Ar C.J. Walsh Technical Blog – Registered Architect, Fire Engineer & Independent Technical/Building Controller …… International Expert on Accessibility for All (including Fire Safety) + 'Real' Sustainability Implementation !
2009-10-07: As previously discussed … but deserving much repetition … the 2006 United Nations Convention on the Rights of Persons with Disabilities (CRPD) became an International Legal Instrument, i.e. entered into force, on 3rd May 2008.
This UN Convention simply aims to ensure that persons with disabilities are able to access human rights on the same basis as everyone else in society. And rights are no more than an elaboration of the responsible basic needs of all human beings.
It is worth recalling that the 1948 Universal Declaration of Human Rights was directly born out of the large-scale death, human misery and environmental destruction of the Second World War in Europe, North Africa, the Middle-East … and throughout Asia and the Pacific.
Human Rights must have – do have – ‘real’ meaning in a civilized society !
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Israel signed the UN Disability Rights Convention on 30th March 2007. At the time of writing, it has not yet signed the Convention’s Optional Protocol. Israel has definitely not ratified the Convention or the Optional Protocol.
[To be fair, Ireland is in exactly the same position as Israel. Why am I not surprised ?!?]
With regard to Situations of Risk, e.g. a fire emergency in a building … or Humanitarian Emergencies, e.g. the Gaza Conflict from December 2008 to January 2009 … the language of Article 11 in the UN Convention is very clear and straightforward:
” States Parties shall take, in accordance with their obligations under international law, including international humanitarian law and international human rights law, all necessary measures to ensure the protection and safety of persons with disabilities in situations of risk, including situations of armed conflict, humanitarian emergencies and the occurrence of natural disasters.”
On 3rd April 2009, the President of the UN Human Rights Council established the United Nations Fact Finding Mission on the Gaza Conflict with the mandate “to investigate all violations of international human rights law and international humanitarian law that might have been committed at any time in the context of the military operations that were conducted in Gaza during the period from 27 December 2008 and 18 January 2009, whether before, during or after.”
The President appointed Justice Richard Goldstone, former judge of the Constitutional Court of South Africa and former Prosecutor of the International Criminal Tribunals for the former Yugoslavia and Rwanda, to head the Mission. The other three appointed members were:
Professor Christine Chinkin, Professor of International Law at the London School of Economics and Political Science, who was a member of the high-level fact finding mission to Beit Hanoun (2008) ;
Ms. Hina Jilani, Advocate of the Supreme Court of Pakistan and former Special Representative of the Secretary-General on the situation of human rights defenders, who was a member of the International Commission of Inquiry on Darfur (2004) ; and
Colonel Desmond Travers, a former Officer in Ireland’s Defence Forces and member of the Board of Directors of the Institute for International Criminal Investigations.
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The Report of the Fact Finding Mission on the Gaza Conflict was presented to the Human Rights Council, in Geneva (Switzerland), on 29th September 2009.
The following is a short extract from that Report …
Section A – XVII The Impact of the Blockade and of the Military Operations on the People of Gaza and their Human Rights
I Persons with Disabilities (Paragraphs 1283-1291)
1283 Information provided to the Mission showed that many of those who were injured during the Israeli military operations sustained permanent disabilities owing to the severity of their injuries and/or the lack of adequate and timely medical attention and rehabilitation. Gaza hospitals reportedly had to discharge patients too early so as to handle incoming emergencies. Other cases resulted in amputations or disfigurement. About 30 per cent of patients were expected to have long-term disabilities.
1284 WHO reported that by mid-April 2009 the number of people with different types of permanent disability (e.g. brain injuries, amputations, spinal injuries, hearing deficiencies, mental health problems) as a result of the military operations was not yet known. It reported speculations that there might be some 1000 amputees; but information provided by the WHO office in Gaza and based on estimates by Handicap International indicated that around 200 persons underwent amputations.
1285 While the exact number of people who will suffer permanent disabilities is still unknown, the Mission understands that many persons who sustained traumatic injuries during the conflict still face the risk of permanent disability owing to complications and inadequate follow-up and physical rehabilitation.
1286 The Mission also heard moving accounts of families with disabled relatives whose disability had slowed their evacuation from a dangerous area or who lived with a constant fear that, in an emergency, their families would have to leave them behind because it would be too difficult to evacuate them.
1287 One testimony concerned a person whose electric wheelchair was lost after his house was targeted and destroyed. Since the residents were given very short notice of the impending attack, the wheelchair could not be salvaged and the person had to be taken to safety on a plastic chair carried by four people.
1288 The Mission also heard a testimony concerning a pregnant woman who was instructed by an Israeli soldier to evacuate her home with her children, but to leave behind a mentally disabled child, which she refused to do.
1289 Even in the relative safety of shelters, people with disabilities continued to be exposed to additional hardship, as these shelters were not equipped for their special needs. The Mission heard of the case of a person with a hearing disability who was sheltering in an UNRWA school, but was unable to communicate in sign language or understand what was happening and experienced sheer fear.
1290 Frequent disruptions in the power supply had a severe impact on the medical equipment needed by many people with disabilities. People using wheelchairs had to face additional hurdles when streets started piling up with the rubble from destroyed buildings and infrastructure.
1291 In addition, programmes for people with disabilities had to be closed down during the military operations and rehabilitation services stopped (for instance, organizations providing assistance were unable to access stocks of wheelchairs and other aids). Many social, educational, medical and psychological programmes have not yet fully resumed.
2009-09-08: It is really enjoyable to be back behind my desk, here in Dublin. Apologies for the prolonged absence.
Since the middle of June last, my travels have taken me to Turkey, France, Italy, the south-west of Ireland to attend my cousin’s wedding in Cork … and back again to Bengaluru (Bangalore) in Southern India to make an important Keynote Presentation at the 2009 Fire & Safety Association of India (FSAI) National Fire Seminar: ‘Engineering a Safe & Secure India’, which was held on Friday, 28th August, at the Leela Palace Hotel.
My Presentation Title & Abstract …
Sustainable Fire Engineering: Fire Safety, Protection & Evacuation for All
India, like other economically advanced developing countries, is at an important crossroads. Difficult, resource-dependent decisions must be made in the next few short years concerning the rapid implementation of a Sustainable Built Environment across a vast country, i.e. one which must serve local needs and meet regional performance requirements during a long life cycle … one which will be adaptable to climate change, variability and extremes … will be in harmony and dynamic balance with the Natural Environment … and, not least, will be super energy-efficient.
