Fire Safety Certificates

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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Disability Access Certificates (DAC’s) – A Time to Worry ? (I)

2009-10-17:  Some of you are already hitting the Internet Search Engines … with fierce intent altogether … about  Disability Access Certificates (DAC’s) !

Is it Time to Panic ?   No.

For a simple and direct hit, the 2 most relevant Irish Legal Instruments are:

1.  Statutory Instrument No. 352 of 2009 – Building Control Act 2007 (Commencement) Order 2009.

This states …

” The 30 September 2009 is appointed as the day on which the provisions of Sections 5 and 6 of the Building Control Act 2007 shall come into operation.”

Section 5 covers the Amendment of Section 6 (Building Control Regulations) of the Building Control Act 1990.

Section 6 covers the Amendment of Section 7 (Appeals) of the Building Control Act 1990.

2.  Statutory Instrument No. 351 of 2009 – Building Control (Amendment) Regulations 2009.

This states …

” These Regulations shall come into effect on 1 October 2009, except for the provisions of Article 8 which shall come into effect on 1 January 2009.”

Article 8 covers Disability Access Certificates and Revised Disability Access Certificates.

For you, yourself, to properly examine all of the ‘ins and outs’ of this New Certification Scheme … download the PDF File below … and then search the document (making sure that it is not case-sensitive !) using the phrase ‘Disability Access Certificate’.  You will find 99 instances where the phrase is used.

Enjoy !

Ireland: Statutory Instrument No. 351 of 2009 – Building Control (Amendment) Regulations 2009

Click the Link above to read/download PDF File (223 Kb)

In order to make full sense of all that is happening, and is intended to happen in the not too distant future … there are a few other Legal Instruments, related to the two listed, which also need to be consulted … but that is an exercise meant for masochists !

In comparison, the European Union Lisbon Treaty was a sweet bedtime story !   Seriously !!

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Is it Time to Worry ?   Yes.

Here are just a few random ideas for your cogitation …

  • If the Department of the Environment, Heritage & Local Government (DEHLG) pays little heed to Submissions made during and after this summer’s ‘consultation’ process … the proposed New Technical Guidance Document M: ‘Access & Use’ will end up looking like a real dog’s dinner of an absolute mess !   FUBAR.

Years were spent in the preparation of the New TGD M.  When it does eventually appear, it will be an accurate reflection of technical capacities within both the Department and the National Disability Authority (NDA).

Deeply regretted is the absence of Mr. Kevin Spencer … a gentle soul … from the DEHLG.  Things have not been the same since his departure.  He knew what he was talking about.

  • Who will deal, at a technical level, with Applications for Disability Access Certificates in the Local Authorities ?   Will they be competent to do so ?   Will their interpretation of the Part M Legal Requirements be harmonized … not just with other/different Authorities … but even with other technical personnel in the same Authority ???
  • In order to make this new certification scheme work, will the Guidance Text in Technical Guidance Document M (whatever version appears !) be operated as if it were Prescriptive Regulation … which will be totally illegal ?

This has been exactly the story … for many years … with the Guidance Text in Technical Guidance Document B … in the course of operation of the Fire Safety Certification Scheme.  FUBAR.

  • If, as I hinted above, the proposed New Technical Guidance Document M: ‘Access & Use’ will be a real dog’s dinner of a mess … falling far short of what can now be reasonably described as minimal accessibility performance (see the Draft International Accessibility-for-All Standard ISO 21542) … this will certainly open Building Owners/Managers of newly completed buildings to Complaints under Irish Equality Legislation.  Why is the Disability Sector so inactive with regard to making complaints ?

and finally …

  • Are the relevant Irish Decision Makers, as I suggested might happen in a previous post, in the process of actually sleepwalking into an unquestioned acceptance of the inadequate British Standards BS 9999 : 2008 and BS 8300 : 2009 ???   Do they know how to do anything else ?

 

For some sublime moments of meditation, however, please chew on the information provided at these Pages on the SDI Support WebSite

Disability Rights & Removing Physical Restrictions on Participation in Society ;

Towards a Sustainable Social Environment, Accessibility-for-All & Facilitation Design (2001 WHO ICF) ;

Fire Evacuation-for-All & Principles of Fire Engineering.

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Quality of Irish Construction – Unacceptable ?

2009-02-12:   So … Anglo-Irish Bank has been caught – finally – playing with numbers and cooking the books.  And … because of inadequate (i.e. a complete lack of effective) control by the National Financial Regulator, this was regarded as a routine, ‘smart’ transaction by privileged individuals.  “What is the problem ?” … they ask … “no laws were being broken”.

 

Holding firmly onto those thoughts, let us briefly turn our attention to the Construction Sector … and the Energy Performance of Buildings …

 

A new Home Energy Savings (HES) Scheme was recently announced by Mr. Eamon Ryan T.D., Minister of Communications, Energy & Natural Resources … €100 million Insulation Scheme to Benefit 50,000 Homes – Programme Will Create 4,000 Jobs … according to an article in The Irish Times, on Monday 9th February 2009, by Mr. Harry McGee.

