Fire Safety Certificate

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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BER Certificates & Necessary Sectoral Infrastructure (IV)

2009-03-14:  The Construction Sector Comedy of Errors continues without intermission …

 

On Tuesday last, 2009-03-10, I attended a Conference in Dublin Castle: ‘Energy Efficiency in Historic(al) Buildings’, organized by the Department of the Environment, Heritage & Local Government (DEHLG) and the Irish Georgian Society.  Boys and girls … we are in trouble … flat, uninspiring presentations from our beloved DEHLG policy makers.  Missing … any wider context of required energy efficiency targets across the whole of the built environment … or views and solutions from anywhere else beyond our two little islands (Ireland & GB) on the periphery of Europe.  The approach taken to this important subject was “let’s just jump in, and see what we can do”.  What a day !

 

[Note: Thanks also to the DEHLG … Ireland still has no National Climate Change Adaptation Policy.]

 

That same morning, on Tuesday, an Opinion Piece: ‘Research Hub Benefits All’ appeared in The Irish Times (page 13), written by no other than Mr. Kieran McGowan, Chairperson of CRH.  He was full of suggestions about research in Ireland, and was most happy to support the proposed research alliance between University College Dublin (UCD) and Trinity College Dublin (TCD).  However, a quick visit to the CRH Holding Company WebSite is both relevant and informative.  There, you will learn that the Company operates in 35 countries, employing approximately 93,500 people.  Entering the key words/phrases … ‘research’, ‘construction research’, and even ‘building research’ … into the site search engine yields nothing of value … that’s right … nichts, nada, niente, zilch, zero !   With all the window dressing about Corporate Social Responsibility (CSR), etc, etc … the principal ‘value’ in CRH still remains short term ‘shareholder value’.  If it looks interesting, gobble it up.  Why waste money on a Research Division ? … which should be located in Ireland !

 

 

Yesterday, 2009-03-13, another Article appeared in The Irish Times (bottom of page 5): ‘Ireland Closer to Kyoto Emissions Target Due to Economic Slump’, by Mr. Harry McGee, IT Political Staff (?).  The Environmental Protection Agency (EPA) Press Release which generated this newspaper article was released on Wednesday, 2009-03-12, at 17.59 hrs. in the evening.

 

The 19-Page EPA Report: ‘Ireland’s Greenhouse Gas Emission Projections 2008-2020’ was issued on the same day as the newspaper article – 2009-03-13.  Excellent media management !

 

These three different texts fail to examine, or even discuss, the following issues …

 

         How many € Millions and € Millions belonging to the Irish Tax Payer are being spent, and will be spent into the far future, on buying this country out of trouble … because of the abject failure to meet our responsibilities under Kyoto I (up to 2012), and the Real EU 2020 Target of -30% GHG Emissions on 1990 levels (assuming there will be an agreement in Copenhagen, next December, on a Post-2012 Kyoto II Instrument).  This has always been the EU Target.  See Paragraph 31, German Presidency Conclusions of the Brussels European Council (8 & 9th March 2007).

 

         Having seen the numbers and range of assumptions which underpin the EPA’s GHG Emission Projections up to 2020 … how Reliable are those projections ?   Where are the critical Statements of Uncertainty ?

 

         Who are the Individuals who sat on their fat, over-paid asses throughout the last 10-15-20 years, and allowed this country to fall into such a haphazard state ?   Would any of these individuals be the same people who are now preaching sermons on ‘responsible’ GHG Emission Compliance … and still foisting upon us Voluntary Codes of Practice and Compliance Schemes, Ineffectual National Marketing Campaigns, Feather Light Regulation, and Press Releases which obscure what is really happening ?

 

Do you see any parallels with current events in the Irish Financial Sector ?

 

         Can the Irish Construction Sector be expected to meet any Real Performance Targets (e.g. Proper Building Energy Rating Labelling, Meaningful GHG Emission Reductions, Serious Energy Efficiency Improvements, whatever … ) – as distinct from Theoretical Performance on paper – without a Very Necessary Sectoral Infrastructure capable of shaping suitable responses to those targets, and ensuring that they are implemented ?

 

 

 

As already discussed in an earlier Post … a Complete Cultural Shift in the Irish Construction Sector is essential.  So, let me give you a small flavour of what we need to do …

 

 

1.  Construction Data & Statistics:

 

Ireland does not currently possess a comprehensive National Construction Database.  No reliable statistics can be presented with regard to building or construction-related performance in 1990, or 2005.  No coherent projections, therefore, can be made for the years 2010, 2012, 2020 or 2050 … under any futures scenario.

 

The Central Statistics Office (CSO) gathers construction-related Economic Data.  Energy Ireland (SEI) Databases are not reliable.

 

Construction is not identified as a separate Sector, by either the Environmental Protection Agency (Ireland) or the European Environment Agency (Denmark), in European Greenhouse Gas Emission (GHG) Databases.

