National Building Regulations

BER Certificates & Necessary Sectoral Infrastructure (IV)

2009-03-14:  The Construction Sector Comedy of Errors continues without intermission …

 

On Tuesday last, 2009-03-10, I attended a Conference in Dublin Castle: ‘Energy Efficiency in Historic(al) Buildings’, organized by the Department of the Environment, Heritage & Local Government (DEHLG) and the Irish Georgian Society.  Boys and girls … we are in trouble … flat, uninspiring presentations from our beloved DEHLG policy makers.  Missing … any wider context of required energy efficiency targets across the whole of the built environment … or views and solutions from anywhere else beyond our two little islands (Ireland & GB) on the periphery of Europe.  The approach taken to this important subject was “let’s just jump in, and see what we can do”.  What a day !

 

[Note: Thanks also to the DEHLG … Ireland still has no National Climate Change Adaptation Policy.]

 

That same morning, on Tuesday, an Opinion Piece: ‘Research Hub Benefits All’ appeared in The Irish Times (page 13), written by no other than Mr. Kieran McGowan, Chairperson of CRH.  He was full of suggestions about research in Ireland, and was most happy to support the proposed research alliance between University College Dublin (UCD) and Trinity College Dublin (TCD).  However, a quick visit to the CRH Holding Company WebSite is both relevant and informative.  There, you will learn that the Company operates in 35 countries, employing approximately 93,500 people.  Entering the key words/phrases … ‘research’, ‘construction research’, and even ‘building research’ … into the site search engine yields nothing of value … that’s right … nichts, nada, niente, zilch, zero !   With all the window dressing about Corporate Social Responsibility (CSR), etc, etc … the principal ‘value’ in CRH still remains short term ‘shareholder value’.  If it looks interesting, gobble it up.  Why waste money on a Research Division ? … which should be located in Ireland !

 

 

Yesterday, 2009-03-13, another Article appeared in The Irish Times (bottom of page 5): ‘Ireland Closer to Kyoto Emissions Target Due to Economic Slump’, by Mr. Harry McGee, IT Political Staff (?).  The Environmental Protection Agency (EPA) Press Release which generated this newspaper article was released on Wednesday, 2009-03-12, at 17.59 hrs. in the evening.

 

The 19-Page EPA Report: ‘Ireland’s Greenhouse Gas Emission Projections 2008-2020’ was issued on the same day as the newspaper article – 2009-03-13.  Excellent media management !

 

These three different texts fail to examine, or even discuss, the following issues …

 

         How many € Millions and € Millions belonging to the Irish Tax Payer are being spent, and will be spent into the far future, on buying this country out of trouble … because of the abject failure to meet our responsibilities under Kyoto I (up to 2012), and the Real EU 2020 Target of -30% GHG Emissions on 1990 levels (assuming there will be an agreement in Copenhagen, next December, on a Post-2012 Kyoto II Instrument).  This has always been the EU Target.  See Paragraph 31, German Presidency Conclusions of the Brussels European Council (8 & 9th March 2007).

 

         Having seen the numbers and range of assumptions which underpin the EPA’s GHG Emission Projections up to 2020 … how Reliable are those projections ?   Where are the critical Statements of Uncertainty ?

 

         Who are the Individuals who sat on their fat, over-paid asses throughout the last 10-15-20 years, and allowed this country to fall into such a haphazard state ?   Would any of these individuals be the same people who are now preaching sermons on ‘responsible’ GHG Emission Compliance … and still foisting upon us Voluntary Codes of Practice and Compliance Schemes, Ineffectual National Marketing Campaigns, Feather Light Regulation, and Press Releases which obscure what is really happening ?

 

Do you see any parallels with current events in the Irish Financial Sector ?

 

         Can the Irish Construction Sector be expected to meet any Real Performance Targets (e.g. Proper Building Energy Rating Labelling, Meaningful GHG Emission Reductions, Serious Energy Efficiency Improvements, whatever … ) – as distinct from Theoretical Performance on paper – without a Very Necessary Sectoral Infrastructure capable of shaping suitable responses to those targets, and ensuring that they are implemented ?

