Ar C.J. Walsh – Consultant Architect, Fire Engineer & Technical Controller – International Expert on : Sustainability Implementation + Accessibility (including Fire Safety) for All + Sustainable Fire Engineering
Sustainable Fire Engineering (SFE) is a Facilitator – no more than Architecture, Structural Engineering, or Spatial Planning – in the task of realizing a Safe, Resilient and Sustainable Built Environment for All. However, SFE has an essential role to fill throughout the difficult journey towards that target. In close collaboration with other design disciplines, many iterations … twists and turns along the road … will be necessary.
Beware Greenwashing !
Sustainability is NOT a graft-on, or an optional extra, to Conventional Fire Engineering. This intricate, open, dynamic and continuously evolving Concept must cut right to the core of everyday design practice, and must positively impact all areas of that practice.
In this third decade of the 21st Century … the Safety Objectives in current Fire Codes / Regulations are limited, inadequate, and lagging far behind today’s creative moulding and re-shaping of the Built Environment ; they are almost, but not entirely, irrelevant in the context of the urgently required transformation of conventional fire engineering. For anybody who cannot see the broad, beautiful landscape beyond codes and regulations … this SFE Road Map is definitely not for you. For those who can see, your constant companion … your compass … will be a Personal Code of Ethics.
Essential Considerations Before Starting Out On The Road …
1.World Trade Centre Attacks in New York City, on 11 September 2001. Two sets of important Recommendations were issued by the U.S. National Institute of Standards and Technology (NIST) in 2005 and 2008. Not only is the implementation of these still incomplete, but the solid progress which has been made e.g. on Firefighter Safety, is continuously under threat from vested interests. Other jurisdictions have tended to ignore the Recommendations. SFE takes full account of this Extreme Man-Made Event.
2.Grenfell Tower Fire in London, on 14 June 2017. Evidence at the Official Inquiry continues to shock and horrify ; the entire fire safety regulatory edifice in England is dysfunctional, and it poses a real and serious danger to Public Health and Safety. Inquiry Phase 1 Recommendations were issued in 2019. Already, the Recommendation concerning Evacuation for Vulnerable Building Users & PEEP’s (#33.22 e and f) has been discarded by AHJ’s … and it has also been stated (#34.14) that as everything about the single narrow staircase in the Tower appeared to be OK, it will not be investigated in Inquiry Phase 2 … a sure sign of dysfunctional dysfunction ! SFE sees beyond these major flaws.
3.Sustainable Buildings Il Bosco Verticale Towers in Milano … this exciting Project, designed by Stefano Boeri and completed in October 2014, has become the International Icon for innovative / environment-friendly construction. These new approaches to building design are posing enormous fire safety challenges. [ Remember back … was it 15 years before fire codes were able to ‘solve’ the Atrium in buildings ? ] SFE, however, must cope with this extraordinary level of architectural creativity ; and Fire Engineering Practitioners must be capable of active participation, collaboratively, within Project Design/Construction Teams.
Looking past the Milan Project … it is important for the reader to experience a more rounded flavour of where the exciting synergy between Creative Design and the Inclusive Language of Sustainability is at present, and where it is tending to go …
4.Building Energy Performance Rating Schemes Under enormous environmental and political pressures, the headlong rush to conserve energy in buildings, and to make them more energy efficient … especially after the 2022 Russian Invasion of Ukraine … is proceeding in blissful ignorance of fire safety and necessary independent technical controls. Measurement of real building performance, after energy refurbishment has been completed, is generally avoided.
The Road Ahead … From Gro Harlem Brundtland To Reliable Fire Statistics …
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
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.
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 …
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) …
Mechanical Resistance and Stability
Safety in Case of Fire
Hygiene, Health and the Environment
Safety and Accessibility in Use
Protection against Noise
Energy Economy and Heat Retention
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 !
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 !
Update 2020-09-01: Although the term ‘Vulnerable People’ remains unaltered, I considered it wise, and very necessary bearing in mind the obvious myopia in the mainstream health, safety and design worlds … clearly demonstrated by the 2017 Grenfell Tower Fire in England, and this current CoronaVirus / CoVID-19 Global Pandemic … to include references to specific social groups …
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, prisoners, the poor, and homeless.
