bazaar District in Old Delhi. Click to enlarge. Photograph taken by Mr. Daljeet Singh, Ministry of Tourism, with CJ Walsh's camera. 2010-01-09.

Unfortunately, the conference was peppered with references to ‘Green’ Buildings … an outdated marketing concept (!) … which, within its limited world-view, gives people the false comfort of not having to deal with thorny issues such as ‘social justice, solidarity & inclusion for all’.  I have discussed this issue many times in previous posts.

Even more unfortunately, where the Brundtland Definition of ‘Sustainable Development’ was actually presented in one session … as usual, it was only the first half of the definition which made any appearance.  The second, and more important, half of the definition had mysteriously vanished without trace … which made the whole effort a meaningless exercise !   What a waste !!   No wonder there is such confusion over the concept … at all levels … in most countries !!!

It was not surprising, therefore, that what was not stressed enough, during the entire conference, was that Sustainable Design Solutions must be appropriate to local geography, climate, economy, culture, social need and language(s)/dialect(s), etc.  The LEED Building Rating System (USA), for example, is not being properly adapted to local conditions in India !

A final issue … another major oversight … another intentional gap … in the design of buildings … Accessibility-for-All !   Even though India ratified the 2006 UN Convention on the Rights of Persons with Disabilities on 1st October 2007 … this essential aspect of design … certainly in Sustainable Buildings … received no mention whatever during the conference … except by yours truly, in my presentation.

Overall … a magnificent achievement for the organizers !

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Yesterday’s Burj Dubai Inauguration – The Tallest ?? How ?

Yesterday (2010-01-04), the Burj Dubai … recently renamed the Burj Khalifa, in honour of Abu Dhabi’s Ruler … was inaugurated.  Dubayy, as it is known locally, is situated in the United Arab Emirates (UAE).  Contrary to most reports, this building has a height of approximately 550 metres !

Colour photograph of the Burj Khalifa Tower in Dubayy, United Arab Emirates ... which was recently inaugurated on 4th January 2010. A romantic image, for now, of the World's Tallest Building. But ... how 'sustainable' ... and 'fire safe' ... is this building ?
Colour photograph of the Burj Khalifa Tower in Dubayy, United Arab Emirates ... which was recently inaugurated on 4th January 2010. A romantic image, for now, of the World's Tallest Building. But ... how 'sustainable' ... and 'fire safe' ... is this building ? Click to enlarge.

Every single metre counts in the race of the ‘tallest’ !   So, the timing of the following CTBUH(USA) Press Announcement, back in November 2009, was most fortunate.  In my opinion, the most meaningful height criterion is … Height to Occupied Floor.  But, what do you think ?   See below.

However … purposefully tripping you up as you race to read all about the height criteria of Tall and Super-Tall Buildings … we should all know and understand, I hope, that comparing the ‘size’ of structural members is a silly schoolboy’s game.  So, I would like to pose Some Important Questions (discussed, ad nauseam, in previous posts) about the Burj Khalifa Tower …

  1. Dubayy (Dubai) is a crude reproduction of the nightmare that is the 20th Century North American City, i.e. it is on the opposite end of the scale from being ‘sustainable’ !   ‘Greenwashing’ aside … How Sustainable is the Burj Khalifa Tower ?
  2. There is no effective system, in Dubayy, of Independent Monitoring and Technical Control of the processes of building design and construction by Local Authorities Having Jurisdiction (AHJ’s) or Competent Technical Controllers … 

How Fire Safe is the Burj Khalifa Tower … for All of the large population, including People with Activity Limitations (2001 WHO ICF), who will undoubtedly be using/occupying the building during its long life cycle ?

Has the Tower been designed to adequately resist Fire-Induced Progressive Collapse ?   ‘Robustness’ and ‘Disproportionate Damage’ are separate, but related, structural concepts.

During my next visit to Dubayy … I will enjoy looking at, and photographing, the completed building.  But, I will not be entering the Burj Khalifa Tower !

Chicago, 2009-11-17:  The Council on Tall Buildings & Urban Habitat (CTBUH) – the international body which arbitrates on tall building height and determines the title of ‘The World’s Tallest Building’ – has announced a change to its height criteria, as a reflection of recent developments with several super-tall buildings.

The new criteria wording – ‘Height is measured from the level of the lowest, significant, open air, pedestrian entrance to …’ allows for the recognition of the increasing numbers of multi-use tall buildings with often several different entrances at different levels, whilst also accommodating buildings constructed in non-traditional urban or suburban locations.  The CTBUH Height Committee has determined that the previous description of where to measure tall building height from – ‘Height is measured from the sidewalk outside the main entrance to …’ is now no longer sufficient.

This will have an impact on both the height of tall buildings and their relative international height rankings.  Burj Dubai, set to open as the world’s tallest building in January 2010, will now be measured from the lowest of its three main entrances (which opens into the entrance lobby for the tower’s corporate suite office function), while the recently completed Trump International Hotel & Towers in Chicago will be measured from the lower, publicly accessible Chicago Riverwalk.  In the case of Trump, this additional 9 metres (approx.) means that it will surpass the Jin Mao Tower in Shanghai to occupy the rank of 6th tallest on the current list of completed buildings.

“Beginning in 2007, with the knowledge that Burj Dubai would be significantly taller than any structure ever built, the CTBUH Height Committee met to review the criteria by which we recognize and rank the height of buildings”, said Peter Weismantle, Chair of the CTBUH Height Committee and Director of Supertall Building Technology at Adrian Smith + Gordon Gill Architecture in Chicago.  “As one might guess, with the committee being made up of architects, engineers, contractors, developers, building owners and academics, a variety of opinions and views were expressed.  The resulting revisions, almost two years later, reflect a general consensus of the committee in recognizing the most recent trends in tall building development around the world.”

Also in response to the changing designs and forms of tall buildings, the Height Committee has elected to discard its previous ‘Height to Roof’ Category.  “The roof category just doesn’t make sense anymore”, said CTBUH Executive Director Antony Wood.  “In the era of the flat-topped modernist tower, a clearly defined roof could usually be identified, but in today’s tall building world – which is increasingly adopting elaborate forms, spires, parapets and other features at the top of the building – it is becoming difficult to determine a ‘roof’ at all, even less so to measure to it.”

