Fire Safety Management Procedures

PEEPS – Fundamentally Flawed & Discriminatory ?

2009-05-13:  The other day, I thought it might be interesting to google ‘PEEPS’.  The surprising results … page after page about the marshmallow candies (in English: sweets) which are sold in Canada and the USA.  I have learned something new !


What I was trying to find, however, was information relating to Personal Emergency Egress PlanS (PEEPS) for building users with disabilities.  PEEPS is widely referenced in British literature … and because certain people (who should know better) believe that the sun, moon and stars rise over London … it has also seeped into the Irish literature by some process of ‘preverted’ osmosis.  Most regrettable !



Yesterday, I discussed the inadequacy of developing Fire Safety Management Procedures … or, in fact, designing buildings … with the sole concern being people with disabilities.


Taking account of all the relevant, and different, types of European and National Legislation … the Rule of Thumb should always be People with Activity Limitations and Accessibility for All.



While fully understanding the need for a catchy acronym … ‘PEEPS’ does not respond well to internet searches on Google.


The next unfortunate feature of Personal Emergency Egress PlanS is the misguided use of Fire Engineering Terminology in English …



Evacuation from a Fire Building

To withdraw, or cause to withdraw, all users from a fire building in planned and orderly phased movements to a Place of Safety remote from the building.



Independent emergence of user(s) from a building, under normal ambient conditions, and removal from its immediate vicinity.



Avoidance of injury or harm which is threatened by imminent danger.



Instrumental Aggression

Aggression which is a means to another end, e.g. pushing someone aside to escape from danger.



Whenever, therefore, the terms ‘evacuation’, ‘egress’ and ‘escape’ are used interchangeably … on the same occasion … and without apparent rhyme or reason … it is time to call a halt to proceedings … and to scream “bullshit – moráns at work” !   Furthermore … the word ‘escape’ should never be used in connection with fire evacuation from a building.  BSI, CEN and ISO … please take careful note !!!



A Personal Emergency Egress Plan (PEEP) is fundamentally flawed and discriminatory because it is …


         person-specific ;  and




Would any able-bodied building user tolerate being told that a document would have to be prepared before he/she could enter and use a building … and that this document would discuss only his/her use of the building … and that use only in specified parts of the building ???   No way !   Are you serious !!   What a joke !!!


The relevant, and different, types of European and Irish National Legislation require that buildings be accessible … covering approach to, entry, use, egress (under normal conditions), evacuation (in the event of a fire emergency) and removal from their immediate vicinity.


Within this legal environment … PEEPS is fundamentally flawed.  And … because building use is limited for specified individuals to specified areas only … PEEPS is also discriminatory.



If there is to be recourse to PEEPS, it should be in very exceptional circumstances only !   And, I can certainly think of one possible situation … existing buildings of historical, architectural and cultural importance … where anything more than moderate interference with the building fabric is both ill-advised and restricted … and everyone’s use of the building must be curtailed to some extent.







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People with Activity Limitations (2001 WHO ICF) ?

2009-05-12:  Or … in French: Personnes à Performances Réduites … a term which should be used much more often !


For many decades, the language of ‘disability’ has been all over the place, to put it mildly … others might suggest, however, that it lacks coherence, and is fragmented and chaotic !   As a result, it has been difficult to make any sort of solid progress on harmonization … at a technical level … in Europe.


Adopted on the 22nd May 2001, the World Health Organization’s International Classification of Functioning, Disability & Health (ICF), changed that situation for the better.  It is important to emphasise that the ICF is a classification of ‘Health’ … not of ‘Disability’.



People with Activity Limitations (English) /

Personnes à Performances Réduites (French):

Those people, of all ages, who are unable to perform, independently and without aid, basic human activities or tasks – because of a health condition or physical/mental/cognitive/psychological impairment of a permanent or temporary nature.


This term includes …


         wheelchair users ;

         people who experience difficulty in walking, with or without aid, e.g. stick, crutch, calliper or walking frame ;

         frail, older people ;

         the very young (people under the age of 5 years) ;

         people who suffer from arthritis, asthma, or a heart condition ;

         the visually and/or hearing impaired ;

         people who have a cognitive impairment disorder, including dementia, amnesia, brain injury, or delirium ;

         women in the later stages of pregnancy ;

         people impaired following the use of alcohol, other ‘social’ drugs, e.g. cocaine and heroin, and some medicines, e.g. psychotropic drugs ;

         people who suffer any partial or complete loss of language related abilities, i.e. aphasia ;

         people impaired following exposure to environmental pollution and/or irresponsible human activity ;




         people who experience a panic attack in a fire situation or other emergency ;

         people, including firefighters, who suffer incapacitation as a result of exposure, during a fire, to poisonous or toxic substances, and/or elevated temperatures.




