FUBAR

Sorry Excuse For A Fire Evacuation Staircase In The Grenfell Tower – Supported By Shoddy ‘Expert’ Evidence !

2024-10-06:  After reading the  Grenfell Tower Inquiry  Phase 1 Recommendations (Chapter 33) … I was naturally curious about what would be happening during the next phase.  Paragraph 34.14 in Chapter 34, however, struck me as strange, even unbelievable … the single narrow #Stairs in the Tower would NOT be the subject of further investigation in Phase 2..

This is the Ridiculous Single Narrow Fire Evacuation Staircase in the High-Rise Residential Grenfell Tower …

Click to enlarge.

Although the Grenfell Tower Inquiry Phase 2 Recommendations (Chapter 113) concluded by looking back to Phase 1, and specifically mentioning Personal Emergency Evacuation Plans (#PEEP) … nothing was said about the Fire Evacuation Staircase.  Case closed.  And there is only one word to describe this outcome: ‘FUBAR’ !

Struggling to understand that highly questionable decision … a deep dive into the Phase 1 ‘Expert’ Technical Evidence led me to this Page from Report BLAS0000019, dated 2018-10-24 …

Click to enlarge.

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Three Important Documents Relevant To Competent Fire Evacuation Staircase Design :

  1. Orientation Manual for First Responders on the Evacuation of People with Disabilities, Document FA-235 / August 2002, published by the Federal Emergency Management Agency (#FEMA) in the #USA.  Yes indeed, this document was published way back in 2002, and is still freely available on the Internet.

A vital piece of information with regard to the Firefighter’s Lift, and the serious harm which can be inflicted on People with Disabilities by its use …

Click to enlarge.

In the absence of an operable Lift/Elevator Fire Evacuation Assembly in a building … which is still usually the norm … this photograph provides vital information with regard to the Correct, Best and Least Hazardous Method of assisting the evacuation of a person using a Manual Wheelchair.  Electric wheelchairs are too heavy, and too awkward in shape, to be lifted down/up a Fire Evacuation Staircase, even with three sturdy individuals assisting.  Note that some elaborate, highly-adapted and very expensive manual wheelchairs cannot facilitate being lifted.  In all cases, however, Vulnerable People requiring Mobility Aids will be most reluctant to leave them behind in an emergency … and they MUST be allowed to keep their personal aid.

Click to enlarge.

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  1. Final Report on the Collapse of the World Trade Centre Towers 1 & 2 (on 2001-09-11), Document NIST NCSTAR 1 / September 2005, published by the National Institute of Standards & Technology (#NIST) in the USA.  Refer to Recommendation 17 on pages 215 and 216.

[ Contraflow Circulation, in a Fire Building:  Emergency access by firefighters or rescue teams into a building and towards a real fire, while building users are still moving away from the fire and evacuating the building. ]

Contraflow Circulation during a Fire Emergency is essential.  This facilitates rapid and safe movement of firefighters towards Fire Protected Lift/Elevator Lobbies and Areas of Rescue Assistance in order to check on the presence, or otherwise, of Vulnerable People who may be waiting for rescue.

Once Firefighters enter a Fire Building … and without provision for #Contraflow Circulation … the ordering of a ‘Stay Put’ Policy for building occupants is the only difficult option … but this is NO LONGER ACCEPTABLE.

Carefully examine the photograph below.  Firefighters wearing heavy protective clothing and also carrying firefighting equipment require far, far more circulation width than 510 mm !!   However, this staircase is still not wide enough to facilitate unhampered building user evacuation.  Notice how people have to twist sideways in order to allow firefighters to pass … and this inevitability slows down evacuation progress in the ‘real’ world.

Click to enlarge.

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  1. International Standard ISO 21542: Building Construction – Accessibility & Usability of the Built Environment, published in 2011 and revised in 2021.  Standardizes good design for accessibility and the safe usability of buildings, which has been common practice for many decades.

Basics Of Staircase Design … Going, Rise, and Height of Handrails … ON BOTH SIDES of every flight of stairs …

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Basics Of Staircase Design … Clear Unobstructed Width – Between 2 Continuous Handrails.  ALL Fire Services MUST adopt this single understanding of ‘clear unobstructed width’ of a staircase !

Click to enlarge.

Basics Of Staircase Design … Staircases pose a serious hazard, especially during the stressful process of Emergency Evacuation … HAZARD Tactile Walking Surface Indicators (stippled, for hazard) at the TOP and BOTTOM of every flight of stairs.  Concerning this particular design issue, British Standards and English Building Regulations MUST be ignored !

Click to enlarge.

Basics Of Staircase Design … Handrail Tactile Plates, essential for the evacuation information to be used by people with a visual impairment in an emergency.  Refer to Figure 38 in ISO 21542.  However, this is a much more informative photograph … from one of my previous visits to Japan.  Notice the high colour contrasting …

Click to enlarge.

Basics Of Fire Evacuation Staircase Design … The Clear Unobstructed Width of 1.50 metres between Continuous Handrails on a Fire Evacuation Staircase facilitates Contraflow Circulation, the Safe Assisted Evacuation of People in Manual Wheelchairs, and Stretcher Evacuation of Building User and/or Firefighter Victims during an emergency.

