International Standard ISO 21542

2014 Zero Project Accessibility Conference – More Hot Air !!

Posted by CJ Walsh

2014-02-07:  Another year, and here we go again !   Except this time around … the bullshit, hot air and ‘blah-blah-blah’ must end !!   Certainly here, and at every other opportunity as well … I will demand to hear far less talk, but to see a lot more effective action on this important issue of human and social rights !!!

Just before Christmas (2013), I received a personal invitation to attend the Zero Project Conference on Accessibility for All, which will take place in a few weeks time on 27 & 28 February … at the United Nations Offices in Vienna (one of my favourite cities), Austria.  You can read all the details about the conference here: http://zeroproject.org/conference/    The following is my polite and restrained reply to that invitation, dated 14 January 2014 …

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RE: 2014 Zero Project Conference on Accessibility for All

To Whom It May Concern,

Thank you very much for your invitation to attend the upcoming Zero Project Conference on ‘Accessibility’ … but, having carefully examined the Draft Conference Programme, I must decline … and will not be attending.

Concerning Accessibility for All … the biggest problem within the European Accessibility Community is that we are all talk and no action.  The shameful reality is that the Human Environment (including the social – built – virtual – economic environments) remains emphatically inaccessible throughout Europe and far beyond !

Even though the U.N. Convention on the Rights of Persons with Disabilities (CRPD) is in place, ratified by the European Union and many of the EU Member States … and International Standard ISO 21542: ‘Building Construction – Accessibility and Usability of the Built Environment’ has been fully adopted … the first conference session is still asking the basic question “What is Accessibility ?”

Instead of a detailed examination of how the elaborate Accessibility Agenda contained in Articles 9, 11 and 19 of the UN CRPD can be properly and satisfactorily implemented, in an independently monitored (Art. 33), harmonized and culturally-sensitive manner across the globe … you will be presenting an ‘Access’ Beauty Pageant.  Istanbul, a beautiful city with which I am very familiar, is only at the earliest stages of awareness about accessibility … and the recently published Hong Kong Fire Safety Code completely ignores fire safety for building occupants with disabilities !   Ireland is determined to delay ratification of the UN CRPD for as long as possible, and will refuse to ratify the Convention’s Optional Protocol … and I also know that implementation of the CRPD is meeting stiff resistance within the Institutions of the European Union.

Sustainable Development and the Post-2015 Sustainable Development Goals (SDG’s) receive no attention in the Zero Project Conference Programme … even though it took a lot of effort to ensure that the innovative and forward-looking Preamble Paragraph (g) was incorporated in the Convention.  Within the rapidly evolving SDG drafting process, it is still not properly understood why and how Accessibility for All is a fundamental attribute of a Sustainable and Resilient Human Environment.

Concerning Mainstreaming … I describe a typical ‘real’ situation on our Technical Blog ( www.cjwalsh.ie/2012/11/new-legal-normative-environment-for-accessibility-in-europe/ ) … but this constant annoying struggle, and discussion on finding common approaches to its successful resolution, are absent from the Programme.

For us, attendance at the 2014 Zero Project Conference would be a waste of scarce organization resources.  For Europe, however, the Conference represents a much greater waste … a magnificent opportunity missed !

Regards,

C. J. Walsh, B Arch FRIAI MIBCI MIFS MIFireE – Consultant Architect, Fire Engineer & Technical Controller.

  • Member, CIB Task Group 87: ‘Urban Resilience – Benchmarking & Metrics’.
  • Member, CIB Working Commission 14: ‘Fire Safety’.
  • Chair, CIB W14 Research Working Group IV: ‘Structural Reliability & Fire-Induced Progressive Damage’.
  • Member, CIB Working Commission 108: ‘Climate Change & the Built Environment’.
  • Member, EU Expert Working Group on Urban Environment Research.
  • Member, EU EYPD Expert Group on Accessibility.

Managing Director, Sustainable Design International Ltd. (Ireland & Italy) and Sürdürülebilir Tasarım Tic.Ltd.Şti. (Turkey).

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This 2014 Zero Project Conference on Accessibility for All is divorced from Reality … and the Real Needs of many vulnerable people in all of our communities !

Without an Effectively Accessible Human Environment (including the social, built, virtual and economic environments) … access to many other human and social rights, e.g. education, housing, medicine, voting, etc., is prevented and unjustly barred.

Building 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’.

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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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Recent Fatal Fire at a Disabled Workshop in SW Germany

Posted by CJ Walsh

2012-11-28:  On Monday last, 26 November 2012 … Fire broke out at a Sheltered Workshop for People with Activity Limitations, located in the small municipality of  Titisee-Neustadt, south-western Germany … not too far from the borders of France and Switzerland.  It was approximately 14.00 hrs in the afternoon … in broad daylight.

German news reports put the death toll at 14 People, including 1 Carer … with 10 People injured.

News reports also state that it took 2 Hours for Firefighters to bring this incident under control.  At the time that Photograph 1, below, was taken … smoke had spread throughout a major part of the building.

Viewers should look closely at the top of the external staircase … then, ask yourselves how any person with an activity limitation can be safely rescued, or assisted to evacuate, by means of a ladder (obscured, at the end of the building on the left) … and, finally, notice the positioning of fire hoses on the ground and on the staircase … some of the many issues which have been discussed extensively here before …

Click to enlarge.
Click to enlarge.
Click to enlarge.
Click to enlarge.