Colour image showing the World's 10 Tallest Buildings ... ranked by the Council on Tall Buildings & Urban Habitat (CTBUH), in November 2009, according to the criterion 'Height to Highest Occupied Floor'. Also included is the Burj Khalifa Tower, which was inaugurated on 4th January 2010.
Colour image showing the World's 10 Tallest Buildings ... ranked by the Council on Tall Buildings & Urban Habitat (CTBUH), in November 2009, according to the criterion 'Height to Highest Occupied Floor'. Also included is the Burj Khalifa Tower, which was inaugurated on 4th January 2010. Click to enlarge.

The Revised CTBUH Height Criteria and Diagrams of the Tallest 10 Buildings in the World as of November 2009 can be found here, ranked according to the three height categories now recognized by CTBUH.  These are: (i) Height to Architectural Top, measured to the topmost architectural feature of the building including spires, but not including antennae, signage, flag poles or other functional-technical equipment;  (ii) Height to Highest Occupied Floor, measured to the level of the highest, consistently occupied floor in the building (thus not including service or mechanical areas which experience occasional maintenance access);  and (iii) Height to Tip, measured to the highest point of the building, irrespective of material or function of the highest element.

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FCCC COP-15: Historical Responsibility & Poverty Reduction ?

2009-12-16:  ‘Chaotic’ is not the only word to describe what is happening right now in Copenhagen !   A few additional parliamentary expletives are required.  Is it just me … or is it obvious to everyone … that the Danes could not organize an orgy at an International Golf Tournament ?

What the world urgently needed was an ambitious, legally binding agreement … a Kyoto II Protocol, for want of a better title … to slot into place when the 1st Commitment Period ends in 2012.  What we may end up with is an ambiguous ‘political’ agreement … which will be worth approximately 1 cent more than the paper on which it will be scrawled.

There is something definitely rotten in the State of Denmark !   Multiple drafts of the same working document circulating at the same time … backroom meetings away from public scrutiny … greedy developed countries trying to avoid responsibility and action … strutting, self-important NGO’s thinking that they know all the answers … etc., etc … kill any confidence in the process stone dead.  These are not the ways of Sustainable Social Partnership.

However … at a far distance from the hustle and bustle … it can be observed that Interesting Side Events are taking place … and Thought Provoking Reports are being presented … before, during and after the main gatherings between the 7th and 18th December 2009:

  • 15th Session of the Conference of the Parties (COP-15) to the United Nations Framework Convention on Climate Change (UNFCCC) ;
  • 5th Meeting of the Parties (MOP-5) to the Kyoto Protocol.

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African Countries are not the only Group having difficulty with what is/is not happening in Copenhagen …

Two recent Discussion Papers from The Energy & Resources Institute (TERI), in India, are worth bringing to your attention.  Both raise issues which are not very popular in this part of the world.  And … it so happens that Dr. Rajendra K Pachauri – Director-General of TERI … is also Chairman of the WMO-UNEP Intergovernmental Panel on Climate Change (IPCC) !

  1. Right to Sustainable Development: An Ethical Approach to Climate Change (December 2009), by Leena Srivastava, Neha Pahuja, Manish Shrivastava & Prabhat Upadhyay.  PDF File, 228 Kb.  Click link to read and/or download.  Discusses ideas such as: ‘equity’, ‘fairness’, ‘historical responsibility’ (of UNFCCC Annex I Countries), ‘climate justice’, etc.
  2. Linking Climate Action & Poverty Alleviation – An Approach to Informed Decision-Making (December 2009), by Atul Kumar.  PDF File, 488 Kb.  Click link to read and/or download.

Notes:

To gain worldwide acceptance – across developed, developing and least developed regions of the world – and to have a reasonable chance of reliable implementation in those disparate regions … mitigation of, and adaptation to, climate change, including variability and extremes, must be fully compatible with the concept of Sustainable Human & Social Development.  This is clearly elaborated in both the 1992 UNFCCC and the 1997 Kyoto Protocol.

To be clear among ourselves on this island … Ireland is specifically named (without any qualification), among other Developed Countries … in Annex I and Annex II of the 1992 United Nations Framework Convention on Climate Change (UNFCCC) … and in Annex B of the 1997 Kyoto Protocol, which is legally binding.  The European Union is not mentioned, at all, in either document.

It is of concern to note that although India ratified the 2006 United Nations Convention on the Rights of Persons with Disabilities (CRPD) in October 2007 – TERI (India) has very recently placed a Document (No.1 above) in the public domain, at Copenhagen, which actively forbids content extraction by people with activity limitations for the purposes of equitable accessibility !   Joined-up thinking !?!?

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Emergency Planning For ALL & Special Needs Populations ?

On 15th August 2008, the United States Federal Emergency Management Agency (FEMA), in association with the U.S. Department of Homeland Security (DHS) Office for Civil Rights & Civil Liberties, published Comprehensive Preparedness Guide #301: ‘Interim Emergency Management Planning Guide for Special Needs Populations’.

What follows are important extracts from CPG #301.  As you slowly read along … consider the chaotic, clapped-out and ramshackle response, at national level, to the Flood Emergency in Ireland

Throughout the history of Emergency Management Planning, considerations for Special Needs Populations have often been inadequate.  From the 1930’s, when disaster response was ad hoc and largely focused on the repair of damaged infrastructure, through to the present day, emergency management culture of ‘readiness’, special needs populations were often given insufficient consideration.  This fact was evident in 2003 during the California wildfires and when Hurricane Katrina devastated the Gulf Coast in 2005.  During these events, some individuals with special needs did not receive appropriate warning, were unable to access shelters, or went without medical intervention.  During the 2006 Nationwide Plan Review, a sample of emergency management plans was reviewed by subject-matter experts on disability and ageing.  The review confirmed that emergency plans from various regions in the United States continue to overlook these populations.  The Nationwide Plan Review Phase 2 Report concluded that “substantial improvement is necessary to integrate people with disabilities into emergency planning and readiness”.

Numerous ‘lessons learned’ reports that followed Hurricane Katrina also pointed out that there is a large segment of the U.S. population who may not be able to successfully plan for, and respond to, an emergency with resources typically accessible to the general population.  The current general population is one that is diverse, ageing, and focused on maintaining independence as long as possible.  The popularity of living situations that provide an ‘as needed’ level of care in the least restrictive manner is fast becoming the norm.  Consideration should therefore be given to people who may be able to function independently under normal situations, but who may need assistance in an emergency situation.

