Accessibility of buildings for people with disabilities

EU Sustainable vs. Green Public Procurement – Beware !

Posted by CJ Walsh

2010-11-02:  For a long, long time … too long … I have been bleating on about the major and substantial difference between Sustainable Design and Green Design … or ‘Sustainability’ and ‘Green-ness’.  See my previous Posts.

This bores me no end !

HOWEVER … there are some serious implications if this difference is not properly understood … particularly by individuals, groups or organizations attempting to advance the Application of Criteria which address Social and/or Ethical Concerns within, for example, the European Union’s Public Procurement Framework … or the EU’s Construction Product Framework.

The following is a nice little example of exactly what I am talking about … explained by no less an authority than the Directorate General for Environment in the European Commission itself … on its very own Public Procurement WebPage at  http://ec.europa.eu/environment/gpp/index_en.htm … as viewed, by me, on 2010-09-12 …

[ For a moment, let’s just overlook the simplistic and crude ‘three pillars’ understanding of Sustainable Development.  See my previous Posts.]

Sustainable Public Procurement (SPP) … means that public authorities seek to achieve the appropriate balance between the three pillars of sustainable development – economic, social and environmental – when procuring goods, services or works at all stages of the project.

Green Public Procurement (GPP) … means that public authorities seek to procure goods, services and works with a reduced environmental impact throughout their life cycle compared to goods, services and works with the same primary function that would otherwise be procured.

Practical Differences Between SPP & GPP !

GPP is often more easily accommodated than SPP within the existing legal and practical framework of procurement.  Green requirements can be included in technical or performance-based specifications for products, services and works.  Provided the conditions set out in the ‘Helsinki Bus’ and ‘Wienstrom’ Cases, and Evropaïki Dynamiki vs. European Environment Agency (EEA) … are met, green award criteria can also be applied (further information on these cases is available at  http://ec.europa.eu/environment/gpp/case_law_en.htm).

The application of Criteria aimed at addressing Social or Ethical Concerns can be more difficult in the context of regulated public procurement procedures.  Public authorities are specifically empowered to include social requirements in their conditions for the performance of contracts or to reserve certain contracts for performance by sheltered workshops or employment programmes (Articles 26 and 19 of Directive 2004/18/EC respectively).

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My Note:  DIRECTIVE 2004/18/EC of the European Parliament and of the Council, of 31 March 2004, on the co-ordination of procedures for the award of public works contracts, public supply contracts and public service contracts.

[ For another moment, let’s just overlook the unfortunate use of disability-related language … which fails, utterly, to take account of the 2001 World Health Organization’s International Classification of Functioning, Disability & Health (ICF).  See my previous Posts.]

Article 19 – Reserved Contracts

Member States may reserve the right to participate in public contract award procedures to sheltered workshops or provide for such contracts to be performed in the context of sheltered employment programmes where most of the employees concerned are handicapped persons who, by reason of the nature or the seriousness of their disabilities, cannot carry on occupations under normal conditions.

The contract notice shall make reference to this provision.

Article 26 – Conditions for Performance of Contracts

Contracting authorities may lay down special conditions relating to the performance of a contract, provided that these are compatible with Community law and are indicated in the contract notice or in the specifications.  The conditions governing the performance of a contract may, in particular, concern social and environmental considerations.

ANNEX VI – Definition of Certain Technical Specifications

For the purposes of this Directive:

1. (a)  ‘technical specification’, in the case of public works contracts, means the totality of the technical prescriptions contained in particular in the tender documents, defining the characteristics required of a material, product or supply, which permits a material, a product or a supply to be described in a manner such that it fulfils the use for which it is intended by the contracting authority.  These characteristics shall include levels of environmental performance, design for all requirements (including accessibility for disabled persons) and conformity assessment, performance, safety or dimensions, including the procedures concerning quality assurance, terminology, symbols, testing and test methods, packaging, marking and labelling and production processes and methods.  They shall also include rules relating to design and costing, the test, inspection and acceptance conditions for works and methods or techniques of construction and all other technical conditions which the contracting authority is in a position to prescribe, under general or specific regulations, in relation to the finished works and to the materials or parts which they involve ;

    (b)  ‘technical specification’, in the case of public supply or service contracts, means a specification in a document defining the required characteristics of a product or a service, such as quality levels, environmental performance levels, design for all requirements (including accessibility for disabled persons) and conformity assessment, performance, use of the product, safety or dimensions, including requirements relevant to the product as regards the name under which the product is sold, terminology, symbols, testing and test methods, packaging, marking and labelling, user instructions, production processes and methods and conformity assessment procedures ;

2.  ‘standard’ means a technical specification approved by a recognised standardising body for repeated or continuous application, compliance with which is not compulsory and which falls into one of the following categories:

–  International Standard: a standard adopted by an international standards organisation and made available to the general public ;

–  European Standard: a standard adopted by a European standards organisation and made available to the general public ;

–  National Standard: a standard adopted by a national standards organisation and made available to the general public.

