ISO/IEC Guide 71 : Guidelines for Standards Developers to Address the Needs of Older Persons and Persons with Disabilities

Open E-Mail to ISO TC 92 (Fire Safety) – Treatment of ‘Disability’

2014-11-05:  ISO TC 92: ‘Fire Safety’ is a long-established Technical Committee within the International Standards Organization (ISO) …  www.iso.org/iso/home/standards_development/list_of_iso_technical_committees/iso_technical_committee.htm?commid=50492  … and down through the many years of its existence, since 1958, it has laboriously constructed a robust foundation which has facilitated the modern evolution of Fire Science and Engineering and the development of many standard fire safety practices and procedures around the world.

BUT …  and in spite the existence of ISO/IEC Guide 71: ‘Guidelines for Standards Developers to Address the Needs of Older Persons and Persons with Disabilities’ (a weak document which is badly in need of revision and updating !)

Recently, having examined some draft standards being processed through ISO TC 92 … I have become very tired of the blatant incompetence … and lack of care and concern merging with feigned ignorance and/or stubborn resistance, within the Technical Committee, when it comes to the issue of ‘disability’ … in other words, the major matter of the real fire safety of vulnerable building users and occupants, i.e. people with activity limitations, in real buildings.

SO …  a few days ago, I wrote the following e-mail message to a Working Group Chairperson (who shall remain nameless, because this same problem pervades the whole TC) …

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Dear X,

With regard to All Aspects of the WG’s Work … one issue, in particular, sticks out like a sore thumb … how you treat ‘disability’.  There is no clarity here, only confusion.  There are no precise terms, only a garbled use of language and concepts.

Please allow me to suggest, with accompanying explanations, a suitable and necessary path forward.

I will circulate this e-mail message separately within ISO, and beyond.

Concerning Normative References … reference must be made to …

ISO 21542 (2011): ‘Building Construction – Accessibility & Usability of the Built Environment’

Within this document, Accessibility is understood to mean the full cycle of independent building use, in an equitable and dignified manner … and to include 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.

Texts relating to ‘fire safety’ have been incorporated into the main body of this International Standard.  It is, however, just a small beginning.  Much work remains to be done.

Accessibility Design Criteria, as described in ISO 21542, must now be applied to the design and maintenance of all fire evacuation routes, fire safety related signage and fittings, etc., etc.

Use of the word escape, in any context, is strongly discouraged.

Concerning Terms & Definitions

People with Activity Limitations:  Those people, of all ages, who are unable to perform, independently and without aid, basic human activities or tasks – because of a health condition or physical/mental/cognitive/psychological impairment of a permanent or temporary nature.

Attached, please find the FireOx International ‘Fire Safety for All’ Matrix … which illustrates how the separate pieces, including ‘disability’, fit together.

Contraflow:  Emergency access by firefighters or rescue teams into a building and towards a fire, while people are still moving away from the fire and evacuating the building.

Concerning Building User/Occupant Numbers & Provision … ‘token’ is not only entirely unacceptable, it is a clear case of professional negligence …

And why, suddenly, all of these ‘musts’ ??

Cogently mandated in the United Nations Convention on the Rights of Persons with Disabilities (CRPD) … the UN CRPD’s principal aim is to ensure that the Built, Social, Economic and Virtual Environments are sufficiently ‘accessible’ to permit a vulnerable and major population group in all of our societies to enjoy the fundamental freedoms and human rights set down in the Universal Declaration of Human Rights (1948).

The language of the Convention is always very robust and very direct: ‘States Parties shall …’

Also attached, please find a United Nations Global Map showing the status of Convention Ratification back in July 2014.  At the time of writing this e-mail message, 151 Countries have ratified the UN CRPD.

Full and Effective Accessibility of the Built Environment is a human right.  Adequate provision must be made for people with disabilities to use all buildings … not just some buildings … and certainly not just limited parts of a building !

In practice, people with disabilities must be included in all practice evacuation drills … and they must be included in all activities related to ‘fire safety’ and/or necessary to prepare for safe evacuation.

Furthermore … because Electronic, Information and Communication Technologies (EICT’s) now serve a function which is critical, during a fire incident, for the safety of all building users and firefighters, property protection, minimizing environmental damage, and sustainability … they must have a user interface which is Accessible for All … from both ends.

With regard to ‘adequate’ provision … please find attached the 2010 USA Disability Statistics … which indicate:

  • Minimum Reasonable Provision for People with Disabilities in a Building … 10% of User/Occupant Population ;
  • Minimum Reasonable Provision for People with Activity Limitations in a Building … 15% of User/Occupant Population.

The numbers of people with disabilities in developing and the least developed economies far exceed numbers in developed economies !

Best wishes for the success of your meeting in Sydney.

C.J. Walsh – Consultant Architect, Fire Engineer & Technical Controller.

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END

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ISO/IEC Guide 71 & CEN/CENELEC Guide 6 – Flawed ?

International Guidance Document … ISO/IEC Guide 71 : Guidelines for Standards Developers to Address the Needs of Older Persons and Persons with Disabilities was issued in November 2001.

European Guidance Document … CEN/CENELEC Guide 6 : Guidelines for Standards Developers to Address the Needs of Older Persons and Persons with Disabilities … a similar document … was issued a little later, in January 2002.

These Guides provide basic guidance to people drafting International & European Standards on how to take into account the needs of people with activity limitations, particularly older persons and people with disabilities.  While recognizing that some people with very extensive and complex impairments may have requirements beyond the level addressed in these documents, a very large number of people have minor impairments which can easily be addressed with a very small change of approach by people writing the Standards.  Typically, the problem is solely a lack of awareness.

