Client Organizations

Grenfell Inquiry Recommendations (2) – Fire Emergency Plans !

Previous Posts In This Series …

2019-10-31:  Grenfell Tower Fire Inquiry’s Phase 1 Report – Information

2019-11-11:  Grenfell Inquiry Recommendations (1) – Vulnerable People ?

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2019-12-21:  Recapping with regard to Vulnerable Building Users … the Grenfell Inquiry Phase 1 Recommendations are pathetically and disgracefully inadequate !  At a later stage and in order to make amends for this serious error … Inquiry Chairperson, Sir Martin Moore-Bick must direct that Proper Consideration – not just Token Consideration – be given, in Law, to the Fire Safety of Vulnerable Building Users, who include people with activity limitations, children under 5 years of age, frail older people (not ALL older people !), women in late stage pregnancy, people with disabilities, refugees, migrants, the poor, and people who do not understand the local culture or cannot speak the local language … OR, to put it another way and to remove any ambiguity … any person who may be vulnerable in a fire emergency, i.e. those with limited abilities in relation to self-protection, independent evacuation to an external place of safety remote from the building, and active participation in the building’s fire emergency procedures.

Do you care that Vulnerable People also use Your Building ?
People with Activity Limitations.  Click to enlarge.

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Now, Over 2.5 Years After The Grenfell Tower Fire … London Fire Brigade Commissioner (#LFB), Dany Cotton, has recently stated that she will retire at the end of December 2019.

On 17 December 2019 … The National Inspectorate in Britain for Police and Fire Services (#HMICFRS … www.justiceinspectorates.gov.uk/hmicfrs) published a report into the performance of London Fire Brigade.  Some extracts from that document …

‘ We have concluded there is a long way to go before London Fire Brigade is as efficient as it could be.  We have criticised both the way it uses resources and makes its services affordable now and in future.  In some areas it is wasteful.  While it has made savings, these are not of the level made in other services.

Worryingly, the Brigade is inadequate at getting the right people with the right skills.  It also needs to improve how it promotes the right values and culture, ensuring fairness and promoting diversity as well as managing performance and developing leaders.

The tragic fire at Grenfell Tower in 2017 was one of the biggest challenges London Fire Brigade has ever had to face.  The incident has had a profound effect on how the Brigade now performs.  Although our findings are broadly consistent with those of the Grenfell Tower Inquiry, it must be emphasised that this was an inspection of the Brigade in 2019.  We found that while the Brigade has learned lessons from Grenfell, it has been slow to implement the changes needed.  This is unfortunately typical of the Brigade’s approach to organisational change.’

Title Page of GB’s National Inspectorate (HMICFRS) Report, published on 17 December 2019.

HMICFRS Report on the Performance of London Fire Brigade  (PDF File, 768 Kb)

If Dany Cotton is the only person to go at the end of December 2019, this is very obviously political scapegoating !

Very Quickly … the entire Culture and Value System of London Fire Brigade must change for the better.  And to ensure that this transformation is Immediate and Fully Effective … ALL of Dany Cotton’s Senior Commanders must also go, or be fired … including Dany’s intended replacement, Andy Roe !

In addition … because it is still attempting to defend the criminal ‘Stay Put’ Policy … the National Fire Chiefs Council (#NFCC … www.nationalfirechiefs.org.uk/) in Britain must be held accountable.  Its Chair, Vice Chairs and those Lead Officers with responsibility for fire safety in buildings must ALL be replaced NOW !

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FIRE  EMERGENCY  MANAGEMENT  PLANNING

The Grenfell Fire Inquiry’s Phase 1 Recommendations were published on 30 October 2019.  Under the initial topics covered … they are far from being comprehensive … they are fragmentary, lack depth and any sort of coherence …

[ Paragraph #33.10 ]  I therefore recommend:

a. that the owner and manager of every high-rise residential building be required by law to provide their local fire and rescue service with information about the design of its external walls together with details of the materials of which they are constructed and to inform the fire and rescue service of any material changes made to them ;

[ Paragraph #33.12 ]  I therefore recommend that the owner and manager of every high-rise residential building be required by law:

a. to provide their local fire and rescue services with up-to-date plans in both paper and electronic form of every floor of the building identifying the location of key fire safety systems ;

b. to ensure that the building contains a premises information box, the contents of which must include a copy of the up-to-date floor plans and information about the nature of any lift intended for use by the fire and rescue services.

I also recommend, insofar as it is not already the case, that all fire and rescue services be equipped to receive and store electronic plans and to make them available to incident commanders and control room managers.

[ Paragraph #33.13 ]  I therefore recommend:

a. that the owner and manager of every high-rise residential building be required by law to carry out regular inspections of any lifts that are designed to be used by firefighters in an emergency and to report the results of such inspections to their local fire and rescue service at monthly intervals ;

b. that the owner and manager of every high-rise residential building be required by law to carry out regular tests of the mechanism which allows firefighters to take control of the lifts and to inform their local fire and rescue service at monthly intervals that they have done so.

[ Paragraph #33.22 ]  I therefore recommend:

a. that the government develop national guidelines for carrying out partial or total evacuations of high-rise residential buildings, such guidelines to include the means of protecting fire exit routes and procedures for evacuating persons who are unable to use the stairs in an emergency, or who may require assistance (such as disabled people, older people and young children) ;

b. that fire and rescue services develop policies for partial and total evacuation of high-rise residential buildings and training to support them ;

c. that the owner and manager of every high-rise residential building be required by law to draw up and keep under regular review evacuation plans, copies of which are to be provided in electronic and paper form to their local fire and rescue service and placed in an information box on the premises ;

d. that all high-rise residential buildings (both those already in existence and those built in the future) be equipped with facilities for use by the fire and rescue services enabling them to send an evacuation signal to the whole or a selected part of the building by means of sounders or similar devices ;

e. that the owner and manager of every high-rise residential building be required by law to prepare personal emergency evacuation plans (PEEP’s) for all residents whose ability to self-evacuate may be compromised (such as persons with reduced mobility or cognition) ;

f. that the owner and manager of every high-rise residential building be required by law to include up-to-date information about persons with reduced mobility and their associated PEEP’s in the premises information box ;

g. that all fire and rescue services be equipped with smoke hoods to assist in the evacuation of occupants through smoke-filled exit routes.