 

 

 

As already discussed in an earlier Post … a Complete Cultural Shift in the Irish Construction Sector is essential.  So, let me give you a small flavour of what we need to do …

 

 

1.  Construction Data & Statistics:

 

Ireland does not currently possess a comprehensive National Construction Database.  No reliable statistics can be presented with regard to building or construction-related performance in 1990, or 2005.  No coherent projections, therefore, can be made for the years 2010, 2012, 2020 or 2050 … under any futures scenario.

 

The Central Statistics Office (CSO) gathers construction-related Economic Data.  Energy Ireland (SEI) Databases are not reliable.

 

Construction is not identified as a separate Sector, by either the Environmental Protection Agency (Ireland) or the European Environment Agency (Denmark), in European Greenhouse Gas Emission (GHG) Databases.

 

 

 

2.  A Concerted Programme of Infrastructure Restoration:

 

         Re-establish and adequately resource an Independent National Institute for Spatial Planning & Construction Research (formerly known as An Foras Forbartha) in Ireland, having joint responsibility with the CSO for maintaining a reliable National Construction Database.

 

Construction Research & Innovation must be given a high national priority !   

 

The National Institute must establish close working relationships with the relevant European Union Institutions, particularly EuroStat in Luxembourg.

 

[By ‘independent’ … I mean at a long, long, long arm’s distance away from the Department of the Environment, Heritage & Local Government (DEHLG).]

 

         Re-establish and adequately resource an Independent and Fully Accredited National Construction Testing & Development Complex.

 

         Re-Format, Revise & Horizontally Integrate the National Building Regulations.

 

The existing format is both limited and seriously flawed.  For discussion in a later Post.

 

         Adequately resource the Irish National Accreditation Board (NAB), and closely monitor the quality of its work.

 

         Adequately resource the National Standards Authority of Ireland (NSAI) and ensure that Ireland participates vigorously in the European Standards Organizations and ISO (International Standards Organization).

 

         Adequately resource an Independent Irish Agrément Board (IAB), and closely monitor the quality of its work.

 

[By ‘independent’ … I mean at a long arm’s distance away from the National Standards Authority of Ireland (NSAI).  These two organizations were supposed to have been separated a few years ago anyway.]

 

         Adequately resource awareness raising and Institutional Capacity building for Sustainability and Climate Change Adaptation in the Department of the Environment, Heritage & Local Government (DEHLG), Energy Ireland (SEI) and the Construction Industry Federation (CIF).

 

         Adequately resource awareness raising, Re-Training and Re-Education for Sustainability and Climate Change Adaptation at all levels in the rest of the Construction Sector, including All (Professional) Design Disciplines and All Construction Organizations.

 

 

 

3.  Initial Construction Quality:

 

Post-completion repairs and/or system retrofitting always involve compromises, are costly and are rarely anywhere near being 100% effective.  Ensure Proper Initial Construction Performance through robust inspection of buildings during construction … checking that all relevant legislation has been complied with and that construction products have been approved, i.e. properly shown to be ‘fit for their intended use (in the location of use)’, etc.

 

         Adequately resource, with Staff (e.g. building controllers, inspectors, administrative, legal), Monitoring Equipment (e.g. sound meters, long wave infra-red cameras, etc.) and Technical Support (e.g. training, library facilities, access to research) … all Building Control Authorities in the country.

 

Introduce a fully Integrated (including Part B of the Building Regulations) and Mandatory Inspection Scheme on all Construction Projects, at the following Construction Stages …

 

Foundations ;

Drainage ;

Ground Floor Construction ;

Super-Structure (above Radon Resisting Membrane) … inspections to take place at a level no higher than first floor ;

Roof.

 

Such an Inspection Scheme must operate uniformly across the country.  Piecemeal variations and maverick procedures operated by National Authorities Having Jurisdiction (AHJ’s) or Individual Local Authorities cannot any longer be tolerated.