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In order for a Criterion … any Criterion … to be acceptable within the European Union’s Public Procurement Framework, it should be expressly linked to the subject matter of the Contract … should be specific … and should be capable of objective verification.

Beware !!

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

Posted by CJ Walsh

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

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

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

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

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

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

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

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

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

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

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

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

Section 3   Terms & Definitions

‘ #3.36  Impairment

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

[ISO/TR 22411:2008]

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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European Parliament’s URBAN InterGroup – Inaugural Meeting

Posted by CJ Walsh

2010-03-03:  On Wednesday afternoon, 24th February 2010, the URBAN InterGroup of the European Parliament met for the first time in the new Parliamentary Term … at 16.30 hrs … in Meeting Room 6Q2 of the Parliamentary Complex in Brussels, Belgium.  Dr. Jan Olbrycht, Member of the European Parliament (MEP), chaired the proceedings.  The attendance was large, and included a large proportion of the 50, or so, MEP’s who are directly involved with the InterGroup.  Please forgive the jargon, but … many other URBAN InterGroup Partners, Sectoral Stakeholders and Interested Practitioners also attended.  However … not one Irish MEP appears to show any interest in this important InterGroup.  Why is that ?

Colour photograph showing the Inaugural Meeting of the European Parliament's URBAN InterGroup, in Brussels, on 24th February 2010. The Meeting, chaired by Mr. Jan Olbrycht MEP, had a large attendance. Click to enlarge. Photograph taken by CJ Walsh. 2010-02-24.
Colour photograph showing the Inaugural Meeting of the European Parliament's URBAN InterGroup, in Brussels, on 24th February 2010. The Meeting, chaired by Mr. Jan Olbrycht MEP, had a large attendance. Click to enlarge. Photograph taken by CJ Walsh. 2010-02-24.

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I was very pleased to attend this Meeting, representing Sustainable Design International Ltd. (a Multi-Disciplinary Design & Research Practice in Europe, and a Micro-SME).  Further to a series of interventions on my part, the following are some Comments on last Wednesday’s Meeting … and a few Suggestions …

1.  Accountable & Representative Governance is an important component in the implementation of Sustainable Human and Social Development.  It is not being too ambitious, therefore, to say that the URBAN InterGroup has an important task to fulfil within the ‘system’ of the European Parliament.

2.  Within such a ‘system’ … it is a big advantage that the InterGroup’s Structure is informal and fluid.  This allows the InterGroup to be cross-party and cross-committee at the Parliament … and to adopt a ‘flexible’ horizontal approach to Urban-Related Issues.

3.  This same Horizontal Approach must, however, be applied to a proper consideration of the Urban Environment (City) itself … which is far more than the sum of its buildings, public spaces, transport systems, engineering infrastructure (roads, bridges, etc.), and service utilities, etc., etc.

4.  In order to deal effectively with Urban-Related Issues and the many different Sectoral Stakeholders … it is essential that the Intergroup discusses and develops a comprehensive and coherent vision of what exactly is a Sustainable Urban Environment (City).  Please see the previous post on this Blog, dated 2010-03-02.

And … even though the regular InterGroup Meetings will be of short duration … it will be of great benefit to link small, individual issues to that larger, coherent vision.  Then, and only then, will the InterGroup always know where it is … and, more importantly, in which direction it is travelling … in order to monitor progress.

5.  It was not clear to me, at the Meeting, that the significant differences between the words ‘Sustainable’ and ‘Green’ are fully understood.  This will cause problems for the InterGroup in the future, and should be examined in more detail.

The European Union (E.U.) Treaties refer to ‘Sustainable Development’ … not to ‘Greenness’ !! 

6.  It was also evident, at the Meeting, that there is a Lack of Communication between the European Parliament and the European Commission on Urban-Related Issues.  Let me immediately say, however, that there is a worrying lack of communication (on any issue !) between the different Directorates-General within the Commission.