Citizens of Developed Nations also have legitimate expectations. They will express anger when they witness recently constructed buildings in seismic zones collapse, in an earthquake, like a deck of cards (China 2008, Italy 2009) … or they discover that federal/state authorities having jurisdiction, which are funded by their taxes, are ill-prepared to respond effectively to intentional traumatic disruptions to the Social Environment (New York 2001, Mumbai 2008). Retaining the public’s confidence in national institutions is a fundamental political priority.
In the case of all new High-Rise Buildings, Iconic Buildings, and Buildings of Innovative Design or having a Critical Function … Trans-Disciplinary Building Design Teams must, at a minimum, properly respond to the Recommendations of the 2005 & 2008 NIST(USA) Final Reports on the 9-11 WTC 1, 2, and 7 Collapses. In practice, the majority of these Recommendations should be applied to the design of all new buildings !
Fire Engineers, competent concerning the processes of ‘real’ building design and construction, must begin to understand the ‘real’ people who occupy or use buildings, every day of every week, in all parts of India … and that they each have widely differing ranges of human abilities and activity limitations. Just as they are different from each other, they will react differently than expected in a ‘real’ building fire emergency.
Based on a Keynote Presentation before International Council for Building Research (CIB) Working Commission 14 : Fire and Sub-Committee 3 & 4 Members of ISO Technical Committee 92 : Fire Safety, at Lund University in Sweden … and his fire safety texts which have been fully incorporated into International Standard ISO DIS 21542 on Accessibility-for-All, currently under development and due for publication before the end of 2010 … CJ Walsh’s Presentation, at the FSAI National Fire Seminar in Bengaluru, will focus on ‘Fire Safety, Protection & Evacuation for All’.
2009-07-11: Practical Implementation of Sustainable Human & Social Development … transforming our Human Environment by gradually improving and monitoring ‘Real’ Sustainability Performance … depends entirely on directly applying a Multi-Aspect Understanding of ‘Sustainability’, in a manner which is both balanced and equitable, to all of the many different facets of Sustainable Design.
Therefore … responding ethically and professionally, in built and/or wrought (worked) form, to the still evolving concept of Sustainable Human & Social Development …
… the specific aim of Sustainable Fire Engineering shall be to design for Maximum Credible Fire & User Scenarios … in order to maintain a proper and satisfactory level of fire safety and protection over the full life cycle of a building.
[Sustainable Fire Engineering can be applied, equally, to other elements of the Built Environment, e.g. means of transport on land or sea.]
As discussed in a previous post … the Minimum Life Cycle of a Sustainable Building is 100 Years. AND, to prolong Building Life Cycle and maximize Building Usability … such a building must be Flexible and Adaptable with regard to internal layout, Accessible for People with Activity Limitations (2001 WHO ICF) … and Structurally Robust.
Maximum Credible Fire Scenario:
A sequence of events during a ‘real’ fire incident in a building – related to design, construction, occupancy, fire loads, ignition sources, spatial geometry, fire protection measures (both passive and active) … and an adverse, but reasonable to anticipate, operation and management status – which culminates in fire conditions which are severe, but reasonable to anticipate over a complete building life cycle.
Maximum Credible User Scenario:
Indicates building user conditions which are also severe but reasonable to anticipate over a complete building life cycle, i.e. …
the Number of People Using a Building increases, on occasions which cannot be specified, to 120% of Calculated Maximum Building Capacity ;
and
10% of People Using the Building (occupants, visitors & other users) have an Impairment (visual or hearing, physical function, psychological, mental or cognitive … with some impairments not being identifiable, e.g. anosognosia).
Sustainable Fire Engineering Strategy:
A coherent and purposeful arrangement of fire protection and fire prevention measures which is developed in order to meet specified Sustainable Fire Engineering Design Objectives.
In designing a building for conditions of fire, and its aftermath, project-specific Sustainable Fire Engineering Design Objectives typically cover the following spectrum of concerns …
Protection of the Health and Safety of All Building Users … including people with activity limitations, visitors to the building who may be unfamiliar with its layout, and contractors or product/service suppliers temporarily engaged in work or business transactions on the premises ;
Protection of Property … including the building, its contents, and adjoining or adjacent properties, from loss or damage ;
Protection of the Health and Safety of Firefighters, Rescue Teams and other First Response Personnel ;
Protection of the Natural Environment from Harm, i.e. adverse impacts ;
Facility, Ease and Cost of carrying out Effective Repair, Refurbishment and Reconstruction Works after the Fire ;
Sustainability of the Human Environment (Social, Built, Virtual, Economic … ).
Human Health:
A state of complete physical, mental and social wellbeing, and not merely the absence of disease or infirmity. (World Health Organization)
2009-06-16: Further to one of our first posts, dated 12th December 2008 (or 2008-12-12 !), concerning the National Disability Authority’s 2008 Publication: ‘Promoting Safe Egress and Evacuation for People with Disabilities’ …
On 15th April 2009 … we were circulated by Mr. Shane Hogan (NDA), in a general e-mail communication which was not addressed to us … with a Proposed 2nd Draft of the Evacuation Document. Comments on this 2nd Draft were requested.
So … here are our comments …
1. We repeat the earlier statement that ‘the document has many technical errors’. It is clear that the National Disability Authority does not possess the requisite technical competence to oversee the proper development of such a publication.
Furthermore … many of the inadequate, flawed and discriminatory practices in relation to Fire Safety, Protection and Evacuation for All which have originated in Britain over many years … and are described yet again and most recently in BS 9999:2008 – Code of Practice for Fire Safety in the Design, Management and Use of Buildings (see previous post) … are just mindlessly regurgitated in the NDA Publication.
2. We very much believe in, and are promoters of, Open Content on the Internet. For that reason, SDI’s Copyright Guidelines are quite liberal. And … although we do reserve all rights … we also state that …
‘ Reproduction by others of content produced and/or developed by Sustainable Design International Limited is permitted, except for commercial purposes, provided the source is acknowledged.’
It is clearly shown in the NDA’s 2nd Draft that copyright material developed by FireOx International (the Fire Engineering Division of Sustainable Design International Ltd.) was used, and abused, by White Young Green Consultants (Ireland) in the original 2008 NDA Publication.
