Technical Control of Design and Construction

Japan’s Fukushima NAIIC Report – Home Truths from Abroad !?!

2012-07-09:  Very recently, the Fukushima Nuclear Accident Independent Investigation Commission, established by the Diet of Japan (National Parliament, comprising the House of Representatives and the House of Councillors) under the NAIIC Act of 30 October 2011, issued an English Executive Summary of its Final Report.

Instead of concentrating on the Fukushima NAIIC Conclusions and Recommendations, which I would usually do in a case like this … I am reproducing below the Message from Kiyoshi Kurokawa, Fukushima NAIIC Chairman, from the beginning of the Executive Summary.  After you read it, you will understand why.

His words are stark, and cut deep to the bone … revealing some unpleasant home truths about Japanese Society and Culture.  BUT … a very large measure of those truths is universal … and there is much of direct relevance which can, and should, be applied in other parts of the world.  I will discuss this issue in more detail again.

THE WEST IS NOT THE BEST !!

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Colour photograph showing a Birdseye View of the Fukushima Nuclear Reactors after the 2011 Explosions. Click to enlarge.

Colour photograph showing a Birdseye View of the Fukushima Nuclear Reactors after the 2011 Explosions. Click to enlarge.

The Executive Summary Report contains a Brief Overview of this ‘Real’ Extreme Event, which commenced on 11 March 2011 in Fukushima Prefecture, Japan … a Summary of the Nuclear Accident Independent Investigation Commission’s Findings … and the Important Conclusions and RecommendationsAppendices present Surveys of Evacuees (10,633) and Workers (2,415).

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Black and white photograph of Kiyoshi Kurokawa - Chairman of the Japanese Diet's Fukushima Nuclear Accident Independent Investigation Commission (NAIIC) Chairman. He is a Medical Doctor, an Academic Fellow of the National Graduate Institute for Policy Studies, and Former President of the Science Council of Japan. Click to enlarge.

Black and white photograph of Kiyoshi Kurokawa – Chairman of the Japanese Diet’s Fukushima Nuclear Accident Independent Investigation Commission (NAIIC). He is a Medical Doctor, an Academic Fellow of the National Graduate Institute for Policy Studies, and Former President of the Science Council of Japan. Click to enlarge.

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MESSAGE FROM FUKUSHIMA NAIIC CHAIRMAN – KIYOSHI KUROKAWA

THE EARTHQUAKE AND TSUNAMI, of 11 March 2011, were natural disasters of a magnitude that shocked the entire world.  Although triggered by these cataclysmic events, the subsequent accident at the Fukushima Dai-ichi Nuclear Power Plant cannot be regarded as a natural disaster.  It was a profoundly man-made disaster – that could and should have been foreseen and prevented.  And its effects could have been mitigated by a more effective human response.

How could such an accident occur in Japan, a nation that takes such great pride in its global reputation for excellence in engineering and technology ?   This Commission believes the Japanese people – and the global community – deserve a full, honest and transparent answer to this question.

Our report catalogues a multitude of errors and wilful negligence that left the Fukushima Plant unprepared for the events of 11 March.  And it examines serious deficiencies in the response to the accident by TEPCO (Tokyo Electric Power Company), Regulators and the Government.

For all the extensive detail it provides, what this report cannot fully convey – especially to a global audience – is the mindset that supported the negligence behind this disaster.

What must be admitted – very painfully – is that this was a disaster ‘Made in Japan’.  Its fundamental causes are to be found in the ingrained conventions of Japanese culture:  our reflexive obedience; our reluctance to question authority; our devotion to ‘sticking with the programme’; our groupism; and our insularity.

Had other Japanese been in the shoes of those who bear responsibility for this accident, the result may well have been the same.

Following the 1970’s ‘oil shocks’, Japan accelerated the development of nuclear power in an effort to achieve national energy security.  As such, it was embraced as a policy goal by government and business alike, and pursued with the same single-minded determination that drove Japan’s post-war economic miracle.