For example, it is estimated that about 13 million individuals aged 50 years or older in the United States will need evacuation assistance, and about half of these individuals will require such assistance from someone outside of their household.  There are well over 1 million people in the United States receiving home healthcare according to 2000 data cited by the National Center for Health Care Statistics.  Populations such as these should be considered when emergency plans are developed to accurately assess the resources needed to adequately respond when a disaster strikes.  The 2000 Census reported that 18% of those surveyed speak a language other than English at home.  This highlights the need to ensure the effectiveness of emergency communications.  Populations described as ‘transportation disadvantaged’ – those who do not have access to a personal vehicle or are precluded from driving – may also require assistance during emergencies.  The 2000 Census reports that in the top ten car-less cities, between 29% and 56% of the households are without a vehicle.  These examples serve to demonstrate community emergency planning should go beyond traditional considerations.

During the Nationwide Plan Review, Emergency Managers consistently requested technical assistance in identifying and incorporating special needs populations into emergency planning.  As described later, defining the term ‘special needs’ is a critical initial step in the planning process.  The Federal Government introduced, within the National Response Framework (NRF), a definition of special needs populations that State, Territorial, Tribal, and Local governments may adopt for use in their Emergency Operation Plan (EOP) development.  It is important to note that though this terminology may appear ambiguous, it is well established in the Emergency Management Vocabulary and when clearly defined, strengthens the planning process.

Although it is recognized that significant emergency planning should be done for incarcerated populations, these groups cannot be integrated into general population planning.  Individuals in correctional settings are institutionalized to protect other members of society; people who are institutionalized in health related settings are there for their own protection and wellbeing.  Emergency management planning for incarcerated populations requires additional consideration such as law enforcement and co-ordination between emergency managers, the Department of Corrections, and prison superintendents to ensure safety of the prisoners and the public.  For these reasons, incarcerated populations are not included in the NRF definition of ‘special needs’, which is the same definition used in this Planning Guide.

 

U.S. Federal Emergency Management Agency (FEMA) CPG #301

Date: 15 August 2008.  PDF File, 301kb.

Interim Emergency Management Planning Guide for Special Needs Populations

Click the link above to read and/or download CPG #301

 

Emergency Management takes into consideration planning for the safety of every person in the community during and following a disaster.  Taking into consideration populations historically considered ‘vulnerable’, ‘at risk’, or ‘special needs’, ultimately improves the overall community’s post-disaster sustainability.

Before drafting Emergency Plans, it is recommended that a state-wide definition for the term ‘special needs’ be developed and used to guide State, Territorial, Tribal, and Local jurisdictions in the planning process.  A consistent use of terminology will result in improved communication and co-ordination of resources across State, Territorial, Tribal, and Local entities.

The NRF Definition for ‘special needs’ provides a function-based approach for planning and seeks to establish a flexible framework that addresses a broad set of common function-based needs, irrespective of specific diagnosis, statuses, or labels (e.g. children, older people, transportation disadvantaged, etc.).  In other words, this function-based definition reflects the capabilities of the individual, not the condition or label.  Governments that choose to align their language to the NRF definition will improve inter-government communication during an incident.

The Definition of Special Needs Populations, as it appears in the U.S. National Response Framework (NRF) is as follows:

Populations whose members may have additional needs before, during, and after an incident in functional areas, including but not limited to:

–   Maintaining Independence ;

–   Communication ;

–   Transportation ;

–   Supervision ;

–   Medical Care.

Individuals in need of additional response assistance may include those who have disabilities; who live in institutionalized settings; who are elderly; who are children; who are from diverse cultures; who have limited English proficiency; or who are non-English speaking; or who are transportation disadvantaged.

[The concept of a function-based approach to defining special needs populations has been developed by June Isaacson Kailes.  See Kailes, J. and Enders, A. in “Moving Beyond ‘Special Needs’: A Function-Based Framework for Emergency Management Planning”.  Journal of Disability Policy Studies, Vol./No. 44/2007.  Pages 230-237.]

At first glance, it may appear that each of the above groups (and a disproportionately large percentage of the population) is automatically classified as having special needs, but this is not the case.  The definition indicates these groups may often include individuals who have special needs and, in the event of an emergency, may need additional assistance or specialized resources.  For example, in a city like New York where less than half of all households own a car, transportation-dependence is not necessarily a ‘special need’.  A special need in this instance is an inability to access the transportation alternatives defined by the Emergency Operation Plan (EOP).  It is important to remember that special needs populations have needs that extend beyond those of the general population.

The definition focuses on the following function-based aspects:

  • Maintaining Independence – Individuals requiring support to be independent in daily activities may lose this support during an emergency or a disaster.  Such support may include consumable medical supplies (baby diapers, formula, bandages, continence supplies, etc.), durable medical equipment (wheelchairs, walkers, scooters, etc.), service animals, and/or attendants or caregivers.  Supplying needed support to these individuals will enable them to maintain their pre-disaster level of independence.
  • Communication – Individuals who have limitations which interfere with the receipt of and response to information will need that information provided in format they can understand and use.  They may not be able to hear verbal announcements, see directional signs, or understand how to get assistance due to hearing, vision, speech, cognitive, or intellectual limitations, and/or limited English proficiency.
  • Transportation – Individuals who cannot drive or who do not have a vehicle may require transportation support for successful evacuation.  This support may include accessible vehicles (e.g., lift-equipped or vehicles suitable for transporting individuals who use oxygen) or information about how and where to access mass transportation during an evacuation.
  • Supervision – Before, during, and after an emergency individuals may lose the support of caregivers, family, or friends or may be unable to cope in a new environment (particularly if they have dementia, Alzheimer’s or psychiatric conditions such as schizophrenia or intense anxiety).  If separated from their caregivers, young children may be unable to identify themselves; and when in danger, they may lack the cognitive ability to assess the situation and react appropriately.
  • Medical Care – Individuals who are not self-sufficient or who do not have adequate support from caregivers, family, or friends may need assistance with: managing unstable, terminal or contagious conditions which require observation and ongoing treatment;  managing intravenous therapy, tube feeding, and vital signs;  receiving dialysis, oxygen, and suction administration;  managing wounds;  and operating power-dependent equipment to sustain life.  These individuals require support of trained medical professionals.

 The above examples illustrate function-based needs that may exist within the community.

 

Important Conclusions for Ireland & Europe Generally:

1.  The innovative approach taken to Special Needs Populations in U.S. FEMA Comprehensive Preparedness Guide #301 is entirely consistent with European concepts of ‘mainstreaming’, ‘accessibility for all’, ‘fire safety, protection and evacuation for all’, etc … and the widespread, standardized and consistent use of the language and terminology in the 2001 World Health Organization (WHO) International Classification of Functioning, Disability & Health (ICF) … an approach which I have long advocated across Europe.

