Department of the Environment Community and Local Government (DECLG)

Ireland’s Draft National Radon Control Strategy – A Fraud !!

2013-02-28:  Submissions on Ireland’s Draft National Radon Control Strategy must arrive at the Department of the Environment, Community & Local Government, our national authority having jurisdiction … by e-mail or hand delivery to either the Custom House in Dublin or the DECLG Offices in Wexford … no later than 17:30 hrs tomorrow, Friday 1 March 2013

DECLG - Draft National Radon Control Strategy Title Page (January 2013)

Ireland’s Draft National Radon Control Strategy – January 2013 Consultation

Click the Link above to read/download PDF File (425 Kb)

The Aim of this Draft Strategy, as stated on the DECLG WebSite, is to ensure that exposure to Radon Gas, which presents a significant public health problem, is addressed in an effective and co-ordinated way across all relevant public authorities through appropriate interventions.  The Draft Strategy was developed by an Inter-Agency Group comprising representatives from relevant public authorities.

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After all of the progress made on radon protection in buildings at the end of the 1990’s and beginning of the 2000’s, it is extremely disappointing to read this miserable excuse for a strategy document.  If the general public in Ireland is under any impression that the ‘powers-that-be’ are deeply concerned about protecting our health … they are making a fatal mistake !

The complete absence of any reference to a Recommended Health-Related Radon Target Level – Safety-Related National Reference Levels which are not clearly explained will result in some injury and harm – Lack of Meaningful Consultation with, and Informed Consent of, the National Population – Horrendously Inadequate Technical Control Procedures on Irish Building Sites – RPII Recommended Indoor Radon Activity Measuring Devices having Very High Measurement Uncertainty (±30% under typical conditions of use) – A Purposeful Lack of Detailed Guidance on Exactly When and How to Measure Indoor Radon – Inadequate RPII Radon Measurement Test Reporting … are just some of the tell-tale signs for a seasoned observer.

In this regard, therefore … and let me be very clear and simple in my use of language … this Draft National Radon Control Strategy is a blatant fraud !!

Fraud:  Deliberate deception, trickery, or cheating intended to gain an advantage – An act or instance of such deception (from Latin Fraus (f): deceit, deception).

Furthermore … the Inter-Agency Group which produced this Draft National Radon Control Strategy for the DECLG Minister, Mr. Phil Hogan T.D., and Senior Civil Servants within the Department … whoever the Group’s participants are, wherever they are … should be thoroughly ashamed of themselves for being associated with this negligent act !

Negligent:  Lacking attention, care or concern.

Negligence:  A wrong whereby a person(s) is in breach of a legal duty of care, resulting in harm or injury to another person(s) … in this case, the Irish Public.

To see a complete overview on this Serious Building-Related Human Health Issue, and for information about a Far Better and More Coherent Approach to Radon Protection in Buildings which takes proper account of European Union (E.U.) legislation, e.g. the Precautionary Principle … please refer to SDI’s Corporate WebSite

NORM, Radon Gas, Radon Activity & Protection from Radon in Buildings

(It is not my intention to reproduce, here, all of the content on this WebPage as part of the Submission.)

I am also the Technical Consultant who drafted these 2 Benchmark Irish Agrément Board (IAB) Certificates for Radon Protection Measures in Buildings …

Monarflex Radon Resisting Membranes – IAB Certificate No. 98/0075

and

Radon Control Systems: Easi-Sump & Easi-Sump Cap-Link – IAB Certificate No. 01/0130

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SDI’s Comments on Ireland’s Draft National Radon Control Strategy (NRCS)

1.   Protecting Human Health versus Reducing Risk to Safety

The following two short extracts from 1. Introduction and Background in the Draft NRCS reveal the true intent of the Inter-Agency Group …

‘ Radon gas is the greatest source of exposure to ionising radiation for the general public and is the second greatest cause of lung cancer in Ireland.  Recognising the serious health risk presented by radon, the Minister for the Environment, Community and Local Government in November 2011 established an inter-agency group to develop a National Radon Control Strategy (NRCS).’

and …

‘ During 2012 the inter-agency group developed a draft NRCS based on wide stakeholder consultation and a health economics evaluation of different radon intervention strategies.  The stakeholder consultation involved a range of individuals and bodies involved in: health care, construction, radon services, Government and academia.  The health economics evaluation was undertaken by the Radiological Protection Institute of Ireland (RPII) and Health Service Executive (HSE) with the assistance of the Health Economics Unit at the University of Oxford.  This draft strategy sets out a range of measures to reduce the risk from radon to people living in Ireland.’

Radon is a serious human health issue, and it is explained in a later section of the document 1.2 The Radon Problem in Ireland that ‘indoor radon is linked to between 150 to 200 lung cancer deaths each year in Ireland, which equates to approximately 13% of all lung cancer deaths.’