With such a powerful mandate, nuclear power became an unstoppable force, immune to scrutiny by civil society.  Its regulation was entrusted to the same government bureaucracy responsible for its promotion.  At a time when Japan’s self-confidence was soaring, a tightly knit elite with enormous financial resources had diminishing regard for anything ‘not invented here’.

This conceit was reinforced by the collective mindset of Japanese bureaucracy, by which the first duty of any individual bureaucrat is to defend the interests of his organization.  Carried to an extreme, this led bureaucrats to put organizational interests ahead of their paramount duty to protect public safety.

Only by grasping this mindset can one understand how Japan’s nuclear industry managed to avoid absorbing the critical lessons learned from Three Mile Island and Chernobyl;  and how it became accepted practice to resist regulatory pressure and cover up small-scale accidents.  It was this mindset that led to the disaster at the Fukushima Dai-ichi Nuclear Plant.

This report singles out numerous individuals and organizations for harsh criticism, but the goal is not – and should not be – to lay blame.  The goal must be to learn from this disaster, and reflect deeply on its fundamental causes, in order to ensure that it is never repeated.

Many of the lessons relate to policies and procedures, but the most important is one upon which each and every Japanese citizen should reflect very deeply.

The consequences of negligence at Fukushima stand out as catastrophic, but the mindset that supported it can be found across Japan.  In recognizing that fact, each of us should reflect on our responsibility as individuals in a democratic society.

As the first investigative commission to be empowered by the legislature and independent of the bureaucracy, we hope this initiative can contribute to the development of Japan’s civil society.

Above all, we have endeavoured to produce a report that meets the highest standard of transparency.  The people of Fukushima, the people of Japan and the global community deserve nothing less.

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Japanese Diet’s 2012 Fukushima NAIIC Executive Summary (in English)

Click the Link Above to read and/or download PDF File (2.2 Mb)

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Progressive Collapse of WTC 7 – 2008 NIST Recommendations – Part 2 of 2

1st Series of Posts on the 2005 NIST WTC 1 & 2 Collapse Recommendations … which began towards the end of 2011 …

2011-10-25:  NIST’s Recommendations on the 9-11 WTC Building Collapses … GROUP 1. Increased Structural Integrity – Recommendations 1, 2 & 3 (out of 30)

Previous Post in this New Series …

2012-01-18:  Progressive Collapse of WTC 7 – 2008 NIST Recommendations – Part 1 of 2 … GROUP 1. Increased Structural Integrity – Recommendation A … and GROUP 2. Enhanced Fire Endurance of Structures – Recommendations B, C, D & E (out of 13)

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2012-01-22:  SOME PRELIMINARY COMMENTS …

  1.     Keeping my ear closely to the ground … I hear you wondering: “So … how did the fires actually start in World Trade Center Building 7 ?”

Extracts from the Executive Summary (pages xxxi – xxxv) – 2008 NIST NCSTAR 1A …

[ Refer back to the WTC 1 & 2 Collapse Damage Plan in the previous post.]

The fires in WTC Building 7 were ignited as a result of the impact of debris from the collapse of WTC Tower 1, which was approximately 110 metres to the south.  The debris also caused some structural damage to the south-west perimeter of WTC 7.  The fires were ignited on at least 10 floors;  however, only the fires on Floors 7 to 9 and 11 to 13 grew and lasted until the time of building collapse.  These uncontrolled fires had characteristics similar to those that have occurred previously in tall buildings.  Their growth and spread were consistent with ordinary building content fires.  Had a water supply for the automatic sprinkler system been available and had the sprinkler system operated as designed, it is likely that the fires in WTC 7 would have been controlled, and the collapse prevented.  However, the collapse of WTC 7 highlights the importance of designing fire resisting structures for situations where sprinklers are not present, do not function (e.g. due to disconnected or impaired water supply), or are overwhelmed.

