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Responder Safety on Roads & ‘Eye-Popping’ Vehicle Markings

2013-09-05:  A few days ago, I was travelling on a motorway in Ireland … the scenery was luscious, and daylight and weather conditions were good … when I noticed that the visibility and marking of Emergency Response and Public Service Vehicles varied considerably.  The rear of one vehicle, in particular, had highly visible markings … but it was pulling a high trailer, without any markings … and, of course, the vehicle itself and its bright luminescent markings were almost obscured.

What would happen at night, in heavy rain … if any of these vehicles had to stop on a road without any public lighting … as they responded to a traffic accident … or because they were part of a Garda/police checkpoint ?   Serious danger for the responders and other road users is the obvious answer !

Then, more recently, while walking around Howth Harbour, in Dublin … I spotted this Irish Coast Guard Vehicle … which made me feel more optimistic …

Irish Coast Guard Vehicle, with High Visibility Markings, at Howth Harbour in Dublin.

Colour photograph showing an Irish Coast Guard Vehicle, with High Visibility Markings, at Howth Harbour in Dublin. Photograph taken by CJ Walsh. 2013-08-24. Click to enlarge.

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CVVFA-ERSI: ‘Vehicle Marking and Technology for Increased Highway Visibility – A Reference Guide for Decision-Makers’ (2013)

Click the Link Above to read and/or download PDF File (4.35 MB)

Produced by the U.S. Cumberland Valley Volunteer Firemen’s Association (CVVFA) Emergency Responder Safety Institute (ERSI) … with the support of the Federal Emergency Management Agency’s United States Fire Administration (USFA), and the National Institute of Justice (NIJ) – the research, development and evaluation agency of the U.S. Department of Justice.

Author: Ron Moore – Chief Instructor, CVVFA Emergency Responder Safety.

CVVFA ERSI WebSite: www.respondersafety.com

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Cover Page - U.S. Fire Administration Report FA-330: 'Traffic Incident Management Systems' (2012)U.S. Fire Administration Report FA-330 – March 2012

USFA: ‘Traffic Incident Management Systems’ (2012)

Click the Link Above to read and/or download PDF File (4.87 MB)

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Both of these documents must be carefully adapted by the reader to suit a European context … as the following List of Recommendations from USFA Report FA-330 will clearly indicate …

To help decrease vehicle-related injuries and fatalities of emergency responders if implemented at the appropriate levels:

1.   Develop a comprehensive database that tracks accidents involving emergency vehicles and any resulting injuries and/or deaths to both emergency responders and civilians.

2.   Limit speeds to a level that is safe for the vehicle being driven and the road conditions on which it is being operated.

3.   Adopt a zero-tolerance alcohol (and drugs) policy and enforce an 8-hour time difference between alcohol consumption and the commencement of work.

4.   Equip all emergency vehicles with appropriate traffic control and safety equipment.

5.   Ensure all traffic-channelizing devices meet applicable standards.

6.   Ensure flaggers, if used, are properly trained and meet Manual of Uniform Traffic Control Devices for Streets and Highways (MUTCD) qualifications.

7.   Require members to wear highly reflective American National Standards Institute (ANSI)/International Safety Equipment Association (ISEA) 107 Class II, Class III, or ANSI/ISEA 207 compliant public safety vests whenever they operate in a roadway.

8.   Mark the emergency vehicle perimeter with retro-reflective striping or markings.

9.   Extinguish forward facing emergency vehicle lighting when parked on the roadway, especially on divided roadways.

10.  Fire departments should consider the implementation of traffic safety response units.

11.  Position the initial-arriving emergency vehicle in a blocking position to oncoming traffic.

12.  Establish an adequately sized work zone.

13.  Develop a formalized Traffic Incident Management (TIM) information sharing method between public safety and transportation agencies.

14.  Manage major traffic incidents using the National Incident Management System (NIMS) Incident Command System (ICS).

15.  Consider the use of Unified Command (UC) to manage traffic incidents involving multiple jurisdictions or disciplines.

16.  Incorporate transportation departments into ICS when appropriate.

17.  Ensure adequate training on roadway hazards and safety procedures for responders.

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Upcoming Building Research Workshop at Galway University

2013-06-08:  Looking forward to some serious, collaborative and multi-disciplinary discussions on the day … and a barrel of laughs in the process (!!) …

The Informatics Research Unit for Sustainable Engineering (IRUSE) in the Department of Civil Engineering … and The Ryan Institute for Environmental, Marine and Energy Research … both at the National University of Ireland Galway (NUIG) … have jointly organized a 1-Day National Research Networking Workshop which will take place on Monday, 24 June 2013.

The NUIG ‘blurb’ for the day states … “Considering the importance of aggressive energy-efficiency measures in the Building Sector, together with the requirements for a safe, healthy, comfortable (and accessible) Built Environment … this NUIG Workshop will explore the topic of Integrated Modelling and Performance of the Built Environment.”

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I was very pleased to receive an invitation to make a Presentation at this prestigious event …

‘Sustainable Fire Engineering Design’  –  My Presentation Abstract

Fire Engineering … involves much more than mere compliance with building regulations and codes … whose fire safety objectives are limited, and whose performance requirements are sometimes inadequate and always minimal.  More problematically … a fundamental conflict is mushrooming between Safe Sustainable Climate Resilient Building Design and Conventional Fire Consultancy Practice.

However … Sustainable Fire Engineering Design Solutions are:

  • Reliability-based ;
  • Person-centred ;

and above all

  • Adapted to Local Context and Heritage (fr: le Patrimoine – see ICOMOS 2011) … geography, climate (incl. change, variability and severity swings), social need, culture, and economy, etc., etc.