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Residents in High-Rise Buildings, whether public or private, must no longer wait in vain for a saviour, or to be saved by the ‘system’.  Instead, the time has arrived to become proactive, and to immediately initiate their own comprehensive programmes of Self-Protection In Case Of Fire … which go far beyond the Recommendations in Moore-Bick’s Phase 1 Report.

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Fire Emergency Management Planning begins very early in the long life cycle of a building.  The following framework should be scaled up or down, depending on the size and extent of a project …

Fire Defence Plan (FDP)

A Fire Defence Plan (#FDP) elaborates the particular fire engineering strategy which has been developed for a specific building at design stage.  It is usually in electronic format and/or hard copy … and comprises fire engineering drawings, descriptive text (including a clear statement of the project’s fire engineering design objectives), a full construction specification (including façade cladding systems), fire safety related product/system information, with supporting calculations and the fire test/approval data which demonstrates their ‘fitness for intended use’.

A Fire Defence Plan must demonstrate a proper consideration for the fire safety, protection and evacuation of all building occupants/users, with a particular and integrated focus on vulnerable building users, especially people with activity limitations.  Refer to Personal Emergency Evacuation Plans (PEEP’s) in my previous post.

In ‘real’ everyday practice, as opposed to academic theorizing … effective fire compartmentation is very difficult to achieve.  Passive/active fire protection measures are never 100% reliable … sometimes nowhere near 100%.  Building management systems are very far from being reliable.  For these reasons, ‘Stay Put’ Policies must be completely avoided !

[ In the specific case of Health Care Facilities, e.g. hospitals, it is highly hazardous to patients and unacceptable with regard to their welfare that they be evacuated during a fire emergency to a place of safety which is remote from the building.  Instead, the optimal fire engineering strategy here is to ‘protect in place’ … which requires a very high level of independently monitored competence, quality and reliability in design, construction, management, operation, and servicing. ]

Fire Defence Plans become ‘live’ during Construction.

A hard copy of the Fire Defence Plan for a building must always be available for inspection on-site.  A copy of the fire defence plan must also be retained at a remote, safe and secure location off-site.

Fire Emergency Planning Committee (FEPC)

Immediately after the completion of construction and occupation of a building, a Fire Emergency Planning Committee (#FEPC) must be established by the building owner(s), in consultation with building occupants/users.  Membership of the FEPC must comprise representatives of the building owner(s), building occupants, and regular users of the building.  The Committee’s task must be to develop, implement and maintain a Fire Emergency Management Plan, consisting of the emergency response procedures and related training and regular practices, which are essential for the effective and efficient management of any fire emergency in the building.  Sufficient resources must be allocated to the FEPC, by the building owner(s), to ensure that it can satisfactorily complete this task.

Fire Emergency Control Room.  Click to enlarge.

The FEPC must ensure that all relevant legislative requirements are met and must examine, if necessary, the need for the appointment of competent, specialist advisors and support.  Special attention must be paid by the FEPC to the fire safety of vulnerable building occupants/users.  The FEPC must establish a Fire Emergency Control Room (#FECR), which must be fitted-out and competently operated – 24/7/365 – in accordance with the Fire Emergency Management Plan.  The FEPC must also appoint a competent Fire Emergency Control Unit Manager.

Fire Emergency Management Plan (FEMP)

The Fire Defence Plan is the basis for, and main component of, a building’s Fire Emergency Management Plan (#FEMP).  This document elaborates the fire emergency response procedures for an occupied building and is produced by the Fire Emergency Control Unit Manager, in liaison with the Local Fire Service.  It contains relevant information about the fire safety preparedness and prevention/protection/recovery measures in the building, and includes the pre-emergency, emergency and post-emergency roles, duties and responsibilities assigned to individuals and, in the case of their absence, nominated deputies.

The Fire Emergency Control Unit Manager liaising with the Local Fire Service.

The objective of a Fire Emergency Management Plan is to ensure that, in the event of a fire emergency, the health and safety of every building occupant/user is protected, including visitors to the building, contractors, and product/service suppliers … and access for, and the safety of, firefighters is assured.  Particular attention must be paid to those occupants with activity limitations.  All Personal Emergency Evacuation Plans (#PEEP’s) must be fully integrated into the overall Fire Emergency Management Plan for the building.  Documented procedures must accurately reflect reality, and real behaviour, in the building.

The Fire Emergency Management Plan must include the procedures, chosen methods of warning to be used during a fire emergency, management control and co-ordination during the fire emergency, communications between each member of the Fire Emergency Control Unit and the building’s occupants/users and with the Fire Service Incident Commander at the scene, emergency response equipment in the building, evacuation actions, arrangements for occupants/users with activity limitations, first-aid personnel, evacuation by lift/elevator fire evacuation assemblies, escalators, travellators and staircases, use and fitting-out of areas of rescue assistance (including visual monitoring and the provision of smoke hoods), lift/elevator lobbies (including visual monitoring and provision of smoke hoods) and floors of temporary refuge, up-to-date emergency contact details, etc.

