each Part has its own separate Supporting Technical Guidance Document

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

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

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

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

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

Here are a Few Suggestions for Discussion …

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

Fire Evacuation for All

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

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

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

Objective (Approach to Buildings)

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

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

Objective (Access to Buildings)

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

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

Passenger Lifts

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

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

Internal Stairs

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

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

And …

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

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

Objective (Facilities in Buildings)

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

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

Objective (Aids to Communication)

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

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

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

Fire Safety in Dwellings for People with Disabilities

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END

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