This Presentation will discuss very rich collaborative research potential in the following areas …

  1. Creative Fire Engineering Concepts and Building Systems
  2. Fire-Induced Progressive Damage in Buildings
  3. Human Behaviour and Abilities in a Fire Situation
  4. Building Design for Firefighter Safety
  5. BMS – Fire Modelling – BIM

Research Output must be targeted at practical implementation in ‘real’ buildings … with actual user/construction performance carefully (i.e. reliably and precisely) monitored !

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If anybody out there is interested in attending this NUIG Research Workshop … please contact Ms. Magdalena Hajdukiewicz (IRUSE) at: hajdukiewicz1@nuigalway.ie

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POST-EVENT UPDATE:  2013-06-27 …

While it was difficult to keep the Workshop Programme, involving a series of short 10-minute presentation slots, on track … discussions during the day were engaging, energetic and extensive.

I happily look forward to a successful and collaborative outcome from the day … Multi-Disciplinary Teams producing Trans-Disciplinary Research Output … which is geared towards practical implementation in ‘real’ buildings, with actual construction and building user performance carefully (i.e. reliably and precisely) monitored !

Galway University (NUIG) Workshop Programme & Presentation Abstracts

Click the Link Above to read and/or download PDF File (193 Kb)

Galway University (NUIG) Built Environment Research Networking Workshop - 24 June 2013

Colour photograph showing the venue for the IRUSE & The Ryan Institute (Galway University – NUIG) Built Environment Research Networking Workshop, which was held in the New Engineering Building on 24 June 2013. Seen here is Dr. Harald Berresheim during his presentation on ‘The Self-Cleansing Capacity of Our Atmosphere – Limitations on Local to Global Scales’. Photograph taken by CJ Walsh. 2013-06-24. Click to enlarge.

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CJ Walsh Presentation: ‘Sustainable Fire Engineering Design’

Click the Link Above to read and/or download PDF File (1.78 MB)

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However … and especially since the Workshop had been organized by IRUSE (the ‘SE’ standing for ‘Sustainable Engineering’) … it was indeed very strange to have to clarify the following points, among others:

1.   The Minimum Life Cycle for a Sustainable Building is 100 Years … not 50 or 60 years !

2.   Future Research Collaboration should be targeted at the multi-aspect ‘Sustainability Agenda’.  The word ‘green’ (where only environmental aspects of sustainability are considered) should be actively discouraged, if not banned entirely !

3.   With regard to Good Indoor Air Quality (IAQ) … two high-level performance indicators which have been developed with the aim of protecting human health, and are both now referenced in International Standard ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’ … are …

      –   Radon Activity (incl. Rn-222, Rn-220, RnD) in a building should, on average, fall within the range of 10 Bq/m3 to 40 Bq/m3, but should at no time exceed 60 Bq/m3 ;

      –   Carbon Dioxide (CO2) Concentrations in a building should not significantly exceed average external levels – typically within the range of 300 parts per million (ppm) to 500 ppm – and should at no time exceed 800 ppm.

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Galway University’s New Engineering Building

Concerning the substantive difference in meaning and scope between ‘sustainable’ and ‘green’ … there is, perhaps, no better way to illustrate this difference than to observe the atrocious ‘Accessibility-for-All’ Performance (Accessibility for People with Activity Limitations !) of the critically acclaimed (?!?) and award winning (?!?) New Engineering Building in Galway University … which flaunts its ‘über-green’ credentials …

Galway University's New Engineering Building - Inadequate Accessibility-for-All (1)

Galway University's New Engineering Building - Inadequate Accessibility-for-All (2)

Galway University's New Engineering Building - Inadequate Accessibility-for-All (3)

Galway University's New Engineering Building - Inadequate Accessibility-for-All (4)

Galway University's New Engineering Building - Inadequate Accessibility-for-All (5)

Can you believe what’s in those photographs ??   More importantly … can you believe what’s not in those photographs ????   In such a recently completed building … “incredible” is the only answer to both questions.

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Under International Law … lack of accessibility, or inadequate accessibility, to the social, built, virtual and economic environments … IS a denial and infringement of the basic human rights of people with activity limitations.  It also limits, needlessly and unnecessarily, the numbers of potential users of those environments … which makes no sense at all.

My strong recommendation to Galway University … is to immediately commission a Competent Accessibility Consultant to give the university campus a thorough going over !   You are failing the campus user population … the local community in Galway … and Irish society generally.

My even stronger recommendation to the Architects for the New Engineering BuildingRMJM Architects (Robert Matthew Johnson-Marshall) in Scotland, and Taylor Architects in Ireland … is to always commission a Competent Accessibility Consultant on all of your projects … small, medium and large … because you haven’t a bull’s notion about this important dimension of building performance !!

And remember folks … Accessibility has been clearly specified in the new International Standard ISO 21542 as including … ‘access to buildings, circulation within buildings and their use, egress from buildings in the normal course of events, and evacuation in the event of an emergency’.

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SDI Practice Announcement – New 32 Storey Hotel in China

2013-04-02:  Sustainable Design International Ltd. (SDI) is pleased to announce that its Managing Director, C.J. Walsh, has been invited to be ‘Project Design Architect’ / ‘Design Professional in Responsible Charge’ for a New 32 Storey Hotel in Yunnan Province, People’s Republic of China (PRC).

He will have responsibility for the Project’s Architectural Concept Design and General Schematic Design … including the overall architectural character and profile of primary exterior surfaces.

Project Approximate Value = € 65 Million (Euros) … excluding interior design, finishes and furnishing (which could end up doubling, or even tripling, the overall project value).

Sustainable Design International Ltd.  maintains a strict practice policy of Client Confidentiality.

[ If this Type of Professional Design Service Appeals to You, or Your Organization – Contact Us Immediately ! ]

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2012 ‘Understanding China’ Policy Briefing Friends of Europe & EuroChambres

An estimated One Billion People will be living in China’s cities by 2030.  This large-scale and very rapid urbanization demands that a sustainable transformation of their urban built, social, economic and institutional environments commences Today – not at some notional point in a far distant future.