and …

There were no serious injuries or fatalities, because the estimated 4,000 occupants of WTC 7 reacted to the airplane impacts on the two WTC Towers and began evacuating before there was significant damage to WTC 7.  The occupants were able to use both the elevators and the stairs, which were as yet not damaged, obstructed, or smoke-filled.  Evacuation of the building took just over an hour.  The potential for injuries to people leaving the building was mitigated by building management personnel holding the occupants in the lobby until they identified an exit path that was safe from the debris falling from WTC Tower 1.  The decisions not to continue evaluating the building and not to fight the fires were made hours before the building collapsed, so no emergency responders were in or near the building when the collapse occurred.

and …

The design of WTC 7 was generally consistent with the New York City Building Code of 1968 (NYCBC), with which, by policy, it was to comply.  The installed thickness of the thermal insulation on the floor beams was below that required for unsprinklered or sprinklered buildings, but it is unlikely that the collapse of WTC 7 could have been prevented even if the thickness had been consistent with building code requirements.  The stairwells were narrower than those required by the NYCBC, but, combined with the elevators, were adequate for a timely evacuation on 11 September 2001, since the number of building occupants was only about half that expected during normal business hours.

The collapse of WTC 7 could not have been prevented without controlling the fires before most of the combustible building contents were consumed.  There were two sources of water (gravity-fed overhead tanks and the city water main) for the standpipe and automatic sprinkler systems serving Floor 21 and above, and some of the early fires on those upper floors might have actually been controlled in this manner.  However, consistent with the NYCBC, both the primary and back-up source of water for the sprinkler system in the lower 20 floors of WTC 7 was the city water main.  Since the collapses of the WTC Towers had damaged the water main, there was no water available (such as the gravity-fed overhead tanks that supplied water to Floor 21 and above) to control those fires that eventually led to the building collapse.

Link to read and/or download a copy of the 2008 NIST NCSTAR 1A Report … www.fireox-international.eu/fire/structdesfire.htm 

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  2.     On a separate subject and quite by chance … a few days ago, I was invited to review a technical paper for a reputable international fire engineering journal (which shall remain nameless).  The paper was discussing a certain aspect of steel column critical temperatures.  After three days, I replied to the journal’s editor as follows …

2012-01-18.

Most regrettably, I must decline your invitation to review Paper XYZ.

The ‘critical temperature’ approach to the fire engineering design of steel-framed structures is deeply flawed … and obsolete.

C. J. Walsh, FireOx International – Ireland, Italy & Turkey.

The ‘critical temperature’ approach is antiquated … and this nonsense has got to stop !   NOW … would be the best time !!

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  3.     In the last post, I wrote …

Structural Fire Engineering is concerned with those aspects of fire engineering which relate to structural design for fire, and the complex architectural interaction between a building’s structure and fabric, i.e. non-structure, under conditions of fire and its immediate aftermath.

Indeed !   But, more needs to be added …

I hope it is becoming clearer now that Structural Fire Engineering is not just ambient structural engineering with a few extra ‘bells and whistles’ grafted on … in token consideration of what could happen in fire conditions, i.e. at high temperatures.

[ If, in some jurisdictions, there are no legal requirements to add even those ‘bells and whistles’ … then, typically, even they will be omitted ! ]

This brings me right back to the typical education of Civil/Structural Engineers;  because:  (i) they exit the educational system with little understanding of anything beyond ‘structure’ … in other words, a ‘real’ building, which also comprises ‘fabric’, i.e. non-structure, is a mystery to them;  and (ii) they have difficulty reading architectural drawings … which is why a walk-through inspection of a building, as it is nearing completion, is much preferred over a detailed discussion about drawings at the most appropriate stage, which is well before construction commences … when faults can be readily identified and easily rectified !