However … after the references above to ‘health economics evaluation’ (!) … to the ‘prevailing  economic situation’ (!!) in section 1.1 Public Consultation … and to ‘health economics tools’ (!!!) in section 2. Draft National Radon Control Strategy … etc … you should then sensitize yourself to the subtle change in language very early in the document … from a consideration of health protection, to reducing the risk from radon (or similar variations on that theme).

The concept of Protecting Human Health is altogether different from the concept of Assessing and Mitigating / Reducing Risk to Safety !   Please refer to SDI’s Corporate WebSite.

As far back as the end of the 1990’s … the Irish Agrément Board, which at the time included a representative from the Department of the Environment, accepted the following …

Radon Activity in Buildings – Recommended Target Health Level

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

This Recommended Target Health Level for Radon now also appears in International Standard ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’, which was published in December 2011.  Please refer to Annex B.8 – Indoor Air Quality (IAQ) in the ISO Standard.

The Draft NRCS must refer to such a Recommended Target Health Level … and it must be stated that it is National Policy to progressively reach that target by 2025 (bearing in mind the ‘prevailing economic situation’ in the country !).

Note:  In contrast to the above … 200 Bq/m3 for Residential Buildings, and 400 Bq/m3 for Workplaces … are NOT Health-Related Target Levels … they are Safety-Related National Radon Reference Levels which result in some measure of harm and injury to people … particularly children under the age of 10 years, and people with activity limitations who constantly remain indoors for prolonged periods of time.

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2.   National Policy Priority:  ‘Real’ Protection from Radon in ‘Real’ Irish Buildings

Yes … in Ireland, we have enormous problems with regard to a lack of awareness among the general population about the serious health hazard posed by indoor radon … and the absence of proper education and training for everyone directly involved in the design, construction, management, operation, servicing or maintenance of our building stock (both new and existing).

BUT … if we are committed to providing ‘real’ radon protection in ‘real’ Irish buildings, then a practical construction-oriented approach is demanded.

This is a Key Paragraph in 2.1 Radon Prevention in New Buildings

‘ The stakeholder engagement also points to some practical difficulties associated with the implementation of the current technical guidance on radon prevention.  These difficulties relate to the correct installation of radon barriers under site conditions, protection of the integrity of radon barriers once installed and identification of radon preventive measures on site.  The stakeholder engagement also indicated the system of building control in place prior to 2012 did not provide adequate assurance that radon preventive measures had been correctly installed ‘

… which we later discover is a masterstroke of understatement and evasion, because none of these important issues are tackled head on in the document.

On the critical issue of Building Control … there is no mention of mandatory inspections of construction projects by competent Local Authority personnel.  Because … it remains the unwritten policy of Ministers and Senior Civil Servants in Ireland’s Department of the Environment, Community & Local Government (DECLG) that Local Authority Building Control Sections will be entirely ineffective.

On the other hand … will Competent Private Independent Technical Controllers be facilitated in carrying out sufficient inspections of all radon protection related works before ‘signing off’ on proper completion ???

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3.   Regulatory Status of RPII’s Radon Prediction Maps

This is NOT a problem unique to Ireland.

The presence of the RPII Radon Prediction Maps in Technical Guidance Document C (Building Regulations), and the status they are given there … are both entirely inappropriate.

While these Maps are a useful design aid, in the case of small construction projects, they offer NO assurance of certainty to either building designers or users.  They are NOT reliable !   And the average values shown in any particular ‘box’ may actually conceal a considerable degree of variability in the radon concentrations found in completed buildings.

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4.   SDI’s Acceptance of RPII Services

Please refer to SDI’s Corporate WebSite.

Unfortunately, until the Radiological Protection Institute of Ireland (RPII) includes proper statements of Measurement Uncertainty in its Test Reports (this is a requirement of European Standard EN ISO/IEC 17025)  … our Organization:

  • cannot recommend any RPII Radon Testing Services to 3rd Parties ;

and

  • will not accept any RPII Test Reports as proper evidence of Radon Test results.

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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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Unheeded Fire Hazards in New Energy Efficient Buildings !!

2012-03-29:  The relentless pressure, within the European Union (EU), to bring a greater measure of stability to imported energy supplies … to reduce our overall use of energy … to be far more efficient in the ways we consume those lesser amounts of energy … to find cleaner sources of energy to replace oil, gas, and especially coal … to comply with ambitious targets on climate change mitigation … are all pointing in one direction with regard to design and construction.  We are forced to super-insulate new buildings !

Without many people realizing it, however, we change how fire behaves in a highly insulated building … especially when insulation materials are part of the interior finishes, not carefully buried within the construction.  [Even the old Building Bye-Laws in Dublin City permitted a cavity in a masonry wall up to 150mm wide !]   And, as usual, Building and Fire Regulations are slow to catch up with these important architectural developments.

Let me show you an example of a basement car park in a new hospital (which shall remain nameless !) … where a serious ‘fire’ problem has been festering since it was opened, and occupied, a few years ago.

This hospital could be anywhere in Europe …

Colour photograph showing the basement car park in a hospital. Click this photograph, and the photographs below, to enlarge.

