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‘Sustainability’ – New Part 11 in India’s National Building Code !

2013-03-17:  Happy Saint Patrick’s Day !!

Submissions on India’s Draft Amendment No.1 to the 2005 National Building Code (SP 7:2005) concerning the Proposed Incorporation of a New Part 11: ‘Approach to Sustainability’ had to arrive at the Bureau of Indian Standards (BIS), in Dilli … by e-mail … no later than Friday last, 15 March 2013 …

Indian National Building Code Proposed New Part 11: 'Approach to Sustainability' - Cover Memo

Click to enlarge.

Indian NBC, Proposed Part 11 on ‘Sustainability’ – December 2012 Consultation

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Extract From Foreword (Page 7):

‘ Developed nations’ approach to sustainability generally concentrates on energy conservation through high technology innovations, and use of products, materials and designs with lower embodied energy.  Their green ratings are based on intent, which implies expert inputs and simulation.  The Indian construction industry will do better using our traditional wisdom and practices, building in harmony with nature through regional common knowledge, consuming as little as necessary, applying low cost technology innovations, using recycled materials, and recognizing performance (not intent) through easily measurable parameters wherever feasible.’

How Right They Are About Prioritizing ‘Real’ Performance !!

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And Just Before That Extract Above:

‘ The authentic (my insert !) Indian way of life is aparigraha (minimum possessions), conservation (minimum consumption), and recycling (minimum waste).  These three attributes are the guiding principles for sustainable buildings as well.  With these attributes and its rich heritage, India can make a substantial contribution in this field and eventually lead the world on the path of sustainability.’

An Overly Ambitious Target ?   Perhaps Not.

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SDI Supporting India’s National Sustainable Buildings Strategy …

We very much welcome this opportunity to make a Submission on India’s Draft Amendment No.1 to the 2005 National Building Code (SP 7:2005) concerning the Proposed Inclusion of a New Part 11 ‘Approach to Sustainability’.

This IS an important development for India … and it DOES mark a substantial contribution to this field, at international level.  We wish that other countries would follow your example … particularly China, the other mushrooming economies in South-East Asia, and the Arab Gulf States.

You may not be aware that Sustainable Design International (SDI) has been specializing in the theory and implementation of a Sustainable Human Environment (social, built, virtual, and economic) since the mid-1990’s.

And, for example … in September 2007, we were invited to make a series of Keynote Presentations to 20 Senior National Decision-Makers, from both the public and private sectors, at a 2-Day Workshop which was organized for us in Lisboa, Portugal.  If invited, we would be delighted to repeat this valuable exercise in Dilli, Bengaluru, and other suitable venues in India.

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IF India is to lead the world on this particular track, i.e. Sustainable Buildings, a coherent philosophy must be outlined in the Proposed New Part 11 of the National Building Code, and a clear direction must also be given there to decision-makers, e.g. clients/client organizations, and designers.

Certain essential content must be included in Part 11.  With regard to an improved layout of Part 11, please review the attached  SDI Document: ‘SEED Building Life Cycle’ (PDF File, 55 Kb) .

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Because you have prioritized ‘real’ building performance over pre-construction design ‘intent’, it is appropriate to begin our comments here …

1.   Sustainability Performance Indicators

In order to prioritize ‘real’ performance, the monitoring of actual sustainability performance in completed and occupied buildings must be comprehensive, accurate and reliable.  Indicators of sustainability performance must, therefore, be included in all sections of the Proposed New Part 11.

Sustainability Performance Indicators provide important signposts for decision-making and design in many ways.  They can translate physical and social science knowledge into manageable units of information which facilitate the decision-making and design processes.  They can help to measure and calibrate progress towards sustainable development goals, and sectoral sustainability targets.  They can provide an early warning to prevent economic, social and environmental damage and harm.  They are also important tools to communicate ideas, thoughts and values because, as statisticians say: “We measure what we value, and value what we measure”.

Performance Indicators may be both quantitative and qualitative … but must cover all stages of the building process, i.e. project feasibility and performance specification, spatial planning, design, construction, management, operation, maintenance and servicing, de-construction, disposal, final site clean-up and sustainable repair.