In ambient conditions … the architectural interaction between a building’s structure and fabric is difficult, not being entirely static.  Before the surface finishes have been applied, it is immediately obvious when this interaction has been properly ‘designed’, and looks neat and tidy … or, on the vast majority of construction sites, when this interaction is a ‘traffic accident’, and the results are desperately ugly … and you know that they can’t apply the surface finishes quickly enough in order to hide everything from view !

In fire conditions … this architectural interaction between building fabric and structure is complex, certainly very dynamic … and fluid !

It would be more appropriate to think of Structural Fire Engineering as ‘Design in the Hot Form’ … which is a completely different mindset.

It is essential, therefore, that Fire Engineers understand ‘real’ buildings … most importantly, the ‘design’ of real buildings … and, that they know which end is ‘up’ on a real construction site !!   See NIST WTC 7 Recommendation L below.

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  4.     Since the collapse of WTC Building 7 on 11 September 2001, it has been generally assumed that Fire-Induced Progressive Collapse is a large-scale, macro-phenomenon only.  But, believe it or not, this phenomenon has also been observed at micro-level in small building types.

In fact … Progressive Collapse was already receiving sporadic attention, in Ireland, as far back as the 1980’s …

  • As organizer of the 1987 Dublin International Fire Conference: ‘Fire, Access & Safety in Residential Buildings’, I requested that the following Paper be presented … ‘Design against Progressive Collapse in Fire’ … by Dr. Willie Crowe, who was Head of Construction Technology, in the old Institute for Industrial Research & Standards (IIRS) in Ireland.  He later became Manager of the Irish Agrément Board (IAB).  Those were the days … and Willie really knew his stuff !

Mr. Noel C. Manning, of FireBar in Ireland (www.firebar.ie),  and I both contributed to the development of his Paper.

And now is as good a time as any to give full credit to Noel Manning for his innovative approach to Structural Fire Engineering back in the early 1980’s.  He’s a ‘hard man’ … a term that we use for some special people in Ireland !

Link to the Dublin International Fire Conferences, and a copy of this Paper … www.fireox-international.eu/fire/dublinfire.htm 

  • For approximately 12 years from the mid-1980’s, I was a Member of the National Masonry Panel – the National Standards Authority of Ireland (NSAI) Masonry Standards Advisory Committee.  A small, but substantial, text on Fire-Induced Progressive Collapse in Buildings was included, by me, in the following standard … Irish Standard 325: Code of Practice for Use in Masonry – Part 2: Masonry Construction (1995).  Appendix A – Determination of Movement in Masonry.  A.3 – Thermal Movement.  Once again … those were the days … when I was the only architect in a sea of engineers !!   Not a pretty experience.

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  5.     What next ?   A final draft of the International CIB W14 Research WG IV Reflection Document on Fire-Induced Progressive Collapse will be completed in time for circulation to all CIB W14 members before the end of March 2012 … well in time for the next CIB W14 Meetings in Greece, near the end of April 2012.

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2008 NIST WTC 7 RECOMMENDATIONS  (Final Report NCSTAR 1A)

5.1.3     GROUP 3.  New Methods for Fire Resisting Design of Structures

The procedures and practices used in the fire resisting design of structures should be enhanced by requiring an objective that uncontrolled fires result in burnout without partial or global (total) collapse.  Performance-based methods are an alternative to prescriptive design methods.  This effort should include the development and evaluation of new fire resisting coating materials and technologies, and evaluation of the fire performance of conventional and high-performance structural materials.

NIST WTC 7 Recommendation F  (NCSTAR 1  Recommendation 8).

NIST recommends that the fire resistance of structures be enhanced by requiring a performance objective that uncontrolled building fires result in burnout without partial or global (total) collapse.  Such a provision should recognize that sprinklers could be compromised, non-operational, or non-existent.  Current methods for determining the fire resistance of structural assemblies do not explicitly specify a performance objective.  The rating resulting from current test methods indicates that the assembly (component or sub-system) continued to support its superimposed load (simulating a maximum load condition) during the test exposure without collapse.  Model Building Codes:  This Recommendation should be included in the national model building codes as an objective, and adopted as an integral pert of the fire resistance design for structures.  The issue of non-operational sprinklers could be addressed using the existing concept of Design Scenario 8 of NFPA 5000, where such compromise is assumed and the result is required to be acceptable to the Authority Having Jurisdiction (AHJ).  Affected Standards:  ASCE-7, AISC Specifications, ACI 318, and ASCE/SFPE 29.