2.  Fragmentation of the Irish Special Needs Population, dissention between different groups within that population or a lack of willingness to work with other groups … the use of far too many ad-hoc labels … and the anarchic abuse of disability-related language and terminology … pose a grave risk to the Safety, Health and Wellbeing of all these groups in Emergencies, whether large or small scale … and create unnecessary, and sometimes insurmountable, barriers to effective communication and the proper co-ordination of emergency response resources.  This problem is deep-rooted and endemic throughout Europe.

3.  French use of the words, e.g. ‘les handicapés’, ‘les invalides’, is both outdated and barbaric.  Similarly, German use of the word ‘die behinderten’ is unacceptable.  A concerted effort, at European level, must be made to modernize and harmonize the use of disability-related terminology in our many different languages.  Large Scale Emergencies in Europe, involving 2, 3 or more E.U. Member States, require … as a priority … effective communication and the proper co-ordination of emergency response resources.

 

 

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Older People in Emergencies – Action & Policy Development (II)

2009-11-25:  In 2008, the World Health Organization (WHO) Report: ‘Older People in Emergencies – Considerations for Action & Policy Development’ was published.

The following are short extracts from that Report …

Older People

Until recently, older peoples’ needs in disasters and conflicts were addressed only by broader adult health and humanitarian programmes.  This has changed, as several recent emergencies highlighted this population’s vulnerabilities.  Of the 14,800 deaths in France during the 2003 heat wave, 70% were people over 75 years of age.  Of the estimated 1,330 people who died in the wake of Hurricane Katrina, most were older people.  In Louisiana, 71% of those who died were older than 60 years;  47% of this group were over 77 years old.  Worldwide, the United Nations High Commissioner for Refugees (UNHCR) has estimated that older people make up 8.5% of the overall refugee population, and in some cases comprise more than 30% of caseloads.  In 2005, approximately 2.7 million people over the age of 60 were living as refugees or internally displaced persons.

Globally, the proportion of older people is growing faster than any other age group.  In 2000 one in ten, or about 600 million, people were 60 years of age or older.  By 2025, this figure is expected to reach 1.2 billion people, and in 2050 around 1.9 billion.  In developing countries, where 80% of older people live, the proportion of those over 60 years old in 2025 will increase from 7% to 12%.  Moreover, life expectancy at birth has increased globally from 48 years in 1955 to 65 in 1995, and is projected to reach 73 in 2025.  By 2050, people over 80 years old are expected to account for 4% of the world’s population, up from 1% today.

Disability & Older People

Worldwide, it is estimated that more than 80% of the disabled population lives in developing countries, where the prevalence of disability is approximately 20%.  That rate is expected to increase dramatically as populations age.  By 2050 in India, the incidence of disability is expected to jump by 120%, in China by 70% and in sub-Saharan Africa by 257%.

Emergency Planners must consider these trends, because poor health and reduced mobility increase the risk of serious injury and illness in disasters.  Older people have sustained more injuries in disasters than other groups because of functional limitations such as poor balance, muscle weakness and exhaustion.  Older people have higher rates of coronary heart disease, diabetes, stroke, cancer, respiratory diseases and rheumatism.  A study in China found that 74% of those over 80 years old had chronic diseases, 1.5% were physically disabled, and 3.46% had Alzheimer’s disease.  In Iraq, more than half of 340 older people surveyed by HelpAge International had chronic joint and bone problems, hypertension, heart problems, diabetes and reduced eyesight and hearing.  In West Darfur, Sudan, 34% of surveyed refugees 50 years of age and over were disabled, 27% could not move without help and 19% had severely impaired vision; while 61% reported chronic diseases that required specialized treatment and/or medicines that were not available.

Objective 1:   Increase Visibility and Raise Awareness among Health Agencies and Humanitarian Organizations about Older Peoples’ Needs and Priorities in Emergencies.

  • Mainstream and integrate issues related to older people and emergencies into existing policies and guidelines (i.e. emergency medicine, nutrition, protection, gender-based violence, participatory assessments and programming).  Include plans for older people in national policy and guideline documents.
  • Highlight the need to assist and protect older people as well as their capacities and contributions in rebuilding affected communities.
  • Develop inter-agency efforts to identify gaps, develop practice guidelines and provide training and education.
  • Promote better practice policies and documents among all stakeholders.
  • Collaborate with funders to increase humanitarian assistance to older people based on needs assessments and reflect these in funding proposal criteria.
  • Involve older people in developing emergency management activities to increase their visibility and ensure their needs are taken into account, for example, in shelter plans and locations.

Objective 2:   Develop Essential Medical and Health Resources for Older People in Emergency Practices.

  • Identify and include essential medicines for older people in emergency kits.  Include medicines for chronic diseases and other illnesses common among this social group.
  • Develop disability aid packages with equipment such as eyeglasses and walking sticks.
  • Develop education modules for health professionals on diseases common among older people, including HIV/AIDS.
  • Develop and disseminate guidelines for geriatric medicine in emergencies and humanitarian crises.
  • Within the health care system, ensure that conditions and needs common to older people are integrated into patient triage, clinical evaluation, treatment, the emergency medical response system and access to specialty care.
  • Ensure that nutritional guidelines for food distribution suitable for older people are integrated into health planning and response plans.
  • Ensure local development of guidelines for feeding older people, using locally available foods to the extent this is possible where populations depend on external food aid.
  • Implement gender-based analyses in planning and programme design to account for differences between older men and women in terms of both health needs and access issues.

Objective 3:   Develop Emergency Management Policies and Tools to Address Older Peoples’ Health-Related Vulnerabilities.

  • Integrate older peoples’ health needs and related issues into assessment tools and practices.
  • Develop community-based tools using disaggregated data to identify vulnerable older people.  Include formats to identify chronic health conditions, disabilities and nutritional needs.
  • Develop procedures to identify hidden and stay-behind older people.
  • Develop standardized tools to assess support needs of older people, including inter-generational and community care options.
  • Develop age-friendly standards and guidelines so that service and care environments are accessible to older people with disabilities.
  • In collaboration with older people, their families and communities, develop personal and household preparedness kits in areas of predictable disasters.
  • Collaborate with communities in identifying and implementing community-based home care and support strategies which may reduce older peoples’ isolation and vulnerability during crises.
  • Develop guidelines and evacuation plans that include mechanisms to identify and transport frail, disabled and older people with special medical conditions.  Identify procedures to ensure adequate care and treatment as necessary.
  • Develop guidelines to ensure safe and adequate treatment of older people in evacuation centres and refugee camps.
  • Ensure that health facilities have feasible plans to care for older people during disasters and humanitarian crises.
  • Develop monitoring and evaluation tools to measure the performance of health care services and humanitarian interventions targeting older people.  These measures should be integrated into existing monitoring and evaluation procedures where possible.

