London

Grenfell Inquiry Recommendations (3) – Fire Alarms !!

Previous Posts In This New Series …

2019-10-31:  Grenfell Tower Fire Inquiry’s Phase 1 Report – Information

2019-11-11:  Grenfell Inquiry Recommendations (1) – Vulnerable People ?

2019-12-21:  Grenfell Inquiry Recommendations (2) – Fire Emergency Plans !

2020-03-23:  The Grenfell Fire Inquiry’s Phase 1 Recommendations (Part V in Volume 4 of the Phase 1 Report), were published on 30 October 2019.  The initial issues covered in those Recommendations are fragmentary, lack depth and coherence … and in the case of Fire Alarms, with just one indirect reference to them in Paragraph #33.22 … they are in serious error.

Colour image showing the Volume 4 Cover Page of the Grenfell Tower Inquiry Phase 1 Report.  The Phase 1 Recommendations are contained in Chapter #33, on Pages 771-780.  Click to enlarge.

[ Paragraph #33.22 ]  There were no plans in place for evacuating Grenfell Tower should the need arise.  I therefore recommend:

d. that all high-rise residential buildings (both those already in existence and those built in the future) be equipped with facilities for use by the fire and rescue services enabling them to send an evacuation signal to the whole or a selected part of the building by means of sounders or similar devices ;

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FUNDAMENTALS OF A SOLUTION

1.  A Fire Alarm (more precisely from here on, a Fire Detection & Warning System) is a critical safety feature in all buildings … ALL BUILDINGS … from the smallest and most simple, to the biggest and most complex … no exceptions !!

In order to survive in a fire emergency, Vulnerable Building Users need more time to react, and evacuate, than other occupants/users.  The valuable time provided by early, accurate and precise detection is the only way to effectively facilitate this.  The ‘Required Time’ to prepare for evacuation depends on many factors, e.g. building complexity, familiarity of users with evacuation routes, range and severity of user activity limitations, etc.

It follows, therefore, that if building occupants/users have to wait 15, or 20, or 30 minutes before firefighters arrive at the fire scene (Full Response Time*) and ‘an evacuation signal to the whole or a selected part of the building’ is only then sent by those firefighters … all of that valuable evacuation time for vulnerable building users has been lost.  This is ridiculous, and makes no sense whatsoever.  This Recommendation must be rejected out of hand, and ignored !

[ *Full Response Time: The time interval from the receipt of an emergency communication at the primary public safety answering point (#PSAP) to when emergency response units are initiating action or intervening to control a fire incident. ]

Colour photograph showing the Single, Narrow Staircase (1.040 metres in width between a handrail on one side of the staircase and a bare wall on the other side) in London’s Grenfell Residential Tower.  This staircase, which was inadequately protected from fire, heat and smoke, was not wide enough to facilitate the ‘contraflow’ circulation of firefighters entering, while occupants evacuated at the same time.  Without a Fire Alarm in the building, occupants could not have known that a serious Fire Emergency was in progress … especially Vulnerable Building Users accommodated high up in the Tower … and they remained in place (‘stayed put’).  Once firefighters arrived at the scene, occupant evacuation using this staircase became impossible or extremely difficult.  Click to enlarge.

Important Note:  In Chapter #34: ‘Looking Ahead to Phase 2’ of Moore-Bick’s Phase 1 Report, Volume 4 … Paragraph #34.14 states …

A question was raised about the width of the stairs, given that they provided the sole means of access to the upper floors of the tower for firefighters as well as the sole means of escape for the occupants.  However, the stairs appear to have complied with requirements of the legislation in force at the time of their construction and the expert evidence supports the conclusion that they had sufficient capacity to enable all the occupants of the building to escape within a reasonable time.  This aspect of the building will not, therefore, be the subject of further investigation in Phase 2.’

Astounding !  Absurd !!  FUBAR !!!

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All Fire Emergency Warning Systems must be designed to accommodate People with Hearing Impairments.  Audible and visual warning devices must be provided together, as a single combined unit.  This is particularly important in noisy and isolated building spaces, e.g. bathrooms, small meeting rooms.  Vibrating devices, such as pagers or mobile phones, can be integrated into a building’s fire emergency warning system in order to provide any individual with a tactile emergency alert.

Colour photograph showing a single combined visual-audible Fire Emergency Warning Device.  Click to enlarge.