Colour photograph showing the basement car park in a hospital. Click this photograph, and the photographs below, to enlarge.

The ceiling height in this car park is low … approximately 2 metres above floor level.  The ceiling comprises a 6mm off-white calcium silicate board of limited combustibility (for the techies out there – this board is not ‘incombustible’, and it is not ‘non-combustible’) … above which is a 40mm rigid phenolic thermal insulation board … all fixed to the underside of a concrete floor slab.

This phenolic insulation board is very efficient … and during the normal course of events, its job is to stop the loss of heat from the hospital wards and other areas above.  A cold concrete floor is also very uncomfortable for people, i.e. hospital staff, having to walk around on it for long periods.

Because the insulation board is efficient, and it is fixed to the underside of the floor slab … in a fire situation, let’s say that a fire starts in a car … the heat from that fire will be reflected by the insulation board back downwards.  The result:  the fire will be encouraged to spread much more quickly to neighbouring vehicles.  And so, in a very short time, we will have a much larger fire … and a much more intense fire … which will be far more difficult to control and extinguish, when the fire services eventually arrive on the scene.

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There are a Number of Twists in This Story …

     1.  For all sorts of normal reasons, there are service penetration openings in the car park ceiling shown above (some small and some large), especially in a hospital which is highly serviced … the overall approach to fire and smoke sealing in this new building is not the best … and workmanship is poor …

… which, together, all mean that it will be easy for fire and smoke to spread upwards into the hospital wards and other areas … in the event of a fire emergency.

In a hospital, not everybody is alert and mobile.  It will be difficult to evacuate some people … and it will be nearly impossible, because of their health condition, to evacuate others.  In order for a fire engineering strategy of horizontal evacuation to a ‘safer’ part of the same building to be successfully put into effect during an emergency … it is imperativethat the level of passive protection from fire and smoke provided is high … much higher, here, than in the case of an average office building, for example.  AND … it is criticalthat this high level of protection from fire and smoke is reliable.

In this new hospital building … the photographic evidence clearly shows that both of these criteria have not been met.

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     2.  Another twist in the story concerns the rigid phenolic thermal insulation board used in the car park ceiling … which, as the evidence also shows, is exposed to direct view in many places …

In a short, brochure-type document produced by the European Phenolic Foam Association (EPFA): ‘Phenolic Foam Insulation – The Ultimate Insulation System for the Construction & Building Services Industry’, the following is stated with regard to the fire performance of this material …

‘ Toxic gas emission from phenolic foam is generally limited to carbon dioxide and carbon monoxide with very low levels of other gases.’

However, in a report produced by the National Research Council of Canada: ‘Toxicity and Smoke Aspects of Foamed Plastic Insulation – An Annotated Bibliography’ … the following abstracts can be found …

  • Toxicity of Off-Gases from Phenolic Rigid Foam

‘ A reference sample of phenolic rigid foam was evaluated for toxicity of off-gases, using various test conditions in the NASA-USF-PSC toxicity screening test method.  Test results show that the response of this material to the various test conditions is similar to that exhibited by the majority of other materials previously evaluated by this method.  That is, animal response times generally decreased with increasing fixed temperature, and with increasing airflow rate under rising temperature conditions.  The authors suggest that formaldehyde is one of the toxicants present although the amount of CO produced at 600°C or higher was enough to be lethal by itself.

  • Toxicity of Off-Gases from Thermal Insulation

‘ Toxicity test data on the off-gases from various thermal insulation materials are presented in this paper.  Under rising temperature without forced airflow test conditions, phenolic foams exhibited the shortest times to death, while polyisocyanurate, polyurethane and polystyrene foams exhibited the longest times to death.  The introduction of airflow significantly reduced time to death, apparently due to a higher degree of oxidation and more rapid delivery of toxicants.  The authors conclude that under the particular test conditions, plastic thermal insulations appear to exhibit less toxicity than cellulosic board and cellulose insulation, with polyimide and phenolic foams being the exceptions.

  • Relative Flammability and Toxicity of Thermal Insulation

‘ Relative flammability and relative toxicity data are presented for 30 samples of thermal insulation materials.  There appears to be no inherent, necessary compromise between flammability and toxicity in the selection of materials.  Cellulosic and plastics insulations appear to represent significantly different combinations of flammability and toxicity hazards, and require different approaches when planning and designing applications.  Polyurethane foam appeared to be significantly less toxic and slightly less flammable than wood and other cellulosic materials.  Polyisocyanurate foam seemed to be more toxic than polyurethane foam but still less toxic than the cellulosic materials.  Polystyrene foam exhibited the longest time to death while phenolic foam showed the second shortest time to death among the group of rigid foams evaluated.

  • Carbon Monoxide Production from Overheated Thermal Insulation Materials

‘ Carbon monoxide yields were obtained for selected thermal insulation materials.  The data are presented and discussed in this paper.  Among the rigid foamed plastics, phenolic gave the highest yield of CO under a rising temperature and no airflow test conditions.  Polyurethane foams based on propoxylated aromatic amino polyol appeared to produce less CO than polyurethane foams based on propoxylated trimethylolpropane polyol.  Under fixed temperatures of 800°C without airflow test conditions, similar results were obtained for the rigid foamed plastics.’

