Ar C.J. Walsh – Consultant Architect, Fire Engineer & Technical Controller – International Expert on : Sustainability Implementation + Accessibility (including Fire Safety) for All + Sustainable Fire Engineering
2014-10-17: Within the professional discipline of Fire Engineering … either a building is ‘fire safe’, or it is not. The Design Philosophy of the Fire Engineer is irrelevant. In fact, nearly everybody involved with fire safety in buildings would collapse in a fit of laughter at the delusional notion that a design philosophy was relevant. People’s lives are at stake !
Similarly, now, we must begin to think and act in the simple terms of a building either being ‘accessible’, or not. At stake, this time, is the quality of life and living for very many vulnerable people in all of our societies.
Accessibility for All, according to International Standard ISO 21542 (2011) … includes the approach, entry to and use of a building, egress during normal conditions and removal from the vicinity of the building … and, most importantly, evacuation during a fire incident to a ‘place of safety’ which is remote from the building.
Concerning that All above … FireOx International’s ‘Fire Safety for All’ Matrix shows who exactly we are talking about … and who must be considered in the development of a Fire Safety Strategy for every building … not just some buildings !
This is not just good design practice … it is also mandated in International Human Rights Law.
Building Fire Safety Codes and Standards exist in almost every country. However – IF they exist at all – those guidelines relating to the Fire Safety of People with Activity Limitations are technically inadequate, entirely tokenistic and/or blatantly discriminatory.
It is time to Reboot this ridiculous, professionally negligent and obsolete old system … Reload with innovative and practical building design, construction, management and personal self-protection solutions … and Implement !
‘ For many Weak and Vulnerable People, today’s Complex Human Environment is inaccessible and unsafe … a hostile ‘reality’ which prevents independent functioning and participation in a local community; it is a blatant denial of their human rights.’
Relevant Human Environment (social – built – virtual – institutional) Factors … factors which are external, or extrinsic, to the context of a person’s life and living situation … include policies and standards, negative attitudes and stigma, lack of services, problems with service delivery, inadequate funding, lack of accessibility in the built environment and to electronic, information and communication technologies, lack of consultation and involvement, and an absence of reliable data and evidence.
Accessibility for All …
Take a really close look at the photograph below … and see a staircase which, in spite of all the legislation in the EU Member States, contravenes almost every accessibility-related design guideline. It is far from being an unusual scene in our European Built Environment …
Now, imagine the consequences of one, tiny slip …
Which is why our concern must be with Accessibility for All … which includes consciously thinking about children under the age of 5 years, women in the later stages of pregnancy, and frail older people (not all older people !) … and how they use and interact with their surroundings.
In addition, however … our attention must also turn to the large numbers of people, in all of our societies, with health conditions which result in serious impairments, activity limitations and participation restrictions. As a prime example, consider the Big-4 Non-Communicable Diseases (NCD’s): Cardiovascular Diseases (e.g. heart attacks and stroke), Cancers, Diabetes, and Chronic Lung Diseases.
These 4 NCD’s – targeted in a World Health Organization (WHO) Global NCD Campaign – share health risk factors (tobacco use, unhealthy diet, lack of physical activity, harmful alcohol use) … cause more than 36 million deaths annually (almost 80 % of deaths, from such diseases, occur in low and middle-income countries) … and result in a high proportion of disability (66.5 % of all years lived with disability in low and middle income countries).
NCD’s can limit one or more of a person’s major life and living activities … such as walking, eating, communicating, and caring-for-oneself. Examples of common NCD-related impairments include paralysis due to stroke, and amputation as a result of diabetic neuropathy.
When Easily Assimilated Signage IS Essential in Buildings …
Good Architectural Design IS ‘intuitive and obvious’ for building users … design characteristics which are critical in the case of Fire Engineering Design. However, what is intuitive and obvious in Ireland may not be so intuitive and obvious in Turkey … and what is intuitive and obvious in Europe will certainly not be intuitive and obvious in Africa, India, or China.
Architectural & Fire Engineering Design must, therefore, be adapted to Local conditions … culture, social need, etc., etc.
When a building is NOT ‘intuitive and obvious’ for the broad range of potential building users … easily assimilated signage IS essential …
International Standard ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’ was published in December 2011, as a full standard. In its Introduction, ISO 21542 is linked to the U.N. Convention on the Rights of Persons with Disabilities (CRPD) … almost like an umbilical cord.
The scope of ISO 21542 covers public buildings. The Accessibility Agenda in the U.N. Convention is very broad … so much standardization work remains to be completed at international level.
Concerning Accessibility Symbols and Signs … reference should be made to ISO 21542: Clause 41 – Graphical Symbols … and on Pages 106, 107, 108, and 109 … the following will be found:
Figure 66 – Accessible Facility or Entrance ;
Figure 67 – Sloped or Ramped Access ;
Figure 68 – Accessible Toilets (male & female) ;
Figure 69 – Accessible Toilets (female) ;
Figure 70 – Accessible Toilets (male) ;
Figure 71 – Accessible Lift / Elevator ;
Figure 72 – Accessible Emergency Exit Route.