Objective 4:   Ensure that Older People are Aware of and Have Access to Essential Emergency Health Care Services.

  • Use established assessment tools to identify and locate frail and disabled older people and those with chronic diseases and special medical conditions, as well as older caretakers of orphaned children.
  • Ensure that assessments are participatory and target all older populations.  Assessments should include information on health conditions, social support needs, caretaking responsibilities and available means to meet basic living needs, including access to food and health services, treatment and medicines.
  • Ensure that assessments are coordinated across primary health care, rehabilitation, long term care and social services to meet the needs of older people.
  • Implement outreach services and referral mechanisms to identify and ensure care for hidden or stay-behind older people.
  • Coordinate primary health care, rehabilitation, long-term care and social services to establish system referral mechanisms that older clients may require.
  • Assess and organize training for health staff to ensure knowledge of geriatric nutritional, health and medical care needs.
  • Establish information programmes to educate older people, families and caregivers about nutritional needs, medical conditions and health care options.
  • Use disaggregated data to assess services by age and gender.

Objective 5:   Provide Age-Sensitive and Appropriate Health and Humanitarian Services to Maintain Older Peoples’ Health.

  • Ensure that equitable access to shelter, clothing, food and sanitation prevent deterioration of health through integrated individual assessments and referrals to health and humanitarian agencies.
  • Ensure that age-friendly practices are used to promote services to older people with disabilities.
  • Provide access to appropriate health care, including medicines for chronic diseases and disability/restorative aids.
  • Collaborate with communities in identifying community-based home care and support options for frail and disabled older people.
  • When appropriate and feasible, develop mobile clinics to extend health services to older people living in remote locations.
  • Implement mechanisms to assess nutritional balance and ensure access to supplementary food programmes when appropriate, taking into account that many older people also care for children.  Provide education on food preparation using supplementary or locally available foods.
  • Ensure that protection needs of older people are integrated into programming (e.g. social welfare or community services) to identify persons at risk and prevent abuse and exploitation.
  • Undertake monitoring to assess continuing effectiveness of services to older people.
  • Use disaggregated data to assess efficiency of implemented activities by age and gender.

Objective 6:   Promote Cross-Sectoral Planning and Co-Ordination to Raise Awareness of Older Peoples’ Needs in Crises and Reduce Their Risk of Marginalization and Deteriorating Health in Emergencies.

  • Raise awareness among agencies and organizations concerning physical and health issues specific to older people and of ways to adapt basic need support to their requirements (e.g. supplementary food rations, livelihood needs and impacts of protection issues on older peoples’ physical and psychological health).
  • Where possible, include older people in planning and programming committees to increase their visibility and ensure their needs and priorities are integrated.
  • In coordination with appropriate partners, establish community self-help groups to facilitate community care for more vulnerable older people.
  • Recognize self-sufficiency as key to maintaining health and encourage the inclusion of older people in training programmes, income-generation schemes, and community development projects.
  • Establish older peoples’ committees to facilitate self-advocacy and communication with authorities and ministries of health to increase access to existing services and entitlements.

Objective 7:   Build Institutional Capacity and Commitment towards Ensuring the Health and Safety of Older People in Emergencies.

  • Integrate cross-cutting health emergency management issues into global/regional/country strategic plans.
  • Promote inter-agency and cross-sectoral consultation on cross-cutting policy and programming issues to build consensus, commitment and capacity to respond to older peoples’ needs in disasters and humanitarian crises.
  • Collaborate with ministries of health to establish mandates and legislation ensuring the provision of care to older people; apply a human rights framework to these issues.
  • Collaborate with ministries of health to develop options to increase older peoples’ access to affordable health care services, including the implementation of subsidized medical and medicine programmes.
  • Advocate for enhanced funding and humanitarian assistance to older people in emergencies and conflicts.  Encourage funding agencies to recognize older people as a priority.
  • Develop frameworks to promote participatory, transparent and accountable processes to advance the needs of older people.
  • Develop sustainable mechanisms to maintain advocacy and consultation of older people within the health care-system.  Establish and involve advocacy committees in the planning, implementation and evaluation of emergency management practices when appropriate, for example regarding the design of community shelters that may be accessed by older disabled people.

Objective 8:   Strengthen the Capacity of Ministries of Health and Health Care Systems to Meet the Needs of Older People in Emergencies.

  • As required, integrate the medical and nutritional needs of older people into local public health and emergency preparedness and response strategies.
  • Develop strategies to ensure that existing health care systems develop capacity (infrastructure and knowledge) to meet the increasing proportion of older people who will be impacted by disasters in the future, taking into account medical, disability and mental health needs, including dementia and Alzheimer’s disease.
  • Collaborate with communities in identifying community-based home care and support strategies for older people as an option to reduce older peoples’ isolation and vulnerability to disasters.
  • Collaborate with communities to develop and maintain disaster reduction committees.  Assist in the implementation of strategies to strengthen community support to older people and reduce their levels of risk during disasters (e.g. development of community emergency response teams or mutual assistance groups among more vulnerable older people).
  • Integrate older peoples’ needs into exercise designs and facilitate the dissemination of lessons learned.
  • Develop performance frameworks and monitoring mechanisms to assess medical response systems and older peoples’ access to specialty care in emergencies.

Objective 9:   Develop Mechanisms to Ensure Continuing Development and Exchange of Expertise as these Relate to Older People in Emergencies.

  • Develop and provide ongoing training and education to staff on the needs and priorities of older people, including responsibility to include this population in planning and policy development.
  • Integrate issues related to older people in emergencies into relevant university curricula.
  • Undertake comparative research to assess the health status (including access to assistance) of older people in emergencies vis-à-vis other age groups.
  • Undertake research to address demographic shifts and the increasing proportion of older people in disasters as this relates to health care and infrastructure/facility development.
  • Ensure emergency preparedness and response considerations are integrated into relevant services and institutions (e.g. facilities caring for frail and disabled older people are required to develop and practice evacuation and emergency care plans).

Objective 10:   Promote Active Ageing as a Strategy to Reduce Vulnerability and Develop Resiliency to Disasters.