Furthermore … replicating a European approach to sustainable design and construction in other regions of the world is doomed to failure.  Urban Transformation in China must be adapted to Local Geography, Climate, Climate Change, Social Needs, Cultures, Economy, and Local Severe Events (e.g. earthquakes, flooding).  With European support and collaboration … China must, and will, find its own way.

Greening China's Cities of Tomorrow (2012) - Report CoverGreening China’s Cities of Tomorrow (Spring 2012)

Click the Link Above to read and/or download a PDF File (4.42 Mb)

Report on a One-Day China Advisory Council Roundtable, co-organized by Friends of Europe and EuroChambres, which was held in Brussels on 8 March 2012.  This event was part of an ‘Understanding China’ Programme (mid-2009 to mid-2012), co-funded by the European Commission.

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2013 Asian Development Bank (ADB) Guidebook: ‘Increasing Climate Change Resilience of Urban Water Infrastructure’ 

This Guide describes a practical approach to bridge the gap between theoretical analyses of climate change impacts and the planning decisions that need to be made by city authorities and utility managers to increase climate change resilience of the water sector in the city of  Wuhan, Hubei Province, People’s Republic of China (PRC).  It focuses on answering the questions currently being asked by city planners and managers all over the world, as follows:

  • What changes might be caused by climate change ?
  • How will these changes affect services and utilities ?
  • What can we do now to prepare for them ?

The long lead time required to plan, finance, build, and commission city infrastructure facilities means that decision makers cannot wait for more detailed data on the effects of future climate change, especially those relating to local circumstances, but must make investment decisions based on what is known now and what can be readily predicted.  An important principle in this kind of ‘robust’ decision-making is provided by the  Intergovernmental Panel on Climate Change (IPCC)  tenet that adaptation investments, which move a city’s infrastructure toward sustainable development (such as providing safe drinking water and better sanitary conditions), are justifiable even without climate change.

This Guide is arranged in clear steps to provide direction and information for similar exercises in other areas.  Having grown out of a specific locality and its needs, the principles and solutions developed in this guide are founded on real world situations and problems …

ADB Guidebook: 'Increasing Climate Change Resilience of Urban Water Infrastructure' (2013) - Cover PageIncreasing Climate Change Resilience of Urban Water Infrastructure (ADB, 2013)

Click the Link Above to read and/or download a PDF File (2.31 Mb)

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***  THIS TALL BUILDING IN YUNNAN PROVINCE  &  SIMILAR COMPLEX ARCHITECTURAL PROJECTS  ***

Working within the professional constraints of ‘client confidentiality’ … it is possible to have a general discussion about current building design, construction and operation issues in an international sector which is operating, more and more, beyond national borders … without adequate, or very often any, national and local regulation.  By ‘regulation’, I mean a flexible system of building-related legislation which is operated in conjunction with mandatory and effective technical control.

In order to cope with today’s complex built environment and the enormous variation in the size and scale of construction projects … a ‘flexible’ mix of functional, performance and prescriptive legal requirements is the sharpest and most appropriate instrument.

And you can forget the hype about performance-based building codes coming out of the USA … hot air, and much ado about little !

Of course, the biggest issue of all is the competence of those individuals who work in Authorities Having Jurisdiction (AHJ’s), i.e. technical controllers.  Even in the most developed economies of the world … there are many occasions when the level of individual incompetence in an AHJ is astounding … and institutional arrangements within the AHJ itself are a mess, i.e. the AHJ is not fit for purpose.

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1.  Sustainable Design – Design Process Efficiency & Proper Preparation for Construction

A tremendous amount of waste is associated with and generated by the processes of conventional building design, construction and operation.  There is a more up-to-date and efficient way of doing things … an essential way for Sustainable Design … and it’s called Building Information Modelling (BIM) !

Furthermore … consider, for a moment, just the initial list of Specialist Consultants who will be engaged directly by the Chinese Client when the project’s conceptual design has reached a sufficiently developed stage.  How can all of these individuals and organizations – listed in the revised and agreed Project Design Agreement – obtain accurate and reliable ‘real time’ information about the rapidly evolving project from a central design library / information database … then feed their new work back into the centre without unnecessary delay ?   How, next, can everyone else who needs to know, be updated with the new design input … again, without delay ?   And perhaps, these consultants may also be based in different countries … working in very different time zones …

  • Building Information Modelling (BIM) Consultant
  • Local Design Institute (LDI) … a local architectural practice which will produce the project’s working drawings, handle local spatial planning and building code approvals, carry out site inspections, and deal directly with construction organization(s), etc., etc.
  • Interior Design Consultant
  • Traffic / Parking Analysis Consultant
  • Curtain Wall Consultant (Curtain Wall, Skylights & Special Roof Structures)
  • Retail Market Analysis Consultant
  • Landscape Design Consultant
  • Quantity Surveying & Cost Estimating Consultant
  • Furniture Design Consultant
  • Geotechnical, Civil Engineering & Structural Engineering Consultant (including structural performance under fire and earthquake conditions, resistance to fire-induced progressive damage and disproportionate damage … and also including climate resilience)
  • Acoustic & Audio-Visual Design Consultant
  • Mechanical, Electrical & Plumbing (MEP) Engineering Consultant
  • Integrated Building Automation & Management / Telecom / Security / Networking Consultant
  • Fire & Life-Safety Engineering Consultant
  • Water Feature Consultant
  • Wind Tunnel Test Consultant
  • Kitchen Equipment and Layout Design Consultant
  • Art, Artefact and Accessories Consultant & Procurement Services for Art, Artefacts, and Accessories
  • Tenant Storefront Design Consultant
  • Helicopter Landing Pad Design Consultant
  • Universal Design / Accessibility for All Consultant [including access to the building, electronic, information and communication technologies (EICT’s), and services offered at the hotel … and including fire safety, protection and evacuation for all]

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2.  The ‘Design Professional in Responsible Charge’ !

