Government

Ireland’s Draft National Radon Control Strategy – A Fraud !!

2013-02-28:  Submissions on Ireland’s Draft National Radon Control Strategy must arrive at the Department of the Environment, Community & Local Government, our national authority having jurisdiction … by e-mail or hand delivery to either the Custom House in Dublin or the DECLG Offices in Wexford … no later than 17:30 hrs tomorrow, Friday 1 March 2013

DECLG - Draft National Radon Control Strategy Title Page (January 2013)

Ireland’s Draft National Radon Control Strategy – January 2013 Consultation

Click the Link above to read/download PDF File (425 Kb)

The Aim of this Draft Strategy, as stated on the DECLG WebSite, is to ensure that exposure to Radon Gas, which presents a significant public health problem, is addressed in an effective and co-ordinated way across all relevant public authorities through appropriate interventions.  The Draft Strategy was developed by an Inter-Agency Group comprising representatives from relevant public authorities.

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After all of the progress made on radon protection in buildings at the end of the 1990’s and beginning of the 2000’s, it is extremely disappointing to read this miserable excuse for a strategy document.  If the general public in Ireland is under any impression that the ‘powers-that-be’ are deeply concerned about protecting our health … they are making a fatal mistake !

The complete absence of any reference to a Recommended Health-Related Radon Target Level – Safety-Related National Reference Levels which are not clearly explained will result in some injury and harm – Lack of Meaningful Consultation with, and Informed Consent of, the National Population – Horrendously Inadequate Technical Control Procedures on Irish Building Sites – RPII Recommended Indoor Radon Activity Measuring Devices having Very High Measurement Uncertainty (±30% under typical conditions of use) – A Purposeful Lack of Detailed Guidance on Exactly When and How to Measure Indoor Radon – Inadequate RPII Radon Measurement Test Reporting … are just some of the tell-tale signs for a seasoned observer.

In this regard, therefore … and let me be very clear and simple in my use of language … this Draft National Radon Control Strategy is a blatant fraud !!

Fraud:  Deliberate deception, trickery, or cheating intended to gain an advantage – An act or instance of such deception (from Latin Fraus (f): deceit, deception).

Furthermore … the Inter-Agency Group which produced this Draft National Radon Control Strategy for the DECLG Minister, Mr. Phil Hogan T.D., and Senior Civil Servants within the Department … whoever the Group’s participants are, wherever they are … should be thoroughly ashamed of themselves for being associated with this negligent act !

Negligent:  Lacking attention, care or concern.

Negligence:  A wrong whereby a person(s) is in breach of a legal duty of care, resulting in harm or injury to another person(s) … in this case, the Irish Public.

To see a complete overview on this Serious Building-Related Human Health Issue, and for information about a Far Better and More Coherent Approach to Radon Protection in Buildings which takes proper account of European Union (E.U.) legislation, e.g. the Precautionary Principle … please refer to SDI’s Corporate WebSite

NORM, Radon Gas, Radon Activity & Protection from Radon in Buildings

(It is not my intention to reproduce, here, all of the content on this WebPage as part of the Submission.)

I am also the Technical Consultant who drafted these 2 Benchmark Irish Agrément Board (IAB) Certificates for Radon Protection Measures in Buildings …

Monarflex Radon Resisting Membranes – IAB Certificate No. 98/0075

and

Radon Control Systems: Easi-Sump & Easi-Sump Cap-Link – IAB Certificate No. 01/0130

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SDI’s Comments on Ireland’s Draft National Radon Control Strategy (NRCS)

1.   Protecting Human Health versus Reducing Risk to Safety

The following two short extracts from 1. Introduction and Background in the Draft NRCS reveal the true intent of the Inter-Agency Group …

‘ Radon gas is the greatest source of exposure to ionising radiation for the general public and is the second greatest cause of lung cancer in Ireland.  Recognising the serious health risk presented by radon, the Minister for the Environment, Community and Local Government in November 2011 established an inter-agency group to develop a National Radon Control Strategy (NRCS).’

and …

‘ During 2012 the inter-agency group developed a draft NRCS based on wide stakeholder consultation and a health economics evaluation of different radon intervention strategies.  The stakeholder consultation involved a range of individuals and bodies involved in: health care, construction, radon services, Government and academia.  The health economics evaluation was undertaken by the Radiological Protection Institute of Ireland (RPII) and Health Service Executive (HSE) with the assistance of the Health Economics Unit at the University of Oxford.  This draft strategy sets out a range of measures to reduce the risk from radon to people living in Ireland.’

Radon is a serious human health issue, and it is explained in a later section of the document 1.2 The Radon Problem in Ireland that ‘indoor radon is linked to between 150 to 200 lung cancer deaths each year in Ireland, which equates to approximately 13% of all lung cancer deaths.’

However … after the references above to ‘health economics evaluation’ (!) … to the ‘prevailing  economic situation’ (!!) in section 1.1 Public Consultation … and to ‘health economics tools’ (!!!) in section 2. Draft National Radon Control Strategy … etc … you should then sensitize yourself to the subtle change in language very early in the document … from a consideration of health protection, to reducing the risk from radon (or similar variations on that theme).

The concept of Protecting Human Health is altogether different from the concept of Assessing and Mitigating / Reducing Risk to Safety !   Please refer to SDI’s Corporate WebSite.

As far back as the end of the 1990’s … the Irish Agrément Board, which at the time included a representative from the Department of the Environment, accepted the following …

Radon Activity in Buildings – Recommended Target Health Level

Radon Activity (incl. Rn-222, Rn-220, RnD) should, on average, fall within the range of 10-40 Bq/m3, but should at no time exceed 60 Bq/m3.

This Recommended Target Health Level for Radon now also appears in International Standard ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’, which was published in December 2011.  Please refer to Annex B.8 – Indoor Air Quality (IAQ) in the ISO Standard.