It must be a Priority for the InterGroup … a difficult one, I know … to have direct access to available Urban-Related Information … across all of the European Union’s Institutions.  It is too wasteful of the InterGroup’s limited resources to be required to ‘re-invent wheels’ !

7.  With regard to the URBAN InterGroup’s Work Programme … it is necessary to add a specific mention of the following Two Subjects:

(i)  Proactive Climate Change Adaptation

Climate Change Adaptation, generally, encompasses actions to reduce the vulnerability and strengthen the resilience of the Human Environment, including ecological and social systems, institutions and economic sectors … to present and future adverse effects of climate change and the impacts of response measure implementation … in order to minimize the threats to life, human health, livelihoods, food security, assets, amenities, ecosystems and sustainable development.

Urban Environment Climate Change Adaptation, more precisely, means … reliably implementing policies, practices, projects and institutional reforms in the Urban Environment (City) … with the aim of reducing the adverse impacts and/or realizing the benefits directly/indirectly associated with climate change, including variability and extremes … in a manner which is compatible with Sustainable Human and Social Development.

Following detailed briefing meetings, in Dublin, from high-level participants in Copenhagen … the suggestion of this subject arises from what happened … or, more correctly, did not happen … to the European Union and its inadequate Climate Change Policies at the 2009 Climate Summit in December.

(ii)  Accessibility for People with Activity Limitations (Personnes à Performances Réduites)

The 2006 United Nations Convention on the Rights of Persons with Disabilities entered into force on 3rd May 2008, i.e. it became an International Legal Instrument.  European Union (E.U.) Member States are currently undertaking the process of ratifying this Convention at national level.  At a certain stage in the near future, the Union (as a polity, post Lisbon Treaty) will certainly also ratify the Convention.

People with Activity Limitations now have a clearly defined right, under International Law, to be able to access and use the Urban Environment (City).  They also have the right to receive an equal and meaningful consideration in situations of risk, e.g. when there is a fire in a building.

The InterGroup must fully take account of these rights !   This is no longer an option.  In this regard and until now, the attitudes and performance of the E.U. Institutions has been nothing less than a complete and utter disgrace.

8.  With regard to the Main Objectives of the URBAN InterGroup … it is necessary to add the following Preamble to those Objectives …

Adopting a long-term perspective, i.e. beyond the lifetime of any single parliamentary term … the Main Objectives of the InterGroup are to:

–   monitor the legislative and non-legislative work of the European Parliament’s Committees on Urban-Related Issues ;

–   work on common European Union Strategies – to put Urban Needs on the agenda of E.U. Policies ;

–   be actively involved in the preparation of E.U. legislation ;

–   constantly stay in contact with partners and practitioners ;

–   be informed about the realization of E.U. Policies on the ground.

Please note well … that the short-term perspective of elected politicians, whether at European, National or Local Levels, is a Serious Impediment to the proper implementation of a Sustainable Urban Environment (City) !

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Accessibility-for-All at the Brussels European Parliament ?!?!

Posted by CJ Walsh

Last Wednesday (2010-02-24), I was very pleased to be in Brussels to attend the Inaugural Meeting of the European Parliament’s URBAN InterGroup for the New Parliamentary Term.  Being very curious, however, there was no way … no way at all … that I could enter the Parliament Building without checking on a specific part of the Early Parliamentary Complex on Rue Wiertz … for any improvements to its past, woeful ‘accessibility’ performance.  Please note that I am not referring, here, to transport issues … but to ‘accessibility’ for people with activity limitations.

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Colour photograph showing the same dangerous public ramp/stair combination near the Main Public Entrance to the European Parliament Building, on Rue Wiertz, in Brussels. During rush hour periods of the working day, this external ramp/stair combination is a very busy public pedestrian route. Click to enlarge. This photograph taken by CJ Walsh. 2010-02-24. For more photographs of this architectural gem, dating from 2000-2001, see SDI's Corporate WebSite.
Colour photograph showing the same dangerous external ramp/stair combination near the Main Public Entrance to the European Parliament Building, on Rue Wiertz, in Brussels. During rush hour periods of the working day, this ramp/stair combination is a very busy public pedestrian route. Click to enlarge. This photograph taken by CJ Walsh. 2010-02-24. For more photographs of this architectural 'gem', dating from 2000-2001, see SDI's Corporate WebSite.

