Sustainability Implementation

Fantasy Climate Change Policies, Landfill Gases & Water ?!?

Posted by CJ Walsh

2011-07-15:  The recent failure by European Union Environment Ministers to increase, unconditionally, the EU 2020 GHG Emission Reduction Target from 20% below 1990 levels to 30% … and the even more recent vote in the European Parliament against such an unconditional increase … leaves a stench in the nostrils.  Something stinks … and it’s the EU’s Climate Change Policy.  Too many alterations to the European Lifestyle … too many sacrifices … are required to effectively implement a ‘real’ climate change policy !

Taken as a whole … this is also a reliable indicator with regard to what is not happening in a strongly related policy area … the implementation of EU Sustainability Policy.

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The next BIG United Nations International Climate Change Conference in 2011 – COP 17 – will take place from 28 November to 9 December, 2011 … in Durban, South Africa.  Let’s not get our hopes up for the long-awaited, very necessary and urgent Global, Legally Binding Consensus Agreement on Climate Change Mitigation to be finalized there … but let’s not be too negative either !

And how are the UNFCCC Annex I Countries doing so far ?   For an answer, please follow the link below to the United Nations Framework Convention on Climate Change (UNFCCC) WebSite …

Official UNFCCC Map – All Annex I Countries

I wrote ‘an answer’ … as this is not ‘the answer’ … because the Climate Change Numbers produced by each country are not yet sufficiently accurate, precise and reliable.  In fact, there is so much massaging of numbers that it might be better just to imagine this whole process as the Climate Change Red Light District !

BUT … we do know enough to be able to identify the worst offenders:

  • 34 – IRELAND !
  • 35 – Iceland
  • 36 – Greece
  • 37 – Portugal
  • 38 – New Zealand
  • 39 – Spain
  • 40 – Canada
  • 41 – Australia
  • 42 – Malta
  • 43 – Turkey

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Looking back to when the Climate Change ‘Train’ began to come off the rails … the 2009 Copenhagen Accord was a political agreement between a small number of Heads of State, Heads of Government, Ministers, and Heads of Delegation from Brazil, South Africa, India and China (BASIC) and the USA … who attended the UNFCCC Climate Change Summit in December 2009.  Many countries have made voluntary submissions, i.e. not legally binding, to Appendices I and II of the Accord.

A general overview of the submissions made by the Developed Economies, however, reveals the following about the emissions targets being undertaken …

     –   they are highly conditional on the performance of other countries ;

     –   they are very disappointing … being far below what is required to cap the planetary temperature rise at 1.5 degrees Celsius ;   and

     –   there is no consistent emission base year … varying, for example, from 1990, 1992, 2000 to 2005.

This is very far from being a signal of serious intent from these countries … and is not … in any way, shape or manner … an acceptance of historical responsibilities.  It would be reasonable, therefore, to surmise that the process of achieving a global, legally binding, consensus agreement on greenhouse gas (GHG) emission reduction targets will be long and difficult.  The Climate Change Mitigation Agenda is fraught with difficulty … and is going absolutely nowhere at present !

Some Conclusions about Copenhagen and Since:

  1. The Danish Organizers were entirely responsible for the 2009 Climate Change Train Wreck !   And … this incompetent bungling continues to contaminate events since then.
  2. All Sectors of Europe’s Social Environment must now take seriously, i.e. pro-actively engage with, the Climate Change Adaptation Agenda … and prepare for a planetary temperature rise of at least 3-4 degrees Celsius before the end of this century !!

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Meanwhile, at national level in Ireland … and further to my post, dated 23 February 2011 … the Environmental Protection Agency (EPA) issued the following Press Release on 4 July 2011 …

‘ Kerdiffstown Landfill Remediation Project – Community Update Number No. 4

Gas flares at the Kerdiffstown Landfill are now installed and fully operational.  The flares burn off odorous gas that is collected by gas wells in two areas at the site – the lined landfill cell, and the North-West corner.

The lined landfill cell has now been fully covered with a heavy plastic membrane that will prevent gas escaping into the air.  This membrane will also stop rainwater getting into the waste and creating ‘leachate’ – the residual liquid that seeps through waste after rainfall.

These temporary gas control measures should result in a reduction in odour coming from the site.  Odour will continue to be encountered on occasion until the full remediation is completed and, in particular, there is a risk of odour during work phases where wastes will be disturbed.

The next major remedial works to occur on site will be the demolition of a number of unsafe buildings. The buildings are scheduled to be demolished in August, and the EPA will communicate the specific dates before the works commence.

On Friday, 1 July 2011, the EPA welcomed a number of TDs, councillors, council officials and members of the local community to the site for a briefing, and tour of the site works done to date.  The EPA would like to thank deputies Emmet Stagg, Anthony Lawlor, and Catherine Murphy, and Councillors Anne Breen, Emer McDaid, and Ger Dunne, for attending.

The EPA then met with members of the Local Community for the first Community Liaison Group meeting.  This group was formed to ensure that those people affected by the site can communicate directly with the people who will clean the site.  The Liaison Group includes EPA staff, Kildare County Council officials, members of CAN (Clean Air Naas), a representative from Kerdiffstown House, and local residents and business people.  The group took a tour of the site to review ongoing remedial works.

The EPA will continue to issue Community Updates as remedial works on the site take place.  For information about works at the site, go to … www.kerdiffstowncleanup.ie .’

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Please read, again, that first paragraph of the Press Release above … and pinch yourself !

Ireland’s EPA has an onerous legal responsibility with regard to the development and implementation of this country’s National Climate Change Policy.  Furthermore … the EPA, on its own WebSite ( http://www.epa.ie/ ) states the following …

‘ The Environmental Protection Agency (EPA) aims to be a leader in the climate change debate in Ireland, and to be the first port of call for information on climate change.  We hope that the information we provide on these WebPages will keep you informed on the latest news, research and events in the climate change area, not only in Ireland but internationally.’

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I ask: “Why are those Landfill Gases at Kerdiffstown being burned off ???”

Because Ireland’s National Climate Change Policy is a ‘paper’ policy … an ‘Alice in Wonderland’ policy … a policy not intended for ‘real’ implementation.  Surely we have a right to expect that, within the same national organization … somebody, somewhere … is able to think laterally ?

Climate Change Time is running out … and there is an immediate and desperate need for simple, direct and honest talk, consultation, awareness raising, training and education … across all sectors of our Social Environment !