We do not wish technical terms to be altered … or our material to be linked directly with BS 8300:2009 – Design of Buildings and Their Approaches to Meet the Needs of Disabled People … and BS 9999:2008. Please re-read our previous post !
White Young Green Consultants (Ireland) gained commercially from the use of our copyright material. They did not inform us … nor did they request any permission from us … prior to that use.
Our material has been used again in the NDA’s 2nd Draft … and still nobody has bothered to seek our permission … for or about anything !
In order to at least appear to be acting ethically … perhaps somebody in the NDA, e.g. Ms. Mary Van Lieshout, Mr. Shane Hogan, Dr. Gerald Craddock or Ms. Angela Kerins might care to communicate directly with us now.
Finally, our private thoughts and feelings with regard to the actions of White Young Green Consultants (Ireland) shall remain just that … private !
Perhaps, however, White Young Green Consultants (Ireland) might cover the costs involved in consulting with our team of legal advisors.
2009-06-14: Ireland has no national standards or codes of practice of its own covering Building Accessibility or Fire Safety in Buildings. Instead, many people and organizations in this country will just switch to automatic pilot and – without thinking or questioning – adopt the following two standards of another jurisdiction as the default Irish National Standards …
British Standard BS 9999:2008 – Code of Practice for Fire Safety in the Design, Management and Use of Buildings … was published on 31 October 2008.
British Standard BS 8300:2009 – Design of Buildings and Their Approaches to Meet the Needs of Disabled People. This Code of Practice was published on 28 February 2009.
If Ireland does not quickly open its eyes … we will be sleep walking into a very problematic legal environment, as far as building accessibility and fire safety in buildings is concerned.
1. An Immediate Challenge
A Sub-Group (established at a meeting of the NSAI Accessibility-for-All Standards Consultative Committee WG1 held on Tuesday 2009-05-19) was tasked with developing a common position, suitable for application in Ireland and compatible with European Technical Harmonization, on the following issues:
Clear Width of Internal & External Door Openings ;
Turning Circles for Occupied Wheelchairs ;
Car Parking Spaces ;
Fire Safety Issues.
A series of coherent proposals will be presented to the next NSAI AASCC WG1 Meeting, on Friday 19th June 2009 … and, given the absence of Irish National Standards, it will also be suggested how these proposals may be confirmed as best current practice here.
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2. Overview of BS 8300:2009 & BS 9999:2008
During the development of the Draft ISO Accessibility-for-All Standard, it has been unanimously agreed that Accessibility encompasses the full range of activity related to buildings: to approach, enter, use, egress from and evacuate a building independently, in an equitable and dignified manner (Introduction, 2nd Paragraph, Page 5). ‘Egress’ under normal, ambient conditions is distinguished from ‘Evacuation’ in the event of a fire emergency. Use of the word ‘Escape’ is discouraged in any circumstance. For the first time, fire safety texts have been fully incorporated into the main body of the Draft ISO Standard.
Accessibility within the British Standards Institution (BSI), on the other hand, is still segregated between BS 8300:2009 – approach, entry and use and BS 9999:2008 – fire evacuation. Conflicts and gaps in content naturally result from such a configuration, which can now be seen as outdated and fundamentally flawed.
This configuration has been replicated, in Irish Building Regulations, with the separate scopes of Part M / Technical Guidance Document M and Part B / Technical Guidance Document B. Integration between these 2 Technical Guidance Documents is very poor. In practice, fire safety for people with activity limitations is widely disregarded within the process of Fire Safety Certification in Ireland.
2.1 BS 8300:2009
BSI has arrogantly gone on a solo run, and decided to deviate from some very widely accepted concepts of accessibility, e.g. ‘clear width’ of a door opening (discussed in more detail later). The ‘Ergonomic Research’ supporting door opening forces of 30 N is at complete variance with earlier research in Britain and must, therefore, be strongly questioned. Perhaps, it is the case that the Fire Services in England & Wales re-asserted their authority, supported by reference to European Fire Product Standards with little if any input from the European Disability Sector, and insisted on a ‘definite’, i.e. high, closing force being exerted on the door leaves in fire resisting doorsets.
2.2 BS 9999:2008
People with disabilities have a right, recognized in international law after 3rd May 2008, to equal opportunity and non-discrimination in matters of building fire safety, protection and evacuation. A minimum response to Article 11 (Situations of Risk) in the 2006 United Nations Convention on the Rights of Persons with Disabilities is required, therefore, from fire regulators and code writers. Such a response is absent in British Standard BS 9999:2008.
A close examination of the fire safety texts relating to ‘disability’ in BS 9999:2008 shows that they have not been properly integrated into the ‘mainstream’ content. In fact, much of the content from the replaced BS 5588:Part 8 has just been grafted onto BS 9999, with very little change or alteration from the first version of Part 8 published in 1988 !
Compare Figure G.1 on Page 360 of BS 9999:2008 … with … Figure 4 on Page 8 of BS 5588:Part 8:1988 … both are exactly the same …
Black and white drawing showing both a token and an inadequate ‘area of rescue assistance’ in BS 9999:2008 – exactly as shown in the first version of BS 5588:Part 8 published back in 1988 ! Click to enlarge.
Two Critical Observations in relation to the ‘area of rescue assistance’ shown above:
– This drawing in BS 9999:2008 is in direct conflict with the text located directly above it … ‘where the wheelchair space is within a protected stairway, access to the wheelchair space should not obstruct the flow of persons escaping’ ;
but, more importantly …
– In BS 9999:2008, fire safety for people with activity limitations receives treatment which is superficial and merely token. Many times in relation to buildings generally, it is stated in Annex G.1, Page 359 …
‘A refuge needs to be of sufficient size both to accommodate a wheelchair and to allow the user to manoeuvre into the wheelchair space without undue difficulty.’
‘ In most premises, it is considered reasonable to have refuges of a size where each one is able to accommodate one wheelchair user. Where it is reasonably foreseeable that the proportion of disabled users in a building will be relatively high, or where the use of the premises is likely to result in groups of wheelchair users being present (e.g. some types of sporting, entertainment, transport or public assembly buildings), consideration should be given to increasing the size and/or number of refuges accordingly.’