The Draft NRCS must refer to such a Recommended Target Health Level … and it must be stated that it is National Policy to progressively reach that target by 2025 (bearing in mind the ‘prevailing economic situation’ in the country !).

Note:  In contrast to the above … 200 Bq/m3 for Residential Buildings, and 400 Bq/m3 for Workplaces … are NOT Health-Related Target Levels … they are Safety-Related National Radon Reference Levels which result in some measure of harm and injury to people … particularly children under the age of 10 years, and people with activity limitations who constantly remain indoors for prolonged periods of time.

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2.   National Policy Priority:  ‘Real’ Protection from Radon in ‘Real’ Irish Buildings

Yes … in Ireland, we have enormous problems with regard to a lack of awareness among the general population about the serious health hazard posed by indoor radon … and the absence of proper education and training for everyone directly involved in the design, construction, management, operation, servicing or maintenance of our building stock (both new and existing).

BUT … if we are committed to providing ‘real’ radon protection in ‘real’ Irish buildings, then a practical construction-oriented approach is demanded.

This is a Key Paragraph in 2.1 Radon Prevention in New Buildings

‘ The stakeholder engagement also points to some practical difficulties associated with the implementation of the current technical guidance on radon prevention.  These difficulties relate to the correct installation of radon barriers under site conditions, protection of the integrity of radon barriers once installed and identification of radon preventive measures on site.  The stakeholder engagement also indicated the system of building control in place prior to 2012 did not provide adequate assurance that radon preventive measures had been correctly installed ‘

… which we later discover is a masterstroke of understatement and evasion, because none of these important issues are tackled head on in the document.

On the critical issue of Building Control … there is no mention of mandatory inspections of construction projects by competent Local Authority personnel.  Because … it remains the unwritten policy of Ministers and Senior Civil Servants in Ireland’s Department of the Environment, Community & Local Government (DECLG) that Local Authority Building Control Sections will be entirely ineffective.

On the other hand … will Competent Private Independent Technical Controllers be facilitated in carrying out sufficient inspections of all radon protection related works before ‘signing off’ on proper completion ???

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3.   Regulatory Status of RPII’s Radon Prediction Maps

This is NOT a problem unique to Ireland.

The presence of the RPII Radon Prediction Maps in Technical Guidance Document C (Building Regulations), and the status they are given there … are both entirely inappropriate.

While these Maps are a useful design aid, in the case of small construction projects, they offer NO assurance of certainty to either building designers or users.  They are NOT reliable !   And the average values shown in any particular ‘box’ may actually conceal a considerable degree of variability in the radon concentrations found in completed buildings.

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4.   SDI’s Acceptance of RPII Services

Please refer to SDI’s Corporate WebSite.

Unfortunately, until the Radiological Protection Institute of Ireland (RPII) includes proper statements of Measurement Uncertainty in its Test Reports (this is a requirement of European Standard EN ISO/IEC 17025)  … our Organization:

  • cannot recommend any RPII Radon Testing Services to 3rd Parties ;

and

  • will not accept any RPII Test Reports as proper evidence of Radon Test results.

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C. J. Walsh – Consultant Architect, Fire Engineer & Technical Controller – Managing Director, Sustainable Design International Ltd. – Ireland, Italy & Turkey.

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New Legal & Normative Environment for Accessibility in Europe

2012-11-27:  On Friday last, 23 November 2012, I had the great pleasure of being invited to attend the 2012 IIEA/TEPSA Irish EU Presidency Conference, which was held in Dublin Castle, Ireland.  The Programme was interesting and diverse … but lacked a vital element …

  • Session 1 – Priorities of the Irish EU Presidency ;
  • Session 2 – Economic Governance & Economic Monetary Union ;
  • Session 3 – Innovation & the Digital/Energy Interface ;
  • Session 4 – The European Union in the World.

[ IIEA – Institute of International & European Affairs ] + [ TEPSA – Trans-European Policy Studies Association ]

Colour photograph showing Tánaiste Eamon Gilmore delivering a Keynote Address, from the podium, at the 2012 Dublin IIEA/TEPSA Irish EU Presidency Conference. In the Chair - looking very pensive - is Mr. Dáithí O'Ceallaigh, Director General of the IIEA. Photograph taken by CJ Walsh. 2012-11-23. Click to enlarge.

Colour photograph showing Tánaiste Eamon Gilmore delivering a Keynote Address, from the podium, at the 2012 Dublin IIEA/TEPSA Irish EU Presidency Conference. In the Chair – looking very pensive – is Mr. Dáithí O’Ceallaigh, Director General of the IIEA. Photograph taken by CJ Walsh. 2012-11-23. Click to enlarge.

Although the serious problem of Youth Unemployment in Europe was discussed (from an economic perspective), and the Ageing Society received a passing mention … there was hardly any consideration of EU Citizenship and the many other Soft Social Issues … with, surprise-surprise, no reference at all to the Weak and Vulnerable Groups of People in all of our countries.

Furthermore … I don’t know whether they were invited to the Dublin EU Presidency Conference … and if they were, whether they couldn’t attend … but I did not notice a significant presence of representatives from Irish Disability Organizations at this important event.

Conference Delegates needed to hear that the European Union is for All of its People … not just its Citizens !   That distinction is critical.

Colour photograph showing Delegates at the 2012 IIEA/TEPSA Irish EU Presidency Conference in Dublin - described by one journalist as "a heavyweight audience of policymakers and 'leading thinkers' " - chatting over morning coffee and tea. Notice the lethal-looking metal handrail extensions in the foreground. Photograph taken by CJ Walsh. 2012-11-23. Click to enlarge.

Colour photograph showing Delegates at the 2012 IIEA/TEPSA Irish EU Presidency Conference in Dublin – described by one journalist as “a heavyweight audience of policymakers and ‘leading thinkers’ ” – chatting over morning coffee and tea. Notice the lethal-looking metal handrail extensions in the foreground. Photograph taken by CJ Walsh. 2012-11-23. Click to enlarge.