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Since the 2006 United Nations Convention on the Rights of Persons with Disabilities became an International Legal Instrument on 3rd May 2008 … people with activity limitations now have a clearly defined right, under international law, to be able to access and use the Built Environment.  They also have the right to receive an equal and meaningful consideration in situations of risk, e.g. when there is a fire in a building.  The language of the Convention is unusually strong.

Once upon a time … 9 or 10 years ago … at the beginning of this decade/century/millennium … a Properly Accessible Built Environment could only be wishful thinking.  Yes, there was some legislation … usually very weak … at national level in the E.U. Member States … but nobody paid much attention to implementation.  The least that could be expected, however, was that Iconic Buildings purposefully intended and designed for occupation by Institutions of the European Union would be examples of ‘good accessibility’ … as so much emphasis has always been placed in the E.U. Treaties, including the New Lisbon Treaty … on the foundation of the European Union being robustly rooted in Human and Social Rights for All … not just a privileged few, or a self-contented majority.

At this Page on Sustainable Design International’s Corporate WebSite … www.sustainable-design.ie/arch/inaccesseubuildings.htm … I recorded the dismal and depressing evidence on the ‘inaccessibility’ of both the Brussels and Strasbourg Parliament Buildings at that time.

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Colour photograph showing the 'special' entrance reserved for 'personnes a mobilite reduite' in another part of the Brussels European Parliamentary Complex. It's too bad if someone who must use this facility cannot understand the incorrectly printed French ! Click to enlarge. Photograph taken by CJ Walsh. 2010-02-24.
Colour photograph showing the 'special' entrance reserved for 'personnes a mobilite reduite' in another part of the Brussels European Parliamentary Complex. It's too bad if someone who must use this facility cannot understand the incorrectly printed French ! Click to enlarge. Photograph taken by CJ Walsh. 2010-02-24.

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So … what has changed in the intervening years ?   Have there been any improvements to a situation which I originally described as being ‘stupid and ridiculous’ ?   [I won’t bore you with all of the reasons why.]   Or, are things worse ?   Have we, in fact, entered into some unknown region of The Twilight Zone ?   Arise again GUBU (Grotesque, Unbelievable, Bizarre and Unprecedented) !!

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Colour photograph showing the Main Entrances associated with the 'special' entrance in the photograph above. They are located approximately 10 metres around the corner on a different side of the building. If the nosings of those steps have been highlighted in yellow, does that mean that these clumsy entrances are 'safe' ?? Click to enlarge. Photograph taken by CJ Walsh. 2010-02-24.
Colour photograph showing the Main Entrances associated with the 'special' entrance in the photograph above. They are located approximately 10 metres around the corner on a different side of the building. If the nosings of those steps have been highlighted in yellow, does that mean that these clumsy entrances are 'safe' ?? Click to enlarge. Photograph taken by CJ Walsh. 2010-02-24.

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Pinch yourselves, a few times, as you examine the photographs closely !  Try to remember that these buildings are not renovated or refurbished existing buildings.  They were all designed and constructed, as ‘new’, on cleared sites within the city !!

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Although Architects, the Brussels Local Authorities and the E.U. Institutions are primarily responsible for ‘inaccessibility’ of the Brussels European Parliament Building … we cannot afford to be smug or complacent in Ireland.  Just look around you !

Again, once upon a time … towards the end of the 1980’s this time … I submitted the following Proposal for a Resolution on Accessibility-for-All to the Council of the Royal Institute of the Architects of Ireland (RIAI) … please forgive the pre 2001 WHO ICF use of language and terminology …

Preamble

The elimination of architectural barriers to mobility of the disabled is an essential and preliminary condition for successful implementation of the principal that all people should be fully integrated into society, participating in and contributing to all aspects of economic and social life.

Resolution

Celebrating the 150th year of its establishment, Council of the Royal Institute of the Architects of Ireland asks all Members:-

(i)   to note the principal that all people should be fully integrated into society, participating in and contributing to all aspects of economic and social life ;

(ii)  to eliminate as far as reasonably practicable, in the design of buildings, architectural barriers to mobility of the disabled.

Was this Resolution passed ?   I’ll give you one guess !   The reason given, at the time, was that the Profession might be viewed as being culpable … which it was … and remains to this day.  The source of this culpability, however, is most definitely the Schools of Architecture.

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

Posted by CJ Walsh

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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Disability Access Certificates & Accessible Toilet Facilities ? (III)

Posted by CJ Walsh

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’ ?

Posted by CJ Walsh

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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