  • Promote a wider understanding among ministries of health and humanitarian organizations of the economic and social factors contributing to the vulnerability of older people, including issues related to livelihoods, inter-generational dependence and social pension.
  • Develop policies that recognize active ageing and resiliency as facilitating older peoples’ capacity to prepare for, cope with and respond to the affects of disasters and conflicts.
  • Include a life course perspective that recognizes health promotion and prevention of disease and disability.
  • Support cross-sectoral forums and activities which link the risks of older people in emergencies to frameworks for livelihoods, protection and gender-based equality, health promotion and social pension.
  • Collaborate with relevant organizations to mainstream the health needs of older people into existing humanitarian programmes addressing shelter, nutrition, livelihoods, protection and gender-based violence.
  • Develop information campaigns and encourage media to highlight both the needs and capacities of older people and to increase their visibility.
  • Collaborate with funding bodies to integrate active ageing as a criterion in funding proposals targeting older people.

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Disability Access Certificates & Accessible Toilet Facilities ? (III)

2009-10-31:  Missing so far in Ireland … but an essential starting point for any discussion about Disability & Accessibility of the Built Environment in many other countries … is the 2006 United Nations Convention on the Rights of Persons with Disabilities, which entered into force, i.e. became an International Legal Instrument, on 3rd May 2008.

This Convention is important because it facilitates access, for a large group of people in all of our communities, to the Rights, i.e. basic needs, of all human beings … which were first elaborated in the 1948 Universal Declaration of Human Rights.  Until now, access to Universal Rights has effectively been denied to people with disabilities.

How is Ireland responding to the UN Convention ?

Ireland signed the Convention on 30th March 2007 … but has still not signed the Convention’s Optional Protocol.  Furthermore … even though other European Union Member States have proceeded to ratify both the Convention and the Optional Protocol on their own, without waiting for all Member States to act in unison … Ireland has not ratified either.  Why is that ???

On the positive side … and at the time of writing …

  • 143 countries, including Ireland, have signed the Convention ;
  • 87 other countries have signed the Optional Protocol ;
  • 71 other countries have ratified the Convention ;
  • 45 other countries have ratified the Optional Protocol.

2006 UN Convention on the Rights of Persons with Disabilities (CRPD)

Click the Link above to read/download PDF File (215 Kb) 

With regard to Accessibility … refer, initially and directly, to Preamble Paragraph (g) and Articles 9 & 11 of the Convention.

[As a matter of routine in all of our work, I prefer to go beyond the scope of the 2006 Disability Rights Convention … and to consider Accessibility for All, i.e. including People with Activity Limitations (2001 WHO ICF), to the Human Environment.]

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Accessibility Implementation in Ireland, and Toilet Facilities

How more basic can you get in every day life and living ?

The WC Cubicle shown in Diagram 13 of the existing Technical Guidance Document M does not work … a black and white / open and shut case.  It has not worked for a long, long time.   It is not ‘accessible’.   Should this come as a sudden surprise to anybody ?   No.

That toilet arrangement dates back to guidance documentation published by the Irish National Rehabilitation Board (NRB) in the early 1980’s.  And since that guidance took a long time to produce … we are talking about well before the end of the 1970’s as its true date of origin.  I know, because I was there … and I have the T-Shirt !

I am not going to show that Diagram here, because I don’t want to encourage anybody to reproduce it again in a ‘real’ building … for any reason whatsoever !

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Nearly 30 years later (!) … the Wheelchair Accessible Unisex WC shown in Diagram 12 of Draft Technical Guidance Document M (2009) is not a significant improvement on the earlier version.  In fact, it is a miserable effort !   And … I am not going to show that Diagram here either … for the same reason.

What I would like to present, however, are Figures 43 & 44 from the Draft International Accessibility-for-All Standard ISO 21542.  This is the level of accessibility performance which we should all be striving to achieve … as a minimum ! 

2 colour drawings showing, on top, an Accessible Toilet Facility, with corner WC arrangement ... and, on the bottom, showing that there is sufficient space for a range of wheelchair to WC transfer options.
2 colour drawings showing, on top, an Accessible Toilet Facility, with corner WC arrangement … and, on the bottom, showing that there is sufficient space for a range of Wheelchair-to-WC transfer options. Click to enlarge.

N.B. A standard, large Wash Hand Basin must no longer be considered as an optional extra in a properly fitted out Accessible Toilet Facility.

Please also note the independent water supply, on the wall side of the corner WC, feeding a shower head type outlet which can be turned on or off at the outlet head … or within easy reach of the WC.  This is Accessibility-for-All in action !

Colour photograph showing what is supposed to be an 'Accessible' Toilet Facility, with a combined Baby Change Facility.  Inadequate management magnifies the already poor accessibility performance of the cramped space.  Click to enlarge.  Photograph taken by CJ Walsh.  2009-09-19.
Colour photograph showing what is supposed to be an ‘Accessible’ Toilet Facility, with a combined Baby Change Facility. Inadequate management magnifies the already poor accessibility performance of the cramped space. Click to enlarge. Photograph taken by CJ Walsh. 2009-09-19.

Many building owners/managers wish to combine an Accessible WC Cubicle with a Baby Change Facility.  More space is required, therefore, above and beyond that shown in the Figures above for the Baby Change fittings and associated ‘equipment’.

Without Proper Accessibility Management … Accessibility Performance will rapidly deteriorate … as shown in the above photograph.

Once we have mastered the minimum building accessibility performance required to meet the needs of a single person with an activity limitation … our next priority must be the Social Dimension of Accessibility.  Existing Building & Fire Regulations, Standards and Design Guidance are still geared very much towards the single building user.  However, for example, if 5 or 6 or 8 wheelchair users decide to use a building’s facilities … not a concept which is off-the-wall (!) … there is almost a complete breakdown and failure in accessibility.  This is no longer acceptable !!

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Building Fire Emergencies – What is a ‘Place of Safety’ ?

2009-10-24:  As I have travelled around … not just Ireland, but many other countries as well … it still remains a puzzle to me, today, why so many Fire Emergency Assembly Areas are located just outside the main entrance of a building.  These locations are not safe in a ‘real’ fire emergency … and they should not even be used for the purposes of test/drill evacuations !

Is the guidance contained in current Building & Fire Regulations, Codes and Standards on what is a ‘Place of Safety’ in a fire emergency clear, simple, direct and precise ?   Are you joking ?   No way !   Let us take a few examples close to home …

In Ireland:

When you look at the array of different Technical Guidance Documents (Building Regulations) at the same time … TGD B (Fire Safety) is way out of proportion, in size, compared to all of the others.  You would expect, therefore, to find exactly what you were looking for in that document.  Wouldn’t you ?