 

 

 

4.  Consumer Protection:

 

         Establish an Independent and Comprehensive National Building Insurance Scheme.

 

Self-Regulation by the Architectural and Legal Professions offers merely the ‘appearance’ of protection to the Irish Consumer.

 

The current system of Royal Institute of the Architects of Ireland (RIAI) / Law Society ‘Opinions on Compliance with Building Regulations’ is inadequate … and offers no protection to the Irish Consumer.  The phrase ‘substantial compliance’ is much misunderstood and widely abused.

 

         Introduce and adequately resource the discipline of Independent Technical Controller.  He/she must be independent from Construction-related Organizations, the Building Design and Legal Professions … Local Authorities … and any other National Authorities Having Jurisdiction (AHJ’s).

 

         Introduce a Mandatory Building Completion Certification System.

 

Before any Building can be occupied, a Certificate of Building Completion Performance, and an Accompanying Report, must be issued by an Independent Technical Controller.  The System will include an independent evaluation of compliance with relevant building legislation and a thorough examination of ‘real’ construction performance.

 

Building Completion Documentation can be designed to include …

         a Fire Safety Certificate, which is issued only after adequate monitoring of the actual fire safety related construction ;

         a Disability Access Certificate, which is issued only after adequate monitoring of the actual access related construction ;

         a Building Energy Rating (BER) Label ;

         a Sustainability Impact Assessment (SIA) ;

         etc., etc.

 

 

 

[Many of the above ideas have been incorporated in the 2008 Institute of International & European Affairs (IIEA) Publication: The Climate Change Challenge, which presents a strategic overview of Irish Climate Change Policy.]

 

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Quality of Irish Construction – Unacceptable ?

2009-02-12:   So … Anglo-Irish Bank has been caught – finally – playing with numbers and cooking the books.  And … because of inadequate (i.e. a complete lack of effective) control by the National Financial Regulator, this was regarded as a routine, ‘smart’ transaction by privileged individuals.  “What is the problem ?” … they ask … “no laws were being broken”.

 

Holding firmly onto those thoughts, let us briefly turn our attention to the Construction Sector … and the Energy Performance of Buildings …

 

A new Home Energy Savings (HES) Scheme was recently announced by Mr. Eamon Ryan T.D., Minister of Communications, Energy & Natural Resources … €100 million Insulation Scheme to Benefit 50,000 Homes – Programme Will Create 4,000 Jobs … according to an article in The Irish Times, on Monday 9th February 2009, by Mr. Harry McGee.

 

Reading the Department of Energy’s own Press Release for the Scheme Launch, dated 2009-02-08 … it is evident that public relations consultants, marketing gurus, senior academics (who should know better) and civil servants were involved in producing ‘paper’ numbers to justify and support the miserable grants being offered in the HES Scheme.  Numbers were even presented for ‘Typical Net BER Improvement’ ?!?

 

When the Scheme is eventually up and running, Thermal Insulation Contractors will be required to comply with a voluntary Energy Ireland (SEI) ‘Contractors Code of Practice & Standards and Specifications Guidelines’ (version 1, 2009-02-03) … and SEI may or may not carry out control inspections in order to monitor the quality of their work.  Does all this sound familiar ?

 

 

But … are these paper energy numbers ‘real’ ?   If he thinks so, Mr. Eamon Ryan is living in Alice’s Wonderland !

 

This is a photograph, taken back in 2000, of expanded polystyrene insulation which was badly installed in an external cavity wall … very badly installed !   When the Irish Construction Industry would later enter extreme ‘over-heat’ mode, the quality of typical construction would deteriorate sharply.

 

Colour Photograph of an External Cavity Wall, showing 'Floating' Thermal Insulation (and, in the background, an Inclined Steel Wall Tie which will later facilitate water ingress). Click to enlarge. Photograph taken by CJ Walsh. 2000-01-19.