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2005 NIST(USA) Final Report on 9-11 World Trade Center 1 & 2 Tower Collapses

–  Recommendation  #17b  –

 To the degree possible, people with activity limitations should be provided with a means for self-evacuation in the event of a building emergency.  Current strategies (and law) generally require these people to shelter-in-place and await assistance.  New procedures, which provide redundancy in the event that the fire warden system or co-worker assistance (e.g. the buddy system) fail, should consider full building evacuation, and may include use of fire-protected and structurally hardened elevators, motorized evacuation technology, and dedicated communication technologies.

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At the heart of the impressive show of fire fighting equipment and technology … and the usual reassuring statements by local officials and other people in authority after the event … there is an equally impressive lie …

Photograph by Patrick Seeger(dpa). Click to enlarge.
Photograph by Patrick Seeger(dpa). Click to enlarge.

Current Building Codes and Regulations, Fire Safety Standards, Building Design Practices, and Building Management Procedures … do not seriously consider the safety of People with Activity Limitations … not properly – not adequately – not even INadequately.  Tokenism is the best offer available in just a few European countries.

Photograph by Patrick Seeger(dpa). Click to enlarge.
Photograph by Patrick Seeger(dpa). Click to enlarge.

According to Spiegel OnLine International …

The rescue was difficult because some people panicked, said Local Fire Chief Alexander Widmaier.  “We are dealing here with people who naturally do not respond rationally”, he said.

IF this is an accurate news report, and bearing in mind that it is also a translation … I SAY …

Let us be generous and kind … Local Fire Chief Alexander Widmaier has NO awareness or understanding of People with Activity Limitations and the daily challenges they face in moving around and using a built environment which is inaccessible and unsafe.

According to AFP OnLine …

Gotthard Benitz, of the Titisee-Neustadt fire service, told AFP earlier that the fire began on the ground floor of the building which also had a basement and an upper floor.

“The victims were all on the same floor where the fire was”, he said adding this was the only area to have sustained fire damage and the stairwell had remained smoke-free meaning those on the other two floors had been able to use it.

He also said firefighters were prepared for dealing with an emergency at the workshop as practice fire alarms were regularly carried out there, with the last one having been last year.

The head of Caritas in Germany, Peter Neher, told ZDF public television that emergency practice drills were done regularly.

IF this is an accurate news report, and bearing in mind that it is also a translation … I SAY …

Gotthard Benitz should also look at the top of the external staircase in Photograph 1 above.  IF there are no circulation hazards, e.g. ice, or obstacles, e.g. fire hoses … able-bodied people can easily go up or down a staircase … people who use wheelchairs or other mobility-aid devices cannot.

In their respective positions of responsibility … Gotthard Benitz and Peter Neher should both understand that all building occupants must be facilitated in acquiring the skill of evacuation to a ‘place of safety’, by way of a safe and accessible route.  An emergency practice drill, although carried out regularly once a year … is ENTIRELY inadequate … and will achieve Very Little.

Skill:  The ability of a person – resulting from training and regular practice – to carry out complex, well-organized patterns of behaviour efficiently and adaptively, in order to achieve some end or goal.

Standard fire evacuation training and practice drill procedures must be adapted to the individual-specific abilities of People with Activity Limitations.

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BUT … the new International Standard ISO 21542 is a very small step in the right direction.  See yesterday’s post.

This situation will only improve to a significant degree, however, when People with Activity Limitations, and their Representative Organizations, begin to act decisively, in unison, and with serious intent …

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Self-Protection from Fire in Buildings – Personal Check List for People with Activity Limitations

1.     Upgrade ‘My’ understanding of Accessibility …

Ease of independent approach, entry, egress, evacuation and/or use of a building and its services and facilities, by all of the building’s potential users – with an assurance of individual Health, Safety and Welfare during the course of those activities ;

2.     Be assertive (not aggressive) with regard to ‘My’ own self-protection in emergency situations ;

3.     Concerning ‘My’ safety … demand that Building Management actively engages in Meaningful Consultation – and receives your Informed Consent ;

4.     Become familiar with the Fire Defence Plan for the building, and know ‘My’ part well ;

5.     Practice – practice – practice … become skilled in evacuation to a Place of Safety ;

6.     Become involved, and participate directly in the Building’s Safety Procedures.

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Self-Protection from Fire in Buildings  – Must-Do List for Representative Organizations & Groups

1.     Upgrade ‘Our’ understanding of Accessibility in a Social Context, its Current Vocabulary, and its Complexity … groups of individuals wish to socialize together … this is now, afterall, a recognised human and social right !

Ease of independent approach, entry, egress, evacuation and/or use of a building and its services and facilities, by all of the building’s potential users – with an assurance of individual Health, Safety and Welfare, and group Wellbeing, during the course of those activities ;

2.     Be assertive (and aggressive) with regard to the availability of proper Data and Statistics – we must clearly identify ‘Our’ problem with the many restrictions placed on our participation in local communities ;

3.     Produce a working statement of an Individual’s Rights – on 1 Page (!) ;

4.     Issue clear guidelines on Reliable Advocacy ;

5.     Become involved, and participate directly in the improvement of Building Codes and Regulations, Fire Safety Standards, Building Design Practices, and Building Management Procedures ;

6.      Demand resources to Monitor ‘Effective’ Implementation … and Target Relevant and ‘Practical’ Research.

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