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At European level … an example, to follow below, of the continuing weak and feeble Climate Change Language still being used by EU Institutions and Official Organizations … where individual employees, of all ranks, are more fearful of offending national and/or EU politicians than they are in doing their jobs properly and protecting EU Citizens and the Environment …

A recently published European Environment Agency (EEA) Technical Report 7: ‘Safe Water & Healthy Water Services in a Changing Environment’ … summarises existing knowledge of Climate Change Impacts on water services and health; the nature and effectiveness of the policy responses; and the coverage and gaps in existing assessments of these themes.

To download the Full Technical Report, go to the EEA’s WebSite … http://www.eea.europa.eu/ .

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‘ Climate Change, Water & Health

• Millennium Development Goal 7 (MDG7) is to halve the proportion of the global population without sustainable access to safe drinking water and basic sanitation by 2015.  A World Health Organization (WHO) assessment in 2010 finds that access to improved water sources, sanitation and wastewater treatment has increased over the past two decades.  In many countries in the Eastern European Region, however, progress is slow.  More than 50% of the rural population in ten countries have no access to improved water, giving rise to important health inequalities.

• It is important to understand how Climate Change and Extreme Weather Events will affect the achievement of MDG7.  Drinking water supplies and sanitation systems will have to be made resilient to Climate Change, and drinking water and sanitation must be fully incorporated into integrated water resource management.

• Climate Change is projected to cause major changes in yearly and seasonal precipitation and water flow, flooding and coastal erosion risks, water quality, and the distribution of species and ecosystems.

• Climate Change will impact all areas of water services – the quality and availability of water sources, infrastructure, and the type of treatment needed to meet quality standards.  We will also see more frequent and severe droughts, flooding and weather events.

• Countries of Eastern Europe, the Caucasus and Central Asia face the greatest threats to safe water.  The infrastructure in many towns and rural areas is in poor condition, and water provision is erratic and of unsatisfactory quality.

• Heavy rainfall events may also lead to flooding, especially in urban areas, and this can have serious impacts on the performance and efficiency of water supply and wastewater treatment systems, which may potentially lead to health risks.  Waterborne diseases arise predominantly from contamination of water supplies after heavy rainfall and flooding.

• Low river flows and increased temperatures during droughts reduce dilution of wastewater effluent, and drinking water quality could be compromised, increasing the need for extra treatment of both effluent and water supplies.

Water Management Policies & Extreme Weather Events

• Water management policies at European and EU Levels are being made increasingly adaptable to Climate Change, which should help safeguard public health and ecosystem services in the future.

• There are numerous guidelines for the design of water and human health policies across Europe (e.g. WHO Guidelines on drinking water quality, Protocol on Water and Health, and draft guidance on water supply and sanitation in extreme weather).  Recently, such Guidance has focused on how policy design and implementation might be affected by and adapted to Climate Change Events.

• The WHO Vision 2030 Study assesses how and where Climate Change will affect drinking water and sanitation in the medium term, and what can be done to maximise the resilience of drinking water and sanitation systems.

• Several existing EU Policies address water management issues (the Urban Wastewater Treatment Directive, the Water Framework Directive, Floods Directive and the EU Water Scarcity and Droughts Strategy) and others deal more directly with potential water-related impacts on human health (e.g. the Drinking Water Directive, and Bathing Water Directive).

• There is a clear recognition that Climate Change creates a need for coherent, sustainable, cross-sectoral policy and regulation; sharing of available tools; facilitating mechanisms for partnerships and financing; and readiness to optimise across sectors during implementation.

• The water utility sector faces a unique set of challenges.  A primary challenge will be enhancing its capacity to cope with Climate Change Impacts and Other Human Pressures on water systems, while fostering greater resiliency to extreme hydrological events.

• With more frequent higher-intensity storms projected, utilities face the need to update infrastructure design practices.  This necessitates investments – not necessarily only in larger structures but also smarter (using better process control technologies) or local measures on storm water run-off.

Assessment Knowledge Base

• At international, national and local levels … much information is produced for assessments of the state of water and related health impacts.  Overall, both the current international and national water and health assessments have limited focus on extreme weather events and their effects on water services.

• In national assessments and programmes, countries appear to be aware of the adverse consequences of Climate Change on water and health.  However, sometimes assessments appear to be based on ‘expert knowledge’, largely qualitative in scope, and not going further than identifying likely scenarios.  The evidence‑base is lacking to make reliable estimates of the health effects of Climate Change resulting from impacts on water resources.

• Much effort is now focused on the impact of Climate Change on water and the environment, including health-related impacts.  Many international and European organisations have mapped out future Climate Change Impacts on water-related issues, identifying vulnerable groups and vulnerable sub-regions.

• The vast majority of the assessments of drought and water scarcity have focused on the impact of water scarcity, water use by sectors and strategies for meeting demand.  Very little consideration has been given to the health effects or consequences of future extreme weather events.

• The health effects of flooding do not feature significantly in national assessments.  The main focus is identifying regions most at risk of flooding and preparing plans for responding and mitigating the main consequences.

• Sufficient public health competences exist to cope with the health effects of Climate Change.  However, no (comprehensive) assessment has been undertaken to predict the severity or extent of future health risks related to the impact of Climate Change on water services.

• Irrespective of an assessment of the disease burden, actions being taken on the wider scale to respond to water scarcity, drought and flooding will help to reduce the health effects associated with Climate Change and water.’

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If you were a Key Decision-Maker … would this language spur you into action … or make you yawn, and put you to sleep ???

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END

Building Design Must Improve Firefighter Safety in Fire Incidents !

Posted by CJ Walsh
2011-07-05 … 
It has been a harsh experience to leave the last post undisturbed for a few weeks !   It was necessary … and I feel better as a result.
 

Back to the present … and in any jurisdiction, news of  Firefighter Fatalities and/or Injuries is very distressing.  It has been remarkable to note, however, how some countries, e.g. Japan, are expending significant time and resources on developing innovative ways to improve firefighter safety in buildings … while most countries are not.  Over many years, I have formed the clear impression that, generally, firefighters are regarded in much the same way as soldiers, i.e. they are a disposable asset … ‘Theirs not to reason why / Theirs but to do and die’ … etc., etc.  This situation is entirely unacceptable, and in need of urgent resolution !

On 6th & 7th July … in Cardiff, Wales … I have been invited by the International President of the Institution of Fire Engineers (IFE), Mr. HG Tay, to make a presentation on ‘Sustainable Fire Engineering’ at the 2011 IFE International Fire Conference and Annual General Meeting.  I am greatly honoured by this invitation.