Colour Photograph of an External Cavity Wall, showing ‘Floating’ Thermal Insulation (and, in the background, an Inclined Steel Wall Tie which will later facilitate water ingress). Click to enlarge. Photograph taken by CJ Walsh. 2000-01-19.

Who can know what is happening inside that cavity when it is all finished and covered up from view ?   Nobody.  Unless, that is, you manage to take an Infra-Red Thermal Image during the next winter heating season – which is far too late to remedy the problem.

 

This is an example of an Infra-Red Thermal Image, taken back in 1998 …

 

Colour Image, with explanatory Text and Horizontal Temperature Bar below, showing the 'Real' Energy Performance of a Building. Click to enlarge. Project Architect: CJ Walsh. Image taken by sub-contractor in 1998.

Colour Image, with explanatory Text and Horizontal Temperature Bar below, showing the ‘Real’ Energy Performance of a Building. Click to enlarge. Project Architect: CJ Walsh. Image taken by sub-contractor in 1998.

 

 

Explaining the Current Context in Ireland …

 

It was 10 Years after the Dublin Stardust Fire Tragedy (February 1981) … before the first legal, National Building Regulations were introduced (December 1991); they became operational during the following summer of 1992.  Around the same time, Building Control Authorities were being established in every Local Authority.

 

Prior to this, legal Building Bye-Laws were operated in just a small number of our major urban centres.

 

Dublin Corporation’s Bye-Laws with respect to the Construction of Buildings, adopted by Dublin City Council on 27th June 1949, were an interesting mix of functional, performance and prescriptive requirements.  An Application, containing detailed construction information, for Building Bye-Law Approval had to be made for every construction project … and I mean ‘every’ project … prior to any construction commencing.  And, ‘every’ project was inspected at the foundation and drainage stages of construction … no exceptions.  The more complex projects were inspected as they progressed further, with special attention being paid, for example, to fire safety related construction.  I know, first-hand, that the surveyors and inspectors in Dublin Corporation’s (as it was then called) Building Control Section had built up a considerable wealth of knowledge and understanding about construction conditions and practices right around the city and suburbs.

 

Anyway … after the introduction of the National Building Regulations, an unwritten national policy was put into action … having as an aim the winding down, and general ‘castration’, of the large, well-established Building Control Sections in Dublin City and County, and Cork.  Meanwhile … in the rush to establish the new Building Control Authorities throughout the rest of the country, it was common to hear of Road Engineers being transferred into the new Control Authorities … usually having little or no experience in dealing with the construction of buildings.

 

Site Inspections under our current system of National Building Regulations are random.  Inspection Statistics produced by the Department of the Environment, Heritage & Local Government (DEHLG) are not reliable.  Building Control Authorities are, purposefully, not sufficiently resourced to be ‘effective’.

 

Commencement Notices, under the National Building Control Regulations, do not have to be accompanied by detailed construction information when being submitted to a Building Control Authority.

 

Fire Safety Certificates, under the National Building Control Regulations, do not involve any Site Inspections – at any stage – by Fire Authorities.

 

 

 

Some Conclusions …

 

The above is a rather long, but simplified, explanation as to why a large number of privileged property developers and shoddy building contractors have been allowed to flourish on Irish Construction Sites without ever understanding the concept of ‘effective’ technical control.  When they do eventually meet this concept, head-on, the level of their resentment can be without limit.

 

Before the recent property crash, did you ever try to present a builder with a Snag List on a new house ?

 

This will also put SEI’s 70% rate of non-compliance into an understandable context.  See my earlier Post, dated 2008-12-12.

 

With regard to BER Certificates … BER Assessors without any sort of architectural background are not competent to assess the construction of existing buildings … and those BER Assessors with an architectural background cannot possibly evaluate, with reliability, the construction of existing buildings without the use, for example, of Infra-Red Thermography and Air Seepage Testing.

 

BER Assessment of Historical Buildings is unsuitable, and not appropriate.

 

An Energy Survey of a Building is an entirely different concept to a BER Assessment.  See our Technical Guidance Note No.95/101(a).

 

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