 

Reading the Department of Energy’s own Press Release for the Scheme Launch, dated 2009-02-08 … it is evident that public relations consultants, marketing gurus, senior academics (who should know better) and civil servants were involved in producing ‘paper’ numbers to justify and support the miserable grants being offered in the HES Scheme.  Numbers were even presented for ‘Typical Net BER Improvement’ ?!?

 

When the Scheme is eventually up and running, Thermal Insulation Contractors will be required to comply with a voluntary Energy Ireland (SEI) ‘Contractors Code of Practice & Standards and Specifications Guidelines’ (version 1, 2009-02-03) … and SEI may or may not carry out control inspections in order to monitor the quality of their work.  Does all this sound familiar ?

 

 

But … are these paper energy numbers ‘real’ ?   If he thinks so, Mr. Eamon Ryan is living in Alice’s Wonderland !

 

This is a photograph, taken back in 2000, of expanded polystyrene insulation which was badly installed in an external cavity wall … very badly installed !   When the Irish Construction Industry would later enter extreme ‘over-heat’ mode, the quality of typical construction would deteriorate sharply.

 

Colour Photograph of an External Cavity Wall, showing 'Floating' Thermal Insulation (and, in the background, an Inclined Steel Wall Tie which will later facilitate water ingress). Click to enlarge. Photograph taken by CJ Walsh. 2000-01-19.
Colour Photograph of an External Cavity Wall, showing ‘Floating’ Thermal Insulation (and, in the background, an Inclined Steel Wall Tie which will later facilitate water ingress). Click to enlarge. Photograph taken by CJ Walsh. 2000-01-19.

Who can know what is happening inside that cavity when it is all finished and covered up from view ?   Nobody.  Unless, that is, you manage to take an Infra-Red Thermal Image during the next winter heating season – which is far too late to remedy the problem.

 

This is an example of an Infra-Red Thermal Image, taken back in 1998 …

 

Colour Image, with explanatory Text and Horizontal Temperature Bar below, showing the 'Real' Energy Performance of a Building. Click to enlarge. Project Architect: CJ Walsh. Image taken by sub-contractor in 1998.
Colour Image, with explanatory Text and Horizontal Temperature Bar below, showing the ‘Real’ Energy Performance of a Building. Click to enlarge. Project Architect: CJ Walsh. Image taken by sub-contractor in 1998.

 

 

Explaining the Current Context in Ireland …

 

It was 10 Years after the Dublin Stardust Fire Tragedy (February 1981) … before the first legal, National Building Regulations were introduced (December 1991); they became operational during the following summer of 1992.  Around the same time, Building Control Authorities were being established in every Local Authority.

 

Prior to this, legal Building Bye-Laws were operated in just a small number of our major urban centres.

 

Dublin Corporation’s Bye-Laws with respect to the Construction of Buildings, adopted by Dublin City Council on 27th June 1949, were an interesting mix of functional, performance and prescriptive requirements.  An Application, containing detailed construction information, for Building Bye-Law Approval had to be made for every construction project … and I mean ‘every’ project … prior to any construction commencing.  And, ‘every’ project was inspected at the foundation and drainage stages of construction … no exceptions.  The more complex projects were inspected as they progressed further, with special attention being paid, for example, to fire safety related construction.  I know, first-hand, that the surveyors and inspectors in Dublin Corporation’s (as it was then called) Building Control Section had built up a considerable wealth of knowledge and understanding about construction conditions and practices right around the city and suburbs.

 

Anyway … after the introduction of the National Building Regulations, an unwritten national policy was put into action … having as an aim the winding down, and general ‘castration’, of the large, well-established Building Control Sections in Dublin City and County, and Cork.  Meanwhile … in the rush to establish the new Building Control Authorities throughout the rest of the country, it was common to hear of Road Engineers being transferred into the new Control Authorities … usually having little or no experience in dealing with the construction of buildings.

 

Site Inspections under our current system of National Building Regulations are random.  Inspection Statistics produced by the Department of the Environment, Heritage & Local Government (DEHLG) are not reliable.  Building Control Authorities are, purposefully, not sufficiently resourced to be ‘effective’.

 

Commencement Notices, under the National Building Control Regulations, do not have to be accompanied by detailed construction information when being submitted to a Building Control Authority.

 

Fire Safety Certificates, under the National Building Control Regulations, do not involve any Site Inspections – at any stage – by Fire Authorities.

 

 

 

Some Conclusions …

 

The above is a rather long, but simplified, explanation as to why a large number of privileged property developers and shoddy building contractors have been allowed to flourish on Irish Construction Sites without ever understanding the concept of ‘effective’ technical control.  When they do eventually meet this concept, head-on, the level of their resentment can be without limit.

 

Before the recent property crash, did you ever try to present a builder with a Snag List on a new house ?

 

This will also put SEI’s 70% rate of non-compliance into an understandable context.  See my earlier Post, dated 2008-12-12.

 

With regard to BER Certificates … BER Assessors without any sort of architectural background are not competent to assess the construction of existing buildings … and those BER Assessors with an architectural background cannot possibly evaluate, with reliability, the construction of existing buildings without the use, for example, of Infra-Red Thermography and Air Seepage Testing.

 

BER Assessment of Historical Buildings is unsuitable, and not appropriate.

 

An Energy Survey of a Building is an entirely different concept to a BER Assessment.  See our Technical Guidance Note No.95/101(a).

 

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