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Which sets the scene, in an odd way, for the following e-mail message I recently sent through the EUropean Concept for Accessibility Network (EuCAN) … a network of European Accessibility Experts, co-ordinated from Luxembourg by Mr. Silvio Sagramola …

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To EuCAN Network Members:

Silvio,

With some concern, I have been following the discussion about Access Officers.

Allow me to explain.

Once upon a time … at a meeting of the EuCAN Management Team in Luxembourg … there was an intense discussion about ‘Accessibility & Human Rights’.  Now that the U.N. Convention on the Rights of Persons with Disabilities has been adopted, entered into force, and been ratified by the European Union and many, though not all, of the EU Member States … I hope that this issue has finally been resolved.

Therefore … the immediate, Pan-European Accessibility Agenda can be found in Articles 9, 11 and 19 of the Convention … all within the context of Preamble Paragraph (g).

BUT … is any organization yet working with this Agenda … and, most importantly, implementing it properly ?

AND … let us not forget that Independent Mechanisms to Monitor Implementation are an essential component of the same Agenda (Article 33.2) … at European, national, and sub-national levels, right down to individual public and private organizations !

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Accessibility has been clearly specified in the new International Standard ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’ as including … ‘access to buildings, circulation within buildings and their use, egress from buildings in the normal course of events, and evacuation in the event of an emergency‘.

The flawed framework, founded on the term ‘Access’ alone, is now obsolete.  And, therefore, the Access Officer is no more.  Let us all finally agree that the responsible individual, whether he or she, is an Accessibility Officer !

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If the EuCAN Network is to have a useful and constructive future, this is the New Legal & Normative Environment which it must confront, carefully examine … and, in support of which, it should produce design guidance, decision-making computer software tools, etc., etc … for the practical purpose of ‘real’ implementation.

AND … any proposed EuCAN Programme of Action (2013-2015) should also include a review and updating of past publications.

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Some Points To Note:

1.     Although the European Union ratified the U.N. CRPD on 23 December 2010 … European Commissioner Viviane Reding (Justice, Fundamental Rights & Citizenship) stated at a Dublin Meeting, in answer to my direct question, that some Member States are offering stiff resistance to integration of the Convention into the EU System.  Why isn’t the European Disability Forum on top of this ?   But also … the European Union has not yet either signed, or ratified, the Convention’s Optional Protocol.

2.     At the time of writing … Finland, Ireland, the Netherlands, and Norway (EEA) … have still not ratified the Convention.  Why not ?   Where is the outcry from disability organizations in those countries ??

In Ireland, unfortunately, national decision-makers would rather commit ritual suicide outside government buildings than acknowledge an individual citizen’s human rights.  And, if Ireland ever does ratify the Convention, proper implementation will be very problematic.

Am I exaggerating ?   Not at all … just look at how Ireland has implemented the U.N. Convention on the Rights of the Child, which it ratified back in September 1992.

3.     In EU Member States that have ratified the U.N. CRPD … the Convention is not always being implemented properly.

Towards the end of the following Blog Post … https://cjwalsh.ie/2011/10/public-procurement-design-for-all-its-crunch-time-folks/ … I have discussed the Concluding Observations on the Initial Report of Spain (September 2011 Session of the U.N. Committee on the Rights of Persons with Disabilities).

4.     Preamble Paragraph (g) of the U.N. CRPD is even more important, now, for this reason … the United Nations has started to develop the Post-2015 Sustainable Development Goals.  It is essential to fully integrate Ability/Disability Issues into this process.  Making a submission to the U.N. could be an interesting task for EuCAN.

5.     The Fire Safety Texts contained in ISO 21542 are essentially just a bare minimum … and they are mostly in the form of recommendations (‘should’), not requirements (‘shall’).  There is a great need to add extra detail to those texts … and to convert them into requirements.  Making a series of submissions to the International Standards Organization (ISO) should be a task for EuCAN.

Regards.

C.J. Walsh, Sustainable Design International Ltd. – Ireland, Italy & Turkey.

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EUropean Concept for Accessibility (EuCAN) – Extract from 2001 Mission Statement

The fundamental basis of a European philosophy for accessibility is the recognition, acceptance and fostering – at all levels in society – of the rights of all human beings, including people with activity limitations … in an ensured context of high human health, safety, comfort and environmental protection.  Accessibility for All is an essential attribute of a ‘person-centred’, sustainable built environment.

An Effectively Accessible Europe for All

Now that a Comprehensive Legal and Normative Environment for Accessibility has finally been created in Europe … there is a vital need for EuCAN for serve … and a vital role for EuCAN to play.

However … Concerted Action must be directed at Implementation … Effective Implementation … ‘real’ accessibility which works.

Enough talk – Enough tokenism !!

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2012 Review of Part B & TGD B – Irish Building Regulations

2012-03-02:  Please bear with me while I update you at the start of this post … rather than at the end, which would be more usual here … and logical.

[ In Ireland … a related problem, which continues to fester and cause a great nuisance in an everyday work environment … concerns the lack of proper, i.e. formal, recognition of electronic communications, and information in an electronic format, by public and private organizations … in spite of the following very clear legal text …

2000 Electronic Commerce Act (No. 27 of 2000)

Section 9 – Electronic Form not to Affect Legal Validity or Enforceability

Information (including information incorporated by reference) shall not be denied legal effect, validity or enforceability solely on the grounds that it is wholly or partly in electronic form, whether as an electronic communication or otherwise. ]

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Yesterday afternoon (1 March 2012), we received the following e-mail communication from the Department of Environment, Community & Local Government (DECLG)

Folks,

Could you please send me your submissions in either Microsoft Word or Excel as it it easier to copy and paste into the format that is required , it is proving rather difficult to copy from a PDF document.

Thank You

Claire Darragh, Architecture / Building Standards, DECLG.