  • Toxicity of Pyrolysis Gases from Phenolic and Isocyanurate Rigid Foams

‘ Special reference samples of phenolic and isocyanurate rigid foams were evaluated for toxicity of pyrolysis gases, using 6 different test conditions of the USF toxicity screening test methods.  Under rising temperature conditions, phenolic foam appeared to be consistently more toxic than the isocyanurate foam.  CO level appears to be the factor, which is twice as high from the phenolic foam.  The temperatures corresponding to the times to death indicate that the toxicants were evolved below 500°C for phenolic and below 640°C for isocyanurate.  These are in agreement with that of the University of Pittsburgh (UP) data.  At a fixed temperature of 800°C, there appeared to be no difference in toxicity between the phenolic and isocyanurate foams, although the former tended to produce more carbon monoxide.’

  • Toxicity of Pyrolysis Gases from Phenolic, Isocyanurate and Polystyrene Rigid Foam Insulation

‘ Samples of phenolic, isocyanurate, and polystyrene rigid foam insulation were evaluated for toxicity of pyrolysis gases, using four different test conditions of the toxicity screening test method developed at the University of San Francisco.  The test conditions were 200 to 800°C rising temperature and 800°C fixed temperature, each without forced airflow and with 1 L/min airflow.  On the average over these four particular test conditions, phenolic foam appeared to exhibit the greatest toxicity and polystyrene foam appeared to exhibit the least toxicity.

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As already discussed in an  earlier post , dated 2011-01-13 … we know that Carbon Monoxide (CO) is an odourless, colourless and toxic gas … and because it is impossible to see, taste or smell the toxic fumes, CO can kill before you are aware it is there.

So … it will be easy for Fire, Visible Smoke and Carbon Monoxide to spread upwards into the hospital wards and other areas of this building … in the event of a fire emergency.

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This Hospital’s ‘Fire’ Problem & Its Solution

The ‘fire’ problem in this hospital has been allowed to fester for a number of years because the issues shown in the photographs above are either inadequately addressed … or not addressed at all … in Ireland’s Technical Guidance Document (TGD) B … a document which is intended merely to present some supporting guidance for operating Part B: ‘Fire Safety’, in the 2nd Schedule of the Building Regulations.

Unfortunately, all parties directly responsible for this hospital debacle are under the very mistaken impression that the guidance in Technical Guidance Document B is prescriptive regulation.  This is a major error !   Furthermore … TGD B is fundamentally flawed … and it is particularly inadequate when the building type is a health facility.

To Correct This ‘Fire’ Problem … a Fire Suppression System should immediately be installed in the basement car park.  At the same time, if not before … ALL Service Penetration Openings in the concrete floor slab should be properly sealed so that, during a fire incident, the passage of fire and smoke and CO into building spaces above the slab will be prevented.  And … the quality of workmanship, on site, must be high !

An appropriate number of Carbon Monoxide Detectors should be installed in the hospital wards and other areas above the concrete floor slab.

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The ‘Institutional’ Problem

The procedure of having to submit so-called Compliance Reports with applications for Fire Safety Certificates, in Ireland, only confirms … and reinforces … the very mistaken impression in everybody’s minds that the guidance in Technical Guidance Document B is prescriptive regulation.

In the case of a different hospital … let me give you an example of a text contained in one such Compliance Report … submitted to an Irish Local Authority, sometime during 2004 …

Single Steps at Final Exit Doors

It is noted that Clause 1.4.3.4 of TGD-B is ambiguous vis-à-vis steps located on the line of final exit doors, i.e. as opposed to a condition where there is a step beyond the line of a door.  Accordingly, it is reasonable and appropriate to make reference to the current England and Wales Approved Document B (2000 Edition) for guidance on this issue in so far as Technical Guidance Document B is based on an early draft of the Approved Document.  It is noted that the UK AD-B in Clauses 6.15 and 6.21 specifically allow single steps at final exits provided they are located on the line of the doorway in question.  Furthermore, the recently issued Northern Ireland Technical Bulletin E (1994) also allows such steps, subject to the riser not exceeding 180mm.  On the basis of the foregoing, single steps are considered acceptable at the final exit doors subject to the riser not exceeding 180mm and the step being located on the line of the door.

This is mindless, incompetent nonsense … and it was accepted by the Local Authority.

How often, anymore, does anybody encounter a step … 180mm high, or of any height … at the front entrance to a new building ?   Building designers have finally understood the message that new buildings must be accessible-for-all … and a single step, in any situation, is a trip or a fall accident waiting to happen.  Now imagine the situation where people are attempting to evacuate an average office building, for example, during a fire emergency … and they encounter a single step at the final fire exit !?!   Now really stretch your imagination … and imagine where people are trying to evacuate a hospital !!??!!

FUBAR !!