The Project Design Agreement requests that the Client receive advice on who might be the different Specialist Consultants listed above.  In addition, it will be necessary to demarcate the boundaries within which each Consultant will operate … and, where appropriate, to prescribe a design performance target (see below) for each speciality … which must be ‘realized’ in the completed and occupied building !

Recalling the many previous posts, here on this Technical Blog, concerning NIST’s 2005 & 2008 Recommendations on the 9-11 World Trade Centre Building Collapses in New York City‘somebody’ must ensure that the many individuals and organizations listed above – members of the Larger (2nd Stage) Design Team – use consistent design data and assumptions … must co-ordinate design documents and specifications to identify overlaps and eliminate gaps … must serve as ultimate liaison between the Client, the Local Design Institute, AHJ officials, and the Construction Organization(s) … and must ensure that everybody is on the same communication wavelength, and working towards the same objective in a trans-disciplinary manner.

That ‘Somebody’ … the Design Professional in Responsible Charge … must be the Project Design Architect !

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3.  Some Sustainable Design Performance Targets

Actual construction and building user performance shall be carefully (i.e. reliably and precisely) monitored … and independently verified …

A.   Basic Functional Requirements … the Building shall comply with the Basic Requirements for Construction Works – elaborated in Annex I of European Union (EU) Regulation No.305/2011 of the European Parliament and of the Council, of 9 March 2011, laying down Harmonized Conditions for the Marketing of Construction Products and Repealing Council Directive 89/106/EEC.

See my Post, dated 2011-09-13 … https://cjwalsh.ie/2011/09/new-eu-construction-product-regulation-3052011-halleluiah/

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B.   Good Indoor Air Quality (IAQ) … Two high-level performance indicators have been developed with the aim of protecting Human Health, and are both now referenced in International Standard ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’

      –   Radon Activity (incl. Rn-222, Rn-220, RnD) in a building should, on average, fall within the range of 10 Bq/m3 to 40 Bq/m3, but shall at no time exceed 60 Bq/m3 ;

      –   Carbon Dioxide (CO2) Concentrations in a building should not significantly exceed average external levels – typically within the range of 300 parts per million (ppm) to 500 ppm – and shall at no time exceed 800 ppm.

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C.   Energy Conservation & Efficiency + A ‘Positive Energy’ Return + Assured Building User Thermal Comfort

See my Post, dated 2013-09-10 … https://cjwalsh.ie/2013/09/passivhaus-standard-is-not-enough-in-new-building-projects/

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D.   Project-Specific Sustainable Fire Engineering Design Objectives

See my Post, dated 2014-04-20 … https://cjwalsh.ie/2014/04/sustainable-fire-engineering-design-targeting-mrv/

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‘Sustainability’ – New Part 11 in India’s National Building Code !

2013-03-17:  Happy Saint Patrick’s Day !!

Submissions on India’s Draft Amendment No.1 to the 2005 National Building Code (SP 7:2005) concerning the Proposed Incorporation of a New Part 11: ‘Approach to Sustainability’ had to arrive at the Bureau of Indian Standards (BIS), in Dilli … by e-mail … no later than Friday last, 15 March 2013 …

Indian National Building Code Proposed New Part 11: 'Approach to Sustainability' - Cover Memo

Click to enlarge.

Indian NBC, Proposed Part 11 on ‘Sustainability’ – December 2012 Consultation

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Extract From Foreword (Page 7):

‘ Developed nations’ approach to sustainability generally concentrates on energy conservation through high technology innovations, and use of products, materials and designs with lower embodied energy.  Their green ratings are based on intent, which implies expert inputs and simulation.  The Indian construction industry will do better using our traditional wisdom and practices, building in harmony with nature through regional common knowledge, consuming as little as necessary, applying low cost technology innovations, using recycled materials, and recognizing performance (not intent) through easily measurable parameters wherever feasible.’

How Right They Are About Prioritizing ‘Real’ Performance !!

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And Just Before That Extract Above:

‘ The authentic (my insert !) Indian way of life is aparigraha (minimum possessions), conservation (minimum consumption), and recycling (minimum waste).  These three attributes are the guiding principles for sustainable buildings as well.  With these attributes and its rich heritage, India can make a substantial contribution in this field and eventually lead the world on the path of sustainability.’

An Overly Ambitious Target ?   Perhaps Not.

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SDI Supporting India’s National Sustainable Buildings Strategy …

We very much welcome this opportunity to make a Submission on India’s Draft Amendment No.1 to the 2005 National Building Code (SP 7:2005) concerning the Proposed Inclusion of a New Part 11 ‘Approach to Sustainability’.

This IS an important development for India … and it DOES mark a substantial contribution to this field, at international level.  We wish that other countries would follow your example … particularly China, the other mushrooming economies in South-East Asia, and the Arab Gulf States.

You may not be aware that Sustainable Design International (SDI) has been specializing in the theory and implementation of a Sustainable Human Environment (social, built, virtual, and economic) since the mid-1990’s.

And, for example … in September 2007, we were invited to make a series of Keynote Presentations to 20 Senior National Decision-Makers, from both the public and private sectors, at a 2-Day Workshop which was organized for us in Lisboa, Portugal.  If invited, we would be delighted to repeat this valuable exercise in Dilli, Bengaluru, and other suitable venues in India.

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IF India is to lead the world on this particular track, i.e. Sustainable Buildings, a coherent philosophy must be outlined in the Proposed New Part 11 of the National Building Code, and a clear direction must also be given there to decision-makers, e.g. clients/client organizations, and designers.

Certain essential content must be included in Part 11.  With regard to an improved layout of Part 11, please review the attached  SDI Document: ‘SEED Building Life Cycle’ (PDF File, 55 Kb) .

