Reliability

BREXIT & EU Construction Products Regulation 305/2011 ~ Woeful Implications for Britain’s Fire Industry

2020-09-08:  Ignoring Britain’s silly sabre-rattling, toothless threats and boorish blackmail attempts reported in the Media during this past weekend, yesterday and today … the actual state of play in the tortuous Brexit Negotiations can best be judged from the following sources …

Michel Barnier’s Presentation to the Institute for International and European Affairs (IIEA), on 2 September 2020 … View it Here on YouTube

Britain’s National Audit Office Report: ‘Learning for Government from EU Exit Preparations’, dated 4 September 2020   (Download PDF File, 197 Kb)

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Map of Europe, in colour, showing the current extent of the European Union.  Points to Note:  a) Europe, as a continent, extends as far as the Ural Mountains in Russia;  b) From 1 January 2021, after an implementation period of one year, Great Britain will be entirely outside the EU and the Single Market;  c) The EU is not a Christian organization and as soon the political classes in certain countries (e.g. France and The Netherlands) get over their hysterical hatreds, Turkey will enter the EU as a full Member State;  d) furthermore and eventually, an Independent Scotland will re-join the EU.  Click map to enlarge.

This is the European Union (EU), a Single Market of approximately 450 Million consumers.  The EU operates under the freedoms and protections of Codified / Written Law, i.e. EU Treaties ratified by all of the EU Member States, EU Secondary Legislation (Regulations and Directives), and EU Administrative Provisions.

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A suite of EU Regulations and Directives covers Industrial Products.  While there is some flexibility with regard to how Directives are implemented at national level in the Member States, no such flexibility exists with Regulations.  Construction Products can only be placed on the EU Single Market if they can be shown to comply with the requirements of the EU’s Construction Products Regulation (CPR) Framework, or in other words, be shown to be ‘fit for their intended use’ in the European Union …

REGULATION (EU) No 305/2011 of the European Parliament and of the Council, dated 9 March 2011, laying down harmonised conditions for the marketing of construction products and repealing Council Directive 89/106/EEC   (Download PDF File, 998 Kb)

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EU Regulation 305/2011.  Article 13(2) Before placing a Construction Product on the market, Importers shall ensure that the assessment and the verification of constancy of performance has been carried out by the Manufacturer.  They shall ensure that the Manufacturer has drawn up the Technical Documentation referred to in the second sub-paragraph of Article 11(1) and the Declaration of Performance in accordance with Articles 4 and 6.  They shall also ensure that the Product, where required, bears the CE Marking, that the Product is accompanied by the required documents and that the Manufacturer has complied with the requirements set out in Article 11(4) and (5).

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BREXIT ~ IMPLICATIONS FOR THE BRITISH FIRE INDUSTRY

Trade ‘No Deal’ or ‘Minimal Deal’ … from 1 January 2021, Great Britain will be completely outside the European Single Market, and the EU’s Construction Products Regulation Framework.  The designation ‘Notified Body’ under that Framework will fall away from British Organizations.  Construction Products/Systems manufactured in, or supplied from, Britain will then have to undergo an entirely new EU Testing and Approvals Programme in order to access the European Single Market.  Fire Safety related Construction Products will have to be tested, and assessed or appraised, against all 7 Basic Requirements for Buildings together, during the same period of time (see Annex I, EU Regulation 305/2011) …

      1.  Mechanical Resistance and Stability
      2.  Safety in Case of Fire
      3.  Hygiene, Health and the Environment
      4.  Safety and Accessibility in Use
      5.  Protection against Noise
      6.  Energy Economy and Heat Retention
      7.  Sustainable Use of Natural Resources

… a process which will be very interesting to observe, since the Fire Industry (particularly England’s Fire Establishment, AHJ’s, etc) dislikes, with intensity, the whole idea of ‘environmental impact’ … the concept of ‘sustainable development’ is hardly understood … and no consideration is given to the reasonable fire safety and accessibility needs of ‘vulnerable building users’ (including people with activity limitations, refugees, migrants, etc).

The tragic 2017 Grenfell Tower Fire, and its sad aftermath, have demonstrated how dysfunctional, and rotten to the core, is the whole national system of Building Fire Safety in England.  More than 3 years later … on the evidence to date of an ongoing, incompetent Inquiry and a series of shoddy responses from Government … will survivors and the victims’ families ever receive Justice, and find Peace ?   cf. The 1981 Stardust Discotheque Fire in Dublin.  Survivors and victims’ families are still waiting for the truth to be revealed.

In parallel, mutual recognition of British Professional Building Designers, e.g. Architects, Structural Engineers, Fire Engineers, etc., within the European Union will cease.

In parallel, British Fire Research involvement in EU Research Networks will also cease … unless a heavy price is paid to be involved as a 3rd Country.  British Institutions should forget any notions they might have about Network Leadership.