Important Note:  Audible sounders, on their own, are never a sufficient Fire Emergency Warning !

2.  The Purpose of a Fire Emergency Warning System is to provoke calm, efficient and adaptable evacuation movement by ALL building users/occupants at the earliest possible stage in a fire incident, without causing user confusion, disorientation or panic. In all building types, therefore, a reliable, informative and accessible fire emergency warning system must be installed, and such a system must always have a fire protected electrical supply.

Colour photograph showing the movement of building occupants and users.  The purpose of a Fire Emergency Warning System is to provoke calm, efficient and adaptable evacuation movement by ALL building occupants at the earliest possible stage in a fire incident, without causing user confusion, disorientation or panic.  During a Fire Emergency, STANDARD MOVEMENT TIMES DO NOT EXIST.  Click to enlarge.

3.  To provoke a Calm Response from Building Users … the output from Fire Emergency Warning Devices, e.g. light, sound and messages, must be adapted to the local context of people and building surroundings.

Fire Emergency Audible Warnings … A sufficient number of low-output audible sounders, i.e. between 60-80 dB, must be specified for effectiveness.  Small numbers of sounders with high output (in order to reduce costs) should never be specified, as this can lead to confusion, disorientation and panic attacks among some building users/occupants.  The output of sounders must be adapted to suit interior surroundings, e.g. in small spaces with hard surfaces a lower sound output will be adequate.

Colour image.  The output from Fire Emergency Audible Sounders must be between 60-80 dB.

Important Note:  When they are asleep, hearing-able children (around ten years of age and under) … and hearing-able older people (around 65 years of age and over) are more difficult to wake and rouse sufficiently for evacuation when alerted by an audible signal alone.

Fire Emergency Visual Warnings … Light strobes/beacons must be clearly visible.  To reinforce #1 above … light strobes/beacons must be placed in wash rooms and in other locations within buildings where people may be alone ; they must also be placed in noisy environments.

A sufficient number of low-output strobes/beacons must be specified for effectiveness.  Small numbers of strobes/beacons with high output (in order to reduce costs) should never be specified, as these produce a glare which may cause confusion, disorientation and panic attacks among some building users/occupants.  The light output of strobes/beacons must be adapted to suit interior surroundings, e.g. in dark rooms.

For light strobes/beacons, a slow rate of flash is important, i.e. no faster than once every two or three seconds, in order to encourage a calm response from building users/occupants and to avoid photosensitivity seizures.  Most importantly, the flash of one strobe/beacon must be synchronized with the flashes of all other light strobes/beacons in view.

Colour video clip (.gif).  The output from Fire Emergency Visual Strobes / Beacons must be no faster than one flash every two or three seconds.  The flash rate shown above is too fast !   Click to run video clip.

Fire Emergency Voice Message Warnings … Are essential to improve Warning Credibility.  In other words, building users are far less likely to sit around wondering, waiting to see whether this is a ‘real’ fire emergency, a false alarm, a practice evacuation, or an electrical error.  Verbal or voice messages must be short and contain appropriate warning information which is easily assimilated.  The speaker should be distinct and easy to understand.  Live messaging during a fire emergency is preferred over pre-recorded, standard messages.  In today’s multi-cultural social environment, messages must be transmitted in at least two to three different languages, as appropriate.

Fire Emergency Directional Warnings … Combination sounder, visible strobe/beacon, and voice messaging Fire Emergency Warning Devices are now a mainstream technology, are readily available, and are being specified in new and existing buildings.

Colour image showing a combination Fire Emergency Directional Audible Sounder, with Voice Messaging capability.  Click to enlarge.

Audible directional signalling must be installed when dealing with difficult building configurations, e.g. in large open office layouts/spaces with minimal signage … where building users/occupants are unfamiliar with their surroundings in modern shopping centres/malls and other complex building types … or visibility of high-level signage may be reduced because of smoke logging.

Directional sounders, which guide building users during a Fire Evacuation towards Exits, Areas of Rescue Assistance and Lift/Elevator Lobbies, must be positioned at carefully chosen, suitable locations.  Once reached, a directional sounder must also have a voice messaging capability in order to inform people about the next phase of evacuation.