‘ NOTE 3 Managers of sporting or other venues where a number of disabled people might be present are advised not to restrict the number of disabled people who can be admitted to that venue on the grounds of the size of refuges, since some disabled people who use mobility aids such as a wheelchair will be able to self-evacuate in the case of a real fire.’
and again in Annex G.2.2 on Page 367 …
‘Where it is reasonably foreseeable that the refuges will be used by more than one user (e.g. some types of sporting, entertainment, transport or public assembly buildings), … ‘
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Within such an inadequate and token context, it is understandable that an unduly heavy reliance is placed on the practice of developing Personal Emergency Evacuation Plans (PEEPS) for individuals with activity limitations. See Paragraph #46.7a) on Page 248, which states …
‘ By taking into account the individual needs of a person when preparing a PEEP, management will be able to make any reasonable adjustments to the premises or procedures that are necessary.’
These Plans are flawed and discriminatory because they are:
– person specific ; and
– location specific ;
… with the underlying assumption in the text being that, beyond the specified location(s), the building is not properly accessible, i.e. does not meet the functional requirements of Parts B & M in the Building Regulations for England & Wales – or, in the case of Ireland, Parts B & M of our Building Regulations.
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There are silly technical errors in BS 9999:2008, e.g. in Annex G.2.3 on Page 368, it states …
‘Unless a different order has been agreed with the fire authority, evacuation should normally be in the following order:
1) the fire floor ;
2) the floor immediately above the fire floor ; [This should read ‘the floors immediately above and immediately below the fire floor’ !]
3) other floors above the fire floor starting at the top storey ;
4) all remaining floors.’
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A Technical Term is used in BS 9999:2008 – Place of Ultimate Safety – which complicates the already widely accepted term: ‘Place of Safety’. The definition provided for the British Term in Section 3: Terms & Definitions (#3.84, Page 17) is so vague that it is of no practical use to fire engineering designers, building managers or building users.
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3. Comments:i) Clear Width of Door Openings
Paragraph #6.4.1, on Page 36 of BS 8300:2009 introduces a new understanding of ‘clear width’ for door openings, which is illustrated in Figure 11 (Page 37) … and also a new term ‘effective clear width’.
The new understanding of ‘clear width’ is a complete departure from the standard understanding, widely accepted throughout the world, which is shown in the bottom left hand drawing of Figure 11.
The new term ‘effective clear width’ will complicate the already difficult concept of ‘clear width’. Wasn’t the ‘clear width’ of a door opening always supposed to be ‘effective’, i.e. properly permit circulation for wheelchair users ?
However, the issue raised in the top right hand drawing of Figure 11 is valid …
Colour photograph showing the Final Fire Exit from a building (somewhere in Ireland). The ‘clear width’ of the door opening is seriously compromised – the door leaf cannot be fully opened and the panic bar reduces the ‘clear width’ still more. Click to enlarge.
Solution: Retain the current international/European/national understanding of ‘clear width’ for door openings in Ireland … but include text, with supporting drawings, in Revised Technical Guidance Documents B & M to ensure that there is no encroachment on that ‘clear width’ caused by protruding door leaf ironmongery or, more importantly, where the door leaf itself cannot be fully opened to 90o-100o.
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4. Comments:i) Clear Width of Door Openings in Existing Buildings
Table 2, on Page 37 of BS 8300:2009, permits the ‘clear width’ for door openings in existing buildings to be reduced significantly below 800mm.
If buildings of historical, architectural and cultural importance are properly identified, and proper allowance is made for these specific building types in Revised Technical Guidance Documents B & M … there is no need to permit a general reduction in the ‘clear width’ for door openings in existing buildings.
Solution: Clearly indicate in the Revised Technical Guidance Document M that the last ‘Existing Buildings’ Column on the right of Table 2 in BS 8300 should be disregarded.
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5. Comments:ii) Turning Circles for Occupied Wheelchairs
Down through the years, it has been just possible to communicate the concept of the ‘wheelchair turning circle’ to building designers and urban planners … whether it be the older 1.5m diameter circle or the newer 1.8m diameter circle.
The new Figures and Tables in Annexes C.3 and C.4 of BS 8300:2009 will be difficult to communicate … and may be a complication too far ?
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6. Comments:iv) Fire Safety Issues
Colour photograph showing people trapped at the top of one of the WTC Towers. This Tower collapsed soon afterwards. Click to enlarge.
The Recommendations contained in the 2005 & 2008 National Institute of Standards & Technology (USA) Reports on the WTC 9-11 Incident in New York provide an invaluable and essential empirical basis for the practice of effective fire engineering design in today’s built environment.
The first of these two reports has special relevance for NSAI AASCC WG1 because the typical problems encountered by people with activity limitations during a ‘real’ building fire incident have been highlighted by NIST and closely investigated. As a result, three important fire engineering keywords have been re-stated with strong emphasis: ‘reality’ – ‘reliability’ – ‘redundancy’. And, a new key phrase in relation to way finding during evacuation has been introduced to the everyday practice of fire engineering design: ‘intuitive and obvious’.
The 2005 NIST Report, particularly, must be given proper consideration during the development of any reputable fire safety related standard or code of practice for the following reasons:
– at the time of the ‘real’ fire incident, approximately 8% of building users were people with disabilities, with 6% having mobility impairments ; [The percentage of ‘building users with activity limitations’ exceeded the 8% quoted above.]
– NIST found that the average surviving occupant in the buildings descended stairwells at about half the slowest speed previously measured for non-emergency/test evacuations. This raises a serious question over the use of standard movement times in fire engineering design calculations for evacuation ;
– NIST strongly recommended that fire-protected and structurally hardened lifts (elevators) should be installed in buildings to facilitate the evacuation of building users with disabilities, and to improve emergency response activities by providing timely emergency access to firefighters ; [In Ireland, building designers have already adopted this approach by constructing cores of reinforced concrete … even in the absence of European/national standards.]
– it was recommended that evacuation routes should have consistent layouts, and be ‘intuitive and obvious’ for all building users, including visitors who may be unfamiliar with the building, during evacuations ;
– NIST recommended that staircase capacity and stair discharge door widths should be adequate to accommodate contraflow in circulation spaces, i.e. the simultaneous emergency access by firefighters into a building and towards a fire, while building users are still moving away from the fire and evacuating the building. This has implications for the minimum clear width of all fire evacuation staircases. Wider staircases facilitate the assisted evacuation and rescue of people with disabilities.