In parallel, Information and Data Flows between Britain and the EU will be disrupted or cease altogether … unless Britain complies fully with the requirements of EU General Data Protection Regulation (GDPR) 2016/679.  As a vassal state of the USA, this compliance may prove difficult for Britain !

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EU Fire Safety Related Product/System Manufacturers ~ A Word of Caution !

Many EU Construction Product/System Manufacturers continue to use the services provided by British Fire Test Laboratories and/or Fire Consultancy Organizations located in Great Britain … some of which have already established EU-based dummy companies and letterheads.  These British organizations must be avoided altogether.  For example, the practice of fire testing in England and later adding a title page of a Full Test Report with an EU location address is entirely unacceptable !

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#Twitter … @walshcj69 …

#Sustainability #Brexit #EU #England #MichelBarnier #GB #PerfidiousAlbion #ConstructionProducts #FireSafety4ALL #VulnerableBuildingUsers #EnvironmentalImpact #SustainableDevelopment #BrexitTrainCrash #BorisCummings #BuildingDesigners #FireEngineers #Architects #Turkey #Scotland #EuropeanUnion #NationalAuditOffice #NobodyLeftBehind #TechnicalControl #FireCodes #SFE #SIA #SustainableFireEngineering #Resilience #Reliability #GrenfellTowerFire #StardustDiscoFire #Dublin #CEmark #FireResearch #GDPR #IIEA #CPRframework #MutualRecognition #Russia #USA #CodifiedLaw #EUtreaties #PwAL

Fire Safety in Buildings – Reliable Design, Supply & Construction

2019-07-31:  A very serious problem in modern buildings (post 1950’s), and in many countries around the world … which can lie dormant and hidden from any and all Surface Inspections … until there is an outbreak of #Fire !

Passive/Active Fire Protection Measures, and Building Management Systems (i.e. any combination of human and smart systems), are never 100% Reliable.  However, Poor Workmanship on Building Sites and Unauthorized Product / System Substitution are reducing this #Reliability to far below the threshold of legal (or any other) ‘acceptability’.

Colour photograph showing a person at work on a construction site.  Is he/she Competent to do this particular work ?  For the task, is he/she using the Correct Tools and Proper Materials (i.e. products/systems which are ‘fit for purpose’) ??  Who is monitoring his/her performance ???  The important objective is a Fire Safe Building for ALL Occupants/Users.  Click photograph to enlarge.

As a result, Fire Evacuation Routes can quickly become full of dense toxic smoke, impairing/incapacitating people trying to evacuate … the integrity of Fire Compartments can very rapidly be compromised, leading to uncontrolled internal fire spread … and Partial Structural Collapse will be a definite probability.

Most in danger and at high risk in ‘real’ building fires are Vulnerable Building Users and #Firefighters !

[ Vulnerable People: Those people – in a community, society or culture – who are most at risk of being physically, psychologically or sociologically wounded, hurt, damaged, injured, or killed … and include, for example, People with Disabilities, Young Children, People with Health Conditions, Frail Older People, Women in Late Pregnancy, Refugees, Migrants, and the Poor. ]

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‘Building Materials and Workmanship’ Must Be Relentlessly Monitored PRIOR TO AND DURING Construction – Afterwards Is TOO LATE !

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In these days of #Architects staring at computer screens all day, not being very ‘smart’ in and around actual construction sites … and with Fire Engineering Design Information still merely a #BIM add-on … there are 5 Fundamental Principles of Reliable Building Design, Product Supply and Construction for Fire Safety :

  1. Design of the works must be exercised by an independent, appropriately qualified and experienced architect/engineer/fire engineer, with design competence relating to the fire protection of buildings ;
  1. The Supply of ‘fit for purpose’ fire safety related construction products/systems to the works must be undertaken by reputable organizations with construction competence, particularly in relation to the fire protection of buildings … and all product/system substitution must be pre-authorized ;
  1. Installation/Fitting of fire safety related construction products/systems must be exercised by appropriately qualified and experienced personnel, with construction competence relating to the fire protection of buildings ;
  1. Supervision of the works must be 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, must be carried out to verify that the works are being executed in accordance with the design.

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Self-Regulation / Self-Monitoring Is NO Regulation / NO Monitoring !!

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Colour photograph showing a larger, more complex construction project … with more complicated working relationships between the Building Design Team, the Principal Construction Organization, Sub-Contractors, and Trades Men/Women.  In this context, the monitoring of Building Materials and Workmanship must be both unrelenting and stringent !  The important objective remains the same: a Fire Safe Building for ALL Occupants/Users.  Click photograph to enlarge.

Incomplete / inaccurate information about the number of People, particularly Vulnerable Building Users, still remaining in a Fire Building, and/or the number of Occupants waiting in Areas of Rescue Assistance and Lift/Elevator Lobbies … all resulting from poor Building Management … will greatly increase the Hazards and Risks involved in Firefighter Search and Rescue Operations, and will result in Building Occupant Injuries and Deaths !

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Mainstream Fire Codes & Standards DO NOT Protect Vulnerable Building Users and Firefighters !!!