While many, though not all, types of building performance can be successfully monitored using lightweight portable equipment … a certain number of monitoring devices must also be permanently installed in the building during construction.  A facility to reliably feed the output from these devices back to data collection points, on site and remote, must also be incorporated in the Building’s Intelligent Management System.

Management and collation of sustainability performance data must be reliable.  Uncertainty is always present.  Therefore, Statements of Uncertainty should always be attached to ‘reliable’ data.

Safety Factors should always be included when targeting critical ‘health and safety’ related types of performance.

Sustainability Performance Indicators must be directly comparable across different Global Regions … within Asia, across different countries … and within India, across different States.  A Balanced, Harmonized Core Set of Indian Performance Indicators should be quickly developed.  A Balanced ‘Local’ Set of Performance Indicators will always be necessary.

People tasked with monitoring sustainable building performance must be competent … and independent, i.e. be unconnected to client, design and construction organizations.

Specifically in relation to Energy Performance, the targets to be achieved in new buildings must be far more ambitious.  Please review the attached  SDI Document: ‘SEED Positive Energy Buildings’ (PDF File, 29 Kb) .

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2.   Properly Defining ‘Sustainable Development’

As currently drafted … Definition 2.26 Sustainable Development, on Page 13 of the Proposed New Part 11, is not only ambiguous, it is inadequate for India’s needs … and it is barely the first half of the full, correct definition …

Sustainable Development  is development that meets the needs of the present without compromising the ability of future generations to meet their own needs.  It contains within it two key concepts:

  • the concept of ‘needs’, in particular the essential needs of the world’s poor, to which overriding priority should be given ;  and
  • the idea of limitations imposed by the state of technology and social organization on the environment’s ability to meet present and future needs.

[ Please refer to the 1987 Report of the World Commission on Environment & Development (WCED): ‘Our Common Future’ – Chapter 2, Paragraph 1.]

This original definition in the 1987 WCED Report IS appropriate for India … and it must become the core definition at the heart of India’s National Sustainable Buildings Strategy !

A careful reading of the full definition makes it clear that there are Many Aspects to this intricate, open, dynamic and still evolving concept … the most important of which are:  Social, Economic, Environmental, Institutional, Political, and Legal.

It is a Fundamental Principle of Sustainability, and one of its Primary Values … that Implementation must be Synchronous, Balanced and Equitable across All Aspects of Sustainability.

The ‘Green Agenda’ merely considers Environmental Aspects of Sustainability … in isolation from all of the other Aspects !   This is a fatal flaw which must be avoided in the Proposed New Part 11 !!

[ I made many references to this issue during the FSAI Conferences in India ! ]

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3.   Sustainability Impact Assessment (SIA) for India !

Rather than Environmental Impact Assessment … surely the Proposed New Part 11: ‘Approach to Sustainability’ must now use, explain and discuss Sustainability Impact Assessment instead !?!

Sustainability Impact Assessment (SIA)

A continual evaluation and optimization assessment – informing initial decision-making, or design, and shaping activity/product/service realization, useful life and termination, or final disposal – of the interrelated positive and negative social, economic, environmental, institutional, political and legal impacts on the synchronous, balanced and equitable implementation of Sustainable Human & Social Development.

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4.   A Robust Legal Foundation for ‘Sustainable Human & Social Development’

Paragraph 4 (Chapter 2, 1987 WCED Report) states …

‘ The satisfaction of human needs and aspirations is the major objective of development.  The essential needs of vast numbers of people in developing countries – for food, clothing, shelter, jobs – are not being met, and beyond their basic needs these people have legitimate aspirations for an improved quality of life.  A world in which poverty and inequity are endemic will always be prone to ecological and other crises.  Sustainable development requires meeting the basic needs of all and extending to all the opportunity to satisfy their aspirations for a better life.’

Trying to list the essential needs of people / the basic needs of all is a very difficult task … but it is work which has been on-going, at international level, since just after the Second World War.

The essential needs of people / the basic needs of all … are specified as being Human Rights and Fundamental Freedoms, and are already fully described within the extensive framework of International Legal Rights Instruments.