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Because you have prioritized ‘real’ building performance over pre-construction design ‘intent’, it is appropriate to begin our comments here …

1.   Sustainability Performance Indicators

In order to prioritize ‘real’ performance, the monitoring of actual sustainability performance in completed and occupied buildings must be comprehensive, accurate and reliable.  Indicators of sustainability performance must, therefore, be included in all sections of the Proposed New Part 11.

Sustainability Performance Indicators provide important signposts for decision-making and design in many ways.  They can translate physical and social science knowledge into manageable units of information which facilitate the decision-making and design processes.  They can help to measure and calibrate progress towards sustainable development goals, and sectoral sustainability targets.  They can provide an early warning to prevent economic, social and environmental damage and harm.  They are also important tools to communicate ideas, thoughts and values because, as statisticians say: “We measure what we value, and value what we measure”.

Performance Indicators may be both quantitative and qualitative … but must cover all stages of the building process, i.e. project feasibility and performance specification, spatial planning, design, construction, management, operation, maintenance and servicing, de-construction, disposal, final site clean-up and sustainable repair.

While many, though not all, types of building performance can be successfully monitored using lightweight portable equipment … a certain number of monitoring devices must also be permanently installed in the building during construction.  A facility to reliably feed the output from these devices back to data collection points, on site and remote, must also be incorporated in the Building’s Intelligent Management System.

Management and collation of sustainability performance data must be reliable.  Uncertainty is always present.  Therefore, Statements of Uncertainty should always be attached to ‘reliable’ data.

Safety Factors should always be included when targeting critical ‘health and safety’ related types of performance.

Sustainability Performance Indicators must be directly comparable across different Global Regions … within Asia, across different countries … and within India, across different States.  A Balanced, Harmonized Core Set of Indian Performance Indicators should be quickly developed.  A Balanced ‘Local’ Set of Performance Indicators will always be necessary.

People tasked with monitoring sustainable building performance must be competent … and independent, i.e. be unconnected to client, design and construction organizations.

Specifically in relation to Energy Performance, the targets to be achieved in new buildings must be far more ambitious.  Please review the attached  SDI Document: ‘SEED Positive Energy Buildings’ (PDF File, 29 Kb) .

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2.   Properly Defining ‘Sustainable Development’

As currently drafted … Definition 2.26 Sustainable Development, on Page 13 of the Proposed New Part 11, is not only ambiguous, it is inadequate for India’s needs … and it is barely the first half of the full, correct definition …

Sustainable Development  is development that meets the needs of the present without compromising the ability of future generations to meet their own needs.  It contains within it two key concepts:

  • the concept of ‘needs’, in particular the essential needs of the world’s poor, to which overriding priority should be given ;  and
  • the idea of limitations imposed by the state of technology and social organization on the environment’s ability to meet present and future needs.

[ Please refer to the 1987 Report of the World Commission on Environment & Development (WCED): ‘Our Common Future’ – Chapter 2, Paragraph 1.]

This original definition in the 1987 WCED Report IS appropriate for India … and it must become the core definition at the heart of India’s National Sustainable Buildings Strategy !

A careful reading of the full definition makes it clear that there are Many Aspects to this intricate, open, dynamic and still evolving concept … the most important of which are:  Social, Economic, Environmental, Institutional, Political, and Legal.

It is a Fundamental Principle of Sustainability, and one of its Primary Values … that Implementation must be Synchronous, Balanced and Equitable across All Aspects of Sustainability.

The ‘Green Agenda’ merely considers Environmental Aspects of Sustainability … in isolation from all of the other Aspects !   This is a fatal flaw which must be avoided in the Proposed New Part 11 !!

[ I made many references to this issue during the FSAI Conferences in India ! ]

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3.   Sustainability Impact Assessment (SIA) for India !

Rather than Environmental Impact Assessment … surely the Proposed New Part 11: ‘Approach to Sustainability’ must now use, explain and discuss Sustainability Impact Assessment instead !?!

Sustainability Impact Assessment (SIA)

A continual evaluation and optimization assessment – informing initial decision-making, or design, and shaping activity/product/service realization, useful life and termination, or final disposal – of the interrelated positive and negative social, economic, environmental, institutional, political and legal impacts on the synchronous, balanced and equitable implementation of Sustainable Human & Social Development.

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4.   A Robust Legal Foundation for ‘Sustainable Human & Social Development’

Paragraph 4 (Chapter 2, 1987 WCED Report) states …

‘ The satisfaction of human needs and aspirations is the major objective of development.  The essential needs of vast numbers of people in developing countries – for food, clothing, shelter, jobs – are not being met, and beyond their basic needs these people have legitimate aspirations for an improved quality of life.  A world in which poverty and inequity are endemic will always be prone to ecological and other crises.  Sustainable development requires meeting the basic needs of all and extending to all the opportunity to satisfy their aspirations for a better life.’

Trying to list the essential needs of people / the basic needs of all is a very difficult task … but it is work which has been on-going, at international level, since just after the Second World War.

The essential needs of people / the basic needs of all … are specified as being Human Rights and Fundamental Freedoms, and are already fully described within the extensive framework of International Legal Rights Instruments.

Which is why, many years ago, SDI developed this definition for Sustainable Human & Social Development … in order:

  • to give this concept a robust legal foundation ;   and
  • (because of widespread confusion in media, political and academic circles) … to clearly establish that we are talking about sustainable human and social development, and not sustainable economic development, or any other type of development !

Sustainable Human & Social Development

Development which meets the responsible needs, i.e. the Human & Social Rights*, of this generation – without stealing the life and living resources from future generations … especially our children, and their children … and the next five generations of children.

*As defined in the 1948 Universal Declaration of Human Rights.

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5.   Climate Change Adaptation & Resilient Buildings in India ?