The Fire Emergency Management Plan must always be available for inspection, in hard copy format, at a convenient location in the building.  A copy must be provided to all building occupants, as they request, in hard copy, electronic and/or alternative formats.  A further copy of the Fire Emergency Management Plan must be provided to the Local Fire Service, as they request, in hard copy and/or electronic formats.

To ensure its effectiveness, the Fire Emergency Management Plan must be regularly practiced at least every three months, tested and reviewed.  If necessary, e.g. in the case of large/complex building types or existing buildings having suspect levels of fire safety, the establishment of an on-site, permanent, competent/specialist Fire Emergency First Response Team (#FEFRT) must be considered.

Fire Emergency Control Unit (FECU)

The Fire Emergency Control Unit (#FECU) must be established by the Fire Emergency Planning Committee to implement, manage, and recommend improvements to the Fire Emergency Management Plan.

In the event of a Fire Emergency, instructions given by the Fire Emergency Control Unit Manager, or his/her Deputy, must take precedence over normal management structures and procedures in the building; and it shall be his/her duty to inform the Local Fire Service, immediately upon their arrival at the scene, about the number/locations of people still in the building, and the number/locations of vulnerable people who may need to be rescued.

Other members of the Fire Emergency Control Unit must accompany occupants/users as they evacuate to place(s) of safety, remote from the building.  Once there, a head count must immediately be taken by those members – now the Person in Charge at a place of safety – to establish the following:

  • That everybody is present, and that nobody has been left behind ;
  • That everybody is uninjured … or if anybody is injured, what appropriate Medical Aid is rendered and/or summoned.

Communications during a fire emergency between all of the interested parties involved can be fraught with difficulty … lack of discipline will cause misunderstandings and confusion … signal strengths may suffer interference because of the building’s construction.  If necessary, Repeater Units must be installed in the building at any signal ‘drop-zones’ … and the development of a Fire Emergency Management Communications ‘App’, for use on FECU/occupant/user smartphones, must also be considered.

The Fire Emergency Control Unit Manager must prepare for the swift and orderly transfer of the Fire Emergency Control Room and its personnel to a safe location off-site, in the unlikely event of a severe fire emergency in the building.

Fire Safety Training & Regular Practice Evacuations

The objective of fire safety training and regular practice evacuations, which are held at least every 3 months, is to ensure that everybody in the building is skilled for evacuation during a fire incident, using safe accessible routes to an external place/places of safety which is/are remote from the building.

Place(s) of Safety.  Click to enlarge.

Fire safety training and regular practice evacuations must be conducted by the Fire Emergency Control Unit Manager for all building occupants and regular visitors to the building, including FECU personnel.  Fire safety training material used, e.g. brochures, hand0outs and fact sheets, must be site-specific, appropriate to an individual’s role and responsibilities, and easily assimilated, i.e. can be comprehended by everyone, including people with activity limitations and those who are illiterate or may use different languages.

A programme of site-specific practice fire evacuations must be developed, in collaboration with the Local Fire Service, by the Fire Emergency Control Unit Manager.

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

Routine Fire Safety/Evacuation Inspections & Maintenance

The Fire Emergency Control Unit Manager must ensure that all fire safety and evacuation related aspects of the Fire Emergency Management Plan, including systems, products and fittings, are routinely inspected, tested and maintained/serviced.  Any deficiencies must be reported to the Fire Emergency Planning Committee at the completion of an inspection and/or test, and must be rectified as soon as it is reasonably practicable.  Records of all activities must be regularly updated and safely/securely stored in the building, with a duplicate copy provided to the Local Fire Service.

Fire Evacuation Performance Indicators (Metrics)

Performance indicators/metrics must be formulated by the Fire Emergency Control Unit Manager in order to evaluate the effectiveness of the fire emergency response procedures in the building.  During practice evacuations, the time between warning communications and first occupant/user movement, the time taken for evacuation to an external place/places of safety remote from the building, the evacuation routes chosen by occupants/users, and the time required to identify everyone who participated in the practice evacuation at the place/places of safety, including those occupants/users who did not participate, must all be recorded.

The Local Fire Service has two functions: a) to suppress and control a fire in the building, and to confirm extinguishment ;  and b) to rescue people in the building who are injured, trapped, or otherwise unable to independently evacuate, e.g. people waiting in areas of rescue assistance and lift/elevator lobbies.  In addition, therefore, the time taken for the first fire service vehicle to arrive on-site and, more importantly, the time taken for the fire services to arrive in sufficient strength to deal effectively with a fire emergency in the building must be recorded.  In the event that either or both of these times are inordinately long, an on-site specialist Fire Emergency First Response Team (FEFRT) must be established by the Fire Emergency Planning Committee.  The FEFRT must work under the control of, and report directly to, the Fire Emergency Control Unit Manager.

‘Contraflow’ movement in Building Circulation Routes.  Click to enlarge.

During the process of evaluation, generous allowance must be made for contraflow circulation during a real fire incident, i.e. emergency access by firefighters into a building and towards a fire, while building occupants/users are still moving away from the fire and evacuating the building.

The Fire Emergency Control Unit Manager must report, in full, the recorded performance and his/her evaluation of practice evacuations to the Fire Emergency Planning Committee.