A neurological disorder marked by the inability of a person to recognize that he/she has an activity limitation or a health condition.




What is the big deal here ?


Because of the stigma which still attaches to ‘disability’ … and because some people are unable to recognise that they have an activity limitation or a health condition … depending on self-declaration, alone, for the purposes of developing suitable Fire Safety Management Procedures in a building (of any type) is a recipe for certain failure of those procedures.


And … of very direct relevance to design practice generally … compare the weak and inadequate definition of people with disabilities in Part M4 of the Irish Building Regulations (there is no reason to suspect that there will be an earth shattering improvement to this definition in the Revised Technical Guidance Document M … whenever it eventually sees the light of day !) … with the definition of disability in Irish Equality Legislation.


Chalk and Cheese !   Or … from the ridiculous to the sublime !   Check it out for yourself.


The consequence of this remarkable difference in definitions for anyone involved in the design and/or construction of a building is that … while they might very well be satisfying the Functional Requirements of Parts M and B in the Building Regulations … they will, more than likely, be still leaving the owner and the person who controls or manages the new building open to a complaint under our Equality Legislation.


In the case of Workplaces … truly brave is the person who will design a ‘place of work’ just to meet the minimal performance requirements of Building Regulations !



As a Rule of Thumb, therefore … architects, engineers, facility managers, construction organizations, etc, etc … should become more comfortable working with the concept of People with Activity Limitations.



This practical Rule of Thumb is also what lies behind the concept of Maximum Credible User Scenario, i.e. building user conditions which are severe, but reasonable to anticipate …


         the number of people using a building may increase, on occasions which cannot be specified, to 120% of calculated maximum building capacity ;   and

         10% of people using the building (occupants, visitors and other users) may have an impairment (visual or hearing, physical function, mental, cognitive or psychological, with some impairments not being identifiable, e.g. in the case of anosognosia).




[ Please note well … that miserable piece of legislation … or, bureaucrats’ charter .. the 2005 Disability Act (Number 14 of 2005) … is irrelevant to the above discussion.  But … when Irish Politicians, Senior Civil Servants and the National Disability Authority begin to take seriously the 2006 United Nations Charter on the Rights of Persons with Disabilities … the 2005 Act will have to be scrapped altogether and/or dramatically re-drafted ! ]







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‘Areas of Rescue Assistance’ in Buildings – More Bytes ?

2009-03-17:  Pull closer to the screen … we can lower the sound level, and be honest with ourselves for a few minutes …


We have enabling legislation spewing out of our ears in the European Union on the subject of ‘fire safety, protection and evacuation for all’ … there is absolutely no shortage whatsoever !


The problem is that far too many fire officers (prevention and operations) and building control officers in local authorities, architects, engineers and quantity surveyors do not know and/or do not care about this issue.


Rates of compliance with legislation are very low.  Proper compliance is such a rare thing … that you would almost feel like holding a party, in celebration, right there on the spot when it’s discovered !   This applies not only to Ireland and Great Britain … but to the rest of Europe as well.


And while many countries have already signed and ratified the 2006 United Nations Convention on the Rights of Persons with Disabilities, which became an International Legal Instrument on 3rd May 2008 … and many more will do likewise during the course of the next year or two, including the United States of America (according to the Whitehouse WebSite !) … I am sure that few individuals in those countries have any understanding of Article 11 (text quoted in an earlier post).



Accessible Fire Engineering:

On that fateful morning of 11th September, 2001 … at the World Trade Center Complex in Lower Manhattan, New York City … we witnessed a catastrophic failure in common practices and procedures … at all levels …

         Architectural / Conventional (‘Ambient’) Engineering / Fire Engineering ;

         Building Management ;

         Emergency Responders / Firefighters / Rescue Teams ;

         Control Organizations Having Authority (AHJ’s) or Jurisdiction ;

         Fire Safety Objectives in Building Legislation, Codes & Standards.


This was a ‘real’ fire incident.  It has been very, very closely examined in the intervening years.  Disability was a major issue at the heart of the tragedy … 6% of WTC building occupants were people with mobility impairments … approximately 8%, in total, were people with disabilities.  The overall number of People with Activity Limitations (2001 WHO ICF), however, was higher.


