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 !
2009-10-18: In everyday practice, the usual short introductory text in Technical Guidance Document M (Ireland) which refers to a linkage between ‘access and use’ of a building with ‘fire safety’ has little impact, because it is not explained … and is typically ignored.
In general … the basic problem is that this issue is hardly dealt with … at all … by Local Fire Authorities right across the country in their handling of Fire Safety Certificates … and where it does become part of the process, it receives inadequate attention. There are exceptions.
A major drawback with the current vertical approach to our Building Regulations … each of the Parts has its own separate Supporting Technical Guidance Document … is that people are not sufficiently aware of the important horizontal linkages between the different Parts. For example, all of the other Parts must be linked to Part D. Quick, run to find out what Part D covers ! Another two examples … Part B must also be linked to Part A and Part M … and Part M must also be linked to Part K and Part B.
So … while grudgingly having to accept that the scope of TGD M should have some limit, under the current flawed system … a precise intervention with just one or two sentences, at critical places in the guidance text, would help to improve the overall consideration of fire safety issues, relevant to Part M, by building designers … and client or construction organizations.
Here are a Few Suggestions for Discussion …
1. Revise Paragraph #0.6 of Draft TGD M (2009) & Add a Title …
Fire Evacuation for All
” Accessibility encompasses the full range of activity related to buildings: to approach, enter, use, egress from under normal conditions, and evacuate a building independently during a fire emergency, in an equitable and dignified manner. Provision for access and use must, therefore, be linked to provision for fire evacuation. For guidance on design for evacuation, reference should be made to Technical Guidance Document B (Fire Safety).”
Note: No such guidance is contained in TGD B (2006). It would be a great wonder if any person with a disability could actually evacuate a building which had been designed in accordance with TGD B. To take a simple example … all of the ‘stairways’ in Table 1.5 of TGD B – Minimum Width of Escape Stairways will not facilitate contraflow or the assisted evacuation of mobility and visually impaired people. Furthermore, those minimum widths specified in the Table may have a clear width which is 200 mm less. See Methods of Measurement, Paragraph #1.0.10 (c) (iii) … ” a stairway is the clear width between the walls or balustrades, (strings and handrails intruding not more than 30 mm and 100 mm respectively may be ignored) ” ! What an incoherent mess !!
2. Insert New Sentence at the End of Paragraph #1.1.1 of Draft TGD M (2009) …
Objective (Approach to Buildings)
” Consideration should be given to the use of the approach and circulation routes around a building as accessible routes to a ‘place of safety’ during a fire emergency.”
3. Insert New Sentence at the End of Paragraph #1.2.1 of Draft TGD M (2009) …
Objective (Access to Buildings)
” Consideration should be given to the use of all entrances to a building as accessible fire exits during a fire emergency.”
4. Insert New Paragraph at the End of Paragraph #1.3.4.1 of Draft TGD M (2009) …
Passenger Lifts
” Manual handling of occupied wheelchairs in a fire evacuation staircase, even with adequate training for everyone directly and indirectly involved, is hazardous for the person in the wheelchair and those people – minimum three – giving assistance. The weight of an average unoccupied powered wheelchair, alone, makes manual handling impractical. Lifts in new buildings should, therefore, be capable of being used for evacuation in a fire situation. For guidance on the use of lifts for fire evacuation, reference should be made to Technical Guidance Document B (Fire Safety).”
5. Insert New Paragraph and New Sentence at the End of Paragraph #1.3.4.2 of Draft TGD M (2009) …
Internal Stairs
” To allow sufficient space to safely carry an occupied wheelchair down or up a fire evacuation staircase, and to accommodate contraflow, i.e. emergency access by firefighters entering a building and moving towards a fire, while people are still evacuating from the building to a ‘place of safety remote from the building, the clear unobstructed width (exclusive of handrails and any other projections, e.g. portable fire extinguishers, notice boards, etc.) of the flight of a single, or multi-channelled, stairs should not be less than 1 500 mm. The surface width of a flight of stairs should not be less than 1 700 mm.”
Note: See Footnote (5) to Table 1.5 in TGD B (2006) … ” The minimum widths given in the table may need to be increased in accordance with the guidance in TGD M: Access for People with Disabilities.” DUH ?
And …
” For the purpose of safe assisted fire evacuation of people, the rise of a step should not have a height greater than 150 mm, and the going of a step should not have a depth less than 300 mm.”
6. Insert New Sentence at the End of Paragraph #1.5.1 of Draft TGD M (2009) …
Objective (Facilities in Buildings)
” Consideration should be given to the use of relevant facilities within a building, by people with disabilities, for the purposes of fire safety, protection and evacuation.”