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I immediately replied …

Dear Claire,

Further to your informal e-mail message, which we received just a short while ago …

Please note that this is not an acknowledgement that the FireOx International Submission was received by the Department … and we certainly do not wish that you copy and paste anything relating to its contents anywhere else.

IF this is a Proper Public Consultation Process … you must adapt internal DECLG systems to suit the Submissions !   We will be communicating with the Minister’s Office concerning this issue.

Once again, I would ask you to properly acknowledge receipt of our Submission, dated 2012-02-14.

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In connection with the original FireOx International Submission … I would also like to take this opportunity to advise you that:

  • Due to an error in ISO (International Standards Organization) … the publication of ISO 21542: ‘Building Construction – Accessibility and Usability of the Built Environment’, on 12 December 2011, was not notified to people directly involved in its development and drafting, or to the participating national standards organizations ; 

and

  • In order to avoid the wide confusion which the term ‘Fire-Induced Progressive Collapse’ is continuing to cause at international level … the preferred term is now Fire-Induced Progressive Damage.

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I have amended our Submission accordingly.

Kind regards.

C. J. Walsh, FireOx International – Ireland, Italy & Turkey.

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2012-02-18:  The following is the text of  FireOx International’s Submission, dated 14 February 2012, to the Department of the Environment, Community & Local Government (DECLG) in Dublin … concerning the current review of the Irish Building Regulations Part B & TGD B … including, for good measure, some initial and very pertinent comments on the Irish Building Control Regulations.

None of these comments will come as any surprise to regular visitors here.

It should also be noted that the same comments are just as relevant in the case of the British (England & Wales) Building Regulations, Part B and Approved Document (AD) B !

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Ms. Claire Darragh, Architecture & Building Standards Section, DECLG.

Dear Claire,

Thank you for this opportunity to advise the Department on some urgent and necessary improvements to Part B: ‘Fire Safety’ of the 2nd Schedule to the Building Regulations in Ireland … and its supporting Technical Guidance Document (TGD) B.

1.  Some Initial Comments

  • The continuing debacle of the Priory Hall Apartment Complex, in Donaghmede Dublin 13, is just the tip of a very large iceberg in Ireland.  Yet, when we now hear that there will be a ‘risk-based’ approach to Septic Tank Inspections, instead of an approach which involves inspecting all septic tanks … independently, competently and thoroughly … it is clear that the Minister, and senior officials in his Department, have failed to learn any lessons from ‘Priory Hall’.

What was happening on Irish construction sites during the Celtic Tiger boom years … has been happening for twenty years all over the country … more precisely, since the introduction of legal national building regulations in 1991, with NO effective building control … and, before that again, in those parts of the country 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 projects … and, depending on the type of project, occasional or frequent inspections above ground level.

Over the years, local authority officials who carried out building bye-law inspections accumulated a considerable wealth of knowledge and understanding about local construction conditions and practices.  This valuable resource, widely used by the construction industry at the time, has now been diluted and discarded.

PLEASE LEARN THE LESSONS FROM ‘PRIORY HALL’ !!

In connection with ALL Applications for Fire Safety Certificates (Part B) and Disability Access Certificates (Part M) … competent and thorough inspections must, from now on, be carried out by local authority personnel to confirm proper implementation of Part B & M, respectively, of the 2nd Schedule to the Building Regulations.

Furthermore … while on site, local authority personnel must not be discouraged, or restricted, from dealing with any other Parts of the 2nd Schedule to the Building Regulations.  Under the present dysfunctional system, important horizontal linkages between different Parts of the 2nd Schedule are being widely disregarded and ignored, e.g. between Parts B & D, between Parts B & M, and between Parts B & A … or between Parts M & D, etc., etc !

  • European Union (EU) Council Directive 89/106/EEC has been repealed … and, instead, we now have EU Regulation No 305/2011 of the European Parliament and of the Council, of 9 March 2011, laying down Harmonised Conditions for the Marketing of Construction Products.

Unlike the earlier EU Directive … this Regulation, applicable in all EU Member States, is binding in its entirety.

And although Annex I of EU Regulation 305/2011 will enter into force from 1 July 2013 … the Department should now prepare for, and slowly begin the process of, incorporating all of the Annex I Basic Requirements for Construction Works into the 2nd Schedule of the Irish Building Regulations.

SEE BELOW …

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2.  Firefighter Safety

Fully consistent with Basic Requirement for Construction Works 2(e), in Annex I of EU Regulation No. 305/2011 … Revise Part B Requirement 5 to read as follows …

B5  Firefighter Safety, and Access and Facilities for the Fire Service

A building shall be so designed and constructed that the safety of firefighters is adequately considered and, in the event of an outbreak of fire, that there is adequate provision for access for fire appliances and such other facilities as may be required to assist the fire service in the protection of life and property.

Two examples of issues which should be highlighted in a relevant revision/addition to TGD B’s Guidance Text:

  • The incorporation, in building designs, of alternative safe means of approach towards the scene of a fire by firefighters ;
  • The provision of wider staircases in buildings in order to facilitate the recovery of an injured/impaired firefighter during the course of firefighting operations.

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3.  Protection of Vulnerable Building Users from Fire

The European Union ratified the United Nations Convention on the Rights of Persons with Disabilities (CRPD) on 23 December 2010.  Ireland has not yet ratified the Convention.

However … fully consistent with Ireland’s legal obligation, under Article 4.3 of the Treaty on European Union (TEU), to co-operate fully with EU Institutions in their implementation of this UN Convention … Revise Part B Requirement 1 to read as follows …

B1  Means of Evacuation in the Event of an Outbreak of Fire

A building shall be so designed and constructed that the protection of vulnerable building users is adequately considered and, in the event of an outbreak of fire, that there are adequate and accessible means of evacuation from the building to a place of safety remote from the building, capable of being safely and effectively used.