Atmospheric Ozone Depletion and Climate Change are mentioned, here and there, in the Proposed New Part 11.  The important implications of these phenomena for Sustainable Building Design in India are not explained … at all.  Why not ?

To properly respond to these phenomena, both must be integrated into India’s National Sustainability Strategies & Policies.

At the very least … we strongly recommend that Design Guidance on Climate Resilient Buildings be immediately drafted.  This guidance must be appropriate for implementation in each of the different climatic regions of India.

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6.   A Sustainable Indian Built Environment which is Accessible for All !

Barrier Free is mentioned, here and there, in the Proposed New Part 11.  This is to be warmly welcomed and congratulated.  Under Social Aspects of Sustainable Human & Social Development … this is an essential attribute of a Sustainable Built Environment !   However, no guidance on this subject is given to decision-makers or designers.  Why not ?

However, you should be aware that India ratified the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) on 1 October 2007.  For your convenience, I have attached copies of the Convention in English, Hindi and Tamil.

You should also be aware that, in December 2011, the International Standards Organization (ISO) published ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’.  In its Introduction, ISO 21542 is directly linked to the U.N. Convention … almost like an umbilical cord.  The scope of this Standard currently covers public buildings.  As the Accessibility Agenda in the U.N. Convention is very broad … much standardization work remains to be finished at international level.

The correct term … Accessibility for All … has been defined in ISO 21542 as including … ‘access to buildings, circulation within buildings and their use, egress from buildings in the normal course of events, and evacuation in the event of an emergency’.

A note at the beginning of the standard also clarifies that Accessibility is an independent activity, i.e. assistance from another person should not be necessary … and that there should be an assurance of individual health, safety and welfare during the course of those (accessibility-related) activities.

In order to fulfil India’s legal obligations as a State Party to the U.N. Convention on the Rights of Persons with Disabilities … adequate Design Guidance on Accessibility must be included in the Proposed New Part 11, supported by ISO 21542.

In addition, the Bureau of Indian Standards (BIS) should immediately adopt ISO 21542 as the Indian National Standard on Accessibility for All … IS / ISO 21542.

[ I made many references to this issue during the FSAI Conferences in India ! ]

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7.   Fire Safety & Protection for All in Sustainable Indian Buildings ?

Yes … there is 1 mention of ‘fire safety’ and 40 other references to ‘fire’ in the Proposed New Part 11 … but no design guidance.  Why not ?

You should be aware that there is a fundamental conflict between Sustainable Building Design Strategies and the current state-of-the-art in Fire Engineering Design.  As a good example … for cooling, heating and/or ventilation purposes in a sustainable building, it is necessary to take advantage of natural patterns of air movement in that building.  On the other hand, fire engineers in private practice, and fire prevention officers in Authorities Having Jurisdiction (AHJ’s), will demand that building spaces be strictly compartmented in order to limit the spread of fire and smoke … thereby dramatically interfering with those natural patterns of air movement.

In everyday practice, there is a vast chasm in understanding and communication between these two very different design disciplines.  As a result, serious compromises are being enforced on Sustainability Building Performance.  If, on the other hand, adequate independent technical control is absent on the site of a Sustainable Building … it is the fire safety and protection which is being seriously compromised.

A range of critical fire safety issues (fatal, in the case of firefighters) are also arising with the Innovative Building Products and Systems being installed in Sustainable Buildings.

Because the emphasis is on pre-construction design ‘intent’ rather than the ‘real’ performance of the completed and occupied building … all of these problems are being conveniently ignored, and they remain hidden from everybody’s view.

This must be addressed in the Proposed New Part 11.

[ I made many references to this issue during the FSAI Conferences in India ! ]

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C. J. Walsh – Consultant Architect, Fire Engineer & Technical Controller – Managing Director, Sustainable Design International Ltd. – Ireland, Italy & Turkey.

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‘Building External Lighting Design’ – An SDI Professional Service

2013-01-30:  The Energy Efficiency of Electrical Light Fittings continues to improve dramatically … and it’s about time too.  So much energy was needlessly wasted before !

Prior to the commencement of the External Lighting Design Project below … this prominent religious building in Dublin City was ‘pitch’ dark at night, almost a black hole in the local urban landscape, a depressing non-entity … people waiting at bus stops on each of the roads beside the building were nervous … muggings occasionally took place … litter was always being thrown into the grounds surrounding the building … evidence screaming out loud that nobody cared !

External Lighting Design Project - Prominent Religious Building, Dublin City, Ireland

Colour photograph showing the finished External Lighting Project for a prominent religious building in Dublin City, Ireland. Project Design and Supervision of Installation by CJ Walsh. Electrician: W. Fleming, Electrical Services. Click to enlarge.

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After Project Completion … the ‘presence’ of this building within the local community was enhanced to an extraordinary extent … it was at once seen to be at its centre … security issues at night were immediately resolved … the building looked as if people cared about it … and a special bonus … architectural features which usually went unnoticed by the public during the day were beautifully highlighted at night.

The Client Organization … in this case, a religious order … was so pleased with the finished work that they commissioned a professional photographer … and then used the image above on the Parish Christmas Cards to be distributed to parishioners.

The Moral of The Story for Clients/Client Organizations is … give serious consideration to how your building (whether it is a church, mosque, or synagogue) looks during daylight … and most importantly, during the long hours of darkness !

External Building Lighting is much more than mere decoration … it is an essential component in the sustainable design of any important / iconic building type !!

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SDI Contact Information

E-Mail:  cjwalsh@sustainable-design.ie

International Phone:  +353 1 8386078   /   National Phone:  (01) 8386078

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

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

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

In Ireland:

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

TGD B (2006), Paragraph #1.0.9 – Definitions

Place of Safety

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

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

In England & Wales:

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

Building Regulations, Requirement B1 – Means of Warning & Escape

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

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

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

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

Place of Ultimate Safety

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

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

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

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

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

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

and

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

and

where people can be identified.