Relevance to WTC 7:  Large, uncontrolled fires led to failure of a critical column and consequently the complete collapse of WTC 7.  In the region of the collapse initiation (i.e. on the east side of Floor 13), the fire had consumed virtually all of the combustible building contents, yet collapse was not prevented.

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NIST WTC 7 Recommendation G  (NCSTAR 1  Recommendation 9).

NIST recommends the development of:  (1) performance-based standards and code provisions, as an alternative to current prescriptive design methods, to enable the design and retrofit of structures to resist real building fire conditions, including their ability to achieve the performance objective of burnout without structural or local fire collapse;  and (2) the tools, guidelines, and test methods necessary to evaluate the fire performance of the structure as a whole system.  Standards development organizations, including the American Institute of Steel Construction, have already begun developing performance-based provisions to consider the effects of fire in structural design.

a.     Standard methodology, supported by performance criteria, analytical design tools, and practical design guidance;  related building standards and codes for fire resistance design and retrofit of structures, working through the consensus process for nationwide adoption;  comprehensive design rules and guidelines;  methodology for evaluating thermo-structural performance of structures;  and computational models and analysis procedures for use in routine design practice.

b.     Standard methodology for specifying multi-compartment, multi-floor fire scenarios for use in the design and analysis of structures to resist fires, accounting for building-specific conditions such as geometry, compartmentation, fuel load (e.g. building contents and any flammable fuels such as oil and gas), fire spread, and ventilation;  and methodology for rating the fire resistance of structural systems and barriers under realistic design-basis fire scenarios.

c.     Publicly available computational software to predict the effects of fires in buildings – developed, validated, and maintained through a national effort – for use in the design of fire protection systems and the analysis of building response to fires.  Improvements should include the fire behaviour and contribution of real combustibles;  the performance of openings, including door openings and window breakage, that controls the amount of oxygen available to support the growth and spread of fires and whether the fire is fuel-controlled or ventilation-controlled;  the floor-to-floor flame spread;  the temperature rise in both insulated and un-insulated structural members and fire barriers;  and the structural response of components, sub-systems, and the total building system due to the fire.

d.     Temperature-dependent thermal and mechanical property data for conventional and innovative construction materials.

e.     New test methods, together with associated conformance assessment criteria, to support the performance-based methods for fire resistance design and retrofit of structures.  The performance objective of burnout without collapse will require the development of standard fire exposures that differ from those currently used.

There is a critical gap in knowledge about how structures perform in real fires, particularly concerning: the effects of fire on the entire structural system (including thermal expansion effects at lower temperatures);  interaction between the sub-systems, elements, and connections;  and scaling of fire test results to full-scale structures (especially for structures with long-span floor systems).

Relevance to WTC 7:  A performance-based assessment of the effects of fire on WTC 7, had it considered all of the relevant thermal effects (e.g. thermal expansion effects that occur at lower temperatures), would have identified the vulnerability of the building to fire-induced progressive collapse and allowed alternative designs for the structural system.

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5.1.4     GROUP 4.  Improved Active Fire Protection

Active fire protection systems (i.e. sprinklers, standpipes/hoses, fire alarms, and smoke management systems) should be enhanced through improvements to the design, performance, reliability, and redundancy of such systems.

NIST WTC 7 Recommendation H  (NCSTAR 1  Recommendation 12).