I use the word ‘accessibility’, and not ‘access’ … because Accessibility has been defined in ISO 21542 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’.
A note at the beginning of the standard also clarifies that Accessibility is an independent activity, i.e. assistance should not be necessary … and that there should be an assurance of individual health, safety and welfare during the course of those (accessibility-related) activities.
During the very long gestation of ISO 21542, an overwhelming consensus emerged in favour of using the term Accessibility for All … thereby sidestepping the thorny issue of different design philosophies which are described as being accessibility-related but, in practice, are limited and/or no longer fit-for-purpose.
The Accessibility Symbol used throughout ISO 21542 is shown above. I know that a small group of people from different countries worked very hard on this particular part of the standard. My only contribution was in relation to the inclusion of Figure 72, concerning Fire Evacuation.
This ‘accessibility’ symbol is an attractive, modern and, of course, abstract representation of a concept … a person with an activity limitation using a wheelchair. The symbol succeeds very well in communicating that concept.
However … as an Accessibility for All Symbol … encompassing people with other than functional impairments, e.g. hearing and visual impairments … and children under the age of 5 years, women in the later stages of pregnancy, frail older people … and people with the four main types of non-communicable disease discussed above … is this symbol, also, limited and no longer fit-for-purpose ??
Shown next, above, is the proposal for a new Area of Rescue Assistance Sign … which is contained in ISO 7010:2011 / FDAM 115 (2013). While it is nice to finally see this Safety Sign appear in the mainstream of safety signage … the title being proposed for the sign and the explanatory texts which accompany it are very problematic …
The technical term being proposed – Evacuation Temporary Refuge – is too long and too difficult to understand ;
The explanatory texts which accompany this Sign are very confusing and misleading.
This problem has arisen because the people who drafted ISO 7010:2011 / FDAM 115 (2013) hadn’t a bull’s notion that ISO 21542 even existed !
In ISO 21542, we use the term Area of Rescue Assistance … which is easy for everybody to understand, including building users, building managers and firefighters, etc., etc.
We also explained, in ISO 21542, that a Place of Safety is a remote distance from the building … not anywhere inside the building !
Mainstreaming Disability …
U.N. CRPD – Preamble
(g) Emphasizing the importance of mainstreaming disability issues as an integral part of relevant strategies of sustainable development,
As ‘disability’ moves closer towards … and is integrated and fully included in the ‘mainstream’ of sustainable community life and living … it is absolutely imperative that individuals and organizations who make up the Disability Sector become much more cohesive (far less fractious within) … that they begin to fully understand the practices and procedures of the mainstream … and actively and robustly engage with that mainstream.
It is ridiculous, for example, that a large amount of the Sector’s energy is still being diverted into meaningless meditations and endless tracts on whether it is ‘universal design’, or ‘design-for-all’, or ‘inclusive design’, or ‘facilitation design’, etc … when an entirely new design paradigm is being demanded by a world (our small planet when seen from the moon !), which is experiencing enormous levels of human poverty, natural resource shortages, human rights violations, and severe weather events. The overriding priority must be ‘real’ implementation … Effective Accessibility for All !
While the wider international design community is working hard on developing an array of Accessibility Symbols to facilitate different health condition and impairment categories, and to suit different environmental situations, e.g. a fire emergency in a building … I recently encountered another interesting contribution …
2012-04-21: The context for considering and properly implementing Accessibility-for-All has changed … changed utterly … but some old problems persist, and stubbornly remain …
NEW INTERNATIONAL CONTEXT
A. At the time of writing, the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) has been ratified by 111 Countries and the European Union.
Concerning Accessibility of the Built Environment … UN CRPD Preamble Paragraph (g), and Articles 9 – 11 – 12 are the most immediately relevant. These texts can be easily found elsewhere on this BLOG … please use the ‘search’ facility at the top, right-hand corner of the WebPage.
With the innovative, and internationally accepted, understanding of ‘Accessibility’ – as distinct from ‘Access’ – contained in ISO 21542 : 2011 … the concept meaning: approach and entry to a building, circulation within and use of all the building’s facilities, egress from and removal from the building’s vicinity during normal circumstances, or evacuation in the event of an emergency and movement – via a safe and accessible route – to a place of safety which is remote from the building … it is now possible to deal with Fire Evacuation of Buildings through Article 9 (Accessibility) of the UN CRPD, where it is more in scale … more at home, so to speak … rather than through Article 11 (Situations of Risk & Humanitarian Emergencies), which had to be the case before.
B.ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’ … is the important new International Standard mentioned above. It was published in December 2011.
Ireland has no National Standard (or Code of Practice) on Accessibility. So, in the absence of an appropriate Harmonized European Standard, ISO 21542 must take precedence over the National Standards of any other European Union Member State.