It is for this reason that three vital WTC Components have neatly dovetailed and fused … to realize an essential rational and empirical basis for a transformed fire engineering approach which can deal effectively with ‘fire safety, protection and evacuation for all’ of the people who use buildings … Accessible Fire Engineering … a subset of Sustainable Fire Engineering …


1.  2005 NIST(USA) NCSTAR 1 Final Report on 9-11 WTC 1 & 2 Tower Collapses. 


2.  2008 NIST NCSTAR 1A Final Report on 9-11 WTC 7 Collapse.


3.  Ongoing NYC-ATSDR World Trade Center Health Registry (established 2002).



Further Information about ‘fire safety, protection and evacuation for all’, the NIST 9-11 Reports and the WTC Health Registry … is available at the FireOx International WebSite




Picking up, therefore, where I left off a few days ago …



An ‘Area of Rescue Assistance’ in a Building should:

         adjoin every fire evacuation staircase in a building ;

         be located on every floor (note: fire evacuation routes at ground level should lead directly to the exterior) ;

         include adequate space for the people in wheelchairs, and their assistants, people using crutches, people with visual impairments, etc., who may be expected to use the area of rescue assistance during a fire emergency ;

         have good lighting at all times (note: lighting activation/de-activation by motion detection, for reasons of energy efficiency, should not be used in an area of rescue assistance) ;

         be clearly indicated with good signage ;

         be fitted with an accessible and reliable communication system placed at a height of 900 – 1 200 mm above finished floor level, facilitating direct contact with a person in the main fire and security control centre for the building ;

         be of sufficient size for the storage of a sufficient number of (powered) evacuation chairs, portable fire extinguishers, a fire hose reel and a manual fire alarm call point, a fire evacuation supply kit containing, for example, smoke hoods, suitable gloves to protect a person’s hands from debris when pushing his/her manual wheelchair, patch kits to repair flat tyres, and extra batteries for powered wheelchairs, etc.



The Size of an Area of Rescue Assistance should:

         relate to expected local usage during a fire emergency.  When the number of people using/occupying/working in/visiting a specific building is considered … calculate how many may have to wait there, if the lifts/elevators cannot be used for evacuation and/or fire safety management procedures fail.


For example, if there are only two fire evacuation staircases on a floor in a building (on opposite sides of the building, of course), each area of rescue assistance should be designed to cater for the expected needs of the full floor.


Please also see the end of my Post: ‘U.S. Disability Statistics – EU Practical Application ?’, dated 2009-02-25.



Evacuation Chairs should be capable of:

         being safely and easily handled ;

         carrying people of large weight (up to 150 kg) ;

         going down staircases, which may be narrow and of unusual shape, particularly in existing buildings ;

         travelling long distances horizontally and externally, perhaps over rough ground, in order to reach a ‘place of safety’.


When it is necessary to go up an evacuation staircase to reach ground level … for example, from a basement or underground shopping centre … Powered Fire Evacuation Chairs should always be provided.



A ‘Reliable’ Buddy System:

In buildings with a reasonably stable user profile, e.g. workplaces, a Buddy System should be introduced throughout the building user population.  For reliability and flexibility, e.g. to accommodate absence or holiday leave, a buddy system should always comprise at least 3 or 4 people.


In the case of a person using a wheelchair, his/her Buddy Unit should never be less than 4 people …


Black and white photograph showing the correct technique for assisting the evacuation of a person who uses a wheelchair. U.S. Fire Administration 'Orientation Manual for First Responders on the Evacuation of People with Disabilities'. FA-235/August 2002.
Black and white photograph showing the correct technique for assisting the evacuation of a person who uses a wheelchair. U.S. Fire Administration ‘Orientation Manual for First Responders on the Evacuation of People with Disabilities’. FA-235/August 2002.


Fire Safety Management Procedures:

Prior to putting any Management Procedures into operation … and certainly before carving any of these procedures in stone … meaningful consultation should take place with building users and local fire authorities … which, particularly in the case of people with activity limitations, will produce the desired outcome of informed consent.


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 (e.g. oral, written, braille) and language understood by that person.


Personal Representative …

A person charged, under European Union or EU Member State national law, with the duty of representing another person’s interests in any specified respect, or of exercising specified rights on that person’s behalf – and including the parent or legal guardian of a child, i.e. a person under the age of 18 years, unless otherwise provided for by European Union or EU Member State national law.



Without wishing to be obscure, or to avoid the issue … Fire Safety Management Procedures need to be developed to suit each specific building, with its own building user population.







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