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Addendum 2020-04-14:  For business application … the National Fire Protection Association (#NFPA) issued a very useful Emergency Preparedness Checklist in September 2018 …… which also covers Business Continuity and Recovery

NFPA Emergency Preparedness Checklist  (English, Download PDF File, 153 Kb)

NFPA Lista De Verificación De Preparación Para La Emergencia  (Spanish, Download PDF File, 158 Kb)

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#GrenfellTowerFire #FireSafety4ALL #NobodyLeftBehind #VulnerableBuildingUsers #PwAL #PwD #NeverStayPut #VulnerablePeople #Firefighters #FFsafety #FFhealth #2019GrenfellRecommendations #SFE #GrenfellTowerFireInquiry #LondonFireBrigade #DanyCotton #AndyRoe #FireResistingDoorsets #FireCompartmentation #FireProtection #FireEvacuation #MooreBick #FireEngineering #FireEngineers #IFE #England #Design #Management #Construction #HighRiseResidentialBuildings #UDHR #HumanRights #Discrimination #AusterityKills #Justice4Grenfell #Contraflow #LocalFireService #Skill4Evacuation

Fire Safety in Buildings – Reliable Design, Supply & Construction

2019-07-31:  A very serious problem in modern buildings (post 1950’s), and in many countries around the world … which can lie dormant and hidden from any and all Surface Inspections … until there is an outbreak of #Fire !

Passive/Active Fire Protection Measures, and Building Management Systems (i.e. any combination of human and smart systems), are never 100% Reliable.  However, Poor Workmanship on Building Sites and Unauthorized Product / System Substitution are reducing this #Reliability to far below the threshold of legal (or any other) ‘acceptability’.

Colour photograph showing a person at work on a construction site.  Is he/she Competent to do this particular work ?  For the task, is he/she using the Correct Tools and Proper Materials (i.e. products/systems which are ‘fit for purpose’) ??  Who is monitoring his/her performance ???  The important objective is a Fire Safe Building for ALL Occupants/Users.  Click photograph to enlarge.

As a result, Fire Evacuation Routes can quickly become full of dense toxic smoke, impairing/incapacitating people trying to evacuate … the integrity of Fire Compartments can very rapidly be compromised, leading to uncontrolled internal fire spread … and Partial Structural Collapse will be a definite probability.

Most in danger and at high risk in ‘real’ building fires are Vulnerable Building Users and #Firefighters !

[ Vulnerable People: Those people – in a community, society or culture – who are most at risk of being physically, psychologically or sociologically wounded, hurt, damaged, injured, or killed … and include, for example, People with Disabilities, Young Children, People with Health Conditions, Frail Older People, Women in Late Pregnancy, Refugees, Migrants, and the Poor. ]

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‘Building Materials and Workmanship’ Must Be Relentlessly Monitored PRIOR TO AND DURING Construction – Afterwards Is TOO LATE !

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In these days of #Architects staring at computer screens all day, not being very ‘smart’ in and around actual construction sites … and with Fire Engineering Design Information still merely a #BIM add-on … there are 5 Fundamental Principles of Reliable Building Design, Product Supply and Construction for Fire Safety :

  1. Design of the works must be exercised by an independent, appropriately qualified and experienced architect/engineer/fire engineer, with design competence relating to the fire protection of buildings ;
  1. The Supply of ‘fit for purpose’ fire safety related construction products/systems to the works must be undertaken by reputable organizations with construction competence, particularly in relation to the fire protection of buildings … and all product/system substitution must be pre-authorized ;
  1. Installation/Fitting of fire safety related construction products/systems must be exercised by appropriately qualified and experienced personnel, with construction competence relating to the fire protection of buildings ;
  1. Supervision of the works must be exercised by appropriately qualified and experienced personnel from the principal construction organization ;
  1. Regular Inspections, by appropriately qualified and experienced personnel familiar with the design, and independent of both the design and construction organizations, must be carried out to verify that the works are being executed in accordance with the design.

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Self-Regulation / Self-Monitoring Is NO Regulation / NO Monitoring !!

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Colour photograph showing a larger, more complex construction project … with more complicated working relationships between the Building Design Team, the Principal Construction Organization, Sub-Contractors, and Trades Men/Women.  In this context, the monitoring of Building Materials and Workmanship must be both unrelenting and stringent !  The important objective remains the same: a Fire Safe Building for ALL Occupants/Users.  Click photograph to enlarge.

Incomplete / inaccurate information about the number of People, particularly Vulnerable Building Users, still remaining in a Fire Building, and/or the number of Occupants waiting in Areas of Rescue Assistance and Lift/Elevator Lobbies … all resulting from poor Building Management … will greatly increase the Hazards and Risks involved in Firefighter Search and Rescue Operations, and will result in Building Occupant Injuries and Deaths !

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Mainstream Fire Codes & Standards DO NOT Protect Vulnerable Building Users and Firefighters !!!

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#SFE #Design #ProductSupply #Construction #FireSafety4ALL #FireEngineering #FireProtection #FireCompartment #FireEvacuation #Buildings #FacilityManagement #Resilience #Sustainability #PoorWorkmanship #ProductSubstitution #ProperMaterials #VulnerablePeople #Firefighters

Sustainable Fire Engineering – Recent Dublin Presentations !

2019-03-19:  Two Conference & Exhibition Events were recently held in Dublin’s City West Convention Centre

2019 City West Summits, Dublin – Colour photograph showing the view over the Exhibition Hall.  Click to enlarge.

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I was very pleased to make a Presentation at both events, adapted to suit an Irish context, on … ‘Sustainable Fire Engineering – Necessary Professional Transformation For The 21st Century’ … which continues to evolve.

Sustainable Fire Engineering:  The creative, person-centred and ethical Fire Engineering response, in resilient built form and smart systems, to the concept of Sustainable Human and Social Development … the many aspects of which must receive synchronous and balanced consideration !

Sustainable Fire Engineering
Internet: www.sfe-fire.eu
Twitter: @sfe2016dublin

Presentation Abstract

Annual Fire Losses, both direct and indirect, amount to a very significant percentage of Gross Domestic Product (#GDP) in all economies, whether they are rich or poor … and result in enormous environmental devastation and social disruption.  Some losses have not yet been fully identified, e.g. environmental impact … while others are not yet capable of being fully quantified, e.g. business interruption, brand and reputation damage.  Globally, fire statistics still remain unreliable.  In all cases, however, the waste of valuable human and natural resources caused by preventable fires is unsustainable and no longer acceptable.

