informed consent

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

Posted by CJ Walsh

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

Posted by CJ Walsh

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 …

 

www.fireox-international.eu

 

 

 

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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