[ Use of the word ‘escape’, in the context of emergencies, should be strongly discouraged at all times. ]

Concerning TGD B’s Guidance Text … reference to ISO 21542: ‘Building Construction – Accessibility and Usability of the Built Environment’ will be more than sufficient.

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Specifically relating to Adequate Protection of Vulnerable Building Users from Fire

NOTE WELL THAT BS 9999 (AND BS 5588:PART EIGHT)  IS (ARE)  ENTIRELY UNFIT FOR PURPOSE !!

Please carefully examine the attached PDF File – My Note for the National Standards Authority of Ireland:  ‘BS 9999:2008 & BS 8300:2009 – Impacts on Accessibility Design in Ireland & Implications for ISO Accessibility & Fire Safety Standards’ , dated June 2009.

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4.  TGD B’s Appendix A – Performance of Materials and Structures

2 Important Notes should be added to Paragraph A21 – Structural Fire Design

  • In complying with Part B, reference should also be made to Part A of the 2nd Schedule of the Building Regulations, particularly Requirement A3 – Disproportionate Collapse ;

and

  • In order to show that a Fire Protection Material/Product/System for Structural Elements properly complies with Part D … it is also necessary, besides showing that it has been adequately fire tested, to show that the material/product/system is durable over a specified, reasonably long life cycle … and that it can adequately resist mechanical damage during construction of the building and, in the event of an outbreak of fire, during the course of that fire incident.

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Specifically relating to Steel Structural Performance in Fire

You should be aware that Table A1 and Table A2 are only appropriate for use by designers in the case of single, isolated steel structural elements.

In steel structural frame systems, no consideration is given in the Tables to adequate fire protection of connections … or limiting the thermal expansion (and other types of distortion) in fire of steel structural elements … in order to reduce the adverse effects of one steel element’s behaviour on the rest of the frame and/or adjoining non-loadbearing fire resisting elements of construction.

In the case of steel structural frame systems, therefore, the minimum fire protection to be afforded to ALL steel structural elements, including connections, should be 2 Hours.  Connections should also be designed and constructed to be sufficiently robust during the course of a fire incident.  This one small revision will contribute greatly towards preventing Fire-Induced Progressive Damage in buildings … a related, but different, structural concept to Disproportionate Damage …

Disproportionate Damage

The failure of a building’s structural system  (i) remote from the scene of an isolated overloading action;  and (ii) to an extent which is not in reasonable proportion to that action.

Fire-Induced Progressive Damage

The sequential growth and intensification of structural distortion and displacement, beyond fire engineering design parameters, and the eventual failure of elements of construction in a building – during a fire and the ‘cooling phase’ afterwards – which, if unchecked, will result in disproportionate damage, and may lead to total building collapse.

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With regard to the above … please carefully examine these 2 Series of Posts on FireOx International’s Technical Blog ( www.cjwalsh.ie ), beginning on the dates indicated …

  • 2011-10-25:  NIST’s (2005) Recommendations on the 9-11 WTC Building Collapses … GROUP 1. Increased Structural Integrity – Recommendations 1, 2 & 3 (out of 30) ;

and

  • 2012-01-18:  Progressive Collapse of WTC 7 – 2008 NIST Recommendations – Part 1 of 2 … GROUP 1. Increased Structural Integrity – Recommendation A … and GROUP 2. Enhanced Fire Endurance of Structures – Recommendations B, C, D & E (out of 13).

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5.  TGD B’s Appendix F – Reference Standards

Add this Important New Standard …

  • ISO 21542 : 2011     Building Construction – Accessibility and Usability of the Built Environment

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6.  TGD B’s Appendix G – Reference Publications

Add these Two Important Publications …

  • NIST (National Institute of Standards and Technology).  September 2005.  Federal Building and Fire Safety Investigation of the World Trade Center Disaster: Final Report on the Collapse of the World Trade Center Towers.  NIST NCSTAR 1.  Gaithersburg, MD, USA.

and

  • NIST (National Institute of Standards and Technology).  August 2008.  Federal Building and Fire Safety Investigation of the World Trade Center Disaster: Final Report on the Collapse of World Trade Center Building 7.  NIST NCSTAR 1A.  Gaithersburg, MD, USA.

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Should you wish to receive further information on any of my comments … please consult FireOx International’s Technical Blog at  www.cjwalsh.ie … or contact me directly.

Please acknowledge receipt of this e-mail communication.

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Kind regards.

C. J. Walsh, FireOx International – Ireland, Italy & Turkey.

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Carbon Monoxide (CO) Protection in Building Habitable Spaces

2011-01-13:  Carbon Monoxide (CO) is an odourless, colourless and toxic gas.  Because it is impossible to see, taste or smell the toxic fumes, CO can kill you before you are aware it is in your home.  At lower levels of exposure, CO causes mild harmful effects which are often mistaken for the flu (influenza).  These symptoms include headaches, dizziness, disorientation, nausea and fatigue.  The effects of CO Exposure can vary greatly from person to person depending on age, overall health and the concentration and length of exposure.  Source: Environmental Protection Agency (EPA), USA.

Recent tragic deaths from CO Poisoning have occurred in Ireland … not only in the home, but also in a hotel.

Sources of Carbon Monoxide (CO) … unvented kerosene and gas space heaters; leaking chimneys and furnaces; back-drafting from furnaces, gas water heaters, wood stoves, and fireplaces; gas stoves; generators and other gasoline powered equipment; automobile exhaust from attached garages; and tobacco smoke.  Incomplete oxidation during combustion in gas ranges and unvented gas or kerosene heaters may cause high concentrations of CO in indoor air.  Worn or poorly adjusted and maintained combustion devices (e.g., boilers, furnaces) can be significant sources, or if the flue is improperly sized, blocked, disconnected, or is leaking.  Car, truck, or bus exhaust from attached garages, nearby roads, or parking areas can also be a source.  Source: EPA, USA.