From an entirely different perspective … Sustainable Buildings are presenting every society with an innovative and exciting re-interpretation of how a building functions in response to critical energy, environmental, climate change and planetary capacity pressures … an approach which has left the International Fire Engineering and Firefighting Communities far behind in its wake, struggling to develop the necessary ‘creative’ and ‘sustainable’ fire safety strategies.

The Aim of Sustainable Fire Engineering (#SFE) is to dramatically reduce direct and indirect fire losses in the Human Environment (including the social, built, economic, virtual, and institutional environments) … to protect the Natural Environment … and, within buildings, to ensure that there is an effective level of Fire Safety for All Occupants, not just for Some, over the full building life cycle.

The following Priority Themes for SFE lie outside, or beyond, the constrained and limited fire safety objectives of current fire regulations, codes and standards – objectives which do not properly protect society, a fire engineer’s clients, or the facility manager’s organization:

  1. Fire Safety for ALL, not just for Some.  Nobody left behind !
  2. Firefighter Safety.  Everyone goes home !   It is easy to dramatically improve firefighter safety with building design.  So, why haven’t NIST’s 2005 and 2008 WTC 9-11 Critical Recommendations been properly implemented anywhere ?
  3. Property Protection.  Fire damage and post-fire reconstruction/refurbishment are a huge waste of resources.  On the other hand, protection of an organization’s image/brand/reputation is important … and business continuity is essential.  Heritage fire losses can never be replaced.
  4. Environmental Impact. Prevention of a fire is far better than any cure !   But prevention must also begin by specifying ‘clean’ technologies and products.  Low Pressure Water Mist Systems are not only person/environment-friendly and resource efficient … they are absolutely essential in airtight and hyper energy-efficient building types (e.g. LEED, PassivHaus, BREEAM) in order to achieve an effective level of fire safety for all occupants, and firefighters.    [ Note: Environmental Impact Assessment (#EIA) has been superseded by Sustainability Impact Assessment (#SIA).]
  5. Building Innovation, People and Their Interaction.  Fire engineers and firefighters must begin to understand today’s new design strategies.
  6. Sustainable Design and Engineering. Wake up and smell the coffee !   Legislation can only achieve so much.  Spatial planners, building designers and fire engineers must subscribe to a robust Code of Ethics * which is fit for purpose in the Human Environment of the 21st Century.

Sustainable Fire Engineering Solutions are …

  • Adapted to a local context, i.e. climate change/variability/extremes, social need, geography, economy, and culture, etc ;
  • Reliability-based – lessons from real extreme and hybrid events, e.g. 2001 WTC 9-11 Attack, 2008 Mumbai/2015 Paris/2016 Brussels Hive Attacks and the 2011 Fukushima Nuclear Incident, are applied to frontline practice ;
  • Person-centred – real people are placed at the centre of creative endeavours and due consideration is given to their responsible needs, and their health, safety, welfare and security in the Human Environment ;
  • Resilient – functioning must be reliable during normal conditions, and include the ability to withstand, adapt to and absorb unusual disturbance, disruption or damage, and thereafter to quickly return to an enhanced state of function.

* Refer to the 2016 Dublin Code of Ethics: Design, Engineering, Construction & Operation of a Safe, Resilient & Sustainable Built Environment for All (PDF File, 112 kb).

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Rigorous Implementation Of Environmental Law – A Priority !

2019-03-17:  Saint Patrick’s Day …

The United Nations Environment Programme (UNEP – https://www.unenvironment.org/) has recently published the First Global Report on Environmental Rule of Law … which finds weak enforcement to be a global trend that is exacerbating environmental threats, despite the prolific growth in environmental laws and agencies worldwide over the last four decades.

The answer, of course, is rigorous implementation of environmental law … most particularly in those developed countries which have amassed their riches, over past centuries, from the plunder of natural, human and cultural resources in Central & South America, Africa and Asia.

UNEP: ‘Environmental Rule of Law – First Global Report’ (2019)

Download The Full UNEP Report Here … https://www.unenvironment.org/resources/assessment/environmental-rule-law-first-global-report   (PDF File, 30.76 MB)

Executive Summary

If human society is to stay within the bounds of critical ecological thresholds, it is imperative that environmental laws are widely understood, respected, and enforced … and the benefits of environmental protection are enjoyed by people and the planet.  Environmental rule of law offers a framework for addressing the gap between environmental laws on the books and in practice, and is key to achieving the U.N. Sustainable Development Goals.

Environmental laws have grown dramatically over the last three decades, as countries have come to understand the vital linkages between environment, economic growth, public health, social cohesion, and security.  As of 2017, 176 countries have environmental framework laws; 150 countries have enshrined environmental protection or the right to a healthy environment in their constitutions; and 164 countries have created cabinet-level bodies responsible for environmental protection.  These and other environmental laws, rights, and institutions have helped to slow – and in some cases to reverse – environmental degradation and to achieve the public health, economic, social, and human rights benefits which accompany environmental protection.

The 1972 United Nations Conference on the Human Environment brought the global environment into the public consciousness, leading to the establishment of the United Nations Environment Programme.  Following the 1992 United Nations Conference on Environment and Development (known as the Rio Earth Summit), many countries made a concerted effort to enact environmental laws, establish environment ministries and agencies, and enshrine environmental rights and protections in their national constitutions.  By the 2012 United Nations Conference on Sustainable Development, the focus had shifted to implementation of environmental laws, which is where progress has waned.

