Al Jazeera

BREXIT & EU Construction Products Regulation 305/2011 ~ Woeful Implications for Britain’s Fire Industry

Posted by CJ Walsh

2020-09-08:  Ignoring Britain’s silly sabre-rattling, toothless threats and boorish blackmail attempts reported in the Media during this past weekend, yesterday and today … the actual state of play in the tortuous Brexit Negotiations can best be judged from the following sources …

Michel Barnier’s Presentation to the Institute for International and European Affairs (IIEA), on 2 September 2020 … View it Here on YouTube

Britain’s National Audit Office Report: ‘Learning for Government from EU Exit Preparations’, dated 4 September 2020   (Download PDF File, 197 Kb)

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Map of Europe, in colour, showing the current extent of the European Union.  Points to Note:  a) Europe, as a continent, extends as far as the Ural Mountains in Russia;  b) From 1 January 2021, after an implementation period of one year, Great Britain will be entirely outside the EU and the Single Market;  c) The EU is not a Christian organization and as soon the political classes in certain countries (e.g. France and The Netherlands) get over their hysterical hatreds, Turkey will enter the EU as a full Member State;  d) furthermore and eventually, an Independent Scotland will re-join the EU.  Click map to enlarge.

This is the European Union (EU), a Single Market of approximately 450 Million consumers.  The EU operates under the freedoms and protections of Codified / Written Law, i.e. EU Treaties ratified by all of the EU Member States, EU Secondary Legislation (Regulations and Directives), and EU Administrative Provisions.

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A suite of EU Regulations and Directives covers Industrial Products.  While there is some flexibility with regard to how Directives are implemented at national level in the Member States, no such flexibility exists with Regulations.  Construction Products can only be placed on the EU Single Market if they can be shown to comply with the requirements of the EU’s Construction Products Regulation (CPR) Framework, or in other words, be shown to be ‘fit for their intended use’ in the European Union …

REGULATION (EU) No 305/2011 of the European Parliament and of the Council, dated 9 March 2011, laying down harmonised conditions for the marketing of construction products and repealing Council Directive 89/106/EEC   (Download PDF File, 998 Kb)

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EU Regulation 305/2011.  Article 13(2) Before placing a Construction Product on the market, Importers shall ensure that the assessment and the verification of constancy of performance has been carried out by the Manufacturer.  They shall ensure that the Manufacturer has drawn up the Technical Documentation referred to in the second sub-paragraph of Article 11(1) and the Declaration of Performance in accordance with Articles 4 and 6.  They shall also ensure that the Product, where required, bears the CE Marking, that the Product is accompanied by the required documents and that the Manufacturer has complied with the requirements set out in Article 11(4) and (5).

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BREXIT ~ IMPLICATIONS FOR THE BRITISH FIRE INDUSTRY

Trade ‘No Deal’ or ‘Minimal Deal’ … from 1 January 2021, Great Britain will be completely outside the European Single Market, and the EU’s Construction Products Regulation Framework.  The designation ‘Notified Body’ under that Framework will fall away from British Organizations.  Construction Products/Systems manufactured in, or supplied from, Britain will then have to undergo an entirely new EU Testing and Approvals Programme in order to access the European Single Market.  Fire Safety related Construction Products will have to be tested, and assessed or appraised, against all 7 Basic Requirements for Buildings together, during the same period of time (see Annex I, EU Regulation 305/2011) …

      1.  Mechanical Resistance and Stability
      2.  Safety in Case of Fire
      3.  Hygiene, Health and the Environment
      4.  Safety and Accessibility in Use
      5.  Protection against Noise
      6.  Energy Economy and Heat Retention
      7.  Sustainable Use of Natural Resources

… a process which will be very interesting to observe, since the Fire Industry (particularly England’s Fire Establishment, AHJ’s, etc) dislikes, with intensity, the whole idea of ‘environmental impact’ … the concept of ‘sustainable development’ is hardly understood … and no consideration is given to the reasonable fire safety and accessibility needs of ‘vulnerable building users’ (including people with activity limitations, refugees, migrants, etc).

The tragic 2017 Grenfell Tower Fire, and its sad aftermath, have demonstrated how dysfunctional, and rotten to the core, is the whole national system of Building Fire Safety in England.  More than 3 years later … on the evidence to date of an ongoing, incompetent Inquiry and a series of shoddy responses from Government … will survivors and the victims’ families ever receive Justice, and find Peace ?   cf. The 1981 Stardust Discotheque Fire in Dublin.  Survivors and victims’ families are still waiting for the truth to be revealed.

In parallel, mutual recognition of British Professional Building Designers, e.g. Architects, Structural Engineers, Fire Engineers, etc., within the European Union will cease.

In parallel, British Fire Research involvement in EU Research Networks will also cease … unless a heavy price is paid to be involved as a 3rd Country.  British Institutions should forget any notions they might have about Network Leadership.

In parallel, Information and Data Flows between Britain and the EU will be disrupted or cease altogether … unless Britain complies fully with the requirements of EU General Data Protection Regulation (GDPR) 2016/679.  As a vassal state of the USA, this compliance may prove difficult for Britain !

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EU Fire Safety Related Product/System Manufacturers ~ A Word of Caution !

Many EU Construction Product/System Manufacturers continue to use the services provided by British Fire Test Laboratories and/or Fire Consultancy Organizations located in Great Britain … some of which have already established EU-based dummy companies and letterheads.  These British organizations must be avoided altogether.  For example, the practice of fire testing in England and later adding a title page of a Full Test Report with an EU location address is entirely unacceptable !