Unfortunately, few Standards Developers … in either organization … are paying the slightest bit of attention to these Guides.

People with Activity Limitations:  Those people, of all ages, who are unable to perform, independently and without aid, basic human activities or tasks – because of a health condition or physical/mental/cognitive/psychological impairment of a permanent or temporary nature.

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1.  A full six months before the appearance of ISO/IEC Guide 71 … all of the 191 Member States of the World Health Organization endorsed, and officially adopted, the International Classification of Functioning, Disability & Health (ICF) on 22nd May 2001 … which replaced the earlier International Classification of Impairment, Disability & Handicap (ICIDH), dating from 1980.

While the previous health indicators had been based on the mortality (i.e. death) rates of populations … the new 2001 WHO ICF dramatically shifted the focus to ‘life’ and ‘living’ … in other words, how everyone is living with his/her health condition(s) and how improvements can be made to ensure a productive, fulfilling life in society.

This had important implications for medical practice; for legal, social, economic, institutional, design and spatial planning policies to improve accessibility, equal opportunity for all and inclusion; and for the protection of the rights of all individuals and groups.

Of special interest for people involved in any of the technical fields mentioned above … the 2001 WHO ICF also introduced a new disability-related language and terminology.

BUT … But … but … ISO/IEC Guide 71 and CEN/CENELEC Guide 6 do not use the 2001 WHO ICF’s innovative language and terminology.  Consequently, these International & European Guides are flawed.

For a very good example of WHAT MUST BE AVOIDED (!) in the drafting of International & European Standards … please examine the following text …

ISO DIS (Draft International Standard) 21542 : Building Construction – Accessibility and Usability of the Built Environment … dated November 2009 …

Section 3   Terms & Definitions

‘ #3.36  Impairment

Limitation in body function or structure such as a significant deviation or loss which can be temporary due, for example, to injury, or permanent, slight or severe and can fluctuate over time, in particular, deterioration due to ageing.

[ISO/TR 22411:2008]

NOTE 1   Body function can be a physiological or psychological function of a body system; body structure refers to an anatomic part of the body such as organs, limbs and their components (as defined in ICIDH-2 of July 1999).

NOTE 2   This definition differs from that in ISO 9999:2002 and, slightly, from ICIDH-2/ICF: May 2001, WHO: ‘any loss or abnormality of a body function, or body structure’.

NOTE 3   The word ‘abnormality’ is strictly used here to refer to a significant deviation from an established population mean, within measured statistical norms. Impairments can be physical, mental, cognitive or psychological.’

As clear as mud … what a mess !   This does nothing only sow needless confusion in the mind of a reader.

Unless and Until … we properly harmonize, at a technical level, disability-related language and terminology … in order to improve communication … we will all continue to run around in circles and make little forward progress !!!

[ At the level of the individual, people should always be free to use whatever language they wish. ]

Our Guidance to All Standards Developers is … whether working within the International Standards Organizations (ISO & IEC) or the European Standards Organizations (CEN & CENELEC) … or both …

People with Activity Limitations must be properly considered at all stages in the development of a Standard … and any disability-related terminology used … should be fully consistent with the World Health Organization’s 2001 International Classification of Functioning, Disability & Health (ICF).  Confusing and contradictory texts should be avoided.’

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2.  In relation to ISO/IEC Guide 71 & CEN/CENELEC Guide 6 – Table 7 (Page 13 in both Guides) … #8.23 Fire Resistance requires a complete re-assessment.  On Page 21 of ISO/IEC Guide 71 and Page 22 of CEN/CENELEC Guide 6 … the supporting text for #8.23 has the different heading of ‘Fire Safety of Materials’ ?!?   Confusing, isn’t it ?

The Revised Title in Table 7 and the supporting text should read … Fire Safety.  ‘Fire Resistance’ is but one of many passive fire protection concepts … a very small sub-set in the wide technical field of ‘fire safety’ in buildings.  ‘Fire Resistance’ is not used in connection with the ignition and fire development behaviour of materials or fabrics.

Relevant Factors for #8.23 are not properly indicated, in Table 7, under Columns #9.2, #9.3, #9.4 (a glaring omission !) & #9.5.

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3.  Pertinent to ‘fire safety’ in buildings … this text was removed from ISO CD (Committee Draft) 21542 … the previous version of the ISO Standard, dating from December 2008 …

ISO CD 21542 – Annex A.1.2 – 2nd Paragraph

‘ Building users should be skilled for evacuation to a place, or places, of safety remote from the 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.’

The Definition for the Term Skill (#3.60) is still retained in the later ISO DIS 21542 version of the Standard …

‘ 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.’

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4.  While there are eight references to ‘Cognitive Impairment’ in both Guides … nowhere is this term defined … or distinguished from ‘Mental Impairment’ …

Cognitive Impairment:  A deficiency of neuropsychological function which can be related to injury or degeneration in specific area(s) of the brain.

Mental Impairment:  A general term describing a slower than normal rate in a person’s cognitive developmental maturation, or where the cognitive processes themselves appear to be slower than normal – with an associated implication of reduced, overall mental potential. 

A deeper understanding, at a technical level, of the many different types of health conditions and impairments (physical/mental/cognitive/psychological) … can only result in a better designed, more facilitating Human Environment.

One final important term … when considering Fire Safety in Buildings

Panic Attack:  A momentary period of intense fear or discomfort, accompanied by various symptoms which may include shortness of breath, dizziness, palpitations, trembling, sweating, nausea, and often a fear by a person that he/she is going mad.

I have long held the view that, in Fire Engineering, dramatic breakthroughs will result from a closer study of Cognitive Psychology.

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END

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