Too often, implementation and enforcement of environmental laws and regulations falls far short of what is required to address environmental challenges.  Laws sometimes lack clear standards or necessary mandates.  Others are not tailored to national and local contexts and so fail to address the conditions on the ground.  Implementing ministries are often underfunded and politically weak in comparison to ministries responsible for economic or natural resource development.  And while many countries are endeavouring to strengthen implementation of environmental law, a backlash has also occurred as environmental defenders are killed and funding for civil society restricted.  These shortfalls are by no means limited to developing nations: reviews of developed nations have found their performance on environmental issues lacking in certain respects.  In short, environmental rule of law is a challenge for all countries.  This Report discusses the range of measures that countries are adopting to address this implementation gap – and to ensure that rule of law is effective in the environmental sphere.

As the first assessment of the global environmental rule of law, this Report draws on experiences, challenges, viewpoints, and successes of diverse countries around the world, highlighting global trends as well as opportunities for countries and partners to strengthen the environmental rule of law.

The Report highlights the need to undertake a regular global assessment of the state of environmental rule of law.  To track progress nationally and globally, it is necessary to utilize a set of consistent indicators.  The Report proposes an indicator framework for environmental rule of law and highlights existing datasets that may be utilized in support of the global assessment.

The Report also calls for a concerted effort to support countries in pilot testing approaches to strengthen environmental rule of law.  Such an initiative could support testing of approaches in diverse contexts, and then adapting them before scaling them up.  It should also foster exchange of experiences between jurisdictions to foster learning.

In addition to these two cross-cutting recommendations, the Report highlights numerous actionable steps that States can take to support environmental rule of law.  For example, States can evaluate the current mandates and structure of environmental institutions to identify regulatory overlap or underlap.  States and partners can build the capacity of the public to engage thoughtfully and meaningfully with government and project proponents.  They can prioritize protection of environmental defenders and whistle-blowers.  States may consider the creation of specialized environmental courts and tribunals, and use administrative enforcement processes to handle minor offences.  And there is an ongoing need to research which approaches are effective under what circumstances.

The benefits of environmental rule of law extend far beyond the environmental sector.  While the most direct effects are in protection of the environment, it also strengthens rule of law more broadly, supports sustainable economic and social development, protects public health, contributes to peace and security by avoiding and defusing conflict, and protects human and constitutional rights.  As such, it is a growing priority for all countries.

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England’s 2017 Grenfell Tower Fire – Never Again Elsewhere ??

2018-06-12 …

As we approach the First Anniversary of the Grenfell Tower Fire Tragedy, in England, on 14 June … a few days ago, on 4 June 2018, the first batch of Grenfell Expert Witness Reports were uploaded (https://www.bbc.com/news/uk-44356660) to the Grenfell Tower Inquiry Website (https://www.grenfelltowerinquiry.org.uk/) for public view.

At this time, in London … multiple, fragmented investigations are taking place into the actual fire incident … the role of the Local Authority, and building management … those involved in the refurbishment (‘tarting up’) design and construction … the fire services, particularly their ‘Stay Put’ Policy and how it adversely impacted on vulnerable Tower occupants during the emergency … and the highly flawed regulatory model of Building and Fire Codes with light-touch Control, which is still operating in England.  One of Murphy’s Laws immediately springs to mind with regard to the intended ineffectiveness of this overly-complex process !

Colour photograph showing Grenfell Tower in the background … undergoing an almost complete ‘cover-up’ … with, in the foreground, mementos of the Fire Tragedy fixed to railings by local residents. Click to enlarge. Photograph taken by CJ Walsh. 2018-04-29.

Many other countries have adopted some or all of this modern English regulatory model which, after the repeal of an older Bye-Law format, has been shaped by political expediency, cost-effectiveness and general ineptitude … with little or no adaptation to local conditions in the adopting jurisdictions.  Ireland adopted this model with some, but not a lot, of adaptation.

Fire Safety In Ireland ?

On 6 June 2018 … while that investigative activity was hitting the headlines in England … Minister Eoghan Murphy, T.D., Ireland’s Minister for Housing, Planning and Local Government, quietly published the Report: ‘Fire Safety in Ireland’http://www.housing.gov.ie/local-government/fire-and-emergency-management/fire-safety/eoghan-murphy-publishes-report-fire … by a High-Level Task Force within his Department’s National Directorate for Fire and Emergency Management, after serious concerns and fears had been expressed in the public media that a similar fire tragedy might also occur in this jurisdiction.

To be crystal clear … this Report is a Bureaucratic Whitewash … an insult to the Public !  Nice sounding technical ‘blarney’ camouflages a failure to deal directly with critical issues, and answer concerns … while other important issues are avoided altogether.

May 2018 – Ireland’s Department of Housing, Planning & Local Government Report

Fire Safety In Ireland  (PDF File, 2.55 MB)

Expanding on my comments in the Interview with Barry Lenihan, on RTE Radio 1’s Drive Time early evening news programme on Friday (2018-06-08) …

A.  Initially, Irish Local Authorities were requested to carry out a preliminary survey to identify all buildings of more than six storeys, or 18m in height.  Specifically, they were asked to identify those buildings which had an external cladding system which might be a cause for concern.

This height threshold of six storeys/18m is arbitrary … an external cladding system can be just as much a cause for concern in a building which is lower.  Imagine discarded cigarette butts or a rubbish fire at the base of such a system … and the resulting speed of fire spread and development across a building façade !

B.  The highly flawed regulatory model of Building and Fire Codes, with light-touch Control, which resulted in the Grenfell Tower Fire Tragedy … we also have.  Wake up and smell the coffee Ireland !