Here, however, there is a very large fly in the ointment … the guidance text in the 2010 Technical Guidance Document M has been ‘lifted’, almost en masse, from a British National Standard on ‘Access’ … not ‘Accessibility’. And this flawed process has imported some serious errors into Irish Accessibility Design and Construction Practice … despite my warnings to the relevant authorities. Please refer back to this post , dated 2009-06-14.
Scope of ISO 21542 : 2011
ISO 21542:2011 specifies a range of requirements and recommendations for many of the elements of construction, assemblies, components and fittings which comprise the built environment. These requirements relate to the constructional aspects of access to buildings, to circulation within buildings, to egress from buildings in the normal course of events and evacuation in the event of an emergency. It also deals with aspects of accessibility management in buildings.
ISO 21542:2011 contains provisions with respect to features in the external environment directly concerned with access to a building or group of buildings from the edge of the relevant site boundary or between such groups of buildings within a common site. It does not deal with those elements of the external environment, such as public open spaces, whose function is self-contained and unrelated to the use of one specific building, nor does it deal with single family dwellings, other than those circulation spaces and fittings that are common to two or more such dwellings.
C. Of direct commercial interest within the European Union (and in any countries outside the EU who wish to trade with the EU and the European Economic Area) … Accessibility-Related Construction Products are now included in the framework of the (relatively) new European Union Regulation No.305/2011 of the European Parliament and of the Council, of 9 March 2011, laying down Harmonized Conditions for the Marketing of Construction Products and Repealing Council Directive 89/106/EEC. [The old EU Directive 89/106/EEC has been repealed … it is finished, it is gone, it is no more ! There will, however, be a suitable transition period from old to new.]
Construction Product (EU Reg.305/2011) means any product or kit which is produced and placed on the market for incorporation in a permanent manner in construction works or parts thereof and the performance of which has an effect on the performance of the construction works with respect to the basic requirements for construction works.
Construction Works (EU Reg.305/2011) means buildings and civil engineering works.
Basic Requirement for Construction Works No. 4 in Annex I of the new EU Regulation 305/2011, states the following …
Safety and Accessibility in Use
The construction works must be designed and built in such a way that they do not present unacceptable risks of accidents or damage in service or in operation such as slipping, falling, collision, burns, electrocution, injury from explosion and burglaries. In particular, construction works must be designed and built taking into consideration accessibility and use for disabled persons.
This is a suitable location for ‘Accessibility’ in Annex I … intimately connected to ‘Safety in Use’. However, there is one potential drawback. Specifying the level of safety in an EU Member State is the sole responsibility of the Authorities Having Jurisdiction (AHJ’s) in that Member State.
An Accessible Building is a Safer Building … but a Safe Building is not necessarily ‘Accessible’. ‘Accessibility’ is a completely different concept to ‘Safety’. EU Member States have no basis in EU Law … no justification whatever … for arbitrarily deciding on which level of ‘Accessibility’ is appropriate within their territories !
SAME OLD PROBLEMS
With all of this New International Context on Accessibility finally in place … I continue to encounter the same old problems …
1.Bad Product Design
An enormous quantity of cheap, atrociously designed … you could almost use the word ‘ugly’ … Accessibility-Related Construction Products are imported every year into Ireland, from Britain. This is one good reason, although not a very satisfactory reason, why architects hate ‘accessibility’ in buildings. Building users notice fittings and fixtures … and if the fittings and fixtures are ugly … the building is ugly ! But occupational therapists, for example, are also specifying these types of products every day of the week here.
This has got to stop. Proper attention must be paid to Good Design of Accessibility-Related Construction Products. An Accessible Building does not have to look like a Hospital Ward ! And Good Design does not have to mean ‘expensive’ !!
I have seen many well designed Accessibility-Related Construction Products, available in the EU marketplace, which have been manufactured in countries such as France, Germany, Italy, and China.
Why can we not access these products in Ireland ??
2.No Product Approval
The National Building Regulations/Codes of EU Member States … and all EU Safety at Work legislation … demand that building products and systems must be properly shown to be ‘fit for their intended use in the location of use’. End of story … very simple ! Regrettably, few people take any notice of this legal requirement.
Late last year, however, I encountered a Chinese Company which manufactured some nicely designed Accessibility-Related Construction Products. I suggested to one of their sales personnel that, in order to place their products on the market anywhere in the European Union (or the European Economic Area) … there was an urgent need to update their existing ‘CE Mark’ Product Approval Documentation. When I checked more closely, this Documentation was dubious. I then suggested that they should place a correct, up-to-date and relevant CE Mark on their construction products … as a matter of priority. And I received the following reply …
” i’d like to suggest that maybe you can pay for the cost to do this CE, and after you place orders in our factory, we promise return that back to you, and if you like, maybe you can act as our agency in Ireland, will you ? “
[ The sum of money being discussed here was €1,000.]