2020-07-20: So many diverse design disciplines and interested groups are involved in the realization, operation and maintenance of a Safe, Inclusive, Resilient and Sustainable Human Environment (built, social, economic, virtual, and institutional) … that the use of simple, easily assimilated language and precise, harmonized technical terminology must be widely exercised. For the effective application of Building Information Modelling (BIM), this is particularly important.
And concerning Fire Engineering, it is not clear when the practice began, but defining a concept simply in terms of performance in a ‘standard test fire’ is entirely inadequate, and fails to explain the actual meaning of the concept.
This Terminology … a body of particular terms, each explaining and defining a single concept, covering inter-related building requirements, e.g. human health, accessibility and fire safety for all, firefighting, social rights, design, performance monitoring, and facility management … takes account of:
Sustainability Impact Assessment (SIA)
WHO International Classification of Functioning, Disability and Health (ICF)
Universal Declaration of Human Rights (UDHR)
U.N. Convention on the Rights of Persons with Disabilities (CRPD)
Fire Engineering Terms … take account of the ‘realistic’ end condition, i.e. a real fire in a real building which is occupied or used by real people with varying behaviour and 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.
General Terms … are also included in order to facilitate a better understanding of:
the complexity of human behaviour and perception (visual, auditory, olfactory, gustatory, tactile and proprioceptive) ;
the wide range of health conditions ; and, more specifically
The words ‘green’, ‘environmental’, ‘ecological’ and ‘sustainable’ are becoming part of everyday language in the Developed World, but are frequently interchanged without understanding. To date, however, the concept of Sustainable Development has been hijacked by Environmentalists. For example, no connection at all may be seen between a ‘sustainable’ building and ensuring that it can be safely and conveniently entered and used by ordinary people.
In other parts of the World, the ambiguous WCED / Brundtland Definition of Sustainable Development is being systematically rejected ; the concept is viewed as an unaffordable luxury and/or as a means of continued domination and control by the ‘North’. Yet, sustainability must be a global compact.
In this intolerant and more fundamentalist 21st Century, the United Nations System, International Law, and Social Justice continue to come under sustained attack. And the Beslan School Tragedy* demonstrates that it is far more hazardous for disadvantaged, vulnerable and indigenous peoples in every society.
Some specific objectives for the 2004 Rio Declaration were as follows …
To present a 2nd Generation Definition of Sustainable Development which is more acceptable to the Developing World ;
To restore primacy to the Social Aspects of Sustainable Development … and particularly the ethical values of Social Justice, Solidarity and Inclusion-for-All ;
To embed the concept of the ‘Person’ in Sustainable Development … rather than the fleeting reference to ‘People’ which too often results in Disadvantaged, Vulnerable and Indigenous Groups being left behind ;
To signal one of the main challenges of Sustainable Development ahead – which will be to establish a framework of horizontal co-ordination at the many institutional levels … and between the many actors and end users … in the human environment.
Adopted in December 2004, at the Brazil Designing for the 21st Century III Conference, the Rio Declaration consists of a Preamble, 10 Principles and 5 Appendices ; its central concern involves People with Activity Limitations (2001 WHO ICF).
This Declaration extols implementation, and the targeting and monitoring of ‘real’ performance – as opposed to ‘imagined’ or ‘paper’ performance.
Essential Considerations for National Authorities Having Jurisdiction (AHJ’s):This Planet is Our Common Home – Be a Good Neighbour to Other Countries (Cuba is a Good Example, USA is a Bad Example) … Global Solidarity & Multilateral Collaboration in Co-Operation with the World Health Organization (WHO) … Act Fast … Perfection is the Enemy of the Good … The Precautionary Principle … Test-Test-Test … Return Test Results within 24 Hours … Trace Contacts within the Next 24 Hours … Collect, Collate and Openly Share Reliable Data & Statistics … Vulnerable People Require Equitable Safety Measures … Uphold and Protect Human & Social Rights.
[ 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, Prisoners, the Poor, and Homeless. ]
Essential Considerations for Each Person in a Community: Wash Hands Often and Properly (see Video below) … Wear a Mask in Outdoor and Indoor Public Spaces (see WHO Guidance below) … Social Separation / Physical Distancing … Be Careful, Always … Pay Attention to Your Mental Health (see UN Policy Brief below).