At the beginning of the 1990’s, when Ireland had been persuaded by the European Commission to finally introduce legal, national building regulations having a functional format … our National Authority Having Jurisdiction, in desperation, grabbed the then Approved Documents for England & Wales … brought them back to Ireland, put Irish covers on them, and originally called them ‘Technical Documents’ … but, after seeing a tiny ray of inspiring light, later changed their title to the more accurate ‘Technical Guidance Documents’ !  This hunger for adopting all things English which are fire safety related continues to this day … with a similar, ongoing division of Technical Guidance Document B: ‘Fire Safety’ into 2 Separate Volumes.

This may have been a convenient response under pressure … but it has been very short-sighted.  It has impeded the growth of a comprehensive and coherent philosophy on Safe, Inclusive, Age-Friendly, Resilient, Sustainable Planning, Design and Construction Codes/Controls which is suited to an Irish context and responsible local needs (not desires!).

C.  Everywhere … this Report has a lot – too much – to say about Fire Risk Assessment !  After the Grenfell Tower Fire, however, Fire Risk Assessments must only be carried out by competent persons … and the process of Fire Risk Assessment, itself, must be radically improved !  And of course, prior to any Risk Assessment … a proper Fire Hazard Appraisal must be carried out.

D.  To accurately present Fire Safety Trends in Ireland … it is not enough to furnish reliable fire fatality statistics.  It is also necessary to produce reliable fire injury statistics … and reliable information on direct/indirect socio-economic losses.

E.  The quality of fire safety related construction on Irish Building Sites continues to be very poor and problematic.  Fire Compartmentation is nowhere near being adequately – never mind acceptably – reliable !  And during the last few years we have had quite a number of close-calls concerning fire incidents in medium-rise residential buildings.

F.  Fire Evacuation for people with activity limitations is still handled atrociously in our current building regulations.  This is ironic because, on 20 March 2018 last, Ireland had to be dragged screaming to ratify the U.N. 2006 Convention on the Rights of Persons with Disabilities (CRPD) !

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Positive Progress By Another Path !

1.  Abandon the outdated English functional requirements in THEIR building regulations … and adopt a far better, more up-to-date body of functional requirements which is already on the Irish Statute Books … Annex I of the European Union’s Construction Products Regulation 305/2011.  And because there are important horizontal linkages between requirements … immediately finish the ridiculous current separation between Fire Safety requirements and all of the other requirements.  And yes … new Technical Guidance Documents will have to be drafted.

.Regulation (EU) 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

EU Regulation 305/2011 – Construction Products.  See Annex I

(PDF File, 998 Kb)

2.  Yes … ‘Persons Having Control’ of buildings have responsibilities with regard to fire safety.  But that is only one side of the coin !  National and Local Authorities Having Jurisdiction have greater responsibilities.

If we are at all serious about Consumer Protection … bad, inadequate, faulty construction must be prevented beforehand … it is too late, too costly and, in many cases, too impractical to correct afterwards.  Self Regulation by building design professions and construction organizations is NO Regulation !  Stringent, independent technical control inspections must be carried out on all projects by Building Control personnel … which used to happen in Dublin City/County and Cork City/County prior to the introduction of legal building regulations in the early 1990’s … and, depending on complexity, must also be carried out at critical stages during the construction process.

Building Control Sections in all Local Authorities must be properly resourced with competent personnel, equipment, training and support infrastructure.

Inspections concerning compliance with all functional requirements in the building regulations, including fire safety, must be carried out only by Building Control Personnel.  Chief Fire Officers must not be allowed to manage or be involved in any aspect of Building Control.  On the same project … a Disability Access Certificate Application and a Fire Safety Certificate Application must be inter-linked and overlap sufficiently, showing no gaps in compliance.  Inspections must be carried out in connection with all Certificate Applications.  Building Control personnel must satisfy themselves that actual construction at least matches, if not improves upon, what is shown in design documentation.

Building Control Inspection Reports must be made available for public view.

3.  Firefighters are NOT a disposable Social Asset !  National and Local Authorities Having Jurisdiction … and some Chief Fire Officers … must begin to understand this fundamental truth !

Fire Services in all Local Authorities must each be properly resourced according to local needs … with competent personnel, equipment, training and support infrastructure.  Shared provision of resources looks very neat on paper but, in practice, works very badly.  Refer to the Grenfell Tower Fire and London Fire Brigade having to borrow firefighting equipment from other Fire Services.

After the 2015 Tianjin Regional Fire Devastation, in China, and the 2001 WTC Attacks on 9-11, in New York City … front line firefighters must be supported by Specialist Hazard Appraisal and Structural Engineering Units.

For Firefighter Safety in buildings and to quickly find people with activity limitations waiting in Areas of Rescue Assistance and/or other survivors in different locations … a portable and reliable Thermal Imaging Camera is an essential piece of every firefighter’s equipment.

And Firefighter Safety begins with good building design.  In all but the most simple building types, Circulation Routes must be designed for Contraflow … people moving away from a fire in a building and towards safety while, at the same time, heavily equipped firefighters are entering the building and moving towards the fire.

Colour photograph showing Contraflow on a building staircase … people moving down a staircase away from a fire and towards safety while, at the same time, heavily equipped firefighters are moving up the staircase towards the fire. Click to enlarge.

There is no place for ‘Stay Put’ Policies in Irish Residential Buildings of any height.

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Ireland’s 2017 Oireachtas Report: ‘Safe As Houses’ …

December 2017 – Houses of the Oireachtas – Joint Committee on Housing, Planning & Local Government

Safe As Houses ?  A Report On Building Standards, Building Controls & Consumer Protection

(PDF File, 1.01 MB)

This was a good effort by our public representatives … but they missed core issues !

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After The Grenfell Tower Fire !

Further to my last Blog, dated 2017-10-10 …

The 2017 Fire in England was not an extraordinary fire.  Since the beginning of this decade, we continue to see a series of such fires: South Korea (2010) – UAE & France (2012) – Chechnya (2013) -Australia (2014) – UAE, Azerbaijan & UAE again (2015) – UAE (2016) – UAE & Russia (2017) – Turkey (2018).