 

If there is a fuel burning / heat-producing appliance in any habitable space, in any building … and if you have not done so already … you must do something NOW to check that you are protected effectively from CO Poisoning.  Shift your ass !

In order to improve energy conservation and efficiency in buildings … direct, natural ventilation from the exterior is still being actively discouraged … and buildings are becoming more tightly sealed, during construction or major refurbishment, to prevent unintended air seepage.  Generally, this has been causing a serious increase in Building Related Ill-Health (also known as ‘Sick Building Syndrome’) … much of which is still going un-reported.

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BRIEF CHECKLIST – IMMEDIATE ATTENTION

1.  Check that there is sufficient, clear, direct natural ventilation in any habitable space which contains a fuel burning / heat-producing appliance.  Next … Check that the terminal unit / outlet of the flue coming from that appliance is not blocked.  Then … Check the route of any flue from the appliance.  If, for example, a flue passes through another habitable space … that space must also be properly ventilated.

2.  Check that all fuel burning / heat-producing appliances are ‘fit for their intended use’ (this must be shown !), are working properly … and that they are regularly serviced by people who are competent to do so.  Paperwork is not a reliable indicator of competence !   Remember the problems with FÁS !?!

3.  Do not confuse Carbon Monoxide Detectors with Smoke Detectors !   Only install a dedicated Carbon Monoxide (CO) Detector for the task of detecting Carbon Monoxide.  And … that Detector must be shown to be ‘fit for its intended use’.  Read the writing on the outside of the box carefully … and then read all of the instructions inside the box !

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With regard to the issue of Carbon Monoxide (CO) Poisoning in Ireland … Statistics Gathering is not reliable.  National Legislation concerning the installation of Carbon Monoxide Detectors in buildings should have been introduced many years ago … but this has not yet happened.  Furthermore … don’t hold your breath waiting for this much-needed legislation.  Based on past performance, technical and administrative officials in our relevant authority having jurisdiction, i.e. the Department of Environment, Heritage & Local Government (DEHLG), will prefer to wait before acting until similar legislation is introduced in Britain (England & Wales).

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I will just describe what I have done in my own house … in the kitchen …

[Smoke Detectors are separately linked into a monitored security and fire warning system.]

In every room where a fuel burning / heat-producing appliance is located … a Carbon Monoxide (CO) Detector is installed.  In the kitchen, for example, the Detector is fixed on the wall … at about head height, when sitting down at a table (appropriate for the normal pattern of use there) … and at a distance of approximately 2 metres from the natural gas kitchen range.  Control of direct, natural ventilation to the appliance is active … meaning, it always receives attention.  The usual kitchen clutter, e.g. clothes ‘waiting’ for ironing, etc., is never allowed to cover or block the Detector.  Everybody in the house understands the purpose of this product.

Colour photograph showing a battery-operated Ei Electronics Carbon Monoxide (CO) Detector, Model Ei206D, fixed (tamper proof) to the kitchen wall. Two of the hanging decorative plates are from France and Turkey. As for the third plate ... does anyone remember the Willow Pattern ? Photograph taken by CJ Walsh. 2011-01-12. Click to enlarge.

Colour photograph showing a battery-operated Ei Electronics Carbon Monoxide (CO) Detector, Model Ei206D, fixed (tamper proof) to the kitchen wall. Two of the hanging decorative plates are from France and Turkey. As for the third plate ... does anyone remember the Willow Pattern ? Photograph taken by CJ Walsh. 2011-01-12. Click to enlarge.

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About the performance of the Carbon Monoxide (CO) Detector in the event of a ‘real’ CO Leakage … I am comfortably assured, as I have known the EI Company in Shannon since the mid-1980’s.  At that time, I was the first architect in Ireland to install smoke detectors in any local authority housing scheme … and EI gave great technical back up and support, for which I am still very grateful.  I might add that those same smoke detectors were installed against the wishes of the local fire department.  A report on the whole test installation process was later presented, by Dr. M. Byrne, Engineering Manager of EI, to an International Fire Conference in Dublin.

The particular Carbon Monoxide (CO) Detector shown in the photograph above is a battery-operated Model Ei206D.  There are no heavy, smoke sealed fire-resisting doorsets in the house … so the sound level of the distinct alarm / warning signal [85 dB(A) minimum at 3 metres] is more than adequate.  A few years ago, this was an expensive item to buy !   Now, however, CO Detectors are widely available … and at a more reasonable price.

Very Importantly … Ei Electronics have also developed a range of products – Solutions for All – which are suitable for use by People with Activity Limitationshttp://www.eielectronics.com/ei-electronics/special-needs

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Harmful Health Effects Associated with Carbon Monoxide (CO) Inhalation … at low concentrations: fatigue in healthy people and chest pain in people with heart disease.  At higher concentrations: impaired vision and co-ordination; headaches; dizziness; confusion; nausea.  Can cause flu-like symptoms which clear up after leaving home.  Fatal at very high concentrations.  Acute effects are due to the formation of Carboxyhaemoglobin (COHb) in the blood, which inhibits oxygen intake.  At moderate concentrations: angina, impaired vision, and reduced brain function may result.  At higher concentrations: CO Exposure can be fatal.  Source: EPA, USA.

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Health Service Executive (Ireland) Factsheet

January 2011

Carbon Monoxide (CO) Poisoning – A Guide for GP’s & Other Medical Professionals

Click the Link Above to read and/or download PDF File (375kb)

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No Budgetary Control at FÁS – What About Technical Controls ?

2009-09-12:  Headlines in Ireland’s News Media, very recently, have concerned a lack of proper budgetary control … make that ‘any’ budgetary control … in FÁS (Foras Áiseanna Saothair) – the Irish Training & Employment Authority.

FÁS operates under the aegis of the Department of Enterprise, Trade and Employment and has functions in relation to the training of people with disabilities and the unemployed, the up-skilling of the employed and the administration of apprenticeships.