During the course of that presentation, I will be referring to Firefighter Safety … but much more needs to be said, beforehand, in relation to the untapped contribution of building design to greater levels of firefighter safety …

INTRODUCTION

It may be obvious for some (but, believe me, not for all !) that with regard to fighting fires in buildings … Firefighters have 2 Basic Functions :

  • to rescue people who are trapped in a Fire Building (i.e. a building which is on fire) … or people who, for some reason, cannot independently evacuate the building (e.g. people with activity limitations) ;   and
  • to fight those fires, and ensure that they are properly extinguished.

Note:  Extinction of a fire is confirmed only after a thorough visual inspection by a competent person.

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DESIGN & CONSTRUCTION

In a previous post, dated 13 December 2010 … I said that it was no longer ethically acceptable to ignore the issue of Firefighter Safety in the design and construction of buildings … because design can make a major contribution to their safety.

Unfortunately, Firefighter Safety must continue to remain an ethical issue because Building Regulations in most countries rarely, if ever, refer to this important aspect of design and construction.  Safety at Work Legislation has a related, but different, intent.

Regrettably, most of the building design professions either have no Code of Ethics … or there is a Code which is ‘lite-lite-lite’, i.e. very weak on ethics … or, worse still, they have a Code … but it is called a Code of Professional Conduct, the principal intent of which is to preserve and protect the profession and its vested interests.

At European Level …

Essential Requirements 1 & 2 (of 6 … for the time being) … in Annex I of European Union (EU) Council Directive 89/106/EEC, of 21 December 1988, on the approximation of laws, regulations and administrative provisions of the Member States relating to Construction Products … state the following …

1. Mechanical Resistance & Stability

The construction works must be designed and built in such a way that the loadings that are liable to act on it during its construction and use will not lead to any of the following:

(a) collapse of the whole or part of the works ;

(b) major deformations to an inadmissible degree ;

(c) damage to other parts of the works or to fittings or installed equipment as a result of major deformation of the load-bearing construction ;

(d) damage by an event to an extent disproportionate to the original cause.

2. Safety in Case of Fire

The construction works must be designed and built in such a way that in the event of an outbreak of fire:

– the load-bearing capacity of the construction can be assumed for a specific period of time ;

– the generation and spread of fire and smoke within the works are limited ;

– the spread of the fire to neighbouring construction works is limited ;

– occupants can leave the works or be rescued by other means ;

– the safety of rescue teams is taken into consideration.

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Sweden … has incorporated all 6 Essential Requirements of EU Construction Products Directive 89/106/EEC into its National Building Regulations … but has omitted the reference to the ‘safety of rescue teams’, i.e. Firefighter Safety.  Why is that ?

Ireland, along with England & Wales, has not incorporated the EU CPD Essential Requirements into its National Building Regulations.  There is no requirement, in Part B of the Building Regulations of either of these two separate jurisdictions, to consider Firefighter Safety in the design and construction of buildings.

In these three specific cases, taken as a simple example, this is a serious legal flaw … especially since the European Template, above, has existed since the late 1980’s !

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Let me illustrate how Building Design & Construction can make a major contribution to improved levels of Firefighter Safety …

     A.  Accessible Internal Staircases Having Sufficient Unobstructed Width

From a building user’s point of view … the success of a building depends, to a large extent, on the ‘quality’ of its circulation spaces.  During the design process, however, an architect is typically concerned with the relationship between different functions and spaces … while, at the same time, he/she is shaping and moulding the internal and external forms of the building.

The full range of tasks and activities in these circulation spaces is rarely, if ever, considered by the building designer.  The subject is not covered in Architectural Schools … and in later professional life, a reluctance to carry out Building Post-Occupation Evaluations (POE’s) reinforces this low level of awareness.

Some Tasks & Activities in Building Circulation Spaces …

  • Access to the building’s spaces and use of its services and facilities ;
  • Egress from the building during normal, everyday circumstances ;
  • Independent Evacuation, in the event of an emergency ;
  • Assisted Evacuation by others, or Rescue by Firefighters, for those building users who cannot independently evacuate the building, e.g. people with activity limitations ;
  • Firefighter Access & Reconnaissance, in the event of an emergency ;
  • Firefighter Attack, as they approach the proximity of the fire scene ;
  • Firefighter Removal from the building, by colleagues, in the event of injury, impairment, or a fire event induced health condition ;
  • Firefighter Withdrawal at the successful conclusion of firefighting operations.

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Colour photograph showing an injured, or impaired, firefighter being assisted by two colleagues in an upward staircase removal exercise. For reasons outlined in a previous post (2010-12-13) ... all three firefighters must continue to wear full Personal Protection Equipment (PPE) ... and use Self-Contained Breathing Apparatus (SCBA). Click to enlarge.
Colour photograph showing an injured, or impaired, firefighter being assisted by two colleagues in an upward staircase removal exercise. For reasons outlined in a previous post (2010-12-13) ... all three firefighters must continue to wear full Personal Protection Equipment (PPE) ... and use Self-Contained Breathing Apparatus (SCBA). Click to enlarge.

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The photograph above was extracted from this  2010 Poster Presentation …

Daniel DiRenzo, Cherry Hill Fire Department, New Jersey, USA

Building Fires – Personal Harness Use – Firefighter Removals

Click the Link Above to read and/or download PDF File (1.73 Mb)

No matter what the jurisdiction … no matter what Building Regulations do or do not require … it is clear that, during a ‘real’ fire emergency, patterns of circulation are not simple … and they cannot easily be segregated into categories with simple titles.  They are complex … and, quite often, they overlap.

In the case of the firefighter removal on a staircase (shown above) … there is a necessity to consider another type of ‘Contraflow’ … where the injured, or impaired, firefighter with two of his/her colleagues rendering assistance are together moving away from the scene of the fire … while other firefighters are moving in the opposite direction, towards the fire.