TGD B (2006), Paragraph #1.0.9 – Definitions

Place of Safety

A place, normally in the open air at ground level, in which persons are in no danger from fire.

Clear as mud !   If there is a fire on O’Connell Street in Dublin … a person is safe on Patrick Street in Cork !   But, how is any Building or Facilities Manager expected to work with such a vague definition ? 

In England & Wales:

No practical definition, as such, is readily provided.  The nearest thing to a definition is an amalgam of the following …

Building Regulations, Requirement B1 – Means of Warning & Escape

The building shall be designed and constructed so that there are appropriate provisions for the early warning of fire, and appropriate means of escape in case of fire from the building to a place of safety outside the building capable of being safely and effectively used at all material times.

Approved Document B: Volume 1 – Dwellinghouses & Volume 2 – Buildings Other Than Dwellinghouses

The ultimate place of safety is the open air clear of the effects of the fire.

British Standard BS 9999 : Code of Practice for Fire Safety in the Design, Management & Use of Buildings : 2008

Place of Ultimate Safety

Place in which there is no immediate or future danger from fire or from the effects of a fire.

Again … all as clear as mud !   Again … how is any Building or Facilities Manager expected to work with such vague guidance ?   Have you also noticed the additional obfuscation introduced by use of the word ‘ultimate’ in BS 9999 ?

It is hard to escape the conclusion that what is urgently needed is a fundamental transformation and re-shaping of the tired, antiquated and flawed ad-hoc assembly of prescriptive ‘solutions’ contained in current national building and fire regulations, codes, standards and administrative provisions … whatever their origin !

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Now … try this for clarity, simplicity, directness and precision …

Place of Safety (Fire Incident in a Building, No Explosion Hazard*)

Any location beyond a perimeter which is [100]* metres from the fire building or a distance of [10]* times the height of such building, whichever is the greater

and

where necessary and effective medical care and attention can be provided, or organized, within one hour of injury

and

where people can be identified.

* Where there is a Risk of Explosion … multiply the numbers in square brackets above by 4.

Was that good for you ?

Furthermore …

The Route to any Place of Safety must be Accessible for All Building Users, including people who use wheelchairs, the visually impaired, frail older people, women in the later stages of pregnancy, children, etc., etc.

Colour photograph showing a Typical Scene at a Building Fire Emergency, with Fire Service Vehicles and Personnel in operation mode.  The haphazard arrangement of firefighting water hoses on the ground makes access difficult for many Building Users to a 'Place of Safety' which is remote from the Fire Building.
Colour photograph showing a Typical Scene at a Building Fire Emergency, with Fire Service Vehicles and Personnel in operation mode. The haphazard arrangement of firefighting water hoses on the ground makes access difficult for many Building Users to a ‘Place of Safety’ which is remote from the Fire Building. Click to enlarge.

With regard to an Adequate, never mind a Proper, Awareness of Disability-Related Issues at a Fire Scene … it is shocking to realize how almost non-existent this is among Fire Services … not just in Ireland and Britain … but in the rest of Europe and North America as well.

Even a hint of criticism will usually … not always … meet the Neanderthal Fire Service Response: “Have you ever been in a ‘real’ building fire ?”

My Response is: “Do you have to be a hen to know when an egg is bad ?”

This discussion will continue later … have no doubt … that is a promise !

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Disability Access Certificates (DAC’s) – Parts M & B ? (II)

2009-10-18:  In everyday practice, the usual short introductory text in Technical Guidance Document M (Ireland) which refers to a linkage between ‘access and use’ of a building with ‘fire safety’ has little impact, because it is not explained … and is typically ignored.

In general … the basic problem is that this issue is hardly dealt with … at all … by Local Fire Authorities right across the country in their handling of Fire Safety Certificates … and where it does become part of the process, it receives inadequate attention.  There are exceptions.

A major drawback with the current vertical approach to our Building Regulations … each of the Parts has its own separate Supporting Technical Guidance Document … is that people are not sufficiently aware of the important horizontal linkages between the different Parts.  For example, all of the other Parts must be linked to Part D.  Quick, run to find out what Part D covers !   Another two examples … Part B must also be linked to Part A and Part M … and Part M must also be linked to Part K and Part B.

So … while grudgingly having to accept that the scope of TGD M should have some limit, under the current flawed system … a precise intervention with just one or two sentences, at critical places in the guidance text, would help to improve the overall consideration of fire safety issues, relevant to Part M, by building designers … and client or construction organizations.

Here are a Few Suggestions for Discussion …

1.  Revise Paragraph #0.6 of Draft TGD M (2009) & Add a Title …

Fire Evacuation for All

” Accessibility encompasses the full range of activity related to buildings: to approach, enter, use, egress from under normal conditions, and evacuate a building independently during a fire emergency, in an equitable and dignified manner.  Provision for access and use must, therefore, be linked to provision for fire evacuation.  For guidance on design for evacuation, reference should be made to Technical Guidance Document B (Fire Safety).”

Note:  No such guidance is contained in TGD B (2006).  It would be a great wonder if any person with a disability could actually evacuate a building which had been designed in accordance with TGD B.  To take a simple example … all of the ‘stairways’ in Table 1.5 of TGD B – Minimum Width of Escape Stairways will not facilitate contraflow or the assisted evacuation of mobility and visually impaired people.  Furthermore, those minimum widths specified in the Table may have a clear width which is 200 mm less.  See Methods of Measurement, Paragraph #1.0.10 (c) (iii) … ” a stairway is the clear width between the walls or balustrades, (strings and handrails intruding not more than 30 mm and 100 mm respectively may be ignored) ” !   What an incoherent mess !!

2.  Insert New Sentence at the End of Paragraph #1.1.1 of Draft TGD M (2009) …

Objective (Approach to Buildings)

” Consideration should be given to the use of the approach and circulation routes around a building as accessible routes to a ‘place of safety’ during a fire emergency.”

3.  Insert New Sentence at the End of Paragraph #1.2.1 of Draft TGD M (2009) …

Objective (Access to Buildings)

” Consideration should be given to the use of all entrances to a building as accessible fire exits during a fire emergency.”