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No consideration was given in BS 9999:2008, however, to any of the Recommendations contained in the 2005 & 2008 NIST Reports … there is not even a mention of either Report in the Bibliography (Pages 423-429).
– For such an important national standard in Europe – BS 9999:2008 – there is no understanding demonstrated of the Fundamental Functional Requirement for Public Safety in Buildings …
Buildings shall remain structurally stable and serviceable …
1. while people are waiting in ‘Areas of Rescue Assistance’ ; and
2. until all of these people can be rescued by Firefighters and can reach a ‘Place of Safety’, which is remote from a fire building – with an assurance of individual health, safety & welfare for the people involved ;
– There is a reference to ‘normal movement times’ which are used to calculate evacuation times in Mobility-Impaired People (Paragraph #46.2, Page 247), even though it was found by NIST that the average surviving occupant in the WTC Towers descended stairwells at about half the slowest speed previously measured for non-emergency evacuations. In a ‘real’ fire incident, there is no such thing as ‘normal’ or ‘standard’ evacuation movement times, and the idea that any building must be clear of occupants within a very short timeframe, e.g. 2.5-3.5 minutes, is ludicrous ;
– In the sensitive area of the Resistance to Damage of Enclosing and Separating Partitions (Paragraph #21.2.5 on Page 101) surrounding Firefighting Shafts, it is still permissible in BS 9999:2008 to use non-robust construction, e.g. lightweight plasterboard. Fire-Induced Progressive Collapse is not discussed in the BS 9999 … and neither is Disproportionate Collapse, which is one of the functional requirements – A3 – in Part A of the Building Regulations for England & Wales (and Ireland !) ;
– Although in Wheelchair Users (Paragraph #46.3 on Page 247), it is stated …
‘It should be noted that it can take as many as four people to use an evacuation chair safely and effectively.’
… the dimensions for the minimum width of staircases in Width of Escape Stairs (Table 14 on Page 88) and Firefighting Stairs (Paragraph #21.3.2 on Page 106) disregard the guidance given on Page 247 … and ignore the minimum clear staircase width (1.5m) required to safely assist the evacuation of a person in a manual wheelchair …
Black and white photograph (US FEMA 2002) showing the correct way to assist the fire evacuation of a wheelchair user in an evacuation staircase … one person at each side, with another person behind.
And … for some unexplained reason, handrails are permitted to intrude into the ‘clear width’ of a firefighting staircase in BS 9999:2008 (Paragraph #21.3.2, Page 106).
Please note well … this method (shown below) of assisting the evacuation of a person in a manual wheelchair is NOT correct. It is not possible to support any weight by holding the foot rests on a manual wheelchair, or by grasping the wheelchair by the front wheels …
Black & white sketch showing how definitely NOT to assist the fire evacuation of a wheelchair user in an evacuation staircase.
Manual handling of occupied wheelchairs in a fire evacuation staircase, even with adequate training for everyone directly and indirectly involved, is hazardous for the person in the wheelchair and those people – minimum three – giving assistance.
The weight of an average unoccupied powered wheelchair, alone, makes manual handling impractical. All lifts (elevators) in new buildings should, therefore, be capable of being used for evacuation in a fire situation. Lifts (elevators) in existing buildings, when being replaced or undergoing a major overhaul, should then be made capable of use for this purpose.
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Contraflow Circulation, i.e. the simultaneous emergency access by firefighters into a building and towards a fire, while building users are still moving away from the fire and evacuating the building, has not been considered at all in BS 9999:2008.
A clear staircase width of 1.5m provides sufficient space for a mobile person to evacuate (700 mm) and a heavily protected and equipped firefighter to simultaneously move in the opposite direction (800 mm) …
Colour drawing, with photograph insets, showing the symbiotic relationship between Contraflow Circulation and Proper Assisted Evacuation in a building. Click to enlarge.
Human Behaviour in Fires should have been discussed in far more detail in BS 9999:2008 … but wasn’t. It is important for fire engineering designers to understand that the ‘real’ people who use ‘real’ buildings every day of every week, in all parts of the world, have widely differing ranges of human abilities and activity limitations … they are different from each other, and they will react differently in a fire emergency.
Building users need to be Skilled for Evacuation to a place, or places, of safety remote from a fire building. In the case of people with a mental or cognitive impairment, there is a particular need to encourage, foster and regularly practice the adaptive thinking which will be necessary during a ‘real’ fire evacuation.
Meaningful Consultation with every person known to occupy or use a building, for the purposes of receiving his/her active co-operation and obtaining his/her informed consent (involving a personal representative, if necessary), is an essential component of adequate pre-planning and preparation for a fire emergency.
Adequate Warning of a fire incident in a building should be communicated well in advance of the time when it is necessary to act and should continue for the full duration of the incident. Warnings should be informative, and easily assimilated in a form (e.g. oral, written, braille) and language understood by the people using the building.
Panic attacks, during evacuation in a ‘real’ fire incident, exist. The 2005 National Building Code of India refers extensively to this issue.
Solution: To resolve the technical inadequacies, inconsistencies and content gaps in BS 9999:2008 … it will be necessary to revise Technical Guidance Document B in Ireland. Fire safety, protection and evacuation from buildings for people with disabilities must be comprehensively included in the process of Fire Safety Certification.
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7. Conclusions – BS 9999:2008 & BS 8300:2009
There are many gaps and conflicts between these two British Standards, principally because … they are two separate standards … drafted by two different Technical Committees within the British Standards Institution (BSI).
Because of its deviation from widely accepted concepts of accessibility and its tortuous use of terminology, BS 8003:2009 will have an adverse impact on the practice of Accessibility Design in Ireland … and has already complicated the development of the ISO Accessibility-for-All Standard (DIS ISO 21542).
Arrogance within BSI is not the only reason for such deviations. Distorting the European Union Single Market, for the purpose of introducing technical barriers to trade, is common in Britain … refer to the ‘deemed-to-satisfy’ status of the Approved Documents in the Building Regulations for England & Wales … and the Fire Protection Association’s ‘LPC Sprinkler Rules’.