 

 

 

2.  A Concerted Programme of Infrastructure Restoration:

 

         Re-establish and adequately resource an Independent National Institute for Spatial Planning & Construction Research (formerly known as An Foras Forbartha) in Ireland, having joint responsibility with the CSO for maintaining a reliable National Construction Database.

 

Construction Research & Innovation must be given a high national priority !   

 

The National Institute must establish close working relationships with the relevant European Union Institutions, particularly EuroStat in Luxembourg.

 

[By ‘independent’ … I mean at a long, long, long arm’s distance away from the Department of the Environment, Heritage & Local Government (DEHLG).]

 

         Re-establish and adequately resource an Independent and Fully Accredited National Construction Testing & Development Complex.

 

         Re-Format, Revise & Horizontally Integrate the National Building Regulations.

 

The existing format is both limited and seriously flawed.  For discussion in a later Post.

 

         Adequately resource the Irish National Accreditation Board (NAB), and closely monitor the quality of its work.

 

         Adequately resource the National Standards Authority of Ireland (NSAI) and ensure that Ireland participates vigorously in the European Standards Organizations and ISO (International Standards Organization).

 

         Adequately resource an Independent Irish Agrément Board (IAB), and closely monitor the quality of its work.

 

[By ‘independent’ … I mean at a long arm’s distance away from the National Standards Authority of Ireland (NSAI).  These two organizations were supposed to have been separated a few years ago anyway.]

 

         Adequately resource awareness raising and Institutional Capacity building for Sustainability and Climate Change Adaptation in the Department of the Environment, Heritage & Local Government (DEHLG), Energy Ireland (SEI) and the Construction Industry Federation (CIF).

 

         Adequately resource awareness raising, Re-Training and Re-Education for Sustainability and Climate Change Adaptation at all levels in the rest of the Construction Sector, including All (Professional) Design Disciplines and All Construction Organizations.

 

 

 

3.  Initial Construction Quality:

 

Post-completion repairs and/or system retrofitting always involve compromises, are costly and are rarely anywhere near being 100% effective.  Ensure Proper Initial Construction Performance through robust inspection of buildings during construction … checking that all relevant legislation has been complied with and that construction products have been approved, i.e. properly shown to be ‘fit for their intended use (in the location of use)’, etc.

 

         Adequately resource, with Staff (e.g. building controllers, inspectors, administrative, legal), Monitoring Equipment (e.g. sound meters, long wave infra-red cameras, etc.) and Technical Support (e.g. training, library facilities, access to research) … all Building Control Authorities in the country.

 

Introduce a fully Integrated (including Part B of the Building Regulations) and Mandatory Inspection Scheme on all Construction Projects, at the following Construction Stages …

 

Foundations ;

Drainage ;

Ground Floor Construction ;

Super-Structure (above Radon Resisting Membrane) … inspections to take place at a level no higher than first floor ;

Roof.

 

Such an Inspection Scheme must operate uniformly across the country.  Piecemeal variations and maverick procedures operated by National Authorities Having Jurisdiction (AHJ’s) or Individual Local Authorities cannot any longer be tolerated.

 

 

 

4.  Consumer Protection:

 

         Establish an Independent and Comprehensive National Building Insurance Scheme.

 

Self-Regulation by the Architectural and Legal Professions offers merely the ‘appearance’ of protection to the Irish Consumer.

 

The current system of Royal Institute of the Architects of Ireland (RIAI) / Law Society ‘Opinions on Compliance with Building Regulations’ is inadequate … and offers no protection to the Irish Consumer.  The phrase ‘substantial compliance’ is much misunderstood and widely abused.

 

         Introduce and adequately resource the discipline of Independent Technical Controller.  He/she must be independent from Construction-related Organizations, the Building Design and Legal Professions … Local Authorities … and any other National Authorities Having Jurisdiction (AHJ’s).

 

         Introduce a Mandatory Building Completion Certification System.

 

Before any Building can be occupied, a Certificate of Building Completion Performance, and an Accompanying Report, must be issued by an Independent Technical Controller.  The System will include an independent evaluation of compliance with relevant building legislation and a thorough examination of ‘real’ construction performance.

 

Building Completion Documentation can be designed to include …

         a Fire Safety Certificate, which is issued only after adequate monitoring of the actual fire safety related construction ;

         a Disability Access Certificate, which is issued only after adequate monitoring of the actual access related construction ;

         a Building Energy Rating (BER) Label ;

         a Sustainability Impact Assessment (SIA) ;

         etc., etc.

 

 

 

[Many of the above ideas have been incorporated in the 2008 Institute of International & European Affairs (IIEA) Publication: The Climate Change Challenge, which presents a strategic overview of Irish Climate Change Policy.]

 

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