NIST recommends that the performance, and possibly the redundancy and reliability of active fire protection systems (sprinklers, standpipes/hoses, fire alarms, and smoke management systems), in buildings be enhanced to accommodate the greater risks associated with increasing building height and population, increased use of open spaces, high-risk building activities, fire department response limits, transient fuel loads, and higher threat profile.

Reliability is affected by (a) redundancy, such that when one water supply is out of service (usually for maintenance), the other interconnected water supply can continue to protect the building and its occupants;  (b) automatic operation of water supply systems (not only for starting fire pumps but also for testing and tank replenishment, with appropriate remote alarms to the fire department and local alarms for notifying emergency personnel);  and (c) the use of suitable equipment and techniques to regulate unusual pressure considerations.

Relevance to WTC 7:  No water was available for the automatic suppression systems on the lower 20 storeys of WTC 7, once water from street-level mains was disrupted.  This lack of reliability in the source of the primary and secondary water supplies allowed the growth and spread of fires that ultimately resulted in collapse of the building.

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5.1.5     GROUP 6.  Improved Emergency Response

Technologies and procedures for emergency response should be improved to enable better access to buildings, response operations, emergency communications, and command and control in large-scale emergencies.

NIST WTC 7 Recommendation I  (NCSTAR 1  Recommendation 24).

NIST recommends the establishment and implementation of codes and protocols for ensuring effective and uninterrupted operation of the command and control system for large-scale building emergencies.

a.     State, local, and federal jurisdictions should implement the National Incident Management System (NIMS).  The jurisdictions should work with the Department of Homeland Security to review, test, evaluate, and implement an effective unified command and control system.  NIMS addresses interagency co-ordination and establishes a response matrix – assigning lead agency responsibilities for different types of emergencies, and functions.  At a minimum, each supporting agency should assign an individual to provide co-ordination with the lead agency at each incident command post.

b.     State, local, and federal emergency operations centres (EOC’s) should be located, designed, built, and operated with security and operational integrity as a key consideration.

c.     Command posts should be established outside the potential collapse footprint of any building which shows evidence of large multi-floor fires or has serious structural damage.  A continuous assessment of building stability and safety should be made in such emergencies to guide ongoing operations and enhance emergency responder safety.  The information necessary to make these assessments should be made available to those assigned responsibility (see related Recommendations 15 and 23 in NIST NCSTAR 1).

d.     An effective command system should be established and operating before a large number of emergency responders and apparatus are dispatched and deployed.  Through training and drills, emergency responders and ambulances should be required to await dispatch requests from the incident command system and not to self-dispatch in large-scale emergencies.

e.     Actions should be taken via training and drills to ensure a co-ordinated and effective emergency response at all levels of the incident command chain by requiring all emergency responders that are given an assignment to immediately adopt and execute the assignment objectives.

f.     Command post information and incident operations data should be managed and broadcast to command and control centres at remote locations so that information is secure and accessible by all personnel needing the information.  Methods should be developed and implemented so that any information that is available at an interior information centre is transmitted to an emergency responder vehicle or command post outside the building.

Relevance to WTC 7:  (1) The New York City Office of Emergency Management (OEM) was located in WTC 7 and was evacuated before key fire ground decisions had to be made.  The location of OEM in WTC 7, which collapsed due to ordinary building fires, contributed to the loss of robust interagency command and control on 11 September 2001.  (2) Due to the collapse of the WTC Towers and the loss of responders and fire control resources, there was an evolving site leadership during the morning and afternoon.  Key decisions (e.g. not to fight the fires in WTC 7 and to turn off power to the Con Edison substation) were reasonable and would not have changed the outcome on 11 September 2001, but were not made promptly.  Under different circumstances (e.g. if WTC 7 had collapsed sooner and firefighters were still evaluating the building condition), the outcome could have been very different.

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5.1.6     GROUP 7.  Improved Procedures and Practices

The procedures and practices used in the design, construction, maintenance, and operation of buildings should be improved to include encouraging code compliance by non-governmental and quasi-governmental entities, adoption and application of evacuation and sprinkler requirements in codes for existing buildings, and retention and availability of building documents over the life of a building.