4.  Fire Emergency Warning Systems must be Accessible (for People with Activity Limitations), i.e. capable of transmitting a warning in many formats in order to ensure that all users/occupants perceive and act upon the warning in a calm manner and, thereafter, that effective evacuation movement commences without delay. Warning Credibility improves in direct relation to the type and number of different warning formats.

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As well as indirectly referring to Fire Detection and Warning Systems, Paragraph #33.22 in Moore-Bick’s Phase 1 Recommendations has some other things to say about Evacuation.  So this is an opportune moment to discuss some practical and human issues concerning Fire Emergency Evacuation … and, straight away, to deal with an unexpected consequence arising from the current CoronaVirus/CoVID-19 Emergency …

CORONAVIRUS / CoVID-19 EMERGENCY

There have been widely reported instances, in many countries, of panic buying in shops because of the 2020 CoronaVirus/CoVID-19 Emergency … but the photograph below illustrates an example of a panic reaction by building management.  This appears to be a crime scene … the yellow and black tape is so dramatic.  In a real Fire Emergency, many building users/occupants will be reluctant to use this final fire exit ; they will not have the time to read the small print on a notice ; they will attempt to re-trace their path of evacuation and find another exit.

Colour photographs showing how, as a panic reaction to the 2020 CoronaVirus/CoVID-19 Emergency, a Final Fire Exit has been blocked off from normal, everyday use.  Click to enlarge.

This panic reaction by building management IS a serious impediment to Fire Evacuation !

Whatever the Motives of Building Management …

  • in countries which have Fire Codes / Regulations, this action is illegal ;   and
  • in these days, when a wide range of ‘smart’ technologies is readily available … this action is inexcusable.

SOME PRACTICAL FIRE EVACUATION ISSUES

A Skill is the ability of a person, resulting from competent training and regular practice, to carry out complex, well-organized patterns of behaviour efficiently and adaptively, in order to achieve some end or goal.  All building occupants/users must be skilled for evacuation to an external ‘place of safety’, which is at a safe and remote distance from the fire building.  Practice fire evacuations must be carried out sufficiently often to equip building users, particularly vulnerable users, with this skill, i.e. at least once every six months ; in complex building types, practices should be carried out more often.  Prior notification to occupants/users, and regular scheduling of practice evacuations should be avoided.

Familiarity with Fire Evacuation Routes will be fostered and greatly improved by means of normal, everyday use by occupants/users.  This is an important task for pro-active Building Management in existing buildings … and an important aspect of new building design for Architects and Fire Engineers.

While the transmission of fire emergency warnings in many formats will increase Warning Credibility, close observation of past tragic ‘real’ fire events, e.g. the WTC 9-11 Attacks in New York City, shows that initiation of evacuation and the actual process of evacuation itself can be problematic.  An interesting, easily assimilated and user-targeted skills programme of training should incorporate practical solutions to deal with the following typical problems:

  1. Fire Emergency Preparedness: Irregular attendance of building occupants/users at fire prevention and safety training sessions, and participation in practice fire evacuations. Users not being familiar with a building’s fire emergency management plan and not knowing who is in charge … not using a building’s fire evacuation route(s), particularly staircases, during practices … or having no information about where to assemble after evacuating … or, once at a place of safety, not having any head count or identification process ;
  2. Delaying Activities Inside The Fire Building: Once building occupants/users decide to evacuate, but before moving to evacuate, they gather personal effects … seek out friends/co-workers … search for others … make phone calls/send tweets … finish tasks/turn off computers … wait around for instructions … change shoes … and try to obtain permission to leave ;
  3. Delaying Activities Outside The Fire Building: Once outside the building’s final fire exit, but before moving directly to a place of safety, building occupants/users stop to see what is happening … look for friends/co-workers … look for a phone … do not know where to go … or, within the ‘danger zone’ of the fire building, stop to receive medical attention.

It may seem obvious that Fire Evacuation Routes must also be Accessible (for People with Activity Limitations), which also makes routes much safer for every other building user … and sufficiently wide to accommodate Contraflow (emergency access by firefighters or rescue teams into a building and towards a real fire, while building users are still moving away from the fire and evacuating the building) … a harsh lesson learned from the 2001 WTC 9-11 Attacks and the 2017 Grenfell Tower Fire. Since they are new, strange and unusual for many building designers, and most fire engineers … these aspects of building performance are overlooked in nearly every building.