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

Was that good for you ?

Furthermore …

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

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

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

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

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

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

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

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

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

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

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

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

Here are a Few Suggestions for Discussion …

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

Fire Evacuation for All

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

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

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

Objective (Approach to Buildings)

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

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

Objective (Access to Buildings)

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

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

Passenger Lifts

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

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

Internal Stairs

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

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

And …

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

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

Objective (Facilities in Buildings)

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

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

Objective (Aids to Communication)

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

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

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

Fire Safety in Dwellings for People with Disabilities

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No Budgetary Control at FÁS – What About Technical Controls ?

2009-09-12:  Headlines in Ireland’s News Media, very recently, have concerned a lack of proper budgetary control … make that ‘any’ budgetary control … in FÁS (Foras Áiseanna Saothair) – the Irish Training & Employment Authority.

FÁS operates under the aegis of the Department of Enterprise, Trade and Employment and has functions in relation to the training of people with disabilities and the unemployed, the up-skilling of the employed and the administration of apprenticeships.

Special Report No.66 (dated 12th June 2009), from the Office of the Comptroller & Auditor General in Ireland, examined:

  • advertising and promotional expenditure by FÁS in the period 2002-2008 ;
  • budgetary control over FÁS’s advertising and promotional expenditure ;
  • general strategy under which advertising and promotional expenditure was spent in FÁS ;
  • the extent to which the effectiveness of this expenditure was evaluated ;
  • procurement of advertising and related services in FÁS.

Overall Examination Findings

Advertising, which accounted for almost half of the overall promotion expenditure by FÁS, is the largest in the non-commercial State sector.  The examination found that

  • Advertising and promotional activities lacked strategic direction insofar as a marketing and communications strategy had not been developed by FÁS despite longstanding commitments to do so.
  • There was a substantial and prolonged breakdown in budgetary control in the area of promotional expenditure in the period under review with expenditure exceeding budgets by 38%.  This lack of control was particularly evident in the area of general advertising where expenditure exceeded budgets by 66% over the seven-year period.
  • Much of the advertising was ineffective in increasing an awareness of the services provided by FÁS.
  • There was nugatory expenditure of €622,000 as a result of a series of transactions for which there was no evidence of goods or services having been provided.
  • There was also considerable non-effective expenditure including over €600,000 spent on producing TV advertisements that were not broadcast and payment of €9,200 for a car that was not delivered.
  • The rates FÁS paid for advertising were reasonably in line with industry norms.

Internal financial control was insufficient to ensure that all commitments were recorded and captured, and that procurement was conducted in accordance with public service norms and within expenditure authorisation limits.  In particular, the examination found that 

  • Commitment controls did not function when agents were used to effect transactions.  Procurement of certain goods and services by Corporate Affairs through contracted agencies meant that the Finance section only became aware of certain commitments when invoices were presented for payment.
  • FÁS was exposed to probity risks through a failure to meet public sector procurement requirements.  Exposures arose from the purchase from contracted agencies of goods and services that were not contemplated within the scope of their contracts and the potential consequences of FÁS playing a role in the selection of third parties by the agencies to provide services.
  • Expenditure authorisation limits were circumvented through the splitting of payment claims into a series of invoices.
  • There was a lack of clear accounting trails in regard to proceeds from the sale of exhibition space.

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Why has it taken so long for this Report to enter the public domain ?

And … if there was no proper/any budgetary control in FÁS … is it reasonable to surmise that there were no proper/any technical controls either ?

  • In reality … how well trained were apprentices ?   When the construction industry started to go ‘wallop’ in Ireland, and our economy then nose dived into the ground, what happened to those apprentices … and where are they now ?
  • How well trained were people with disabilities ?   Did they get a fair deal ?   What was the quality of their employment, after the FÁS training ?   Are they still employed ?
  • How good/effective were FÁS’s training courses dealing with, e.g. ‘safety on construction sites’, or ‘radon protection of buildings’, etc ?   Was it a case of jobs for the ‘boys’ ?

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Architectural & Structural Engineering Design for Robustness !

2009-07-11:  Earlier in the year … a certain non-native English speaking colleague of mine, who is very active in European and International standardization work (and has very good English !), had never heard of the word ‘robust’.  She just could not get her head around either the word or the concept … and thought I was making it all up !

Fast forward a few months … and as a long-time member of the International Association for Bridge & Structural Engineering (IABSE), an occasional ‘freebie’ lands on my desk.  This one was a real treat !

Published by IABSE in Switzerland … Structural Engineering Document #11: Design for Robustness … was written, in language accessible to both structural engineers and architects alike, by Franz Knoll and Thomas Vogel.

The objective of these Structural Engineering Documents is to provide in-depth information to practicing architects and structural engineers, in reports of high scientific and technical standards, on a wide range of structural engineering topics.

Check out the IABSE Website … http://www.iabse.org/publications/orderform/ … and get yourself a copy … pronto !

 

In previous posts concerning Areas of Rescue Assistance in Buildings, for example, I have often referred to robust, fire resisting construction

Robust (in the above specific context):  Structurally hardened, and resistant to severe mechanical damage during the fire and for a period of time afterwards, i.e. the cooling phase.

The further development of Fire-Induced Progressive Damage … will inevitably take place within wider considerations of Robustness.

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BER Certificates – A Proposal for What’s Next ! (VI)

2009-06-08:  The other day, I received an impassioned e-mail … an extract …

 

” We are an energy rating company involved in a campaign for enforcement.  Yesterday, we made a presentation to SEI (see attached).  It was the result of a 2-month attempt to meet with the DEHLG and SEI.  You are right in your article about them ‘not WANTING to know’.