NIST WTC 7 Recommendation J  (NCSTAR 1  Recommendation 27).

NIST recommends that building codes incorporate a provision that requires building owners to retain documents, including supporting calculations and test data, related to building design, construction, maintenance, and modifications over the entire life of the building.*  Means should be developed for off-site storage and maintenance of the documents.  In addition, NIST recommends that relevant information be made available in suitably designed hard copy or electronic formats for use by emergency responders.  Such information should be easily accessible by responders during emergencies.

[ * F-12  The availability of inexpensive electronic storage media and tools for creating large searchable databases makes this feasible.]

Relevance to WTC 7:  The efforts required in locating and acquiring drawings, specifications, tenant layouts, and material certifications, and especially shop fabrication drawings, significantly lengthened the investigation into the collapse of WTC 7.

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NIST WTC 7 Recommendation K  (NCSTAR 1  Recommendation 28).

NIST recommends that the role of the ‘Design Professional in Responsible Charge’* be clarified to ensure that:  (1) all appropriate design professionals (including, e.g. the fire protection engineer) are part of the design team providing the highest standard of care when designing buildings employing innovative or unusual fire safety systems;  and (2) all appropriate design professionals (including, e.g. the structural engineer and the fire protection engineer) are part of the design team providing the highest standard of care when designing the structure to resist fires, in buildings that employ innovative or unusual structural and fire safety systems.

[ * F-13  In projects involving a design team, the ‘Design Professional in Responsible Charge’ – usually the lead architect – ensures that the team members use consistent design data and assumptions, co-ordinates overlapping specifications, and serves as the liaison between the enforcement and reviewing officials and the owner.  This term is defined in the International Building Code (IBC) and in the International Code Council’s Performance Code for Buildings and Facilities (where it is the Principal Design Professional).]

Relevance to WTC 7:  Following typical practice, none of the design professionals in charge of the WTC 7 Project (i.e. architect – structural engineer – fire protection engineer) was assigned the responsibility to explicitly evaluate the fire performance of the structural system.  Holistic consideration of thermal and structural factors during the design or review stage could have identified the potential for the failure and might have prevented the collapse of the building.

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5.1.7     GROUP 8.  Education and Training

The professional skills of building and fire safety professionals should be upgraded through a national education and training effort for fire protection engineers, structural engineers, and architects.  The skills of building regulatory and fire service personnel should also be upgraded to provide sufficient understanding and the necessary skills to conduct the review, inspection, and approval tasks for which they are responsible.

NIST WTC 7 Recommendation L  (NCSTAR 1  Recommendation 29).

NIST recommends that continuing education curricula be developed, and programmes be implemented for:  (1) training fire protection engineers and architects in structural engineering principles and design;  and (2) training structural engineers, architects, fire protection engineers, and code enforcement officials in modern fire protection principles and technologies, including the fire resisting design of structures;  and (3) training building regulatory and fire service personnel to upgrade their understanding and skills to conduct the review, inspection, and approval tasks for which they are responsible.  The outcome would further the integration of the disciplines in effective fire-safe design of buildings.

Relevance to WTC 7:  Discerning the fire-structure interactions that led to the collapse of WTC 7 required research professionals with expertise in both disciplines.  Assuring the safety of future buildings will require that participants in the design and review processes possess a combined knowledge of fire science, materials science, heat transfer, and structural engineering, and design.

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NIST WTC 7 Recommendation M  (NCSTAR 1  Recommendation 30).

NIST recommends that academic, professional short-course, and web-based training materials in the use of computational fire dynamics and thermo-structural analysis tools be developed and delivered to strengthen the base of available technical capabilities and human resources.

Relevance to WTC 7:  NIST stretched the state-of-the-art in the computational tools needed to reconstruct a fire-induced progressive collapse.  This enabled identification of the critical processes that led to that collapse.  Making these expanded tools and derivative, validated, and simplified modelling approaches usable by practitioners could prevent future disasters.