This proposal was off-the-wall, as we say here in Ireland. But, I found it impossible to get annoyed … because this strange and weird understanding of the CE Mark, particularly in relation to Accessibility-Related Construction Products, is rife among European Manufacturers also … and European Notified Bodies. How crazy is that ?
Perhaps my most unusual experience, back in the mid-1990’s, was having to explain to a Manager in a TÜV Laboratory, in Germany, that a Full Test Report must be issued to a Test Sponsor … after the test(s) has/have been completed. This task required two to three hours of heated discussion !
And … in the absence of any reference to ‘Accessibility’ in the now repealed EU Directive 89/106/EEC … I have encountered some European Manufacturers of Accessibility-Related Construction Products … who, being fully aware of the value of a CE Mark, have used the backdoor method of the EU Medical Devices Directive in order to obtain a CE Mark. And these were definitely not medical devices !
There is no effective control over the CE Marking of Construction Products within the European Union. This is no reason to ignore the system … or to abuse the system.
However … if many more people paid attention to the legal requirement, and necessity, of Proper Product Approval and the CE Marking of Accessibility-Related Construction Products … and the professional duty and responsibility to check that compliance/conformity is properly shown … we would have a more Accessible and much Safer Built Environment !!!
2012-03-25: No news about this momentous development, yet, on the International Design and Disability Networks … (why is that ? – are they all asleep out there ?) … but International Standard ISO 21542: ‘Building Construction – Accessibility and Usability of the Built Environment’ was finally published by the International Standards Organization (ISO) in December 2011 ! Even ISO, and national standards organizations, have been slow with an official notification.
This International Standard now provides building users, architects, designers, engineers, builders, building owners and managers, manufacturers, policy makers and legislators with the requirements and recommendations to create a Sustainable Built Environment which is Accessible.
The First Edition of ISO 21542, dated 2011-12-15, represents an agreement reached by strong consensus between different countries all over the world … an agreement patiently constructed and pieced together by a small, dedicated international group of Accessibility Experts. As one of those experts, I am tremendously relieved that this main task has been accomplished … but the process must continue … there are still errors in the document … and the fire safety texts must be expanded.
This is also an agreement which signals that uniform implementation of the main provisions (accessibility-related) in the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) can commence across the globe, not just in the developed economic regions.
The purpose of this International Standard is to define how the built environment … in particular, public buildings … should be designed, constructed and managed to enable people to approach, enter, use, egress from and evacuate a building independently, in an equitable and dignified manner and to the greatest extent possible.
A new international understanding of ‘Building Accessibility’ is hereby established … ‘Access’ (approach, entry and use) can no longer be divorced from ‘Egress’ (in the normal course of events) and ‘Evacuation’ (in the event of an emergency).
The concept of ‘Access’, in isolation, and the role of the ‘Access Consultant’ are, therefore, outdated and obsolete ! And use of the word ‘Escape’, in any context, is to be firmly and rigorously discouraged !!
The intention of this International Standard is to meet the needs of the majority of people. This goal is achieved by agreement on minimum standards of accessibility and usability which are generally accepted to accommodate diversities of age and the human condition.
In future … proper emphasis must be placed on Real and Effective Implementation of Accessibility-for-All in the built environment … to meet the needs of real people in all of our communities.
In the past … too many scarce human resources have been diverted into pointless discussions and arguments about accessibility design philosophies. And, particularly in Europe, we have been far too fond of ‘talk’, instead of ‘action’ ! No more !!
ISO 21542 : 2011 applies to new and existing buildings.
IF this Standard’s requirements and recommendations are taken into consideration during the earliest stages of New Building Design … the costs of providing satisfactory accessibility and usability in a building will be minimal.
Yes, there are problems with improving the accessibility performance of Existing Buildings … just as there are problems, for example, with improving their energy performance. However … creativity, design flexibility, and an in-depth understanding of the principles of Accessibility-for-All … will ensure that the functional requirements of this Standard are properly met.
Mindful of the 1964 Venice Charter and other similar international instruments … accessibility must also be facilitated in Existing Buildings of Historical, Architectural and Cultural Importance. In such cases, it will be necessary for national authorities having jurisdiction to allow some relaxation of the requirements in this International Standard … as well as to proactively recommend appropriate alternative accessibility measures.
This new approach to Accessibility-for-All in the Built Environment … as set down in ISO 21542 … was directly informed by Preamble Paragraph (g) and Articles 9, 10 and 11 of the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD).
At the time of writing … the UN CRPD has been ratified by the European Union (EU) and 109 Other Countries.
An Important Note for Parties to the Convention which is entirely outside the scope of ISO 21542, and standardization generally … but very relevant to the implementation, for example, of Article 11 at national level in the ratifying Countries and EU Member States …
UN CRPD Article 12 – Equal Recognition Before The Law
1.States Parties reaffirm that persons with disabilities have the right to recognition everywhere as persons before the law.
2.States Parties shall recognize that persons with disabilities enjoy legal capacity on an equal basis with others in all aspects of life.