 

My only question is: do you have any ideas on what’s next ? ”

 

 

 

The BER Gold Rush Soap Opera so far …

 

There are thousands of BER Assessors out there around the country … each having paid a ‘pretty penny’ for training, for exams, and for registration … and work on the ground is very scarce.  A significant number of those Assessors have an inadequate understanding of building construction … while some of the people who are involved in providing Validated BER Training Courses are, to put it mildly, similarly unendowed.

 

Energy Ireland (SEI) is the Issuing Authority, but it has absolutely no experience as a Control Authority.  And has anyone bothered to read the relevant Legal Disclaimer on the SEI WebSite ?   It does, however, have a large marketing budget … those smarmy, wall-to-wall radio advertisements, which refer to the ‘property game’, continue to irritate my sensitive ear drums !

 

Apparently … 20% of BER Assessments are turning out to be faulty, i.e. they have not been properly carried out by Registered BER Assessors.  In other words, 1 out of every 5 BER Certificates needs to be thrown in the paper recycling bin.  Furthermore … I have discussed in one of my first posts how there is only a very tenuous relationship between a BER Certificate and the ‘real’ energy performance of a specific building.  And in relation to ‘real’ buildings … there is a general non-compliance rate of 70% on Irish Building Sites with the minimal energy performance requirements in Part L of the Irish Building Regulations.

 

SEI’s Register of BER Assessors is unreliable.

 

What a magnificent waste of time, energy and money !

 

 

 

Some Comments on a Recent BER Certificate … 

 

Sitting on the desk to the left of my computer keyboard is a recent Building Energy Rating (BER) Certificate and its accompanying Advisory Report … issued sometime during the second half of May 2009 … for a private, single-occupation dwelling house somewhere in Leinster … and using the DEAP Version 3.0.0 computer software.  I do not wish to identify the specific Certificate.

 

This particular BER Certificate Documentation comprises:

 

         the actual BER Certificate ;

 

Can I be sure that the correct choices were made with regard to the software input information/data ?   No.

 

         its accompanying BER Advisory Report.

 

Not missing any marketing trick, and in stark contrast to the actual BER Certificate … there is an Energy Ireland (SEI) Logo at the top of the first page of the Advisory Report … and an elaborate footer with SEI contact information on the last page.

 

Meanwhile, there is not one single mention of Statutory Instrument No. 666 of 2006: European Communities (Energy Performance of Buildings) Regulations 2006 anywhere in the Report … nothing to explain that SEI is the Issuing Authority for the purposes of this national legislation … or that there is such a thing as a BER Register … etc, etc, etc.

 

The Advisory Information provided in the Report is too vague to be useable … and there are silly typographical errors.

 

Did the BER Assessor request any information from the owner about the house ?   It is impossible to tell whether he/she made any such request.

 

Am I assured that the BER Assessor had an adequate understanding of building construction ?   Definitely not.

 

[ Specific comments about other issues might identify the actual BER Certificate. ]

 

 

 

What’s Next ?

 

The following remarks are directed at those BER Assessors, building owners, landlords, building professionals and general punters who do wish to spend their money on something worthwhile … something which has meaning, and is useful.

 

Energy Labelling of Buildings, just as in the case of other energy using/consuming industrial products … is positive and very worthwhile.

 

The legal basis established by European Union (EU) Directive 2002/91/EC of the European Parliament and of the Council, of 16 December 2002, on the Energy Performance of Buildings … is a good start.

 

I would much prefer if this Directive were linked in more directly to the Extensive Framework of the Construction Product Directive … EU Council Directive 89/106/EEC, of 21 December 1988, on the Approximation of Laws, Regulations and Administrative Provisions of the Member States relating to Construction Products.  The reason that this has not already happened is because of a startling lack of horizontal integration between the different Directorates-General in the European Commission.

 

If there are problems with how the BER Legislation is operating at national level in Ireland, it is not the fault of Brussels or Directive 2002/91/EC … it is our problem … and it is up to us to remedy the situation.

 

There are 3 Immediate Priorities for Building Energy Rating in Ireland:

 

         increase accuracy ;

         reduce uncertainty ;

         improve reliability.

 

 

 

An Initial Proposal

 

Without amending any legislation … and without reference to the Department of the Environment, Heritage & Local Government (DEHLG), Energy Ireland (SEI) and the Construction Industry Federation (CIF) … none of which have shown any proper leadership in relation to these issues, but seem interested only in playing games …

 

 

1.  The BER Certificate

 

Attach a Single-Page Appendix to the actual BER Certificate which clearly shows the Input Information/Data selected by the Registered BER Assessor.  Include a Statement of Measurement/Calculation Uncertainty concerning the Energy Rating Process … and a Statement of Competence in Building Construction, with the Assessor’s Signature … at the bottom of the page.

 

Show the Page Number on the Certificate as Page No.1 of 2 … and on the Appendix as Page No.2 of 2.

 

A BER Certificate should not be valid without this Appendix.

 

 

2.  The Accompanying BER Advisory Report

 

Generally … tighten up the information provided in the Report, make it easier to understand … and make it more useable !   DO NOT TIE energy performance, or any other aspects of building performance, to the minimal – ‘abysmal’ – performance targets described in the guidance texts of Technical Guidance Documents A-M in the Irish Building Regulations.  We have to aim much, much higher !!   The European Union’s 2020 Climate Change Targets will be heavy going for Ireland, even if there is no agreement in Copenhagen at the end of 2009.  And … insert Page Numbers !!!

 

Include Additional Components in the BER Advisory Report:

 

         Findings of a Formal Interview/Questionnaire Survey with the building owner, landlord or manager – some questions should have an open format ;

         Results of Infra-Red Thermography and Air Seepage Testing – discussed at length in previous posts ;

         Results of a Radon Test – as already discussed, an important indicator of Indoor Air Quality and whether or not there is adequate Ventilation in the building.

 

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