7. Insert New Sentence at the End of Paragraph #1.6.1 of Draft TGD M (2009) …
Objective (Aids to Communication)
” Consideration should be given to the use of relevant aids to communication, by people with disabilities, for the purposes of fire safety, protection and evacuation.”
Note: More guidance could be provided under each of the individual paragraphs of Section #1.6 of Draft TGD M (2009). See Draft International Accessibility-for-All Standard ISO 21542.
8. Insert New Section #2.6 of Draft TGD M (2009) …
Fire Safety in Dwellings for People with Disabilities
2009-10-17: Some of you are already hitting the Internet Search Engines … with fierce intent altogether … about Disability Access Certificates (DAC’s) !
Is it Time to Panic ? No.
For a simple and direct hit, the 2 most relevant Irish Legal Instruments are:
1. Statutory Instrument No. 352 of 2009 – Building Control Act 2007 (Commencement) Order 2009.
This states …
” The 30 September 2009 is appointed as the day on which the provisions of Sections 5 and 6 of the Building Control Act 2007 shall come into operation.”
Section 5 covers the Amendment of Section 6 (Building Control Regulations) of the Building Control Act 1990.
Section 6 covers the Amendment of Section 7 (Appeals) of the Building Control Act 1990.
2. Statutory Instrument No. 351 of 2009 – Building Control (Amendment) Regulations 2009.
This states …
” These Regulations shall come into effect on 1 October 2009, except for the provisions of Article 8 which shall come into effect on 1 January 2009.”
For you, yourself, to properly examine all of the ‘ins and outs’ of this New Certification Scheme … download the PDF File below … and then search the document (making sure that it is not case-sensitive !) using the phrase ‘Disability Access Certificate’. You will find 99 instances where the phrase is used.
Click the Link above to read/download PDF File (223 Kb)
In order to make full sense of all that is happening, and is intended to happen in the not too distant future … there are a few other Legal Instruments, related to the two listed, which also need to be consulted … but that is an exercise meant for masochists !
In comparison, the European Union Lisbon Treaty was a sweet bedtime story ! Seriously !!
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Is it Time to Worry ? Yes.
Here are just a few random ideas for your cogitation …
If the Department of the Environment, Heritage & Local Government (DEHLG) pays little heed to Submissions made during and after this summer’s ‘consultation’ process … the proposed New Technical Guidance Document M: ‘Access & Use’ will end up looking like a real dog’s dinner of an absolute mess ! FUBAR.
Years were spent in the preparation of the New TGD M. When it does eventually appear, it will be an accurate reflection of technical capacities within both the Department and the National Disability Authority (NDA).
Deeply regretted is the absence of Mr. Kevin Spencer … a gentle soul … from the DEHLG. Things have not been the same since his departure. He knew what he was talking about.
Who will deal, at a technical level, with Applications for Disability Access Certificates in the Local Authorities ? Will they be competent to do so ? Will their interpretation of the Part M Legal Requirements be harmonized … not just with other/different Authorities … but even with other technical personnel in the same Authority ???
In order to make this new certification scheme work, will the Guidance Text in Technical Guidance Document M (whatever version appears !) be operated as if it were Prescriptive Regulation … which will be totally illegal ?
This has been exactly the story … for many years … with the Guidance Text in Technical Guidance Document B … in the course of operation of the Fire Safety Certification Scheme. FUBAR.
If, as I hinted above, the proposed New Technical Guidance Document M: ‘Access & Use’ will be a real dog’s dinner of a mess … falling far short of what can now be reasonably described as minimal accessibility performance (see the Draft International Accessibility-for-All Standard ISO 21542) … this will certainly open Building Owners/Managers of newly completed buildings to Complaints under Irish Equality Legislation. Why is the Disability Sector so inactive with regard to making complaints ?
and finally …
Are the relevant Irish Decision Makers, as I suggested might happen in a previous post, in the process of actually sleepwalking into an unquestioned acceptance of the inadequate British Standards BS 9999 : 2008 and BS 8300 : 2009 ??? Do they know how to do anything else ?
For some sublime moments of meditation, however, please chew on the information provided at these Pages on the SDI Support WebSite …
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’.
2009-06-16: 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.
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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.
2009-05-12: Or … in French: Personnes à Performances Réduites … a term which should be used much more often !
For many decades, the language of ‘disability’ has been all over the place, to put it mildly … others might suggest, however, that it lacks coherence, and is fragmented and chaotic ! As a result, it has been difficult to make any sort of solid progress on harmonization … at a technical level … in Europe.
Adopted on the 22nd May 2001, the World Health Organization’s International Classification of Functioning, Disability & Health (ICF), changed that situation for the better.It is important to emphasise that the ICF is a classification of ‘Health’ … not of ‘Disability’.