3.States Parties shall take appropriate measures to provide access by persons with disabilities to the support they may require in exercising their legal capacity.
4.States Parties shall ensure that all measures that relate to the exercise of legal capacity provide for appropriate and effective safeguards to prevent abuse in accordance with international human rights law. Such safeguards shall ensure that measures relating to the exercise of legal capacity respect the rights, will and preferences of the person, are free of conflict of interest and undue influence, are proportional and tailored to the person’s circumstances, apply for the shortest time possible and are subject to regular review by a competent, independent and impartial authority or judicial body. The safeguards shall be proportional to the degree to which such measures affect the person’s rights and interests.
5. Subject to the provisions of this article, States Parties shall take all appropriate and effective measures to ensure the equal right of persons with disabilities to own or inherit property, to control their own financial affairs and to have equal access to bank loans, mortgages and other forms of financial credit, and shall ensure that persons with disabilities are not arbitrarily deprived of their property.
ISO 21542 : 2011 is available from the International Standards Organization (ISO) at … www.iso.org/
The Official Abstract on the ISO WebSite states …
ISO 21542 : 2011 specifies a range of requirements and recommendations for many of the elements of construction, assemblies, components and fittings which comprise the built environment. These requirements relate to the constructional aspects of access to buildings, to circulation within buildings, to egress from buildings in the normal course of events and evacuation in the event of an emergency. It also deals with aspects of accessibility management in buildings.
ISO 21542 : 2011 contains provisions with respect to features in the external environment directly concerned with access to a building or group of buildings from the edge of the relevant site boundary or between such groups of buildings within a common site. It does not deal with those elements of the external environment, such as public open spaces, whose function is self-contained and unrelated to the use of one specific building, nor does it deal with single-family dwellings, other than those circulation spaces and fittings that are common to two or more such dwellings.
2009-06-14: Ireland has no national standards or codes of practice of its own covering Building Accessibility or Fire Safety in Buildings. Instead, many people and organizations in this country will just switch to automatic pilot and – without thinking or questioning – adopt the following two standards of another jurisdiction as the default Irish National Standards …
British Standard BS 9999:2008 – Code of Practice for Fire Safety in the Design, Management and Use of Buildings … was published on 31 October 2008.
British Standard BS 8300:2009 – Design of Buildings and Their Approaches to Meet the Needs of Disabled People. This Code of Practice was published on 28 February 2009.
If Ireland does not quickly open its eyes … we will be sleep walking into a very problematic legal environment, as far as building accessibility and fire safety in buildings is concerned.
1. An Immediate Challenge
A Sub-Group (established at a meeting of the NSAI Accessibility-for-All Standards Consultative Committee WG1 held on Tuesday 2009-05-19) was tasked with developing a common position, suitable for application in Ireland and compatible with European Technical Harmonization, on the following issues:
Clear Width of Internal & External Door Openings ;
Turning Circles for Occupied Wheelchairs ;
Car Parking Spaces ;
Fire Safety Issues.
A series of coherent proposals will be presented to the next NSAI AASCC WG1 Meeting, on Friday 19th June 2009 … and, given the absence of Irish National Standards, it will also be suggested how these proposals may be confirmed as best current practice here.
2. Overview of BS 8300:2009 & BS 9999:2008
During the development of the Draft ISO Accessibility-for-All Standard, it has been unanimously agreed that Accessibility encompasses the full range of activity related to buildings: to approach, enter, use, egress from and evacuate a building independently, in an equitable and dignified manner (Introduction, 2nd Paragraph, Page 5). ‘Egress’ under normal, ambient conditions is distinguished from ‘Evacuation’ in the event of a fire emergency. Use of the word ‘Escape’ is discouraged in any circumstance. For the first time, fire safety texts have been fully incorporated into the main body of the Draft ISO Standard.
Accessibility within the British Standards Institution (BSI), on the other hand, is still segregated between BS 8300:2009 – approach, entry and use and BS 9999:2008 – fire evacuation. Conflicts and gaps in content naturally result from such a configuration, which can now be seen as outdated and fundamentally flawed.
This configuration has been replicated, in Irish Building Regulations, with the separate scopes of Part M / Technical Guidance Document M and Part B / Technical Guidance Document B. Integration between these 2 Technical Guidance Documents is very poor. In practice, fire safety for people with activity limitations is widely disregarded within the process of Fire Safety Certification in Ireland.
2.1 BS 8300:2009
BSI has arrogantly gone on a solo run, and decided to deviate from some very widely accepted concepts of accessibility, e.g. ‘clear width’ of a door opening (discussed in more detail later). The ‘Ergonomic Research’ supporting door opening forces of 30 N is at complete variance with earlier research in Britain and must, therefore, be strongly questioned. Perhaps, it is the case that the Fire Services in England & Wales re-asserted their authority, supported by reference to European Fire Product Standards with little if any input from the European Disability Sector, and insisted on a ‘definite’, i.e. high, closing force being exerted on the door leaves in fire resisting doorsets.