Click to enlarge.

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CONCLUSIONS

Having been directly involved in the drafting of national and international Accessibility Standards and Technical Guidance since the 1980’s … I am really, really annoyed by the inept and incompetent misuse of raw anthropometric data to try to justify the width of this sorry excuse for a Fire Evacuation Staircase in the Grenfell Tower … and inflicting the Firefighter’s Lift/Carry on People with Disabilities is NOT ACCEPTABLE.  This shoddy ‘expert’ evidence clearly demonstrates a profound ignorance of Building Design, and about how ‘real’ people use ‘real’ buildings.

My great fear is that the technical justification for this shambolic fire evacuation staircase will become a benchmark for similar shambolic staircases in other buildings … not just in England, but in other jurisdictions who are dim-witted enough to copy England’s bad example … whatever it does.

Professional building design, construction and technical control disciplines, who practice in England, MUST carefully read … and keep re-reading, as necessary … Paragraph 113.12 in the Grenfell Tower Inquiry Phase 2 Report … which is expressed in too mild a form for my liking …

Our investigations have shown that levels of competence in the construction industry are generally low and that by the time of the Grenfell Tower fire many contractors, designers and building control officers treated the Statutory Guidance as containing a definitive statement of the legal requirements.  It is understandable that those who turn to the Guidance for advice about how to comply with the Building Regulations should be tempted to treat it as if it were definitive … We therefore recommend that a revised version of the guidance contain a clear warning in each section that the legal requirements are contained in the Building Regulations and that compliance with the Guidance will not necessarily result in compliance with them.

I must go further … where the Technical Guidance in any of the English Approved Documents is known to be inadequate, or even suspect, it is the ethical duty and responsibility of a true professional to find a better way of complying with the relevant Functional Requirements in Building/Fire Regulations.

In addition, and specifically in relation to Building Fire Safety … it is necessary, at the same time, to comply with ALL of the relevant Functional Requirements in England’s Building Regulations … that means NOT ONLY WITH REQUIREMENT B … BUT ALSO WITH REQUIREMENTS A, K & M (for a start) !   The recent publication of a single document which merges ALL of the Approved Documents is a small step in the right direction of improving a deeply flawed body of building legislation.

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Competent Building Design / Ethical Building Design … Lies Beyond Codes !!

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#FireSafety4ALL #NobodyLeftBehind #NeverStayPut #VulnerablePeople #SustainableFireEngineering #SFE #GrenfellTowerFire #GrenfellTowerInquiry #ShoddyTechnicalEvidence #FireEvacuationStaircase #EthicalDesign #BeyondCodes #PeopleWithActivityLimitations #PwAL #WHO #ICF #PeopleWithDisabilities #PwD #Accessibility4ALL #InclusiveAccessibility #FUBAR

U.S. Implementation of NIST’s 9-11 WTC Recommendations ?!?!

2016-05-05:  A Mickey Mouse Effort would be a polite way of describing the long drawn-out and tortuous process of implementing NIST’s Recommendations in the United States.  A better description might be … FUBAR !

15 Years After the 2001 WTC 9-11 Attacks in New York City … absolutely nothing has been done concerning the implementation of a significant number of Recommendations … other Recommendations have been only partially implemented, with many being limited to application in buildings over 128m high (420 feet in ye olde silly imperial units of measure), or else buildings over 22.86m high (75 feet) which have an occupant load exceeding 5,000 people or are essential facilities, e.g. hospitals.  And believe it or not, some implementing measures are still being challenged and they may yet be reversed in the years ahead.  Forget about discussing the already narrow Fire Safety Objectives in building codes/regulations, or Protecting Society, etc., etc.  In essence, it has all come down to that ‘durty’ four letter word: COST !

But read this 2011 Status Report for yourselves.  I have kept in touch with the current situation over there.

NIST’s WTC 9-11 Recommendations Status Report (2011-08-08) – PDF File, 330 Kb

Why should this matter ?

In 2005 & 2008, the U.S. National Institute of Standards & Technology issued a series of very important [ critical ] Recommendations on badly needed revisions to the Design – Construction – Management – Firefighting Procedures for Very High/Tall Buildings, High-Risk Buildings, Iconic Buildings, and Innovatively Designed Buildings.  Many, if not all, of these Recommendations were, and remain, just as valid and just as necessary in the case of other building types … whatever their height.

A lot of effort was expended here, a few years ago, on a detailed examination of the NIST Recommendations.  In one respect, the Recommendations have become dated and obsolete.  The recent 2016 Brussels and 2015 Paris Hive Attacks have altered how we must categorize and deal with buildings of ‘high-risk’.  From the start, however, the disability-related Recommendations only concerned mobility impaired building occupants … a serious flaw.

NIST does not have the legal authority to implement its own Recommendations within the United States.  However, implementation by the Model Code (e.g. IBC & NFPA) Organizations has been brutally slow and entirely inadequate.

And … it is very noticeable how so many other countries around the world are continuing  to completely ignore NIST’s Recommendations.  9-11 never happened !

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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 !)

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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