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#SFE #Design #ProductSupply #Construction #FireSafety4ALL #FireEngineering #FireProtection #FireCompartment #FireEvacuation #Buildings #FacilityManagement #Resilience #Sustainability #PoorWorkmanship #ProductSubstitution #ProperMaterials #VulnerablePeople #Firefighters

Sustainable Fire Engineering – Recent Dublin Presentations !

2019-03-19:  Two Conference & Exhibition Events were recently held in Dublin’s City West Convention Centre

2019 City West Summits, Dublin – Colour photograph showing the view over the Exhibition Hall.  Click to enlarge.

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I was very pleased to make a Presentation at both events, adapted to suit an Irish context, on … ‘Sustainable Fire Engineering – Necessary Professional Transformation For The 21st Century’ … which continues to evolve.

Sustainable Fire Engineering:  The creative, person-centred and ethical Fire Engineering response, in resilient built form and smart systems, to the concept of Sustainable Human and Social Development … the many aspects of which must receive synchronous and balanced consideration !

Sustainable Fire Engineering
Internet: www.sfe-fire.eu
Twitter: @sfe2016dublin

Presentation Abstract

Annual Fire Losses, both direct and indirect, amount to a very significant percentage of Gross Domestic Product (#GDP) in all economies, whether they are rich or poor … and result in enormous environmental devastation and social disruption.  Some losses have not yet been fully identified, e.g. environmental impact … while others are not yet capable of being fully quantified, e.g. business interruption, brand and reputation damage.  Globally, fire statistics still remain unreliable.  In all cases, however, the waste of valuable human and natural resources caused by preventable fires is unsustainable and no longer acceptable.

From an entirely different perspective … Sustainable Buildings are presenting every society with an innovative and exciting re-interpretation of how a building functions in response to critical energy, environmental, climate change and planetary capacity pressures … an approach which has left the International Fire Engineering and Firefighting Communities far behind in its wake, struggling to develop the necessary ‘creative’ and ‘sustainable’ fire safety strategies.

The Aim of Sustainable Fire Engineering (#SFE) is to dramatically reduce direct and indirect fire losses in the Human Environment (including the social, built, economic, virtual, and institutional environments) … to protect the Natural Environment … and, within buildings, to ensure that there is an effective level of Fire Safety for All Occupants, not just for Some, over the full building life cycle.

The following Priority Themes for SFE lie outside, or beyond, the constrained and limited fire safety objectives of current fire regulations, codes and standards – objectives which do not properly protect society, a fire engineer’s clients, or the facility manager’s organization:

  1. Fire Safety for ALL, not just for Some.  Nobody left behind !
  2. Firefighter Safety.  Everyone goes home !   It is easy to dramatically improve firefighter safety with building design.  So, why haven’t NIST’s 2005 and 2008 WTC 9-11 Critical Recommendations been properly implemented anywhere ?
  3. Property Protection.  Fire damage and post-fire reconstruction/refurbishment are a huge waste of resources.  On the other hand, protection of an organization’s image/brand/reputation is important … and business continuity is essential.  Heritage fire losses can never be replaced.
  4. Environmental Impact. Prevention of a fire is far better than any cure !   But prevention must also begin by specifying ‘clean’ technologies and products.  Low Pressure Water Mist Systems are not only person/environment-friendly and resource efficient … they are absolutely essential in airtight and hyper energy-efficient building types (e.g. LEED, PassivHaus, BREEAM) in order to achieve an effective level of fire safety for all occupants, and firefighters.    [ Note: Environmental Impact Assessment (#EIA) has been superseded by Sustainability Impact Assessment (#SIA).]
  5. Building Innovation, People and Their Interaction.  Fire engineers and firefighters must begin to understand today’s new design strategies.
  6. Sustainable Design and Engineering. Wake up and smell the coffee !   Legislation can only achieve so much.  Spatial planners, building designers and fire engineers must subscribe to a robust Code of Ethics * which is fit for purpose in the Human Environment of the 21st Century.

Sustainable Fire Engineering Solutions are …

  • Adapted to a local context, i.e. climate change/variability/extremes, social need, geography, economy, and culture, etc ;
  • Reliability-based – lessons from real extreme and hybrid events, e.g. 2001 WTC 9-11 Attack, 2008 Mumbai/2015 Paris/2016 Brussels Hive Attacks and the 2011 Fukushima Nuclear Incident, are applied to frontline practice ;
  • Person-centred – real people are placed at the centre of creative endeavours and due consideration is given to their responsible needs, and their health, safety, welfare and security in the Human Environment ;
  • Resilient – functioning must be reliable during normal conditions, and include the ability to withstand, adapt to and absorb unusual disturbance, disruption or damage, and thereafter to quickly return to an enhanced state of function.

* Refer to the 2016 Dublin Code of Ethics: Design, Engineering, Construction & Operation of a Safe, Resilient & Sustainable Built Environment for All (PDF File, 112 kb).

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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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