In all but the most simple and smallest building types, this is what a Fire Evacuation Staircase should look like below … having a clear unobstructed staircase width, between handrails, of 1500 mm … with a stair going/tread of 300 mm, and a stair riser of 150 mm.  Proper attention by the designer to Accessibility Design Criteria will also make the staircase far, far easier … and safer … for Firefighter Movement …

Colour drawing taken from International Standard ISO FDIS 21542, and associated inset photographs ... showing a Fire Evacuation Staircase suitable for All Building Types, which is designed for Firefighter Safety. The staircase is also designed to accommodate Building User Evacuation/Firefighter Contraflow, illustrated with an inset colour photograph ... the Rescue/Assisted Evacuation of People with Activity Limitations, also illustrated with an inset colour photograph ... and the Use of a Stretcher. The staircase design is based on the work of CJ Walsh. Click to enlarge.
Colour drawing taken from International Standard ISO FDIS 21542, and associated inset photographs ... showing a Fire Evacuation Staircase suitable for All Building Types, which is designed for Firefighter Safety. The staircase is also designed to accommodate Building User Evacuation/Firefighter Contraflow, illustrated with an inset colour photograph ... the Rescue/Assisted Evacuation of People with Activity Limitations, also illustrated with an inset colour photograph ... and the Use of a Stretcher. The staircase design is based on the work of CJ Walsh. Click to enlarge.

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     B.  Accessible Façade Walkways in High-Rise Buildings

With today’s powerful drivers of greater energy conservation and efficiency in buildings, adaptation to climate change, and a paradigm shift in thinking on the reduction of adverse environmental impact by buildings … External Façade Design is rapidly evolving … becoming far more complex and, in many cases, comprising multiple ‘skins’.

Just check out this architectural feature, below, in an Osaka (Japan) High-Rise Hotel … which not only serves as an accessible route for evacuation and/or rescue in the event of a fire incident … but also permits much easier access for maintenance and window cleaning.

This architectural feature should be mandatory in the case of high-rise buildings with a single, central core …

Colour photograph showing the High-Rise Swissôtel Nankai in Osaka, Japan. Photograph by CJ Walsh. 2010-04-20. Click to enlarge.
Colour photograph showing the High-Rise Swissôtel Nankai in Osaka, Japan. Photograph by CJ Walsh. 2010-04-20. Click to enlarge.

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Colour photograph showing the External Walkway on the Building Façade of the High-Rise Swissôtel Nankai in Osaka, Japan. Photograph by CJ Walsh. 2010-04-19. Click to enlarge.
Colour photograph showing the External Walkway on the Building Façade of the High-Rise Swissôtel Nankai in Osaka, Japan. Photograph by CJ Walsh. 2010-04-19. Click to enlarge.

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Colour photograph showing the Hotel Room Evacuation Panel to the External Façade Walkway, which can also facilitate rescue by firefighters during a fire incident. Photograph by CJ Walsh. 2010-04-19. Click to enlarge.
Colour photograph showing the Hotel Room Evacuation Panel to the External Façade Walkway, which can also facilitate rescue by firefighters during a fire incident. Photograph by CJ Walsh. 2010-04-19. Click to enlarge.

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Building Design can make a substantial contribution to greater Firefighter Safety !!

BUT … who is raising the awareness of building designers about this issue ???

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Recent Terenure Terraced Housing Fires – Party Wall Failures !!

Posted by CJ Walsh

2011-04-06:  Further to my earlier Post, dated 11 November 2010 … specifically, the photographs in that Post which showed that there was NO Fire and Smoke Separation between a house and its neighbouring property … and my statement that those photographs “could have been taken in almost any house, anywhere in the country” … so widespread is this problem …

On Friday afternoon last, 1 April 2011 … fire spread through a long terrace of houses in the Dublin City Suburbs of Terenure.  Luckily, no one was killed … but it was reported that some people were injured, including a firefighter.  This was very far from being an April Fool’s Day Joke for the owners and occupants of the buildings.  The fire losses for everyone concerned, both direct and indirect, were enormous … and will continue to increase for quite some time.

The unsustainable losses to society, waste of valuable resources and environmental damage … will never be quantified and will remain unknown …

Colour photograph showing the cordoned-off scene in the aftermath of the fires at a Terrace of Housing in Terenure, Dublin City. In the foreground, Gardaí are keeping a watchful eye. Photograph taken by CJ Walsh. 2011-04-04. Click to enlarge.
Colour photograph showing the cordoned-off scene in the aftermath of the fires at a Terrace of Housing in Terenure, Dublin City. In the foreground, Gardaí are keeping a watchful eye. Photograph taken by CJ Walsh. 2011-04-04. Click to enlarge.

I will make no comment here about the fires, how they started, or any of the people involved on the day of the fire. 

Colour photograph showing the Detail of a Party Wall ... the wall separating one property from another ... in the aftermath of the fires at a Terrace of Housing in Terenure, Dublin. Photograph taken by CJ Walsh. 2011-04-04. Click to enlarge.
Colour photograph showing the Detail of a Party Wall ... the wall separating one property from another ... in the aftermath of the fires at a Terrace of Housing in Terenure, Dublin. Photograph taken by CJ Walsh. 2011-04-04. Click to enlarge.

What I can say, with clarity and precision, is that the Party Walls between the different properties utterly failed to perform, i.e. to provide adequate Fire Separation between those properties … in other words, to resist the passage of heat, smoke and flame from one side of the Party Wall to the other … both during the fire, and for a minimum period afterwards … during the ‘cooling phase’.

I was shocked at how these fires spread through the long terrace … but I was not surprised !

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Why has this serious problem with our housing stock been allowed to fester for so long ???

Most of the Answer lies not in the Relevant Functional Requirements of Part B of the Irish Building Regulations … but in this Diagram 13 below, which is contained in Technical Guidance Document B (2006): ‘Fire Safety’.  The details shown are technically incompetent, and will NOT work in a ‘real’ fire incident.  The reference to Paragraph 3.2.5.10 at the top right hand corner of the diagram is an error … the reference should be to Paragraph 3.2.5.11: ‘Junction of Compartment Wall and Roof’.

Black and white graphic image showing part of Diagram 13: 'Junction of Compartment Wall with Roof' ... in Irish Building Regulations Technical Guidance Document B: 'Fire Safety'. These details are technically incompetent. Click to enlarge.
Black and white graphic image showing part of Diagram 13: 'Junction of Compartment Wall with Roof' ... in Irish Building Regulations Technical Guidance Document B: 'Fire Safety'. These details are technically incompetent. Click to enlarge.