4.  Insert New Paragraph at the End of Paragraph #1.3.4.1 of Draft TGD M (2009) …

Passenger Lifts

” Manual handling of occupied wheelchairs in a fire evacuation staircase, even with adequate training for everyone directly and indirectly involved, is hazardous for the person in the wheelchair and those people – minimum three – giving assistance.  The weight of an average unoccupied powered wheelchair, alone, makes manual handling impractical.  Lifts in new buildings should, therefore, be capable of being used for evacuation in a fire situation.  For guidance on the use of lifts for fire evacuation, reference should be made to Technical Guidance Document B (Fire Safety).”

5.  Insert New Paragraph and New Sentence at the End of Paragraph #1.3.4.2 of Draft TGD M (2009) …

Internal Stairs

” To allow sufficient space to safely carry an occupied wheelchair down or up a fire evacuation staircase, and to accommodate contraflow, i.e. emergency access by firefighters entering a building and moving towards a fire, while people are still evacuating from the building to a ‘place of safety remote from the building, the clear unobstructed width (exclusive of handrails and any other projections, e.g. portable fire extinguishers, notice boards, etc.) of the flight of a single, or multi-channelled, stairs should not be less than 1 500 mm.  The surface width of a flight of stairs should not be less than 1 700 mm.”

Note:  See Footnote (5) to Table 1.5 in TGD B (2006) … ” The minimum widths given in the table may need to be increased in accordance with the guidance in TGD M: Access for People with Disabilities.”   DUH ?

And …

” For the purpose of safe assisted fire evacuation of people, the rise of a step should not have a height greater than 150 mm, and the going of a step should not have a depth less than 300 mm.”

6.  Insert New Sentence at the End of Paragraph #1.5.1 of Draft TGD M (2009) …

Objective (Facilities in Buildings)

” Consideration should be given to the use of relevant facilities within a building, by people with disabilities, for the purposes of fire safety, protection and evacuation.”

7.  Insert New Sentence at the End of Paragraph #1.6.1 of Draft TGD M (2009) …

Objective (Aids to Communication)

” Consideration should be given to the use of relevant aids to communication, by people with disabilities, for the purposes of fire safety, protection and evacuation.”

Note:  More guidance could be provided under each of the individual paragraphs of Section #1.6 of Draft TGD M (2009).  See Draft International Accessibility-for-All Standard ISO 21542.

8.  Insert New Section #2.6 of Draft TGD M (2009) …

Fire Safety in Dwellings for People with Disabilities

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Disability Access Certificates (DAC’s) – A Time to Worry ? (I)

2009-10-17:  Some of you are already hitting the Internet Search Engines … with fierce intent altogether … about  Disability Access Certificates (DAC’s) !

Is it Time to Panic ?   No.

For a simple and direct hit, the 2 most relevant Irish Legal Instruments are:

1.  Statutory Instrument No. 352 of 2009 – Building Control Act 2007 (Commencement) Order 2009.

This states …

” The 30 September 2009 is appointed as the day on which the provisions of Sections 5 and 6 of the Building Control Act 2007 shall come into operation.”

Section 5 covers the Amendment of Section 6 (Building Control Regulations) of the Building Control Act 1990.

Section 6 covers the Amendment of Section 7 (Appeals) of the Building Control Act 1990.

2.  Statutory Instrument No. 351 of 2009 – Building Control (Amendment) Regulations 2009.

This states …

” These Regulations shall come into effect on 1 October 2009, except for the provisions of Article 8 which shall come into effect on 1 January 2009.”

Article 8 covers Disability Access Certificates and Revised Disability Access Certificates.

For you, yourself, to properly examine all of the ‘ins and outs’ of this New Certification Scheme … download the PDF File below … and then search the document (making sure that it is not case-sensitive !) using the phrase ‘Disability Access Certificate’.  You will find 99 instances where the phrase is used.

Enjoy !

Ireland: Statutory Instrument No. 351 of 2009 – Building Control (Amendment) Regulations 2009

Click the Link above to read/download PDF File (223 Kb)

In order to make full sense of all that is happening, and is intended to happen in the not too distant future … there are a few other Legal Instruments, related to the two listed, which also need to be consulted … but that is an exercise meant for masochists !

In comparison, the European Union Lisbon Treaty was a sweet bedtime story !   Seriously !!

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Is it Time to Worry ?   Yes.

Here are just a few random ideas for your cogitation …

  • If the Department of the Environment, Heritage & Local Government (DEHLG) pays little heed to Submissions made during and after this summer’s ‘consultation’ process … the proposed New Technical Guidance Document M: ‘Access & Use’ will end up looking like a real dog’s dinner of an absolute mess !   FUBAR.

Years were spent in the preparation of the New TGD M.  When it does eventually appear, it will be an accurate reflection of technical capacities within both the Department and the National Disability Authority (NDA).

Deeply regretted is the absence of Mr. Kevin Spencer … a gentle soul … from the DEHLG.  Things have not been the same since his departure.  He knew what he was talking about.

  • Who will deal, at a technical level, with Applications for Disability Access Certificates in the Local Authorities ?   Will they be competent to do so ?   Will their interpretation of the Part M Legal Requirements be harmonized … not just with other/different Authorities … but even with other technical personnel in the same Authority ???
  • In order to make this new certification scheme work, will the Guidance Text in Technical Guidance Document M (whatever version appears !) be operated as if it were Prescriptive Regulation … which will be totally illegal ?

This has been exactly the story … for many years … with the Guidance Text in Technical Guidance Document B … in the course of operation of the Fire Safety Certification Scheme.  FUBAR.

  • If, as I hinted above, the proposed New Technical Guidance Document M: ‘Access & Use’ will be a real dog’s dinner of a mess … falling far short of what can now be reasonably described as minimal accessibility performance (see the Draft International Accessibility-for-All Standard ISO 21542) … this will certainly open Building Owners/Managers of newly completed buildings to Complaints under Irish Equality Legislation.  Why is the Disability Sector so inactive with regard to making complaints ?

and finally …

  • Are the relevant Irish Decision Makers, as I suggested might happen in a previous post, in the process of actually sleepwalking into an unquestioned acceptance of the inadequate British Standards BS 9999 : 2008 and BS 8300 : 2009 ???   Do they know how to do anything else ?

 

For some sublime moments of meditation, however, please chew on the information provided at these Pages on the SDI Support WebSite

Disability Rights & Removing Physical Restrictions on Participation in Society ;

Towards a Sustainable Social Environment, Accessibility-for-All & Facilitation Design (2001 WHO ICF) ;

Fire Evacuation-for-All & Principles of Fire Engineering.

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