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To The Barricades ! … Creative Architecture In Context !!

Posted by CJ Walsh

2014-08-28:  Earlier this month … the final straw … as I caught up on a ‘piece’ in McGraw Hill’s Architectural Record … which reproduced an original, intriguing article from designMENA.com, posted on 12 August 2014, by Nick Ames …

Rebel Architects Star In New TV Show

Qatar-based broadcaster Al Jazeera is to show a series of films focusing on radical architects from Pakistan, Brazil, Nigeria, Spain, Palestine and Vietnam.  The series – entitled ‘Rebel Architecture’ – focuses on architects using design to confront urban, environmental and social problems in their communities.

Dan Davies, producer of the series, said: “We couldn’t help noticing that despite all the problems afflicting humanity, many of which architecture uniquely has the ability to assist and even solve, most of the mainstream and architectural press celebrates the aesthetics of huge iconic projects, marvelling at insanely complicated ways to fold giant sheets of metal.”

“As we face issues from floods and natural disasters to an explosion of urban populations, soaring inequality and displacement through conflict, architecture seems wholly absent.  So we wanted to look beyond the discussion of the aesthetics of Star-chitecture and see what architects outside the mainstream are doing.”

The six-part series, which starts on 18 August, begins with a film documenting the work of Spanish architect Santiago Cirugeda, who uses his knowledge of planning law to occupy abandoned properties and to build structures on unused land.

It also features Pakistani architect Yasmeen Lari, who designs disaster relief shelters and Eyal Weizman, professor of spatial and visual cultures at Goldsmiths University, who explores the way the built environment is used as an instrument of occupation.

In Vietnam, the series follows Vo Trong Nghia, whose projects focus on open spaces and sustainable design, while in Nigeria, Kunlé Adeyemi has designed floating buildings to solve issues of flooding and overcrowding.

The final episode explores Rocinha, the largest favela in Brazil, with builder Ricardo de Oliveira, and master planner Luis Toledo.

“The rebel architects have to push boundaries, but they must also look beyond their own buildings,” said Davies.  “They start by looking at the wider context in which they live – be it Spain hit by the financial crisis, or Pakistan ravaged by floods – and work out how they can change the status quo with architecture.”

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I SAY …

Shouldn’t every Architect be concerned about the issues raised in Nick’s article ?   And if not … why not ??

Architecture is a wide and complex field of human creative, artistic and scientific endeavour.  Yet in the international and national media, both mainstream and architectural … it does appear, as presented, to be narrowly confined to the “aesthetics of huge iconic projects”, and “insanely complicated ways to fold giant sheets of metal”.  And the various media continue to focus on and enthusiastically applaud the current, outrageous phallic skyscraper contest in, for example, the Arab Gulf Region, China and South-East Asia … a contest which is actively promoted by such international organizations as the US-based Council on Tall Buildings & Urban Habitat.  [ I might add … with entirely insufficient attention being paid to fire safety, resilience and sustainability in those Super-Tall Buildings !! ]

If Santiago Cirugeda, Yasmeen Lari, Eyal Weizman, Vo Trong Nghia, Kunlé Adeyemi, Ricardo de Oliveira, and Luis Toledo are indeed Rebels … [ I would argue that they most definitely are not ] … and each one is working in isolation … then we must urgently instigate a Revolution …

Creative Architecture In Context !!

 

PRINCIPAL BARRIER …

The Institutional Framework of Today’s Conventional Architecture … typically developed to promote and protect a 19th Century Model of Architectural Practice … exerts a powerful stranglehold over the architectural profession and the schools of architecture in many countries.  It is no longer ‘fit for purpose’ in the 21st Century !

Here in Ireland … a few days before reading the Nick Ames article … I attended a long Extraordinary General Meeting of the Royal Institute of the Architects of Ireland (RIAI) … called by 10 Institute Members to demand urgent, concerted action from the Institute’s Council in response to the new and very flawed Building Control Amendment Regulations (Statutory Instruments Nos.9 & 105 of 2014), which came into effect from 1 March 2014.

Far from being an enlightening and pleasurable occasion … for many small reasons, it was annoying and frustrating.  The biggest reason of all, however, was that I saw no evidence whatever that either Council or the Membership understands the simple, fundamental truth that … self-regulation/self-certification does NOT work !

Refer back to my previous post.

The General Public in Ireland … also known as ‘The Long-Suffering Consumer’ … does not trust the Medical and Legal Professions to self-regulate, despite the vociferous protestations from both that their internal regulatory systems are packed-packed-packed with civilians.  Yes … ‘selected’ civilians !

That particular evening in the Davenport Hotel, Dublin … the RIAI’s Extraordinary General Meeting (EGM) went nowhere … aided and abetted by Council Members at the head table. It was interesting to note that none of the 10 Institute Members who had called the meeting had a seat at that same table.

As we exit the Profound Economic Crisis following the Extravagant Celtic Tiger Years … and coldly look around us … we witness an architectural profession lost in a contextual wilderness – urban, environmental and social – while fumbling around in a legal and political maze.  And, every day, we experience a sprawling, ugly, depressing and unsustainable built environment which is engaged in a sad and brutal conflict with nature.

It has taken at least a generation … but the RIAI has directly overseen the slow and progressive dilution of what it means to be an Architect in Ireland.

Time for The Revolution … To The Barricades !!

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