The System is not only entirely dysfunctional … it is corrupt !

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2012 Review of Part B & TGD B – Irish Building Regulations

2012-03-02:  Please bear with me while I update you at the start of this post … rather than at the end, which would be more usual here … and logical.

[ In Ireland … a related problem, which continues to fester and cause a great nuisance in an everyday work environment … concerns the lack of proper, i.e. formal, recognition of electronic communications, and information in an electronic format, by public and private organizations … in spite of the following very clear legal text …

2000 Electronic Commerce Act (No. 27 of 2000)

Section 9 – Electronic Form not to Affect Legal Validity or Enforceability

Information (including information incorporated by reference) shall not be denied legal effect, validity or enforceability solely on the grounds that it is wholly or partly in electronic form, whether as an electronic communication or otherwise. ]

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Yesterday afternoon (1 March 2012), we received the following e-mail communication from the Department of Environment, Community & Local Government (DECLG)

Folks,

Could you please send me your submissions in either Microsoft Word or Excel as it it easier to copy and paste into the format that is required , it is proving rather difficult to copy from a PDF document.

Thank You

Claire Darragh, Architecture / Building Standards, DECLG.

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I immediately replied …

Dear Claire,

Further to your informal e-mail message, which we received just a short while ago …

Please note that this is not an acknowledgement that the FireOx International Submission was received by the Department … and we certainly do not wish that you copy and paste anything relating to its contents anywhere else.

IF this is a Proper Public Consultation Process … you must adapt internal DECLG systems to suit the Submissions !   We will be communicating with the Minister’s Office concerning this issue.

Once again, I would ask you to properly acknowledge receipt of our Submission, dated 2012-02-14.

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In connection with the original FireOx International Submission … I would also like to take this opportunity to advise you that:

  • Due to an error in ISO (International Standards Organization) … the publication of ISO 21542: ‘Building Construction – Accessibility and Usability of the Built Environment’, on 12 December 2011, was not notified to people directly involved in its development and drafting, or to the participating national standards organizations ; 

and

  • In order to avoid the wide confusion which the term ‘Fire-Induced Progressive Collapse’ is continuing to cause at international level … the preferred term is now Fire-Induced Progressive Damage.

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I have amended our Submission accordingly.

Kind regards.

C. J. Walsh, FireOx International – Ireland, Italy & Turkey.

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2012-02-18:  The following is the text of  FireOx International’s Submission, dated 14 February 2012, to the Department of the Environment, Community & Local Government (DECLG) in Dublin … concerning the current review of the Irish Building Regulations Part B & TGD B … including, for good measure, some initial and very pertinent comments on the Irish Building Control Regulations.

None of these comments will come as any surprise to regular visitors here.

It should also be noted that the same comments are just as relevant in the case of the British (England & Wales) Building Regulations, Part B and Approved Document (AD) B !

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Ms. Claire Darragh, Architecture & Building Standards Section, DECLG.

Dear Claire,

Thank you for this opportunity to advise the Department on some urgent and necessary improvements to Part B: ‘Fire Safety’ of the 2nd Schedule to the Building Regulations in Ireland … and its supporting Technical Guidance Document (TGD) B.

1.  Some Initial Comments

  • The continuing debacle of the Priory Hall Apartment Complex, in Donaghmede Dublin 13, is just the tip of a very large iceberg in Ireland.  Yet, when we now hear that there will be a ‘risk-based’ approach to Septic Tank Inspections, instead of an approach which involves inspecting all septic tanks … independently, competently and thoroughly … it is clear that the Minister, and senior officials in his Department, have failed to learn any lessons from ‘Priory Hall’.

What was happening on Irish construction sites during the Celtic Tiger boom years … has been happening for twenty years all over the country … more precisely, since the introduction of legal national building regulations in 1991, with NO effective building control … and, before that again, in those parts of the country outside of the major urban areas having legal building bye-laws AND effective building control, i.e. mandatory inspections by competent local authority personnel at the foundation level and drainage level of ALL projects … and, depending on the type of project, occasional or frequent inspections above ground level.

Over the years, local authority officials who carried out building bye-law inspections accumulated a considerable wealth of knowledge and understanding about local construction conditions and practices.  This valuable resource, widely used by the construction industry at the time, has now been diluted and discarded.

PLEASE LEARN THE LESSONS FROM ‘PRIORY HALL’ !!

In connection with ALL Applications for Fire Safety Certificates (Part B) and Disability Access Certificates (Part M) … competent and thorough inspections must, from now on, be carried out by local authority personnel to confirm proper implementation of Part B & M, respectively, of the 2nd Schedule to the Building Regulations.

Furthermore … while on site, local authority personnel must not be discouraged, or restricted, from dealing with any other Parts of the 2nd Schedule to the Building Regulations.  Under the present dysfunctional system, important horizontal linkages between different Parts of the 2nd Schedule are being widely disregarded and ignored, e.g. between Parts B & D, between Parts B & M, and between Parts B & A … or between Parts M & D, etc., etc !