Which is why, many years ago, SDI developed this definition for Sustainable Human & Social Development … in order:

  • to give this concept a robust legal foundation ;   and
  • (because of widespread confusion in media, political and academic circles) … to clearly establish that we are talking about sustainable human and social development, and not sustainable economic development, or any other type of development !

Sustainable Human & Social Development

Development which meets the responsible needs, i.e. the Human & Social Rights*, of this generation – without stealing the life and living resources from future generations … especially our children, and their children … and the next five generations of children.

*As defined in the 1948 Universal Declaration of Human Rights.

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5.   Climate Change Adaptation & Resilient Buildings in India ?

Atmospheric Ozone Depletion and Climate Change are mentioned, here and there, in the Proposed New Part 11.  The important implications of these phenomena for Sustainable Building Design in India are not explained … at all.  Why not ?

To properly respond to these phenomena, both must be integrated into India’s National Sustainability Strategies & Policies.

At the very least … we strongly recommend that Design Guidance on Climate Resilient Buildings be immediately drafted.  This guidance must be appropriate for implementation in each of the different climatic regions of India.

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6.   A Sustainable Indian Built Environment which is Accessible for All !

Barrier Free is mentioned, here and there, in the Proposed New Part 11.  This is to be warmly welcomed and congratulated.  Under Social Aspects of Sustainable Human & Social Development … this is an essential attribute of a Sustainable Built Environment !   However, no guidance on this subject is given to decision-makers or designers.  Why not ?

However, you should be aware that India ratified the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) on 1 October 2007.  For your convenience, I have attached copies of the Convention in English, Hindi and Tamil.

You should also be aware that, in December 2011, the International Standards Organization (ISO) published ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’.  In its Introduction, ISO 21542 is directly linked to the U.N. Convention … almost like an umbilical cord.  The scope of this Standard currently covers public buildings.  As the Accessibility Agenda in the U.N. Convention is very broad … much standardization work remains to be finished at international level.

The correct term … Accessibility for All … 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 from another person 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.

In order to fulfil India’s legal obligations as a State Party to the U.N. Convention on the Rights of Persons with Disabilities … adequate Design Guidance on Accessibility must be included in the Proposed New Part 11, supported by ISO 21542.

In addition, the Bureau of Indian Standards (BIS) should immediately adopt ISO 21542 as the Indian National Standard on Accessibility for All … IS / ISO 21542.

[ I made many references to this issue during the FSAI Conferences in India ! ]

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7.   Fire Safety & Protection for All in Sustainable Indian Buildings ?

Yes … there is 1 mention of ‘fire safety’ and 40 other references to ‘fire’ in the Proposed New Part 11 … but no design guidance.  Why not ?

You should be aware that there is a fundamental conflict between Sustainable Building Design Strategies and the current state-of-the-art in Fire Engineering Design.  As a good example … for cooling, heating and/or ventilation purposes in a sustainable building, it is necessary to take advantage of natural patterns of air movement in that building.  On the other hand, fire engineers in private practice, and fire prevention officers in Authorities Having Jurisdiction (AHJ’s), will demand that building spaces be strictly compartmented in order to limit the spread of fire and smoke … thereby dramatically interfering with those natural patterns of air movement.

In everyday practice, there is a vast chasm in understanding and communication between these two very different design disciplines.  As a result, serious compromises are being enforced on Sustainability Building Performance.  If, on the other hand, adequate independent technical control is absent on the site of a Sustainable Building … it is the fire safety and protection which is being seriously compromised.

A range of critical fire safety issues (fatal, in the case of firefighters) are also arising with the Innovative Building Products and Systems being installed in Sustainable Buildings.

Because the emphasis is on pre-construction design ‘intent’ rather than the ‘real’ performance of the completed and occupied building … all of these problems are being conveniently ignored, and they remain hidden from everybody’s view.

This must be addressed in the Proposed New Part 11.

[ I made many references to this issue during the FSAI Conferences in India ! ]

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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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Ireland’s Draft National Radon Control Strategy – A Fraud !!

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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END

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