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Status of the Guidance Text in Ireland’s TGD B: ‘Fire Safety’

‘ The materials, methods of construction, standards and other specifications (including technical specifications) which are referred to in this document are those which are likely to be suitable for the purposes of the Regulations.  Where works are carried out in accordance with the guidance in this document, this will, prima facie, indicate compliance with Part B of the Second Schedule of the Building Regulations.  However, the adoption of an approach other than that outlined in the guidance is not precluded provided that the relevant requirements of the Regulations are complied with.’   [Page 2 of Technical Guidance Document B]

It is of critical importance to know and understand that Guidance Text in the Irish Technical Guidance Documents is NOT prescriptive regulation, and it is NOT ‘deemed-to-satisfy’.  All of the Technical Guidance Documents contain errors … they are not infallible documents … and, with sufficient time, technical guidance becomes outdated and inadequate.  This is routine, and to be expected.

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Similar Details to those in Diagram 13 above, which are shown in the various editions of the HomeBond House Building Manual, are equally incompetent.  Furthermore, before the First Edition of the Manual was ever published in the early 1990’s … I stated this fact, very directly, to the individual having responsibility for leading the Manual Project.

And furthermore … Similar Details, which are contained in Diagram 11 of the British (England & Wales) Building Regulations Approved Document B (2006): ‘Fire Safety’ … Volume 1 – Dwellinghouses, are just as incompetent as the Irish details.  This is compellingly relevant, at the present time, since word on the jungle drums is very strongly indicating that our Department of the Environment, Heritage & Local Government (DEHLG) is seriously considering a major updating of Ireland’s Technical Guidance Document B.  And just give one guess where they will go for the model template ??!!??   Ah, go on … go on … go on … go on … guess !!!

The Rest of the Answer can be put down to the Poor Technical Skills of Designers, Bad Workmanship on Site, building with Materials and Products which are not ‘Fit for their Intended Use’ … and an Inadequate National System of Local Authority and/or Independent Technical Control.

Check out the Party Walls in your Attic Roof Spaces today !!

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END

Sustainability in Action ?!? – The Edge’s Malibu Housing Project

Posted by CJ Walsh

2011-04-02:  While ‘sustainability’ may be a difficult concept to understand and implement … our collective consciousness of what is not sustainable … unsustainable … should be improving.  Does this, or that, intuitively ‘feel’ wrong ?   Please discuss.

This item came to my attention a few days ago, via an Architectural e-Newsletter from the ‘US of A’ … and it is a sad, sad reminder of the unsustainable construction frenzy which infected so many people in Ireland during the Celtic Tiger Years.

The Edge is one of our own … we delight in his success, and we are proud of him !

Colour photograph, extracted from the Project Fact Sheet (available to download from the 'Leaves in the Wind' WebSite), showing the view from Surfrider Beach of The Edge's Proposed 5 House Coastal Development in Malibu, California. The hilltop locations of 4 of the houses are indicated by white arrows. Where is the last house ? Click to enlarge.
Colour photograph, extracted from the Project Fact Sheet (available to download from the 'Leaves in the Wind' WebSite), showing the view from Surfrider Beach of The Edge's Proposed 5 House Coastal Development in Malibu, California. The hilltop locations of 4 of the houses are indicated by white arrows. Where is the last house ? Click to enlarge.

At the beginning of a slick and convincing promotional video, the Proposed Coastal Housing Development by The Edge (David Evans) and his wife Morleigh Steinberg, is described as follows …

” Leaves in the Wind is an innovative five-home green building and organic design project in Malibu, California.  Each home is actively seeking LEED Gold Certification from the U.S. Green Building Council.

All five terrain-appropriate, environmentally sustainable homes will be built on just over 1 acre of the 156-acre site, leaving most of the land untouched and in its natural state.”

A vague ‘artistic impression’ of each of the 5 Houses, available to download from the Project WebSite, shows that the designs are far from being earth-shatteringly innovative … and, in the case of at least 4 of the Houses, they will break the skyline at the top of the hills …

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David (aka The Edge) … some Questions and Comments …

  1. A building which breaks a hilltop skyline has an enormously adverse visual impact.  Just visit the Bodrum Peninsula, in the south-west of Turkey, to see exactly what I am talking about.  Please move the houses in Malibu.  They are not ‘terrain-appropriate’.  Don’t destroy the visual enjoyment of the landscape for everyone else in the local community !
  2. Yes … there are 5 Sites available for constructing 5 Houses.  BUT … do you really have a desperate urge to build all 5 ?   Why not just 1 … or 2 at the most … and find a ‘sustainable’ use, or uses, for the rest of the landscape ??   Are you familiar with ‘sustainable’ management ?   Would you like to do something to slow down the rate of, and perhaps even reverse, biodiversity loss in Malibu ?   If you have not done so already … would you like to consult, meaningfully, with members of the local community about your ideas … even at this advanced stage ?
  3. Have you fully considered the large range of adverse environmental impacts during the long, difficult process of construction ?
  4. Finally (for now) … I regret very much that you have been an innocent victim of Ubiquitous American Greenwash Marketing … with profound apologies to Canada, Mexico and the rest of Central and South America !   The U.S. Green Building Council’s LEED (Leadership in Energy and Environmental Design) Building Rating System is only concerned with certain environmental aspects of Sustainable Human & Social Development.  There are many other aspects to sustainability which are equally, if not more, important.  LEED is not a Sustainable Building Rating System.  And the Green Building Council, itself, knows this !   Please do some proper research !   And PLEASE … do this before the ‘real’ design process commences … and definitely, before any work starts on site !!

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Landfill Fires & Contaminated Water Supplies – Join Some Dots ?

Posted by CJ Walsh

2011-02-23:  With the blanket media coverage of the upcoming Irish General Election, which will be held on Friday next, 25 February 2011 … the following 2 Environmental Protection Agency (EPA) Press Releases concerning the ongoing Kerdiffstown Landfill Fire Incident in County Kildare … which were issued in quick succession on Friday afternoon last, 18 February 2011 … may not have received adequate public attention …

1.  Friday 18th February 2011: Statement on Behalf of Co-Ordinating Group

Re:  Kerdiffstown Fire

Date released: Feb 18 2011, 3:12 PM

Active firefighting has been wound down as brigades undertake a phased withdrawal from the Kerdiffstown landfill site near Naas.  The fire, which flared up on 18 January 2011, was unprecedented in Ireland and it proved very challenging.  Initial assessments indicate that, by comparison with international experience, the time taken to suppress the fire was relatively short – given its nature and the environment in which it took place.  Fire brigades will maintain a precautionary watch on the site until the middle of next week.  The site remains a very dangerous area and people should not enter it for any reason.  The Environmental Protection Agency has increased security in the interests of public safety and to prevent further trespass in the area.