Input from the Disability Sector during the drafting of BS 9999:2008 was not at all sufficient to ensure that there was a meaningful consideration of the problems encountered by people with activity limitations during a ‘real’ building fire incident. The necessary range of available and effective fire engineering solutions has not, therefore, been presented in the standard.
In addition … the complete and abject failure to consider the important Recommendations contained in the 2005 & 2008 National Institute of Standards & Technology (USA) Reports on the WTC 9-11 Incident in New York was an inexcusable and unforgivable technical oversight.
The result is a crassly inadequate, discriminatory and deeply flawed national fire safety standard in Great Britain & Northern Ireland. BS 9999:2008 became obsolete on the very day of its publication !
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Postscript
Please refer to our 1999 Submission to the Department of the Environment & Local Government, in Dublin, concerning the use of British Standard BS 5588:Part 8 in Ireland …
Following this Submission, our understanding is that an ‘Internal’ Working Party was established within the Department. However, the Working Party never reported. No proper response to this Submission has ever been received from the Minister or the Department.
.
On 29th November 2006, similar and very polite comments were sent directly to the British Standards Institution (BSI) by e-mail. Receipt of this e-mail was never acknowledged by anyone in BSI.
2009-05-13: The other day, I thought it might be interesting to google ‘PEEPS’.The surprising results … page after page about the marshmallow candies (in English: sweets) which are sold in Canada and the USA.I have learned something new !
What I was trying to find, however, was information relating to Personal Emergency Egress PlanS (PEEPS) for building users with disabilities. PEEPS is widely referenced in British literature … and because certain people (who should know better) believe that the sun, moon and stars rise over London … it has also seeped into the Irish literature by some process of ‘preverted’ osmosis. Most regrettable !
Yesterday, I discussed the inadequacy of developing Fire Safety Management Procedures … or, in fact, designing buildings … with the sole concern being people with disabilities.
Taking account of all the relevant, and different, types of European and National Legislation … the Rule of Thumb should always be People with Activity Limitations and Accessibility for All.
While fully understanding the need for a catchy acronym … ‘PEEPS’ does not respond well to internet searches on Google.
The next unfortunate feature of Personal Emergency Egress PlanS is the misguided use of Fire Engineering Terminology in English …
Evacuation from a Fire Building
To withdraw, or cause to withdraw, all users from a fire building in planned and orderly phased movements to a Place of Safety remote from the building.
Egress
Independent emergence of user(s) from a building, under normal ambient conditions, and removal from its immediate vicinity.
Escape
Avoidance of injury or harm which is threatened by imminent danger.
Instrumental Aggression
Aggression which is a means to another end, e.g. pushing someone aside to escape from danger.
Whenever, therefore, the terms ‘evacuation’, ‘egress’ and ‘escape’ are used interchangeably … on the same occasion … and without apparent rhyme or reason … it is time to call a halt to proceedings … and to scream “bullshit – moráns at work” !Furthermore … the word ‘escape’ should never be used in connection with fire evacuation from a building.BSI, CEN and ISO … please take careful note !!!
A Personal Emergency Egress Plan (PEEP) is fundamentally flawed and discriminatory because it is …
–person-specific ;and
–location-specific.
Would any able-bodied building user tolerate being told that a document would have to be prepared before he/she could enter and use a building … and that this document would discuss only his/her use of the building … and that use only in specified parts of the building ???No way ! Are you serious !!What a joke !!!
The relevant, and different, types of European and Irish National Legislation require that buildings be accessible … covering approach to, entry, use, egress (under normal conditions), evacuation (in the event of a fire emergency) and removal from their immediate vicinity.
Within this legal environment … PEEPS is fundamentally flawed.And … because building use is limited for specified individuals to specified areas only … PEEPS is also discriminatory.
If there is to be recourse to PEEPS, it should be in very exceptional circumstances only !And, I can certainly think of one possible situation … existing buildings of historical, architectural and cultural importance … where anything more than moderate interference with the building fabric is both ill-advised and restricted … and everyone’s use of the building must be curtailed to some extent.
2009-05-06: From the late 1980’s and the beginning of the 1990’s in European Union (EU) Research Programmes, it was noticeable that the more pressing early concerns about Energy-efficiency – logical after the oil crises of the 1970’s – were beginning to merge with those of Environment-friendliness, i.e. protection of the environment.Even at that time, however, faint background references to Sustainability were becoming more common.
In 1995, therefore, Sustainable Design International developed and introduced the acronym ‘SEED’ … which stands for Sustainable, Environment-friendly, Energy-efficient Development … as a practical control, or check, on our own work output.
The next break-through came a few years later.I briefly discussed the wide conceptual basis for our Corporate Design Philosophy in the post: ‘Sustainable Human & Social Development ?’, dated 2009-03-31.This basis, while still continually evolving, is critical in terms of services provided, performance targets to be achieved, methods of working and relationships with client organizations, builders, craftsmen/women, manufacturers, etc.
This should explain the futility, in our humble view, of the ‘Green’ Agenda (as distinct from the ‘Sustainability’ Agenda) … and approaches based solely on Environmental Aspects of Sustainable Development.They are a complete waste of time and resources.
Now in 2009, we remain fully convinced that Sustainable Design Solutions are appropriate to local geography, social need, climate, economy and culture … and are ‘person-centred’ and ‘reliability-based’.
Forget the images of mud housing and reading by candle light … the Future of our Built Environment is High-Tech, Smart … and Sustainable ! Let there be no doubt !!
Why not begin, so, by looking at a Simple Building Type … Sustainable Housing ?
With all of the current hype and fuss about German ‘Passiv’ Houses and Austrian High-Tech Timber Framed Construction … we have been in contact with a number of manufacturers in this region of Central Europe.After many meetings and detailed discussions, we are disappointed … broken hearted !
Below follows our shopping list for the practical, commercial and affordable application, i.e. non-research, of Advanced Systems of Construction (small/medium/large scale projects – new-build and existing projects).
N.B. Current Irish legal requirements and local authority technical control procedures are entirely inadequate.
Is anybody out there listening ???