2.2 BS 9999:2008
People with disabilities have a right, recognized in international law after 3rd May 2008, to equal opportunity and non-discrimination in matters of building fire safety, protection and evacuation. A minimum response to Article 11 (Situations of Risk) in the 2006 United Nations Convention on the Rights of Persons with Disabilities is required, therefore, from fire regulators and code writers. Such a response is absent in British Standard BS 9999:2008.
A close examination of the fire safety texts relating to ‘disability’ in BS 9999:2008 shows that they have not been properly integrated into the ‘mainstream’ content. In fact, much of the content from the replaced BS 5588:Part 8 has just been grafted onto BS 9999, with very little change or alteration from the first version of Part 8 published in 1988 !
Compare Figure G.1 on Page 360 of BS 9999:2008 … with … Figure 4 on Page 8 of BS 5588:Part 8:1988 … both are exactly the same …
Two Critical Observations in relation to the ‘area of rescue assistance’ shown above:
– This drawing in BS 9999:2008 is in direct conflict with the text located directly above it … ‘where the wheelchair space is within a protected stairway, access to the wheelchair space should not obstruct the flow of persons escaping’ ;
but, more importantly …
– In BS 9999:2008, fire safety for people with activity limitations receives treatment which is superficial and merely token. Many times in relation to buildings generally, it is stated in Annex G.1, Page 359 …
‘A refuge needs to be of sufficient size both to accommodate a wheelchair and to allow the user to manoeuvre into the wheelchair space without undue difficulty.’
‘ In most premises, it is considered reasonable to have refuges of a size where each one is able to accommodate one wheelchair user. Where it is reasonably foreseeable that the proportion of disabled users in a building will be relatively high, or where the use of the premises is likely to result in groups of wheelchair users being present (e.g. some types of sporting, entertainment, transport or public assembly buildings), consideration should be given to increasing the size and/or number of refuges accordingly.’
‘ NOTE 3 Managers of sporting or other venues where a number of disabled people might be present are advised not to restrict the number of disabled people who can be admitted to that venue on the grounds of the size of refuges, since some disabled people who use mobility aids such as a wheelchair will be able to self-evacuate in the case of a real fire.’
and again in Annex G.2.2 on Page 367 …
‘Where it is reasonably foreseeable that the refuges will be used by more than one user (e.g. some types of sporting, entertainment, transport or public assembly buildings), … ‘
Within such an inadequate and token context, it is understandable that an unduly heavy reliance is placed on the practice of developing Personal Emergency Evacuation Plans (PEEPS) for individuals with activity limitations. See Paragraph #46.7a) on Page 248, which states …
‘ By taking into account the individual needs of a person when preparing a PEEP, management will be able to make any reasonable adjustments to the premises or procedures that are necessary.’
These Plans are flawed and discriminatory because they are:
– person specific ; and
– location specific ;
… with the underlying assumption in the text being that, beyond the specified location(s), the building is not properly accessible, i.e. does not meet the functional requirements of Parts B & M in the Building Regulations for England & Wales – or, in the case of Ireland, Parts B & M of our Building Regulations.
There are silly technical errors in BS 9999:2008, e.g. in Annex G.2.3 on Page 368, it states …
‘Unless a different order has been agreed with the fire authority, evacuation should normally be in the following order:
1) the fire floor ;
2) the floor immediately above the fire floor ; [This should read ‘the floors immediately above and immediately below the fire floor’ !]
3) other floors above the fire floor starting at the top storey ;
4) all remaining floors.’
A Technical Term is used in BS 9999:2008 – Place of Ultimate Safety – which complicates the already widely accepted term: ‘Place of Safety’. The definition provided for the British Term in Section 3: Terms & Definitions (#3.84, Page 17) is so vague that it is of no practical use to fire engineering designers, building managers or building users.
3. Comments:i) Clear Width of Door Openings
Paragraph #6.4.1, on Page 36 of BS 8300:2009 introduces a new understanding of ‘clear width’ for door openings, which is illustrated in Figure 11 (Page 37) … and also a new term ‘effective clear width’.
The new understanding of ‘clear width’ is a complete departure from the standard understanding, widely accepted throughout the world, which is shown in the bottom left hand drawing of Figure 11.
The new term ‘effective clear width’ will complicate the already difficult concept of ‘clear width’. Wasn’t the ‘clear width’ of a door opening always supposed to be ‘effective’, i.e. properly permit circulation for wheelchair users ?
However, the issue raised in the top right hand drawing of Figure 11 is valid …
Solution: Retain the current international/European/national understanding of ‘clear width’ for door openings in Ireland … but include text, with supporting drawings, in Revised Technical Guidance Documents B & M to ensure that there is no encroachment on that ‘clear width’ caused by protruding door leaf ironmongery or, more importantly, where the door leaf itself cannot be fully opened to 90o-100o.
4. Comments:i) Clear Width of Door Openings in Existing Buildings
Table 2, on Page 37 of BS 8300:2009, permits the ‘clear width’ for door openings in existing buildings to be reduced significantly below 800mm.