And …

2.  EPA to Develop Remediation Plan for Kerdiffstown Landfill, Naas, County Kildare.

Date released: Feb 18 2011, 3:26 PM

The EPA, HSE, Kildare County Council, Defence Forces and Gardaí have, for the past 27 days, been co-ordinating actions to deal with the fire and other environmental issues at Kerdiffstown Landfill, near Naas.  In particular, the EPA has been working closely with Kildare Fire Service, providing expert advice in fighting the serious fire at the Kerdiffstown landfill site, contracting in providers of cold gas injection equipment and providing air monitoring and analysis.  The EPA is exercising its powers under Section 56 of the Waste Management Act to secure the site and to start the longer-term process of remediation of the whole site.  Already the EPA has begun the following preliminary works:

  • removing stockpiles of fire-risk waste ;
  • providing 24-hour security personnel at the site for the long-term ;
  • establishing an on-site office ;
  • increased on-site monitoring and inspection ;
  • dealing with immediate Health & Safety issues on the site ;
  • removing landfill leachate.

As the plan for the remediation progresses, the EPA will be meeting with the local community on a regular basis in order to hear their views and update them on the remediation project.  Remediation works will be phased and the EPA will prioritise work that alleviates odour from the site in the short to medium term.  Funding for the short-term emergency works to date has been provided by the Department of Environment, Heritage & Local Government.  Further funding for the remediation will be released on a phased basis.  The EPA has taken enforcement action against those involved in the operation of the Kerdiffstown site, including three High Court cases.  High Court orders are in place preventing the deposit of any further waste onto the Kerdiffstown site.  The EPA will use its powers under the Waste Management Acts to seek recovery of all costs expended by the State during the remediation project.  The EPA is also seeking orders against directors of the companies who formerly operated the site in order to recover these costs.  A criminal investigation file relating to the previous operations at the site has been submitted to the Director of Public Prosecutions.

A lot of words have been used in these press releases … but the amount of actual information which has been communicated to the public is Sweet FA !   And … please note well … there is no statement that the Landfill Fire has been extinguished.

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PROTECTION OF FIREFIGHTERS & KERDIFFSTOWN LOCAL COMMUNITY

We consider that it is very important for Firefighters and Members of the Kerdiffstown Local Community, i.e. anybody who lives within 2 Km of the Landfill Site, to have sufficient information about Landfill Fires … in order to ask some pertinent questions about this fire incident.

I hate to say this … but, languishing on an important page of the FireOx International WebSite for many years … http://www.sustainable-design.ie/fire/proenv.htm … unloved (?!?) … has been this 2002 United States Report …

U.S. Fire Administration – Federal Emergency Management Agency

May 2002 / FA-225

LANDFILL FIRES – Their Magnitude, Characteristics, and Mitigation

Click the Link Above to read and/or download PDF File (583 kb)

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As you read the document … pinch yourself hard, and try to remember that the Regulatory Control over Landfill Sites in Ireland has been LITE-LITE-LITE !!!   … That there has been much illegal dumping all over the country !!   … AND … That some Local Authorities have even forgotten where old, inactive Landfill Sites are located … a case I myself encountered in Clontarf, within the functional area of what was then known as Dublin Corporation !

Black and white drawing ... Figure 1 in the 2002 U.S. FEMA Landfill Fires Report above ... showing the components of a Regulated Landfill Site, courtesy of the California Waste Management Board. How many Landfill Sites in Ireland, or in Europe for that matter, have all ... or any ... of the components illustrated above ? Click to enlarge.
Black and white drawing ... Figure 1 in the 2002 U.S. FEMA Landfill Fires Report above ... showing the components of a Regulated Landfill Site, courtesy of the California Waste Management Board. How many Landfill Sites in Ireland, or in Europe for that matter, have all ... or any ... of the components illustrated above ? Click to enlarge.

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LANDFILL EMISSIONS – CLIMATE CHANGE & FIRE SAFETY ISSUES !

Extract from the 2002 U.S. Report … Page 8 …

Landfill emissions are the result of the decomposition of organic materials in the landfill (including yard waste, household waste, food waste, and paper).  Because of the nature of the construction of landfills, this decomposition is anaerobic and results in the production of large quantities of Methane (which is highly flammable) and Carbon Dioxide.  In fact, landfills are the largest source of methane emissions in the United States, accounting for 35% of methane emissions in 1999.  MSW (municipal solid waste) landfills generate about 93% of U.S. landfill emissions; industrial landfills account for the remaining emissions.  Methane emissions from landfills are affected by site-specific factors such as waste composition, available moisture, and landfill size.  Approximately 28% of the methane generated in landfills in 1999 was recovered.  The remainder of landfill-generated methane was dispersed in the air.

Approximately 50% of gas emitted from landfills is methane; carbon dioxide accounts for about 45 percent, and the remainder is composed of nitrogen, oxygen, hydrogen, and other gases.  Both Methane and Carbon Dioxide are Greenhouse Gases (GHG’s) that pose environmental problems.  Of the two gases, methane is far more potent than carbon dioxide.

[Media reports have also stated that Carbon Dioxide was used during attempts to suppress the Kerdiffstown Landfill Fire in County Kildare !?!]

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HEALTH EFFECTS OF LANDFILL FIRES !

Extract from the 2002 U.S. Report … Pages 14 & 15 …

In addition to the burn and explosion hazards posed by landfill fires, smoke and other by-products of landfill fires also present a health risk to firefighters and others exposed to them.  Smoke from landfill fires generally contains Particulate Matter (the products of incomplete combustion of the fuel source), which can aggravate pre-existing pulmonary conditions or cause respiratory distress.  As with all fires, those in landfills produce toxic smoke and gases.  The danger and level of toxicity of these gases depend on the length of exposure one has to them and on the type of material that is burning.

Underground fires can result in CO (Carbon Monoxide) levels in excess of 50,000 ppm (parts per million) – the Occupational Safety & Health Administration (OSHA) permissible exposure limit for CO is 50 ppm.  OSHA standards prohibit worker exposure to more than 50 parts of the gas per million parts of air averaged during an 8-hour time period.  Carbon Monoxide is harmful when breathed because it displaces oxygen in the blood and deprives the heart, brain, and other vital organs of oxygen, which can cause permanent damage or death.