Practice Evacuations should include exercise of the buddy system ; fire safety fittings, e.g. portable fire extinguishers ; and fire evacuation devices intended for use by people with activity limitations which will require more intensive training.

Colour image showing a range of personal Facilitation / Mobility Aids.  People with Activity Limitations must be allowed, and positively encouraged, to keep these Aids during practice and real fire evacuations.  Prior meaningful consultation (see below) is essential.  Click to enlarge.

Important Note:  During fire emergencies, People with Activity Limitations must be permitted to keep possession of their own personal Facilitation / Mobility Aids.

SOME HUMAN FIRE EVACUATION ISSUES

The actual people who use and occupy buildings are individuals.  They are different from each other, and they each have a different range of abilities (in relation to self-protection, independent evacuation to an external place of safety remote from a fire building, and active participation in a building’s fire emergency management plan), behaviour and manner of perceiving their surroundings.  Two apparently similar people will also show variations in how they react to and behave in any specific situation, particularly a fire emergency.

Ability / Disability is a Continuum – a gentle gradient on which every person functions and acts at different levels due to personal and environmental, i.e. external, factors.

In situations of severe stress, e.g. during a fire emergency in a building, where there is a lack of preparedness for such an event, a lack of familiarity with evacuation routes, lack of reliable evacuation information, lack of competent leadership and clear direction, and the presence of smoke, user/occupant confusion, disorientation and panic will occur.  Standard evacuation movement times will also be non-existent.  In addition, people with activity limitations must then deal with many physical barriers which routinely impede their evacuation from buildings, e.g. fire resisting doorsets which are difficult to open, steps along evacuation routes and at final fire exits.

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 evacuation a real fire incident.

People with respiratory health conditions will not be able to enter or pass through smoke.  People with visual impairments will require continuous, linked tactile and/or voice information during the whole process of fire evacuation.  People with psychological impairments, i.e. vertigo and agoraphobia, will be unable to use fire evacuation staircases with glass walls in high-rise buildings.  Because of the stigma still associated with disability in many countries, some users/occupants who will need assistance during a fire emergency will be reluctant to self-identify beforehand.  Other people may not even be able to recognize that they have an activity limitation or a health condition.

Meaningful Consultation with a person known to occupy or use a building, for the purposes of receiving his/her active co-operation and informed consent (involving a personal representative, if necessary), is an essential component of adequate pre-planning and preparation for a fire emergency.

Building Designers, Fire Engineers and Firefighters should be aware of the following human conditions:

Agoraphobia: A fear of open spaces.

Commentary: Agoraphobia is one of the most commonly cited phobic disorders of people seeking psychiatric or psychological treatment. It has a variety of manifestations, e.g. a deep fear of leaving a building, or of being caught alone in some public place. When placed in threatening situations, agoraphobics may experience a panic attack.

Anosognosia: A neurological disorder marked by the inability of a person to recognize that he/she has an activity limitation or a health condition.

Dementia: Any degenerative loss of intellectual capacity, to the extent that normal and occupational activities can no longer be carried out.

Panic: A sudden overwhelming feeling of anxiety, which may be of momentary or prolonged duration.

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.

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#SFE #GrenfellTowerFire #FireSafety4ALL #NobodyLeftBehind #VulnerableBuildingUsers #PwAL #PwD #NeverStayPut #VulnerablePeople #Firefighters #FFsafety #FFhealth #2019GrenfellRecommendations #SFE #GrenfellTowerFireInquiry #London #FireResistingDoorsets #FireCompartmentation #FireProtection #FireEvacuation #MooreBick #FireEngineering #FireEngineers #IFE #England #RIBA #Design #Management #Construction #HighRiseResidentialBuildings #UDHR #HumanRights #unCRPD #Discrimination #AusterityKills #Justice4Grenfell #Contraflow #LocalFireServices #Skill4Evacuation #Resilience #CoronaVirus #CoVID19 #Panic #SIA

Successful Elaboration of ‘Fire Safety for All’ in China’s Bay Area !

2019-07-26:  This time last month, in June … I was visiting a hot and humid Hong Kong and Macau, only 1 hour apart on a sea ferry, in China’s Bay Area … to make a Keynote CPD Presentation on Fire Safety for All – Nobody Left Behind ! in the Hong Kong Institute of Architects … and following that up with a full morning Workshop and an afternoon Plenary Presentation at the large 2019 Rehabilitation International Asia-Pacific Region Conference, in Macau, later in the week.