People with Activity Limitations (English) /
Personnes à Performances Réduites (French):
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.
This term includes …
–wheelchair users ;
–people who experience difficulty in walking, with or without aid, e.g. stick, crutch, calliper or walking frame ;
–frail, older people ;
–the very young (people under the age of 5 years) ;
–people who suffer from arthritis, asthma, or a heart condition ;
–the visually and/or hearing impaired ;
–people who have a cognitive impairment disorder, including dementia, amnesia, brain injury, or delirium ;
–women in the later stages of pregnancy ;
–people impaired following the use of alcohol, other ‘social’ drugs, e.g. cocaine and heroin, and some medicines, e.g. psychotropic drugs ;
–people who suffer any partial or complete loss of language related abilities, i.e. aphasia ;
–people impaired following exposure to environmental pollution and/or irresponsible human activity ;
and
–people who experience a panic attack in a fire situation or other emergency ;
–people, including firefighters, who suffer incapacitation as a result of exposure, during a fire, to poisonous or toxic substances, and/or elevated temperatures.
Anosognosia:
A neurological disorder marked by the inability of a person to recognize that he/she has an activity limitation or a health condition.
What is the big deal here ?
Because of the stigma which still attaches to ‘disability’ … and because some people are unable to recognise that they have an activity limitation or a health condition … depending on self-declaration, alone, for the purposes of developing suitable Fire Safety Management Procedures in a building (of any type) is a recipe for certain failure of those procedures.
And … of very direct relevance to design practice generally … compare the weak and inadequate definition of people with disabilities in Part M4 of the Irish Building Regulations (there is no reason to suspect that there will be an earth shattering improvement to this definition in the Revised Technical Guidance Document M … whenever it eventually sees the light of day !) … with the definition of disability in Irish Equality Legislation.
Chalk and Cheese !Or … from the ridiculous to the sublime !Check it out for yourself.
The consequence of this remarkable difference in definitions for anyone involved in the design and/or construction of a building is that … while they might very well be satisfying the Functional Requirements of Parts M and B in the Building Regulations … they will, more than likely, be still leaving the owner and the person who controls or manages the new building open to a complaint under our Equality Legislation.
In the case of Workplaces … truly brave is the person who will design a ‘place of work’ just to meet the minimal performance requirements of Building Regulations !
As a Rule of Thumb, therefore … architects, engineers, facility managers, construction organizations, etc, etc … should become more comfortable working with the concept of People with Activity Limitations.
This practical Rule of Thumb is also what lies behind the concept of Maximum Credible User Scenario, i.e. building user conditions which are severe, but reasonable to anticipate …
–the number of people using a building may increase, on occasions which cannot be specified, to 120% of calculated maximum building capacity ;and
–10% of people using the building (occupants, visitors and other users) may have an impairment (visual or hearing, physical function, mental, cognitive or psychological, with some impairments not being identifiable, e.g. in the case of anosognosia).
[ Please note well … that miserable piece of legislation … or, bureaucrats’ charter .. the 2005 Disability Act (Number 14 of 2005) … is irrelevant to the above discussion.But … when Irish Politicians, Senior Civil Servants and the National Disability Authority begin to take seriously the 2006 United Nations Charter on the Rights of Persons with Disabilities … the 2005 Act will have to be scrapped altogether and/or dramatically re-drafted ! ]
2009-05-04: At my request … Agenda Item #6 for the CIB W14 Meeting, recently held on the campus of Lund University in Sweden (see post: 2009-04-30), covered the following subject …
‘ 2005 & 2008 NIST Recommendations on WTC 9-11 Incident – Fundamental Implications for Fire Engineering Design & Practice ‘
I began the presentation by explaining that architects are frustrated people at the best of times …
[It is a never ending, soul-destroying struggle to faithfully realize an architectural ‘vision’ on a building site … especially in the absence of craftsmen/women and access to a wide range of well-designed, ‘approved’ construction products.]
… but, I have been intensely frustrated for some time … as a fire engineer … in particular, for the following reasons:
1.Negative, Irresponsible Attitude of European Lift Manufacturers
In order to effectively solve the issues of safe fire evacuation for people with activity limitations … and the timely evacuation of everyone in tall buildings … we must have lifts/elevators capable of being used for evacuation … all lifts/elevators … in all building types.This should be the norm … the standard specification.
Ever since 2003, however, when I was a Member of the European Union (EU) Expert Group on Accessibility, I have been pressing Mr. Luc Rivet, Secretary General of the European Lift Association (ELA) to ensure that the Association acts responsibly and makes this happen in Europe … now … not at any far distant point in the future.The time for ‘pretty’, meaningless talk at conferences, seminars and workshops has ended.