First Affiliated Hospital, Zhejiang University School of Medicine, China
The First Affiliated Hospital has treated 104 patients who tested positive for CoVID-19 in 50 days. It has achieved zero deaths in patients diagnosed, zero patients misdiagnosed, and zero infections in medical staff. Its experts documented real treatment experience when combating the virus, 24 hours a day, and quickly published this Handbook.
Public Health Emergencies often lead to Stigma, Discrimination and Abuse towards certain communities and social groups, or affected people. Within the context of CoVID-19, this has already happened … with the disease being recklessly and maliciously associated with a specific population or nationality.
Independent Oversight & Advisory Committee for the WHO Health Emergencies Programme
Established to facilitate on-line communication and collaboration internationally, as well as to provide Frontline Medical Teams around the world with the necessary communication channels to share practical experience about fighting, controlling and overcoming the pandemic.
The European Commission, together with several Partners, launched this Platform on 20 April 2020 … to enable the rapid collection and sharing of available Research Data. The Platform, part of the ERAvsCorona Action Plan (download PDF File, 153 Kb), is a significant effort to support Researchers in Europe and around the World in the fight against the CoronaVirus pandemic.
Vulnerable People, such as Those with Activity Limitations (#PwAL) or Disabilities (#PwD), are more impacted by #CoronaVirus/#CoVID19. These impacts can be mitigated if simple Self-Protection Measures are taken.
As Fire Departments and local Authorities Having Jurisdiction (AHJ’s) continue planning to respond to CoronaVirus/CoVID-19 occurrences in their communities, the IAFC Coronavirus Task Force has developed a guide to identify best practices … and key recommendations which are based largely on guidance from the U.S. Centers for Disease Control and Prevention (CDC – https://www.cdc.gov/) and the World Health Organization (WHO – https://www.who.int/emergencies/diseases/novel-coronavirus-2019). When planning for CoVID-19, Fire Chiefs must also be sure to collaborate with local Stakeholders, both individuals and organizations !
2020-03-24: Established relatively recently, in 2015 … the Lafcadio Hearn Japanese Gardens are located in Tramore, County Waterford, in the south-east of Ireland. Who Patrick Lafcadio Hearn (1850-1904) was, his Irish heritage, his historical links with Japan, and the layout of the Irish Gardens … can all be found at: http://lafcadiohearngardens.com/
Some special Sights & Sounds from a Visit to the Japanese Gardens on 13 March 2020 …
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 !
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:
Fire Safety for ALL, not just for Some. Nobody left behind !
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 ?
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.
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).]
Building Innovation, People and Their Interaction. Fire engineers and firefighters must begin to understand today’s new design strategies.
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.
The creative, person-centred and ethical fire engineering response – in resilient built or wrought form, and using smart systems – to the intricate, open, dynamic and continually evolving concept of Sustainable Human & Social Development … the many aspects of which must receive balanced and synchronous consideration.
SFE PRIORITY THEMES
1. Fire Safety for ALL – Not Just for SOME People. Nobody Left Behind !
Do Building Designers and Fire Engineers have any understanding of what it feels like to be left behind in a fire emergency … perhaps to die ?
Do Building Designers and Fire Engineers have any understanding of the ‘real’ people who use their buildings … or their ‘real’ needs ?
2. Firefighter Safety – It’s So Easy to Dramatically Improve Their Safety At A Fire Scene ! A Firefighter’s Protective Clothing and Equipment are not enough !
Conscious awareness of this issue by Building Designers and Fire Engineers is required … and appropriate education/training.
3. Property Protection – A Minor Code Fire Safety Objective, Insofar As It Is Necessary to Protect the Safety of Building Users … Only !
Fire damage and post-fire reconstruction/refurbishment are a huge waste of resources. On the other hand, protection of an organization’s image/brand is important … and business continuity is essential.
Heritage Fire Losses cannot be replaced !
To properly protect Society and the interests of a Client/Client Organization … Building Designers and Fire Engineers are ethically bound to clearly explain the limitations of Code and Standard Fire Safety Objectives to their Client/Client Organization.
4. Environmental Impact – Prevention Is Far, Far Better Than Cure. Instead of resisting, and erecting ‘professional’ barriers … Spatial Planners, Building Designers and Fire Engineers must begin to properly understand this concept … and act ethically to defend and protect the environment !