Special Report No.66 (dated 12th June 2009), from the Office of the Comptroller & Auditor General in Ireland, examined:

  • advertising and promotional expenditure by FÁS in the period 2002-2008 ;
  • budgetary control over FÁS’s advertising and promotional expenditure ;
  • general strategy under which advertising and promotional expenditure was spent in FÁS ;
  • the extent to which the effectiveness of this expenditure was evaluated ;
  • procurement of advertising and related services in FÁS.

Overall Examination Findings

Advertising, which accounted for almost half of the overall promotion expenditure by FÁS, is the largest in the non-commercial State sector.  The examination found that

  • Advertising and promotional activities lacked strategic direction insofar as a marketing and communications strategy had not been developed by FÁS despite longstanding commitments to do so.
  • There was a substantial and prolonged breakdown in budgetary control in the area of promotional expenditure in the period under review with expenditure exceeding budgets by 38%.  This lack of control was particularly evident in the area of general advertising where expenditure exceeded budgets by 66% over the seven-year period.
  • Much of the advertising was ineffective in increasing an awareness of the services provided by FÁS.
  • There was nugatory expenditure of €622,000 as a result of a series of transactions for which there was no evidence of goods or services having been provided.
  • There was also considerable non-effective expenditure including over €600,000 spent on producing TV advertisements that were not broadcast and payment of €9,200 for a car that was not delivered.
  • The rates FÁS paid for advertising were reasonably in line with industry norms.

Internal financial control was insufficient to ensure that all commitments were recorded and captured, and that procurement was conducted in accordance with public service norms and within expenditure authorisation limits.  In particular, the examination found that 

  • Commitment controls did not function when agents were used to effect transactions.  Procurement of certain goods and services by Corporate Affairs through contracted agencies meant that the Finance section only became aware of certain commitments when invoices were presented for payment.
  • FÁS was exposed to probity risks through a failure to meet public sector procurement requirements.  Exposures arose from the purchase from contracted agencies of goods and services that were not contemplated within the scope of their contracts and the potential consequences of FÁS playing a role in the selection of third parties by the agencies to provide services.
  • Expenditure authorisation limits were circumvented through the splitting of payment claims into a series of invoices.
  • There was a lack of clear accounting trails in regard to proceeds from the sale of exhibition space.

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Why has it taken so long for this Report to enter the public domain ?

And … if there was no proper/any budgetary control in FÁS … is it reasonable to surmise that there were no proper/any technical controls either ?

  • In reality … how well trained were apprentices ?   When the construction industry started to go ‘wallop’ in Ireland, and our economy then nose dived into the ground, what happened to those apprentices … and where are they now ?
  • How well trained were people with disabilities ?   Did they get a fair deal ?   What was the quality of their employment, after the FÁS training ?   Are they still employed ?
  • How good/effective were FÁS’s training courses dealing with, e.g. ‘safety on construction sites’, or ‘radon protection of buildings’, etc ?   Was it a case of jobs for the ‘boys’ ?

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Part B – Careless Disregard for Firefighter Safety ?

2009-05-15:  Firefighters have two functions:

         fighting fires ;   and

         rescuing people who are trapped in buildings, or for some reason, cannot independently evacuate a building which is on fire.

 

 

Compare for a moment, therefore, Part B5 in the Irish Building Regulations …

 

B5  Access & Facilities for the Fire Service

 

A building shall be so designed and constructed that there is adequate provision for access for fire appliances and such other facilities as may be reasonably required to assist the fire service in the protection of life and property.

 

 

… with Essential Requirement 2 of the European Union (EU) Construction Products Directive 89/106/EEC …

 

2.  Safety in Case of Fire

 

The construction works must be designed and built in such a way that in the event of an outbreak of fire:

– the load-bearing capacity of the construction can be assumed for a specific period of time ;

– the generation and spread of fire and smoke within the works are limited ;

– the spread of the fire to neighbouring construction works is limited ;

– occupants can leave the works or be rescued by other means ;

– the safety of rescue teams is taken into consideration.

 

 

Can you spot the difference ?   Go to the last indent in Essential Requirement 2.

 

There is a complete and careless disregard for Firefighter Safety in the Irish Building Regulations … it isn’t even mentioned.  And forget about any references to ‘firefighter safety’ in the guidance text of Technical Guidance Document B … there are none.

 

 

In July 2003 … the results of a U.S. Firefighter Disorientation Study, examining firefighter fatalities in the years 1979-2001, were released.  This important Study was prepared by Captain William R. Mora of the San Antonio Fire Department in Texas.

 

Firefighter Disorientation – loss of direction due to the lack of vision in a building fire – is one of the oldest, least understood and deadliest hazards of firefighting inside a building.  And according to the U.S. National Institute of Occupational Safety & Health (NIOSH) … disorientation usually precedes firefighter fatality.

 

Capt. Mora’s Study focused on 17 building fires in which disorientation played a major part in 23 firefighter fatalities.

 

In the cases studied, the typical Disorientation Sequence was as follows:

 

A fire in an enclosed building with smoke showing occurs.  The arriving fire services immediately initiate an aggressive interior attack to search for the source of the fire.  During the search, the source cannot be located and conditions deteriorate with the production of heat, smoke and prolonged zero visibility.  As firefighters perform an emergency evacuation due to deteriorating conditions, hoseline separation occurs or tangled hoselines are encountered.  Disorientation then occurs as firefighters exceed their air supply, are caught in flashovers or backdrafts, or are trapped by a collapsing floor or roof.  When a firefighter is not located quickly enough, the outcome is a fatality or serious injury.  The disorientation sequence usually unfolds in a building that does not have a sprinkler system or one that is inoperable.

 

The 17 Buildings displayed a wide range of architectural features … including differences in size, height and type of construction.  In 100% of the fire incidents, however, the buildings had an ‘enclosed’ design with very few windows or doors (necessary for prompt ventilation and emergency evacuation by firefighters) in relation to the size of the building.  They also included basements.