To meet the urgency of Climate Change Adaptation and the challenge of Reliable Sustainability Implementation … a ‘SEED’ Building in Ireland must reach these performance targets:
–be set in Sustainable Landscaping (where appropriate) with Life Cycle Sustainable Drainage … and exhibit a considered, harmonious relationship between the building’s ‘interior’ environment and the ‘exterior’ built and social environments ;
–have a Minimum Building Life Cycle of 100 Years ;
–be Smart/Intelligent, Electronically Mature and facilitate Remote Building Management ;
–be properly shown to be Fit for Intended Use (in the Location of Use) … by CE Marking, using European Standards/Norms & European Technical Approvals (refer to Part D of the Irish Building Regulations and similar requirements in other European national building codes, European Union Safety at Work and Product Liability Legislation) ;
–be Super Energy-Efficient, with negligible thermal bridging and accidental air seepage … and promote and encourage, by design, Energy Conservation ;
–have a substantial component of Renewable Energy & Heat Technologies … sufficient to return a multiple of the building’s energy consumption to an Intelligent Regional or District Grid … and also incorporate Recycling, Rainwater Re-Use and Waste Management Technologies ;
–offer a high level of Indoor Air Quality, including proper protection from Natural Radon ;
–be Flexible and Adaptable with regard to internal layout, and Accessible for People with Activity Limitations (2001 WHO ICF) – in order to prolong Building Life Cycle and maximize Building Usability ;
–contain, as standard and for reasons of safety, a Domestic Sprinkler System and a remotely monitored Fire Detection System … plus a Carbon Monoxide (CO) Detection System, with a detection unit in the vicinity of each fuel burning appliance ;
and
–be Competently Built and Reliably Completed to project programme and cost estimate … with the building’s ‘Real’ Performance-in-Use capable of being tested, and continually monitored, over the complete building life cycle ;
and
–be simple and straightforward for Building Users/Occupiers to operate.
Principal Areas of Inadequate Performance …
1.Showing Fitness for Intended Use.Although a Single European Market for the Construction Sector exists on paper (not yet in reality) … this requirement is not well understood by manufacturers … particularly in Germany and Austria, where outdated national approaches to building product/system approval still take precedence over anything at European level.
2.Domestic Sprinkler Systems.There is a high level of resistance, among most manufacturers, to the installation of these systems.Not acceptable !!
3.Accessibility of Buildings for People with Activity Limitations.Not well understood by manufacturers and building organizations (at all levels).Although there is a lot of legislation in Europe covering this particular issue … it is routinely disregarded and/or very poorly implemented.In Germany and Austria, for example, the long outdated term ‘barrier-free design’ is still in common use. Can you believe that ?
4.Radon Protection of Buildings.Not considered important in Germany and Austria … so manufacturers just don’t bother.
5.Fabric Thermal Performance.Where building systems are ‘adapted’ for use in Ireland, I have seen thermal performance, as originally designed in Germany/Austria, seriously compromised by the installation of meter boxes and permanent ventilation openings in external walls.Just the tip of the iceberg !
2009-03-24: Permit me, first of all, to vigorously reclaim the word ‘accessibility’ back from the Transport Sector.This important conference in Barcelona was not about transport networks or distances from the nearest transportation node … but about Accessibility of the Human Environment for People with Activity Limitations (2001 WHO ICF), i.e. Accessibility-for-All.
A 2-Day Conference organized by EuCAN – the European Concept for Accessibility Network co-ordinated from Luxembourg – it was held in the TRYP APOLO Hotel (Av. Paral-lel, 57-59), on the 19-20th March 2009 … an impressive start-up event for the next EuCAN Project … a publication elaborating the business opportunities being created by Design-for-All for manufacturers and service providers across Europe.
I was very pleased to make a presentation on the exciting business potential of Accessible Fire Engineering … a subset of Sustainable Fire Engineering …
Colour image showing the Title Page (only) of CJ Walsh’s Presentation: ‘Accessible Fire Engineering’, at the recent 2-Day EuCAN Conference in Barcelona, Spain. Held on 19-20th March, 2009. Click to enlarge.
There were, however, some developments at the conference which should be brought to wider public attention for consideration and discussion … here in Ireland, but also in other European countries …
Colour photograph showing the West/’Passion’ Elevation of the Templo Expiatorio de la Sagrada Familia in Barcelona, Spain. An architectural wonder designed by Catalan Architect, Antoni Gaudí i Cornet (1852-1926), and still under construction. Click to enlarge. Photograph taken by CJ Walsh. 2009-03-20.
1.News was announced at the conference that the Proposed International Accessibility-for-All Standard (at present ISO CD 21542.3) has been overwhelmingly supported (mid-March 2009) for progress to the Draft International Standard (DIS) stage in its development.If everything goes well, we should see this International Standard being published sometime during the first half of 2010.
The ISO Accessibility-for-All Standard, which will be an essential implementation tool for Articles 9 & 11 of the 2006 United Nations Convention on the Rights of Persons with Disabilities in relation to Buildings, is particularly important for 2 Reasons:
–‘Fire Safety’ Texts are now included in the Main Body of the Standard ;
–‘Fire Evacuation’ is fully integrated into the definition and meaning of ‘Accessibility’.
Colour photograph showing the Interior of the Templo Expiatorio de la Sagrada Familia in Barcelona, Spain. Current state of progress with the Nave. An architectural wonder designed by Catalan Architect, Antoni Gaudí i Cornet (1852-1926), and still under construction. Click to enlarge. Photograph taken by CJ Walsh. 2009-03-20.
2.A conversation during the conference morning coffee break, on Friday 20th March, with Bojana Rudić and Miodrag Počuč of the Centar Živeti Uspravno in Serbia, has finally convinced me that all of the various Accessibility Design Philosophies …
–design-for-all (some attempts have been made to develop 6 Principles for this rather vague philosophy) … used by EU Institutions, and more widely throughout Europe in reaction to universal design ;
–universal design (with its 7 Principles/Commandments) … preached from the USA … but in Japan, for example, a more practical application can be seen.Strangest of all is the relatively recent establishment in Ireland of the Centre for Universal Design, within the lumbering qwango that is the National Disability Authority (NDA) ;
–inclusive design (with its 5 Principles) … originating from Great Britain ;
–barrier-free design (a philosophy long out of date) … still widely referred to in Germany and other parts of Central Europe ;
–facilitation design (a newer philosophy based on 2 WHO ICF Terms: ‘Facilitator’ and ‘Environmental Factors’ and intended to update barrier-free design) … not yet well known ;
… are not only causing enormous confusion about accessibility among the ‘un-initiated’ and architectural students, to take just two examples … but are diverting scarce resources away from the process of ‘real’ accessibility implementation.