Environmental Impact: Any effect caused by a given activity on the environment, including human health, safety and welfare, flora, fauna, soil, air, water, and especially representative samples of natural ecosystems, climate, landscape and historical monuments or other physical structures, or the interactions among these factors ; it also includes effects on accessibility, cultural heritage or socio-economic conditions resulting from alterations to those factors.
This Planet – Our Common Home – can no longer suffer the scale and extent of total devastation seen after the 2015 Tianjin (China) Regional Fire Disaster !
5. Building Innovation, People and Their Interaction – Fire Engineers and Firefighters must understand current approaches to more sustainable building design, the ‘real’ people who use the built environment, and the complex interactions between both.
People with Activity Limitations (E) / Personnes à Performances Réduites (F): Those people, of all ages, who are unable to perform, independently and without aid, basic human activities or tasks – because of a health condition or physical/mental/cognitive/psychological impairment of a permanent or temporary nature.
The above Term, in English and French, includes …
people who experience difficulty in walking, with or without a facilitation aid, e.g. stick, crutch, calliper or walking frame ;
wheelchair users ;
the very young (people under 5 years of age), frail older people, and women in the later stages of pregnancy ;
people who are visually and/or hearing impaired ;
people who suffer from arthritis, asthma, or a heart condition … or any partial or complete loss of language related abilities, i.e. aphasia … or who have a cognitive impairment disorder, including dementia, amnesia, brain injury, or delirium ;
people impaired after the use of alcohol, other ‘social’ drugs e.g. cocaine and heroin, and some medicines … or following exposure to environmental pollution and/or other irresponsible human activity, e.g. war or terrorism ;
people who experience a panic attack in a real fire situation or other emergency ;
people, including firefighters, who suffer incapacitation as a result of exposure, during a real fire, to smoke and poisonous/toxic substances and/or elevated temperatures.
6. Sustainable Design & Engineering – Get With The Programme ! The extensive United Nations 2030 Sustainable Development Framework Agenda was overwhelmingly agreed and adopted in 2015.
Sustainability Impact Assessment (SIA): A continual evaluation and optimization process – informing initial decision-making, design, shaping activity/product/service realization, useful life, and termination or final disposal – of the interrelated positive and negative social, environmental, economic, institutional, political and legal impacts on balanced and equitable implementation of Sustainable Human & Social Development.
‘Carrots and Sticks’ can only achieve so much. Spatial Planners, Building Designers and Fire Engineers must – individually and as a group – subscribe to a robust Code of Ethics which is fit for purpose in today’s Human Environment.
New CIB W14: ‘Fire Safety’ Research Working Group VI Reflection Document: ‘Sustainable Fire Engineering Design, Construction & Operation’, which will establish a framework for the future development of Sustainable Fire Engineering.
Preparation of this Document will soon begin, and the following issues will be explored:
Conceptual Framework for Sustainable Fire Engineering (SFE), with a necessary accompanying Generic SFE Terminology ;
Strategy for Future SFE Development ;
Implementation of 2005 & 2008 NIST WTC 9-11 Recommendations ;
Fresh, New SFE Research Agenda ;
Resilient Implementation of SFE Research Agenda.
Would you like to get involved, and help with this work ?
PRIORITY THEME 1 – FIRE SAFETY FOR ALL (2017)
The Fire Safety Task Group, chaired by CJ Walsh, of ISO Technical Committee 59, Sub-Committee 16, Working Group 1, has already commenced the revision and further development of the fire safety texts in International Standard ISO 21542 (2011): ‘Building Construction – Accessibility & Usability of the Built Environment’.
The main effort, initially, has been focused on developing a coherent Fire Safety for All approach … token consideration, or a post-design graft-on, of the fire safety needs of people with activity limitations do not work, and are unacceptable.
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 NBC, Proposed Part 11 on ‘Sustainability’ – December 2012 Consultation
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 !!
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.
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.
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.
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.
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 ! ]
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.
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.
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.
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 ! ]
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 ! ]
C. J. Walsh – Consultant Architect, Fire Engineer & Technical Controller – Managing Director, Sustainable Design International Ltd. – Ireland, Italy & Turkey.