2019 Rehabilitation International Asia-Pacific Conference (Macau) – 26 to 28 June

The Theme of this 3-Day Conference, in #Macau, was Together, Leaving No One Behind, In Disability-Inclusive & Rights-Based Progress.  Attended by 1,500 delegates from 30 different countries, the event also gathered together more than 250 international experts, practitioners, academics and researchers from all over the world.

Two Exhibitions, visited by 6,000 people, were organized alongside the Conference: 1) ‘Facilitation and Mobility Aids + Assistive Technologies’ … and 2) ‘Art’.

It is worthwhile noting  that #China ratified the U.N. Convention on the Rights of Persons with Disabilities (#CRPD) on 1 August 2008 … but has not yet signed, never mind ratified, the Convention’s Optional Protocol … a clear signal of current political intent which, hopefully, will change in the not-too-distant future.  Every year, Hong Kong and Macau submit reports to Beijing regarding CRPD compliance status and implementation.

Colour photograph showing CJ Walsh, as he addresses a Plenary Session on ‘Fire Safety for All – Nobody Left Behind !’ at the 2019 Rehabilitation International Asia-Pacific Region Conference, in Macau.  Click to enlarge.
Colour image showing the Matrix of ‘Fire Safety for All’ … a Priority Theme of Sustainable Fire Engineering … which is particularly concerned with the fire safety of #PwAL’s (People with Activity Limitations), but also with #PwD’s (People with Disabilities).  After the 2017 Grenfell Tower Fire, in London, it is important that these concerns stretch to include the #Poor, #Refugees and #Migrants.  Click to enlarge.

Without being able to use a #Lift/#Elevator for Fire Evacuation in a building … there is No Fire Safety for All !

In a developing fire incident, People with Activity Limitations must be provided with a safe, alternative evacuation route – just like all other building users – which is a Fundamental Principle of all Fire Engineering.  However … just one #User/#Occupant Fire Evacuation Lift/Elevator in a building is an empty, meaningless, Token Gesture !

Colour photograph showing the participants from 30 different countries who attended the 2019 Rehabilitation International Asia-Pacific Region Conference.  The venue was The Venetian Macau.  Click to enlarge.
‘Fire Safety for All’ must be considered at the start of the Design Process.  Colour image explaining how #Buildings must remain #Serviceable, not merely Structurally Stable, for a minimum Required Period of Time.  Click to enlarge.

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‘Fire Safety for All’ on Macau TV News … Friday night, 28 June 2019 … my friend and colleague, Ar Joseph Kwan (Architect & Accessibility Consultant based in Hong Kong), is the person being interviewed …

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Hong Kong Institute of Architects CPD Seminar – 24 June 2019

Continuing Professional Development (#CPD) is an important aspect of Ethical Architectural Practice.  Arriving drenched in a heavy rain downpour on the Monday evening … I was not surprised, therefore, to find that this Seminar was well attended by local architects.  Representatives of HK Authorities Having Jurisdiction (#AHJ’s), and Local Fire Services, as well as senior personnel involved in the development of the HK Code of Practice for Fire Safety in Buildings and the HK Barrier Free Design Manual were active participants in the panel discussion afterwards.

Colour image showing the Title Page of CJ Walsh’s Keynote CPD Presentation on ‘Fire Safety for All – Nobody Left Behind !’.  This Page also signals how ‘Fire Safety for All’ is integrated into the wider context of Sustainable Design.  Click to enlarge.
Colour photograph showing CJ Walsh, as he makes a Keynote CPD Presentation on ‘Fire Safety for All – Nobody Left Behind !’ in the offices of the Hong Kong Institute of Architects.  Click to enlarge.

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After Grenfell: Reliable Design, Supply & Construction Essential !

2017-10-10:  After the Grenfell Tower Fire Tragedy in London, on 14 June 2017, the integrity of the English Regulatory and Technical/Building Control Systems is now so compromised that a complete Systems Transformation is immediately required !   Closer to home, here in Ireland … what nobody is daring to say, even our tame media, is that Our Regulatory System is based very closely on the English System.  And Our Technical/Building Control System is purposefully under-resourced … so it is weak and ineffective.