With regard to Command & Control of Large Scale Emergencies … English AHJ’s should have paid attention to the 2005 & 2008 U.S. National Institute of Science & Technology (NIST) Recommendations following the 9-11 WTC Buildings 1, 2 & 7 Collapses.

The Fire Safety Objectives in current Building & Fire Codes/Regulations are very limited.  In Ireland, this is clearly stated in Technical Guidance Document B …

‘ Building Regulations are made for specific purposes.  Part B of the Second Schedule to the Building Regulations is therefore primarily concerned with the health, safety and welfare of persons.  The fire safety measures outlined in this guidance document are intended for the protection of life from fire.’

Only insofar as it is necessary to protect the lives of able-bodied building users/occupants … is there a concern for property protection.

There is only inadequate, token concern for the protection of people with disabilities.

Client organizations, facility managers, building designers, construction organizations … and journalists … must fully comprehend these limits.

In the photograph below … look closely at the External Firefighting Operations at the bottom of the Tower.  There are limits to what can be achieved from outside a building !

Colour photograph showing the developed fire at Grenfell Tower, in London. At the bottom of the Tower, external firefighting operations can be viewed. Click to enlarge.

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  • A Fire Suppression System (Water Sprinklers/Mist/Hybrid) is an essential Fire Protection Measure in ALL Medium and High-Rise Residential Buildings … which include Apartment Blocks, Hotels, Hostels, Student Accommodation & Social Housing, i.e. ANYWHERE there is a Sleeping Hazard.

 

  • A Reliable and Credible Fire Detection & Warning System is an essential Fire Protection Measure in ALL Buildings … and must be capable, under the control of Building Management, of transmitting warnings in many formats, i.e. Audible + Visual + Multi-Lingual Voice + Tactile.

 

  • Fire Evacuation Routes in Buildings must be designed for CONTRAFLOW … people moving away from a fire and towards safety while, at the same time, heavily equipped firefighters are entering the building and moving towards the fire.

 

  • Good Fire Evacuation Route Design is INTUITIVE and OBVIOUS.  In many buildings, however, this is not always the reality.  Effective Fire Evacuation Signage … comprising high-level signage, low-level signage, with both supplemented by photoluminescence … must be installed in ALL Buildings.

 

  • For the purpose of protecting Vulnerable Building Users in Fire Emergencies, ALL Lifts/Elevators in Buildings must be capable of being used for Evacuation.

 

  • Fire Risk Assessments must NO LONGER be carried out by people WITHOUT COMPETENCE in Fire Engineering AND Building Design & Construction … and the Fire Risk Assessment Process itself must be thoroughly re-examined and upgraded.

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After Grenfell: Reliable Design, Supply & Construction Essential !

2017-10-10:  After the Grenfell Tower Fire Tragedy in London, on 14 June 2017, the integrity of the English Regulatory and Technical/Building Control Systems is now so compromised that a complete Systems Transformation is immediately required !   Closer to home, here in Ireland … what nobody is daring to say, even our tame media, is that Our Regulatory System is based very closely on the English System.  And Our Technical/Building Control System is purposefully under-resourced … so it is weak and ineffective.

Let there be no confusion … Priory Hall and Longboat Quay, both in Dublin, are just the tip of an enormous iceberg …

Colour photograph showing the Grenfell Tower Fire, in London … early in the morning, after dawn, on Wednesday, 14 June 2017.  Harsh, tragic Reality !  Click to enlarge.

So where do we start again ?

Reality – Reliability – Redundancy – Resilience !

With regard to Reliable Fire Engineering Related Design, Supply and Construction … this is how we must proceed …

  1. Design of the works is exercised by an independent, appropriately qualified and experienced architect/engineer/fire engineer, with design competence relating to the fire protection of buildings ;
  1. Supply of fire safety related construction products/systems to the works is undertaken by reputable organizations with construction competence, particularly in relation to the fire protection of buildings ;
  1. Installation/fitting of fire safety related construction products/systems is exercised by appropriately qualified and experienced personnel, with construction competence relating to the fire protection of buildings ;
  1. Supervision of the works is exercised by appropriately qualified and experienced personnel from the principal construction organization ;
  1. Regular inspections, by appropriately qualified and experienced personnel familiar with the design, and independent of both the design and construction organizations, are carried out to verify that the works are being executed in accordance with the design.

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2017 Architecture & Building Expo – An Annoying Experience !!

2017-10-09:  On Saturday last, 7 October, I had the great misfortune to attend the Architecture & Building Expo … which was being held, in conjunction with the RIAI’s (Royal Institute of the Architects of Ireland) Annual Conference, at the RDS (Royal Dublin Society) Main Hall in Ballsbridge, Dublin …

Colour photograph showing the Entrance to the RDS Main Hall … and the 2017 Architecture & Building Exhibition.  Click to enlarge.
Colour photograph showing a high level view over the 2017 Architecture & Building Exhibition in the RDS Main Hall.  Click to enlarge.
Colour photograph showing some of the people who attended the 2017 Architecture & Building Exhibition in the RDS Main Hall.  Click to enlarge.

What was annoying … really annoying … and depressing, all at the same time … was having to introduce a senior individual on one Exhibition Stand to Part D of the Irish Building Regulations !   I even had to show that same individual where to find Technical Guidance Document D on the Irish DHPLG (Department of Housing, Planning & Local Government) Website.  And on more than a few other Stands … having to explain what is a CE Mark !!   This is entirely unacceptable.  FUBAR.

And let us all not forget that this Exhibition was being held in conjunction with the RIAI’s 2017 Annual Conference

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