If buildings of historical, architectural and cultural importance are properly identified, and proper allowance is made for these specific building types in Revised Technical Guidance Documents B & M … there is no need to permit a general reduction in the ‘clear width’ for door openings in existing buildings.
Solution: Clearly indicate in the Revised Technical Guidance Document M that the last ‘Existing Buildings’ Column on the right of Table 2 in BS 8300 should be disregarded.
5. Comments:ii) Turning Circles for Occupied Wheelchairs
Down through the years, it has been just possible to communicate the concept of the ‘wheelchair turning circle’ to building designers and urban planners … whether it be the older 1.5m diameter circle or the newer 1.8m diameter circle.
The new Figures and Tables in Annexes C.3 and C.4 of BS 8300:2009 will be difficult to communicate … and may be a complication too far ?
6. Comments:iv) Fire Safety Issues
The Recommendations contained in the 2005 & 2008 National Institute of Standards & Technology (USA) Reports on the WTC 9-11 Incident in New York provide an invaluable and essential empirical basis for the practice of effective fire engineering design in today’s built environment.
The first of these two reports has special relevance for NSAI AASCC WG1 because the typical problems encountered by people with activity limitations during a ‘real’ building fire incident have been highlighted by NIST and closely investigated. As a result, three important fire engineering keywords have been re-stated with strong emphasis: ‘reality’ – ‘reliability’ – ‘redundancy’. And, a new key phrase in relation to way finding during evacuation has been introduced to the everyday practice of fire engineering design: ‘intuitive and obvious’.
The 2005 NIST Report, particularly, must be given proper consideration during the development of any reputable fire safety related standard or code of practice for the following reasons:
– at the time of the ‘real’ fire incident, approximately 8% of building users were people with disabilities, with 6% having mobility impairments ; [The percentage of ‘building users with activity limitations’ exceeded the 8% quoted above.]
– NIST found that the average surviving occupant in the buildings descended stairwells at about half the slowest speed previously measured for non-emergency/test evacuations. This raises a serious question over the use of standard movement times in fire engineering design calculations for evacuation ;
– NIST strongly recommended that fire-protected and structurally hardened lifts (elevators) should be installed in buildings to facilitate the evacuation of building users with disabilities, and to improve emergency response activities by providing timely emergency access to firefighters ; [In Ireland, building designers have already adopted this approach by constructing cores of reinforced concrete … even in the absence of European/national standards.]
– it was recommended that evacuation routes should have consistent layouts, and be ‘intuitive and obvious’ for all building users, including visitors who may be unfamiliar with the building, during evacuations ;
– NIST recommended that staircase capacity and stair discharge door widths should be adequate to accommodate contraflow in circulation spaces, i.e. the simultaneous emergency access by firefighters into a building and towards a fire, while building users are still moving away from the fire and evacuating the building. This has implications for the minimum clear width of all fire evacuation staircases. Wider staircases facilitate the assisted evacuation and rescue of people with disabilities.
No consideration was given in BS 9999:2008, however, to any of the Recommendations contained in the 2005 & 2008 NIST Reports … there is not even a mention of either Report in the Bibliography (Pages 423-429).
– For such an important national standard in Europe – BS 9999:2008 – there is no understanding demonstrated of the Fundamental Functional Requirement for Public Safety in Buildings …
Buildings shall remain structurally stable and serviceable …
1. while people are waiting in ‘Areas of Rescue Assistance’ ; and
2. until all of these people can be rescued by Firefighters and can reach a ‘Place of Safety’, which is remote from a fire building – with an assurance of individual health, safety & welfare for the people involved ;
– There is a reference to ‘normal movement times’ which are used to calculate evacuation times in Mobility-Impaired People (Paragraph #46.2, Page 247), even though it was found by NIST that the average surviving occupant in the WTC Towers descended stairwells at about half the slowest speed previously measured for non-emergency evacuations. In a ‘real’ fire incident, there is no such thing as ‘normal’ or ‘standard’ evacuation movement times, and the idea that any building must be clear of occupants within a very short timeframe, e.g. 2.5-3.5 minutes, is ludicrous ;
– In the sensitive area of the Resistance to Damage of Enclosing and Separating Partitions (Paragraph #21.2.5 on Page 101) surrounding Firefighting Shafts, it is still permissible in BS 9999:2008 to use non-robust construction, e.g. lightweight plasterboard. Fire-Induced Progressive Collapse is not discussed in the BS 9999 … and neither is Disproportionate Collapse, which is one of the functional requirements – A3 – in Part A of the Building Regulations for England & Wales (and Ireland !) ;
– Although in Wheelchair Users (Paragraph #46.3 on Page 247), it is stated …
‘It should be noted that it can take as many as four people to use an evacuation chair safely and effectively.’