 

This ‘enclosed’ form was the result of Architectural Design or alteration after construction was completed.  When owners altered a building, pre-existing windows or doors were closed up using materials such as plywood sheeting or brickwork.

 

 

 

Another Issue … a Fundamental Principle of Fire Engineering Design … after the WTC 9-11 Incident in New York … is to always ensure the provision of Alternative, Safe & ‘Intuitive’ Evacuation Routes for ALL building users.

 

Fully understanding the different functions of firefighters … and giving proper consideration to their safety … why aren’t Alternative, Safe and ‘Intuitive’ Fire Attack Routes for Firefighters provided, as the norm, in buildings ?

 

 

What is ‘Intuitive and Obvious’ Design for Fire Evacuation, anyway ?

 

 

Are Architects and Fire Engineers given any education or training about …

 

         Visuo-Spatial Learning ?

         Proprioception ?

         Cognitive Psychology ?

 

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‘112’ – A Single European Emergency Phone Number ??

2009-03-16:  Wherever you are in the European Union (EU) … and whatever you are doing … there is just one phone number that you need to remember for emergency services – ‘112’.

 

Now that Bulgaria has set up its own 112 Hotline, the single EU Emergency Phone Number works in All EU Member States, without exception …

 

Check out your country … here !

 

 

When you call ‘112’, – from a land line, a public pay phone or a mobile/cell/handy phone – a local operator will either deal with your call directly, or redirect you to the emergency service you need – ambulance, police, or the fire services.

 

There is no charge for a ‘112’ Phone Call.

 

The single EU Emergency Phone Number does not replace existing national emergency phone numbers – it works alongside them.

 

Did you know that this number has been around for almost 20 years … and still only 22% of Europeans know about it ?

 

 

However, one small little problem remains … you can only call this number … that is, if you are physically capable of making a call and having a phone conversation !

 

Article 9 of the 2006 United Nations Convention on the Rights of Persons with Disabilities (text quoted in an earlier post !), which became an International Legal Instrument on 3rd May 2008, requires that the …

 

EU ‘112’ Emergency Phone Number System SHALL be ACCESSIBLE !

 

Get your fingers out Brussels !!!

 

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UPDATE 2013-04-06:   In the interim … there has been no dramatic improvement …

 

Flash EuroBarometer 368 – February 2013 – Summary Report

 

The European Emergency Number ‘112’

Click the Link above to read/download PDF File (1.4 MB)

 

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Dublin Stardust Fire Tragedy – The End ?

2009-02-05:  ‘In the early hours of the 14th February 1981, a catastrophic fire swept through the Stardust Ballroom in Artane, Dublin, killing forty eight people and causing serious injury to one hundred and twenty eight others.  The overwhelming majority of the victims were in the age group of eighteen to twenty five and came from the neighbouring areas of Artane, Kilmore and Greater Coolock.  The scale and horror of the tragedy was such that it was, and remains, the greatest disaster to have occurred in the history of the State.’

 

Paragraph 1.2, Report of the Independent Examination of the Stardust Victims Committee’s Case for a Reopened Inquiry into the Stardust Fire Disaster.

 

In the middle of January 2009, relatives of Stardust Fire Victims were forced to hold a lengthy sit-in protest at Government Buildings, in Dublin … in order to gain access to this recent Report by Mr. Paul Coffey, Senior Counsel.  See the Photograph of four forlorn relatives, by Mr. Dara Mac Dónaill, on the Front Page of The Irish Times (2009-01-15).

 

 

In Paragraph 5.15(1) of the Report (no reference number, no publication date) … Mr. Coffey recommended:

 

         that the Government should consider whether it can … place on the public record an acknowledgement of the (Stardust) Tribunal’s findings that there is no evidence that the fire was started deliberately and that its cause is unknown ;

 

Paragraph 5.15(2) continued:

 

         in the event that this cannot be done, there should be a further inquiry … ;

 

 

On Tuesday evening, 3rd February 2009, in the Dáil (Irish Parliament) … the Irish Government moved, with haste, to formally correct the public record in accordance with Mr. Coffey’s recommendation in Paragraph 5.15(1).  See the Dáil Report on the Stardust Tragedy, by Ms. Marie O’Halloran, in The Irish Times (2009-02-04).

 

Should this be the end of the matter ?   No.

 

Have the events surrounding this tragedy been well managed ?   Yes.

 

 

 

In Separate Letters, dated 4th April 2006, sent by registered post to the Editors of The Irish Times (Dublin), The Irish Independent (Dublin) and The Irish Examiner (Cork), I wrote the following …

 

Re:  Stardust Fire Re-Examination Now Due !

 

As a young architect in private practice, I saw the Dublin Fire ‘Establishment’ disappear from public view, without trace, after the 1981 Stardust Fire;  it was almost impossible, for at least a year after, to have a meeting with a Fire Prevention Officer.

 

Would it not be reasonable to expect that, in 25 years, our understanding of fire behaviour in buildings, and of the practices and procedures associated with serious fire incidents, has improved ?

 

On 26th October 2005, the NIST Final Report on the 9-11 WTC 1 & 2 Tower Collapses was presented to Congress in the United States.  Chapter 9 of that Report contains 30 important Recommendations which must radically alter professional fire engineering practice in the case of all building types, of all sizes … even in Dublin !

 

The time is now due for an Independent and Impartial Technical Re-Examination of the Stardust Fire Incident, and any relevant events which occurred during a period of time beginning 6 Months before 14th February 1981 and terminating approximately 18 Months after that day.

 

Such a Re-Examination must exclude any involvement by the Department of the Environment, Heritage and Local Government (DEHLG).

 

Signed:  C. J. Walsh, Chief Technical Officer, FireOx International.

 

 

 

A Similar Management Exercise is taking place in relation to the series of Fatal Fire Incidents at the Oldcourt Local Authority Housing Estate in Bray, County Wicklow.

 

 

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