Another serious concern in landfill fires is the emission of Dioxins.  Accidental fires at landfills and the uncontrolled burning of residential waste are considered the largest sources of dioxin emissions in the United States.  The term ‘dioxins’ refers to a group of chemical compounds with similar chemical and biological characteristics that are released into the air during the combustion process.  Dioxins are also naturally occurring and are present throughout the environment.  However, exposure to high levels of dioxins has been linked to cancer, liver damage, skin rashes, and reproductive and developmental disorders.

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ENVIRONMENTAL IMPACT OF LANDFILL FIRES !

Extract from the 2002 U.S. Report … Pages 16 & 17 …

The smoke and run-off from landfill fires can be dangerous to those living in the area and to the environment.  It is important that air and water quality issues be addressed early in a fire suppression operation to prevent contamination as much as possible.  As mentioned earlier, water used to suppress a landfill fire can overwhelm a facility’s leachate collection system, if one exists (older facilities may have been constructed prior to regulations requiring leachate collection systems).

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FIRE & LANDFILL CONTENTS !

Extract from the 2002 U.S. Report … Page 17 …

Fires occurring in landfills where hazardous wastes are buried can be particularly difficult.  In past years, illegal dumping of hazardous and toxic materials in landfills and other dumping sites was relatively common.  When a fire occurs and rescue workers have wrong or misleading information about the buried contents (e.g., illegal or unknown toxic or radioactive wastes), the fire suppression operation can be extremely dangerous.

Although not a landfill fire, the Wade Dump Fire in February 1978 clearly illustrates the dangers posed by fires involving unknown hazardous materials.  Firefighters responded to a suspected tyre fire at an abandoned rubber shredding plant on the Delaware River outside of Philadelphia.  They were unaware that the property’s owner and namesake, Melvin Wade, had transformed the plant into one of the most toxic hazardous waste dumpsites in U.S. history.  By the night of the fire, more than 3 million gallons of cyanide, benzene, toluene, and other chemicals were stored on the site – plus thousands of junk tyres.  The burning chemicals produced multi-coloured smoke and noxious fumes, which alerted firefighters to the unusual nature of the fire they were fighting.  Intensified by chemicals and other fuels, the fire raged for hours.  Drums of chemicals exploded, injuring firefighters and even damaging fire trucks.  As the night progressed, firefighters and other emergency workers noticed that the chemicals were dissolving their protective gear and making it difficult for them to breathe; more than 40 firefighters were sent to a nearby hospital for treatment.  Over the past 20 or more years, dozens of those who were present at the Wade Dump fire have become ill, and many have died from cancers and other diseases.  Melvin Wade and others responsible for creating the toxic site were found criminally responsible for their actions.

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JOINING SOME DOTS – CONTAMINATED PUBLIC WATER SUPPLIES IN IRELAND

On Thursday, 17 February 2011 … the Environmental Protection Agency (EPA) released the following report … with an accompanying, ‘spinned’ press release …

Environmental Protection Agency – Ireland

2011-02-17

The Provision & Quality of Drinking Water in Ireland – A Report for the Years 2008-2009

Click the Link Above to read and/or download PDF File (2.77 Mb)

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Once again … pinch yourself hard, and try to remember that the Regulatory Control over Public Water Supplies in Ireland has been LITE-LITE-LITE !!!   Our Public Water Supplies are not in good shape … to say the least.  However, the management and control of the country’s landfill sites – legal, illegal and no longer known – IS a relevant and related issue to the contamination of our public water supplies … not the only issue.

Now, I don’t know about you … but I certainly am not happy about either the accuracy, or the reliability, of the recent EPA Report on Ireland’s Public Water Supplies !

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EU Ratification of UN Disability Convention – EFC Legal Study

Posted by CJ Walsh

2011-02-05:  Further to my post, dated 15 January 2011 …

Many people directly or indirectly involved with Disability-Related Issues in Europe … may not yet know that, a few weeks ago, the European Union ratified the 2006 United Nations Convention on the Rights of Persons with Disabilities (UN CRPD).  They may not even know that their own country, as a Member State of the European Union, had perhaps already ratified the UN Convention one or two years earlier.

At this time, the majority of Member States have proceeded, voluntarily, to ratify the Convention … with some of those, inexplicably, declining/refusing to ratify the Convention’s Optional Protocol.

Human & Social Rights can be a difficult subject area !

Ireland has not ratified the UN Convention … and, unfortunately, the attitude of many policy-makers and decision-makers within our Irish Institutions of State, large and small, is that it’s business as usual … no need to worry or fuss, or give a damn … until this country does actually sign on the Convention’s bottom line … an attitude which displays a magnificent ignorance of the changed reality, post Lisbon Treaty, which is the European Union’s Current Legal Environment !!

Please examine carefully, for yourselves, the findings of this Legal Study, recently approved for publication by the European Commission …

European Foundation Centre (EFC)

Brussels, October 2010

Study on Challenges and Good Practices in the Implementation of the UN Convention on the Rights of Persons with Disabilities

Click the Link Above to read and/or download PDF File (1.46 Mb)

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EU RATIFICATION OF THE UN CRPD – ASPECTS OF EU LAW

The following are selected extracts from the EFC Study … my selection (!) … to answer specific issues relating to UN CRPD Implementation within the European Union.  Typographical errors in the Study have also been corrected … and, post Lisbon Treaty, references to the EU Treaties have been properly updated …

The legal basis for the conclusion of the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) signals the appropriate legal basis for its implementation within the European Union (EU).  In this respect, and in line with Article 4 of the UN Convention, implementation implies that instruments may be adopted or modified by the Union in order to comply with the Convention and give effect to its provisions and principles.  Although the choice of the legal basis for the decision concluding an international agreement is very important, it is not decisive for implementation.  In European Court of Justice Case C-178/0345, which concerned the implementation of the Rotterdam Convention on International Trade in Hazardous Chemicals, the Court stated that ” the fact that one or more provisions of the Treaty have been chosen as legal bases for the approval of an international agreement is not sufficient to show that those same provisions must also be used as legal bases for the adoption of measures intended to implement that agreement at Community level “.   The latter statement means that EU Treaty provisions other than those mentioned in EU Council Decision 2010/48/EC to conclude the UN CRPD can be used as legal bases to implement UN CRPD obligations in specific fields.

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The United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) is an international human rights agreement where both the European Union (EU) and its Member States are contracting parties.  The UN Convention is thus a Mixed Agreement.  Mixed Agreements involve a Shared Contractual Relationship between the EU, its Member States and one or more third countries and/or international organisations.  As a Mixed Agreement, the UN CRPD covers fields that fall in part within the competence of the EU, in part within that of the Member States and in part within the shared competence of the EU and its Member States.  It is therefore essential for the EU and the Member States to closely co-operate, in order to implement legislation stemming from the Convention in a coherent manner and ensure unity in the international representation of the Union.