… the dimensions for the minimum width of staircases in Width of Escape Stairs (Table 14 on Page 88) and Firefighting Stairs (Paragraph #21.3.2 on Page 106) disregard the guidance given on Page 247 … and ignore the minimum clear staircase width (1.5m) required to safely assist the evacuation of a person in a manual wheelchair …
And … for some unexplained reason, handrails are permitted to intrude into the ‘clear width’ of a firefighting staircase in BS 9999:2008 (Paragraph #21.3.2, Page 106).
Please note well … this method (shown below) of assisting the evacuation of a person in a manual wheelchair is NOT correct. It is not possible to support any weight by holding the foot rests on a manual wheelchair, or by grasping the wheelchair by the front wheels …
Manual handling of occupied wheelchairs in a fire evacuation staircase, even with adequate training for everyone directly and indirectly involved, is hazardous for the person in the wheelchair and those people – minimum three – giving assistance.
The weight of an average unoccupied powered wheelchair, alone, makes manual handling impractical. All lifts (elevators) in new buildings should, therefore, be capable of being used for evacuation in a fire situation. Lifts (elevators) in existing buildings, when being replaced or undergoing a major overhaul, should then be made capable of use for this purpose.
Contraflow Circulation, i.e. the simultaneous emergency access by firefighters into a building and towards a fire, while building users are still moving away from the fire and evacuating the building, has not been considered at all in BS 9999:2008.
A clear staircase width of 1.5m provides sufficient space for a mobile person to evacuate (700 mm) and a heavily protected and equipped firefighter to simultaneously move in the opposite direction (800 mm) …
Human Behaviour in Fires should have been discussed in far more detail in BS 9999:2008 … but wasn’t. It is important for fire engineering designers to understand that the ‘real’ people who use ‘real’ buildings every day of every week, in all parts of the world, have widely differing ranges of human abilities and activity limitations … they are different from each other, and they will react differently in a fire emergency.
Building users need to be Skilled for Evacuation to a place, or places, of safety remote from a fire building. In the case of people with a mental or cognitive impairment, there is a particular need to encourage, foster and regularly practice the adaptive thinking which will be necessary during a ‘real’ fire evacuation.
Meaningful Consultation with every person known to occupy or use a building, for the purposes of receiving his/her active co-operation and obtaining his/her informed consent (involving a personal representative, if necessary), is an essential component of adequate pre-planning and preparation for a fire emergency.
Adequate Warning of a fire incident in a building should be communicated well in advance of the time when it is necessary to act and should continue for the full duration of the incident. Warnings should be informative, and easily assimilated in a form (e.g. oral, written, braille) and language understood by the people using the building.
Panic attacks, during evacuation in a ‘real’ fire incident, exist. The 2005 National Building Code of India refers extensively to this issue.
Solution: To resolve the technical inadequacies, inconsistencies and content gaps in BS 9999:2008 … it will be necessary to revise Technical Guidance Document B in Ireland. Fire safety, protection and evacuation from buildings for people with disabilities must be comprehensively included in the process of Fire Safety Certification.
7. Conclusions – BS 9999:2008 & BS 8300:2009
There are many gaps and conflicts between these two British Standards, principally because … they are two separate standards … drafted by two different Technical Committees within the British Standards Institution (BSI).
Because of its deviation from widely accepted concepts of accessibility and its tortuous use of terminology, BS 8003:2009 will have an adverse impact on the practice of Accessibility Design in Ireland … and has already complicated the development of the ISO Accessibility-for-All Standard (DIS ISO 21542).
Arrogance within BSI is not the only reason for such deviations. Distorting the European Union Single Market, for the purpose of introducing technical barriers to trade, is common in Britain … refer to the ‘deemed-to-satisfy’ status of the Approved Documents in the Building Regulations for England & Wales … and the Fire Protection Association’s ‘LPC Sprinkler Rules’.
Input from the Disability Sector during the drafting of BS 9999:2008 was not at all sufficient to ensure that there was a meaningful consideration of the problems encountered by people with activity limitations during a ‘real’ building fire incident. The necessary range of available and effective fire engineering solutions has not, therefore, been presented in the standard.
In addition … the complete and abject failure to consider the important Recommendations contained in the 2005 & 2008 National Institute of Standards & Technology (USA) Reports on the WTC 9-11 Incident in New York was an inexcusable and unforgivable technical oversight.
The result is a crassly inadequate, discriminatory and deeply flawed national fire safety standard in Great Britain & Northern Ireland. BS 9999:2008 became obsolete on the very day of its publication !
Please refer to our 1999 Submission to the Department of the Environment & Local Government, in Dublin, concerning the use of British Standard BS 5588:Part 8 in Ireland …
Following this Submission, our understanding is that an ‘Internal’ Working Party was established within the Department. However, the Working Party never reported. No proper response to this Submission has ever been received from the Minister or the Department.
On 29th November 2006, similar and very polite comments were sent directly to the British Standards Institution (BSI) by e-mail. Receipt of this e-mail was never acknowledged by anyone in BSI.