  • European Union (EU) Council Directive 89/106/EEC has been repealed … and, instead, we now have EU Regulation No 305/2011 of the European Parliament and of the Council, of 9 March 2011, laying down Harmonised Conditions for the Marketing of Construction Products.

Unlike the earlier EU Directive … this Regulation, applicable in all EU Member States, is binding in its entirety.

And although Annex I of EU Regulation 305/2011 will enter into force from 1 July 2013 … the Department should now prepare for, and slowly begin the process of, incorporating all of the Annex I Basic Requirements for Construction Works into the 2nd Schedule of the Irish Building Regulations.

SEE BELOW …

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2.  Firefighter Safety

Fully consistent with Basic Requirement for Construction Works 2(e), in Annex I of EU Regulation No. 305/2011 … Revise Part B Requirement 5 to read as follows …

B5  Firefighter Safety, and Access and Facilities for the Fire Service

A building shall be so designed and constructed that the safety of firefighters is adequately considered and, in the event of an outbreak of fire, that there is adequate provision for access for fire appliances and such other facilities as may be required to assist the fire service in the protection of life and property.

Two examples of issues which should be highlighted in a relevant revision/addition to TGD B’s Guidance Text:

  • The incorporation, in building designs, of alternative safe means of approach towards the scene of a fire by firefighters ;
  • The provision of wider staircases in buildings in order to facilitate the recovery of an injured/impaired firefighter during the course of firefighting operations.

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3.  Protection of Vulnerable Building Users from Fire

The European Union ratified the United Nations Convention on the Rights of Persons with Disabilities (CRPD) on 23 December 2010.  Ireland has not yet ratified the Convention.

However … fully consistent with Ireland’s legal obligation, under Article 4.3 of the Treaty on European Union (TEU), to co-operate fully with EU Institutions in their implementation of this UN Convention … Revise Part B Requirement 1 to read as follows …

B1  Means of Evacuation in the Event of an Outbreak of Fire

A building shall be so designed and constructed that the protection of vulnerable building users is adequately considered and, in the event of an outbreak of fire, that there are adequate and accessible means of evacuation from the building to a place of safety remote from the building, capable of being safely and effectively used.

[ Use of the word ‘escape’, in the context of emergencies, should be strongly discouraged at all times. ]

Concerning TGD B’s Guidance Text … reference to ISO 21542: ‘Building Construction – Accessibility and Usability of the Built Environment’ will be more than sufficient.

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Specifically relating to Adequate Protection of Vulnerable Building Users from Fire

NOTE WELL THAT BS 9999 (AND BS 5588:PART EIGHT)  IS (ARE)  ENTIRELY UNFIT FOR PURPOSE !!

Please carefully examine the attached PDF File – My Note for the National Standards Authority of Ireland:  ‘BS 9999:2008 & BS 8300:2009 – Impacts on Accessibility Design in Ireland & Implications for ISO Accessibility & Fire Safety Standards’ , dated June 2009.

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4.  TGD B’s Appendix A – Performance of Materials and Structures

2 Important Notes should be added to Paragraph A21 – Structural Fire Design

  • In complying with Part B, reference should also be made to Part A of the 2nd Schedule of the Building Regulations, particularly Requirement A3 – Disproportionate Collapse ;

and

  • In order to show that a Fire Protection Material/Product/System for Structural Elements properly complies with Part D … it is also necessary, besides showing that it has been adequately fire tested, to show that the material/product/system is durable over a specified, reasonably long life cycle … and that it can adequately resist mechanical damage during construction of the building and, in the event of an outbreak of fire, during the course of that fire incident.

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Specifically relating to Steel Structural Performance in Fire

You should be aware that Table A1 and Table A2 are only appropriate for use by designers in the case of single, isolated steel structural elements.

In steel structural frame systems, no consideration is given in the Tables to adequate fire protection of connections … or limiting the thermal expansion (and other types of distortion) in fire of steel structural elements … in order to reduce the adverse effects of one steel element’s behaviour on the rest of the frame and/or adjoining non-loadbearing fire resisting elements of construction.

In the case of steel structural frame systems, therefore, the minimum fire protection to be afforded to ALL steel structural elements, including connections, should be 2 Hours.  Connections should also be designed and constructed to be sufficiently robust during the course of a fire incident.  This one small revision will contribute greatly towards preventing Fire-Induced Progressive Damage in buildings … a related, but different, structural concept to Disproportionate Damage …

Disproportionate Damage

The failure of a building’s structural system  (i) remote from the scene of an isolated overloading action;  and (ii) to an extent which is not in reasonable proportion to that action.

Fire-Induced Progressive Damage

The sequential growth and intensification of structural distortion and displacement, beyond fire engineering design parameters, and the eventual failure of elements of construction in a building – during a fire and the ‘cooling phase’ afterwards – which, if unchecked, will result in disproportionate damage, and may lead to total building collapse.