Let there be no confusion … Priory Hall and Longboat Quay, both in Dublin, are just the tip of an enormous iceberg …

Colour photograph showing the Grenfell Tower Fire, in London … early in the morning, after dawn, on Wednesday, 14 June 2017.  Harsh, tragic Reality !  Click to enlarge.

So where do we start again ?

Reality – Reliability – Redundancy – Resilience !

With regard to Reliable Fire Engineering Related Design, Supply and Construction … this is how we must proceed …

  1. Design of the works is exercised by an independent, appropriately qualified and experienced architect/engineer/fire engineer, with design competence relating to the fire protection of buildings ;
  1. Supply of fire safety related construction products/systems to the works is undertaken by reputable organizations with construction competence, particularly in relation to the fire protection of buildings ;
  1. Installation/fitting of fire safety related construction products/systems is exercised by appropriately qualified and experienced personnel, with construction competence relating to the fire protection of buildings ;
  1. Supervision of the works is exercised by appropriately qualified and experienced personnel from the principal construction organization ;
  1. Regular inspections, by appropriately qualified and experienced personnel familiar with the design, and independent of both the design and construction organizations, are carried out to verify that the works are being executed in accordance with the design.

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PEEPS – Fundamentally Flawed & Discriminatory ?

2009-05-13:  The other day, I thought it might be interesting to google ‘PEEPS’.  The surprising results … page after page about the marshmallow candies (in English: sweets) which are sold in Canada and the USA.  I have learned something new !

 

What I was trying to find, however, was information relating to Personal Emergency Egress PlanS (PEEPS) for building users with disabilities.  PEEPS is widely referenced in British literature … and because certain people (who should know better) believe that the sun, moon and stars rise over London … it has also seeped into the Irish literature by some process of ‘preverted’ osmosis.  Most regrettable !

 

 

Yesterday, I discussed the inadequacy of developing Fire Safety Management Procedures … or, in fact, designing buildings … with the sole concern being people with disabilities.

 

Taking account of all the relevant, and different, types of European and National Legislation … the Rule of Thumb should always be People with Activity Limitations and Accessibility for All.

 

 

While fully understanding the need for a catchy acronym … ‘PEEPS’ does not respond well to internet searches on Google.

 

The next unfortunate feature of Personal Emergency Egress PlanS is the misguided use of Fire Engineering Terminology in English …

 

 

Evacuation from a Fire Building

To withdraw, or cause to withdraw, all users from a fire building in planned and orderly phased movements to a Place of Safety remote from the building.

 

Egress

Independent emergence of user(s) from a building, under normal ambient conditions, and removal from its immediate vicinity.

 

Escape

Avoidance of injury or harm which is threatened by imminent danger.

 

 

Instrumental Aggression

Aggression which is a means to another end, e.g. pushing someone aside to escape from danger.

 

 

Whenever, therefore, the terms ‘evacuation’, ‘egress’ and ‘escape’ are used interchangeably … on the same occasion … and without apparent rhyme or reason … it is time to call a halt to proceedings … and to scream “bullshit – moráns at work” !   Furthermore … the word ‘escape’ should never be used in connection with fire evacuation from a building.  BSI, CEN and ISO … please take careful note !!!

 

 

A Personal Emergency Egress Plan (PEEP) is fundamentally flawed and discriminatory because it is …

 

         person-specific ;  and

         location-specific.

 

 

Would any able-bodied building user tolerate being told that a document would have to be prepared before he/she could enter and use a building … and that this document would discuss only his/her use of the building … and that use only in specified parts of the building ???   No way !   Are you serious !!   What a joke !!!

 

The relevant, and different, types of European and Irish National Legislation require that buildings be accessible … covering approach to, entry, use, egress (under normal conditions), evacuation (in the event of a fire emergency) and removal from their immediate vicinity.

 

Within this legal environment … PEEPS is fundamentally flawed.  And … because building use is limited for specified individuals to specified areas only … PEEPS is also discriminatory.

 

 

If there is to be recourse to PEEPS, it should be in very exceptional circumstances only !   And, I can certainly think of one possible situation … existing buildings of historical, architectural and cultural importance … where anything more than moderate interference with the building fabric is both ill-advised and restricted … and everyone’s use of the building must be curtailed to some extent.

 

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