EU Member States, when participating in Mixed Agreements, do not act as entirely autonomous subjects of international law; they are subject to a Duty of Loyal Co-Operation between one another and the EU.  This duty extends to each of the negotiation, conclusion and implementation phases.  In this sense, there is a collective management of the obligations under international law.  The duty of loyal co-operation, deriving from Article 4.3 of the Treaty on European Union (TEU), embraces two sets of obligations: first, Member States shall take appropriate measures, whether general or particular, to ensure fulfilment of the obligations arising out of the EC Treaty or resulting from action taken by the EU Institutions;  and second: Member States shall facilitate the achievement of the Union’s tasks and shall abstain from any measure which could jeopardise the attainment of the Union’s objectives … which are set out in Article 3 of the Treaty on European Union (TEU).

Treaty on European Union (TEU) – Consolidated Version, as Amended by the Treaty of Lisbon

Article 4.3

Pursuant to the principle of sincere mutual co-operation, the Union and the Member States shall, in full mutual respect, assist each other in carrying out tasks which flow from the Treaties.

The Member States shall take any appropriate measure, general or particular, to ensure fulfilment of the obligations arising out of the Treaties or resulting from the acts of the institutions of the Union.

The Member States shall facilitate the achievement of the Union’s tasks and refrain from any measure which could jeopardise the attainment of the Union’s objectives.

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In relation to EU Member States‘ Compliance with a Mixed Agreement concluded by the EU … the European Court of Justice has inferred that for matters falling within EU competence … the Member States fulfil, within the EU system, an obligation in relation to the Union which has assumed responsibility for due performance of the agreement.  In other words, if a Member State fails to take all appropriate measures to implement provisions of the Mixed Agreement that fall within the competence of the EU … it not only fails to fulfil its international obligation, but is also acting in breach of EU Law.  The European Commission may thus bring an infringement case against a Member State that has not properly fulfilled its duty.  The principle underpinning such mechanisms is the ‘duty of loyal co-operation’, which provides the foundation for managing shared competence within Mixed Agreements.

The line dividing international responsibility for implementation of the International Mixed Agreement between the EU and its Member States depends on the obligations respectively assumed.  The UN CRPD contains a clause setting out ‘separate’ responsibility.  According to Article 44.1, Regional Integration Organisations acceding to the Convention shall declare, in their instruments of formal confirmation or accession, the extent of their competence.  This division of responsibility for implementation implies that the European Union only bears responsibility for the breach of those obligations it has assumed.

EU Council Decision 2010/48/EC on the conclusion of the UN CRPD refers to EU competence in respect of those matters governed by the UN CRPD, and lists EU Instruments which demonstrate such competence.

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STRUCTURE OF THE EFC REPORT

The main objective of the Study was to analyse the obligations set out in the UN CRPD and, in particular, to gather information about the various practices of the EU Member States and the European Union in implementing the UN CRPD.

The work was carried out by the European Foundation Centre (EFC), representing the European Consortium of Foundations on Human Rights and Disability … under Contract No. VC/2008/1214 … for the European Commission‘s Directorate-General for Employment, Social Affairs & Inclusion.

Section 1 of this Report sets the appropriate background for the analysis that will follow.

Section 2 of the Report provides an overview and general recommendations on the implementation of the social model of disability, and core obligations deriving from Article 1 and Preamble Paragraph (e) of the UN CRPD.

Section 3 of the Report provides an overview and general recommendations on the implementation of Article 3 (General Principles), Article 4 (General Obligations), Article 5 (Equality and Non-Discrimination), and Article 9 (Accessibility) of the UN CRPD.  The section also reviews UN CRPD articles on Inter-Sectionality, namely Articles 6 (Women with Disabilities) and Article 7 (Children with Disabilities).  It is worth noting that the articles addressed in this section are articles of general and crosscutting application, and therefore their application is relevant for the implementation of all articles of the Convention.

Section 4 of the Report provides an overview and general recommendations on the implementation of selected substantive provisions of the UN CRPD which apply existing civil, political, economic, social and cultural rights within the context of disability.  Specifically, the section considers the implementation of Articles 16 (Freedom from Exploitation, Violence and Abuse) and 17 (Protecting the Integrity of the Person), which are seeking to assert protections that underscore the humanity of all persons with disabilities.  The section also considers the implementation of Articles 12 (Equal Recognition before the Law) and 19 (Living Independently and Being Included in the Community), both of which aim at maintaining and safeguarding the autonomy of the person.  Furthermore, articles on specific accessibility rights, namely Article 13 (Access to Justice) and Article 29 (Participation in Political and Public Life), are likewise addressed.  Finally, the section considers the implementation of Articles 24 (Education) and 27 (Work and Employment).

Section 5 of the Report contains an overview and general recommendations on the implementation of articles which outline steps that are necessary to support reforms.  Specifically, the section considers the implementation of Article 31 (Statistics and Data Collection), Article 32 (International Co-Operation), and Article 33 (National Implementation and Monitoring).

Section 6 of the Report suggests good practices for the EU and national policy-makers for the future and overall implementation of the Convention, and the effective achievement of its objectives.

It is worth noting that, while it is hard to be definitive, given that the UN Committee on the Rights of Persons with Disabilities is still in its infancy and has yet to pronounce on the obligations of the UN CRPD … it is nevertheless possible on the basis of the general principles of the Convention and interpretative tools, such as the Vienna Convention on the Law of Treaties, to identify illustrative challenges to the implementation of the UN CRPD.  For the purposes of this Study, the review of EU and Member States policies and legal instruments is based on the analysis of the UN CRPD and checklists that were produced from this Study to measure progress.

Finally, for the purposes of the Study, a challenge is defined as a ‘difficulty’ posed by existing national or EU practice which may potentially hamper the full and effective implementation of the UN CRPD by the EU Member States and/or the European Union.  In order to meet such challenges, it will be necessary, inter alia, for the EU (as appropriate) and/or its Member States to review legislation and/or policy with a view to full compliance.  On the other hand, a practice is defined as good if it fulfils certain requirements of the Convention or mainstreams the general principles, consistent with Article 3 of the UN CRPD, and has an awareness-raising impact.

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