The ELA still refuses to act responsibly !
2.Crass Inadequacy of British Standard BS 9999 : 2008
Of interest to me … but not a cause for undue concern … except that far too many people in Ireland are already giving this Standard the status of Default Irish National Standard … and too many people in other countries are doing likewise …
On 31st October 2008, the British Standards Institute (BSI) published British Standard BS 9999 – Code of Practice for Fire Safety in the Design, Management and Use of Buildings.It took many years to draft this new national standard.
During all of that time, however, it is not clear to me that the simple idea of considering the Recommendations contained in the 2005 & 2008 NIST Reports on the WTC 9-11 Incident ever saw the light of day within the BSI Technical Committee which drafted BS 9999. The whole basis for the British Standard might have to be entirely re-examined … how awfully dreadful !?!
This amazing technical oversight has ensured that BS 9999 became inadequate on the very day that it was published.
Furthermore, although I had received assurances from certain people that British Standard 5588 : Part 8 would be properly incorporated into DD 9999 during the earlier stages of its development … in fact, this never happened.
Far too late in the drafting process, BS 5588 : Part 8 appears to have been shoe-horned into DD 9999.The resulting disability-related texts in the new Standard are vague … and represent a step backwards from BS 5588 : Part 8.And, there were many problems even with that earlier British Standard.
Finally, it has become blatantly obvious to me that nobody from BSI should ever again be allowed near the fire engineering terminology for any International or European Standards.BSI has polluted the international terminology of fire engineering.
Let me give you an irritating example which has had a seriously adverse impact on fire safety in buildings, in many countries, down through the years …
The term Fire Door has no meaning, and should not be used … Not Ever … Never !
It still leads to endless confusion on building sites … and very poor construction.It has been a disaster, in my own direct experience … and for everybody else associated with fire safety in buildings … including fire prevention officers in Local Authorities.
On the other hand, the term Fire Resisting Doorset / Shutter Assembly means:
‘ A doorset / shutter assembly, suitably installed or mounted on site, the function of which is to resist the passage of heat, smoke and flame for a specified time during a fire.’
A single concept … explained in simple language that anyone can understand.
I could go on about BSI and British Standards … but, I would rapidly bore myself to sleep !
Presentation at the CIB W14 Lund Meeting …
International Fire Engineering must – now – evolve as a direct result of the WTC 9-11 Incident in New York.This necessary evolution has been delayed for far too long by selfish vested interests.
And it is essential that an Empirical and Rational Basis is clearly identified for the practice of Fire Engineering Design in the 21st Century, i.e. after 9-11.Architects and Engineers, specifically, are desperately seeking reliable design guidance.
Colour image showing the Title Page (only) of CJ Walsh’s Presentation: ‘A Delayed Evolution in Fire Engineering ?’, at the recent CIB W14 Meeting in Lund, Sweden. Originally scheduled for 2 Days, all commission business was efficiently completed on 23rd April 2009. Click to enlarge.
The Recommendations of the 2005 & 2008 NIST Reports must, at the very least, be applied to the design of ‘High-Rise’, ‘Iconic’, ‘Critical Function’ & ‘Innovative Design’ Buildings.In a previous post, dated 2009-01-13, I had proposed that the Recommendations should generally be applied to High-Rise Buildings of more than 7 or 8 storeys and Iconic Buildings of more than 2 storeys. This is merely good fire engineering practice.
There are valuable lessons, from the NIST Reports, to be applied to the Fire Engineering Design of ALL buildings. This is demonstrated in the Lund Presentation … and, for any ‘Doubting Thomas’ out there, the collapse of WTC Building 7 makes this absolutely obvious.
For a more detailed discussion about the WTC 9-11 Incident and to download the 2005 & 2008 NIST Reports, please visit this Page on our Support WebSite …
Extensive content relating to other key words and phrases in the Lund Presentation can be found elsewhere on the Site.
Importance of the CIB W14 Lund Meeting …
The discussion which followed my Lund Presentation was lively and very interesting.This gave me an opportunity, throughout the rest of the meeting, to tweak the Proposed Future Work Programme of CIB W14 towards a more substantive consideration of the Recommendations from the 2 NIST Reports and the Continuing WTC Health Monitoring Studies.
Reluctantly … I will be the Project Leader for an International Team which will examine Fire-Induced Progressive Collapse over the next three years.
I will also be a Member of another Team which will examine Human Behaviour in Fire for a similar period.At the meeting, I indicated that I will be concentrating on Fire Evacuation for People with Activity Limitations (2001 WHO ICF).‘People with Activity Limitations’ is translated into French as ‘Personnes à Performances Réduites’.
Another Page on CIB W14 : Fire Engineering will soon be added to this Technical Blog.