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With regard to the above … please carefully examine these 2 Series of Posts on FireOx International’s Technical Blog ( www.cjwalsh.ie ), beginning on the dates indicated …

  • 2011-10-25:  NIST’s (2005) Recommendations on the 9-11 WTC Building Collapses … GROUP 1. Increased Structural Integrity – Recommendations 1, 2 & 3 (out of 30) ;

and

  • 2012-01-18:  Progressive Collapse of WTC 7 – 2008 NIST Recommendations – Part 1 of 2 … GROUP 1. Increased Structural Integrity – Recommendation A … and GROUP 2. Enhanced Fire Endurance of Structures – Recommendations B, C, D & E (out of 13).

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5.  TGD B’s Appendix F – Reference Standards

Add this Important New Standard …

  • ISO 21542 : 2011     Building Construction – Accessibility and Usability of the Built Environment

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6.  TGD B’s Appendix G – Reference Publications

Add these Two Important Publications …

  • NIST (National Institute of Standards and Technology).  September 2005.  Federal Building and Fire Safety Investigation of the World Trade Center Disaster: Final Report on the Collapse of the World Trade Center Towers.  NIST NCSTAR 1.  Gaithersburg, MD, USA.

and

  • NIST (National Institute of Standards and Technology).  August 2008.  Federal Building and Fire Safety Investigation of the World Trade Center Disaster: Final Report on the Collapse of World Trade Center Building 7.  NIST NCSTAR 1A.  Gaithersburg, MD, USA.

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Should you wish to receive further information on any of my comments … please consult FireOx International’s Technical Blog at  www.cjwalsh.ie … or contact me directly.

Please acknowledge receipt of this e-mail communication.

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Kind regards.

C. J. Walsh, FireOx International – Ireland, Italy & Turkey.

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END

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Fixing ‘Priory Hall’ in Dublin – Practical Solutions Needed Now !

2011-10-18:  A large ‘can of worms’ has recently been opened in Ireland …

For the last few days, including today, I have been listening intently to Joe Duffy on the RTE Radio ‘Liveline’ Programme at lunchtime.  Joe is being very cautious because he cannot quite believe his ears … either about the unfolding harrowing events for occupants in ‘Priory Hall’, Donaghmede, Dublin 13 – a Private, Multi-Storey Apartment Development – or the tales and anecdotes about Irish Building Sites during the Celtic Tiger Years.

This will be of no consolation to anybody … but the big surprise, for me, is that there is so much public shock.  ‘Priory Hall’ is the Tip of the Iceberg !   Ireland’s current dysfunctional approach to the development of Our(!) Built Environment … has been designed (for want of a better word) in a chaotic, haphazard and malevolent way … to end up in exactly the sort of mess which we are all now witnessing in North County Dublin.

Just to be clear … what has been happening in the Irish Construction Industry, during the boom years, has been happening for twenty years all over the country … more precisely, since the introduction of Legal National Building Regulations, with NO Effective Building Control, in 1991 … and, before that again, in those parts of this jurisdiction, outside of the major urban areas having Legal Building Bye-Laws, and Effective Building Control, i.e. mandatory inspections by competent local authority personnel at the foundation level and drainage level of all building sites … and, depending on the type of project, occasional or frequent inspections above ground level.

[ 1991:  Statutory Instrument No.304 of 1991 – Building Control Act, 1990 (Commencement Order), 1991;  Statutory Instrument No.305 of 1991 – Building Control Regulations, 1991;  Statutory Instrument No.306 of 1991 – Building Regulations, 1991 ]

And the biggest joke of all … is that the sum of the many resources, both human and material, required to repair sub-standard construction throughout Ireland … will count as a positive contribution towards the economic indicator of GDP (Gross Domestic Product) !   FUBAR

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Colour photograph showing 'Priory Hall' ... a private, multi-storey apartment development located in North County Dublin, Ireland. Click to enlarge.

Colour photograph showing 'Priory Hall' ... a private, multi-storey apartment development located in North County Dublin, Ireland. Click to enlarge.

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PRACTICAL SOLUTIONS NEEDED NOW

What I have not been hearing from the radio, or reading in the newspapers, is practical solutions.

Lest there be any doubt … this is one of the professional services we provide at Sustainable Design International !

So … how do we fix Priory Hall as the situation now presents itself … in such a way that, as soon as it is practicable, a satisfactory level of long-term safety, protection, convenience and comfort will be provided for the occupants of Priory Hall … and the social wellbeing of the local community, there, can be restored.

Afterwards … we can worry about who’s responsible, and about the reasons for the many ‘system’ failures in Ireland.

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FIXING ‘PRIORY HALL’ IN DUBLIN

The following list of practical suggestions … a simple roadmap … is addressed to the Owners and Occupants of Apartments in Priory Hall.

As they have a large vested interest in the problems of Priory Hall … either directly or indirectly … no assurances or undertakings should be accepted, on face value, from either Dublin City Council (DCC) or the Department of the Environment, Community & Local Government (DECLG) … or their representatives.