In some cases, devotion to these philosophies is so consuming that I have experienced, first-hand, a general tendency to discourage any talk about rights … with some prominent members of the International Accessibility Community (who shall remain nameless !) not even bothering to read the actual text of the 2006 UN Disability Rights Convention !
Colour photograph showing a General View, from within, of the 1929 Barcelona Pavilion – a Master Statement of Modern Architecture – designed by German Architect, Ludwig Mies van der Rohe (1886-1969). De-constructed in early 1930 after the Barcelona International Exposition, it was constructed again in 1986. Click to enlarge. Photograph taken by CJ Walsh. 2009-03-20.
3.Concerning the development of a European Accessibility Business Strategy …
Yes … Accessibility-for-All is about much more than making life and living easier for people with disabilities.Children, frail older people (not all older people !), women in the later stages of pregnancy, people who have a health condition, etc., all now need to be included in a more Person-Centred Approach to the design and sustainable transformation of our Human Environment.This is absolutely essential.
But … the 2006 UN Convention must be used as a Product & Service Checklist which covers the basic, i.e. minimum, responsible needs of people with disabilities … a sizeable social group in all of our societies. Failure to complete this simple task is a fundamental strategic error !
The 2006 UN Convention on the Rights of Persons with Disabilities is also their sole route of access to the human and social rights set down in the 1948 Universal Declaration of Human Rights.
–Integration of Accessibility-for-All Performance
Building Accessibility, to take a specific example, is now more complex … and includes …
–Approach to the building from the site boundary ;
–Entry through principal entrance(s) ;
–Health, Safety, Convenience & Comfort In Use, including thermal and acoustic comfort, good indoor air quality, protection from fire, etc ;
–Egress under normal conditions ;
–Evacuation in the Event of a Fire, or other emergency ;
–Removal from the vicinity of the building back to the site boundary ;
and …
–Each stage of a Work Process, at every level, in places of work ;
–Use of Electronic, Information & Communication Technologies (EICT’s) – at minimum, those permanently fixed in/to the building ;
and …
–Management, Services & Attitudes of People in the organization using the building ;
–Recruitment, Employment, Promotion & Training Practices within the same organization.
Performance in all of these different, and up until now separate, components must be brought together and properly integrated.
–Accessibility-related Products
In Ireland, we suffer from an over-supply of British manufactured accessibility-related products which are badly-designed and inadequately tested … or not tested at all.Inability to show compliance with Part D of the Irish Building Regulations is a big issue … that is, if those manufacturers even realize that we have our own separate building legislation over here.
By the way, failure to be able to show compliance with Regulation 7 of the Building Regulations for England & Wales is an issue across the water as well !
The situation isn’t much better in the rest of Europe.Yes … the quality of design is much, much better, but there is still enormous confusion about CE Marking.
Accessibility-related Products are still, and always have been, industrial products which are being placed on the Single European Market. Normal rules apply !
–Accessibility-related Services
Hopefully, we will soon see the demise of the Access Consultant … a plentiful species, particularly in Great Britain … an individual who only deals with ‘approach to’, ‘entry’ and ‘use’ of a building or facility … and nothing about ‘fire evacuation’.Their days are slowly numbered !
The rest of us, however, need to familiarize ourselves with necessary new services …
–Accessibility Impact Assessment ;
–Accessibility Performance Indicators ;
–Accessibility Benchmarking, Target Setting and Progress Evaluation ;
–Independent Accessibility Verification ;
–Etc.
Accessibility-related Services must be dragged out of prehistoric caves … screaming, if necessary.Services must become much more professional !
2009-02-17: Mr. Joe Duffy, presenter of the popular phone-in RTÉ Radio 1 Programme: ‘Liveline‘ (13.45-15.00 hrs. local time in Ireland), covered an item of major importance today … the complete lack, in our country, of ‘accessible’ emergency services for people with a hearing impairment (2001 WHO ICF).
To place this issue in a necessary wider context … back in December 2006, the United Nations adopted the Convention on the Rights of Persons with Disabilities.After various procedural ‘jigs and reels’, the Convention became an International Legal Instrument on 3rd May 2008. This is now International Law !
It is worth quoting from some of the UN Convention’s Text …
Article 9 – Accessibility
1. To enable persons with disabilities to live independently and participate fully in all aspects of life, States Parties shall take appropriate measures to ensure to persons with disabilities access, on an equal basis with others, to the physical environment, to transportation, to information and communications, including information and communications technologies and systems, and to other facilities and services open or provided to the public, both in urban and in rural areas.These measures, which shall include the identification and elimination of obstacles and barriers to accessibility, shall apply to, inter alia:
(a)Buildings, roads, transportation and other indoor and outdoor facilities, including schools, housing, medical facilities and workplaces ;
(b)Information, communications and other services, including electronic services and emergency services.
Article 11 – Situations of Risk & Humanitarian Emergencies
States Parties shall take, in accordance with their obligations under international law, including international humanitarian law and international human rights law, all necessary measures to ensure the protection and safety of persons with disabilities in situations of risk, including situations of armed conflict, humanitarian emergencies and the occurrence of natural disasters.
[Note: Article 11 covers risk situations such as … fires in buildings.]
Progress with regard to the continuing Ratification of this United Nations Convention can be viewed here.
Although Ireland signed the Convention on 30th March 2007, amidst much publicity, this country has still not ratified it.Why is that ?Other European Union Member States have ratified it without any problem.
Yet again, why haven’t the National Disability Authority … and particularly Ms. Angela Kerins, NDA & Equality Authority Chairperson – ‘valiant protector, against all odds and foes, of disability & equal rights’ … screamed and protested loudly about Ireland’s disgraceful tardy ratification of the UN Disability Convention ?Did we even hear a whimper from them ?Definitely not.
This is an issue where an essential leadership role must be taken up – enthusiastically – by our politicians and senior civil servants.The correct signals must be given to society as a whole.
What Mr. Joe Duffy does not understand, unfortunately, is that Irish Politicians and Senior Civil Servants would all rather commit ritual suicide on Merrion Street (outside the Dáil and Government Buildings) than give people with disabilities their rights.
There is no longer any acceptable reason whatsoever … why ‘accessible’ emergency services cannot be introduced immediately in this country … or throughout the rest of Europe.