     1.  Informed Consent of Apartment Owners and Occupants

Demand that the Informed Consent of the Owner/Occupant of an Apartment is required, in writing, before any necessary Corrective/Repair/Refurbishment Works are carried out …

Informed Consent:  Consent freely obtained – without threats or improper inducements – after appropriate disclosure to a person of relevant, adequate and easily assimilated information in a form and language understood by that person.

     2.  ‘As Constructed’ Drawings & Specification of Entire Development

If they exist … we’re on the way !   But, if they don’t exist … and they may not … demand that an ‘As Constructed’ Survey of the Entire Development be carried out immediately.

Demand to see a copy of the Detailed ‘As Constructed’ Drawings, and Specification, for the Entire Development.

CHECK the adequacy of the Detailed Drawings and Specification !

At this stage, remember … all of the emphasis must now be placed on actual construction … not on paperwork !   The ‘As Constructed’ Survey Drawings and Specification are only a means towards a satisfactory end … that’s all !!

     3.  Failures to Properly Comply with Current Building Regulation Requirements A to M (Second Schedule to Irish Building Regulations)

Demand to see a Detailed Schedule of the many failures to properly comply with current Building Regulation Requirements, i.e. Parts A to M in the Second Schedule to the Building Regulations, as amended.

Do not entertain, even for a moment, any discussion about past legal building regulation requirements, which were in force at the time of initial design or construction !

An important point to note !   The Guidance Texts in, for example, Technical Guidance Document B: ‘Fire Safety’ are merely that … GUIDANCE !   This guidance is not infallible … and in a few respects, is entirely inadequate … for example, when dealing with the structural performance of buildings during conditions of fire, and the ‘cooling phase’ immediately afterwards … and the fire evacuation of people with activity limitations, in which case the guidance actually ensures that fire evacuation is made extremely difficult, if not prevented altogether !

Do not be sucked in to any conversations about what is stated, or not stated, in the Technical Guidance Documents.  This is irrelevant.  The Law mandates proper compliance with the Requirements !

Some people may even attempt to quote from the Building Regulation Approved Documents for England & Wales.  Just tell them to take a long jump off a short pier … suggest Howth Harbour !

Become very, very suspicious whenever there is a use of, or reference to, the term ‘Substantial Compliance’ !!

CHECK the adequacy of this Detailed Schedule !   And … ensure that it is Comprehensive !!

     4.  The Necessary Corrective/Repair/Refurbishment Works

Demand to see Full Detailed Information, in the form of annotated drawings and descriptive texts, etc., etc … on the exact nature, timetable and phasing of all of the Corrective/Repair/Refurbishment Works which are necessary to effectively solve the serious problems in the Development.

Beware of decorative solutions, which look good to a superficial visual inspection in ambient conditions … but don’t actually solve anything !

CHECK the adequacy of this Full Detailed Information !

     5.  Independent Technical Control of Construction Works

Demand only Category A Construction Execution of the necessary Corrective/Repair/Refurbishment Works …

Category A Construction Execution:

(a)  Supervision of the works is exercised by appropriately qualified and experienced personnel from the principal construction organization ;

(b)  Regular inspections, by appropriately qualified and experienced personnel familiar with the design and independent of the construction organization(s) … and other vested interests … are carried out to verify that the works are being executed in accordance with the design.

Demand receipt of a clear undertaking, in writing, that this will be the case … before any Corrective/Repair/Refurbishment Works commence.

And remember these words from the 2005 Final Report of the U.S. National Institute of Standards & Technology (NIST) on the 9-11 World Trade Center Tower Collapses …

” NIST urges state and local agencies to rigorously enforce building codes and standards since such enforcement is critical to ensure the expected level of safety.  Unless they are complied with, the best codes and standards cannot protect occupants, emergency responders, or buildings.”

CHECK the adequacy of the Proposed Method of Independent Technical Control during execution of the Corrective/Repair/Refurbishment Works !

     6.  Meeting & Discussion with Other Owners/Occupants

Do not act alone … meet the other Owners/Occupants, and discuss issues with them.  Share and collate all available information together.  Try to identify information gaps.  If you do not understand something … ask !

When, and only when, you are happy … signal your Informed Consent that works should commence.

     7.  Commencement of Corrective/Repair/Refurbishment Works

Visit the Construction Site Office regularly … to show that you are taking a keen interest in what is happening.  Keep your eyes and ears wide open.

Expect that you will not be permitted to just wander around the Site.  Construction Sites are one of the most hazardous ‘workplaces’ in this country !

CHECK the adequacy of the Independent Technical Control actually being undertaken.

Demand to be updated, regularly, and at the very least on the progress of Corrective/Repair/Refurbishment Works at your Apartment … in the Common Areas of your Block … and throughout the full extent of the Approach Routes to your Block Entrances and Exits.

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Advisory Note:  Should you, or the Residents’ Committee of your Building or Development, be concerned about any matter discussed in this Post … please contact C.J. Walsh  by e-mail: cjwalsh@sustainable-design.ie  or by phone: (01) 8386078 / +353 1 8386078.

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END  (for now, but to be continued soon !)

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