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NIST WTC Recommendations 29-30 > Improved Fire Education

Previous Posts in This Series …

2011-10-25:  NIST’s Recommendations on the 9-11 WTC Building Collapses … GROUP 1. Increased Structural Integrity – Recommendations 1, 2 & 3 (out of 30)

2011-11-18:  NIST WTC Recommendations 4-7 > Structural Fire EnduranceGROUP 2.  Enhanced Fire Endurance of Structures – Recommendations 4, 5, 6 & 7

2011-11-24:  NIST WTC Recommendations 8-11 > New Design of StructuresGROUP 3.  New Methods for Fire Resisting Design of Structures – Recommendations 8, 9, 10 & 11

2011-11-25:  NIST WTC Recommendations 12-15 > Improved Active ProtectionGROUP 4.  Improved Active Fire Protection – Recommendations 12, 13, 14 & 15

2011-11-30:  NIST Recommendations 16-20 > Improved People EvacuationGROUP 5.  Improved Building Evacuation – Recommendations 16, 17, 18, 19 & 20

2011-12-04:  NIST WTC Recommendations 21-24 > Improved FirefightingGROUP 6.  Improved Emergency Response – Recommendations 21, 22, 23 & 24

2011-12-07:  NIST WTC Recommendations 25-28 > Improved PracticesGROUP 7.  Improved Procedures and Practices – Recommendations 25, 26, 27 & 28

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2011-12-08:  SOME PRELIMINARY COMMENTS …

  1.     At last, we arrive at the Group 8 Recommendations !   At this stage … my impression is that the NIST Team began to run out of steam, because these two short Recommendations barely scratch the surface with regard to the significant education and training needs of the many different design, construction, management, operation, maintenance and emergency response disciplines engaged with, and confronted by, the Built Environment … every day of every week.

After a careful reading of all 30 NIST WTC Recommendations, I hope that you have satisfied yourself/yourselves that these Recommendations must be applied to ALL Buildings … not just Tall Buildings.  At various times … Iconic Buildings, and Buildings having a Critical Function or an Innovative Design have been specifically mentioned.  And look back to Recommendation 22a … tunnels and subways also made an appearance !   The proper focus for the International Fire Science and Engineering Community must be on the Built Environment as a whole.

At All Levels in a Typical Construction Project … there are also pressing education and training needs.  It is of little use if the Project Design Documentation is 100% … and the people actually installing the passive fire protection measures or the active fire protection systems on site don’t know which end is ‘up’ !   The Project Design Documentation, in whatever format, is merely a means to an end … a fully realized and occupied Building, which is fire-safe.

Preferably … we should be discussing the mandatory Re-education and Re-training of Practitioners in the different Disciplines … [CPD (Continuing Professional/Personal Development) is not at all sufficient !] … accompanied by a very necessary Re-engineering of the Stakeholder Professional and Educational Institutions … and other related Organizations, particularly National Authorities Having Jurisdiction (AHJ’s).

Our Best Hope for Transformation … lies with the current crop of third-level undergraduate students in the different disciplines.  And, as we are discovering with the introduction of the Structural EuroCodes in the European Union, it will take perhaps 5-8 years of continuous student output to transform pre-9/11 conventional fire engineering … into a post-9/11 and post-Mumbai fire engineering which is properly ‘reliability-based’ and ‘person-centred’, i.e. Sustainable Fire Engineering !

As for the Future, and Some Conclusions to this Series … coming shortly to a computer monitor screen near you !

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2005 NIST WTC RECOMMENDATIONS

GROUP 8.  Education and Training

The professional skills of building and fire safety professionals should be upgraded through a national education and training effort for fire protection engineers, structural engineers, and architects.  The skills of building regulatory and fire service personnel should also be upgraded to provide sufficient understanding and the necessary skills to conduct the review, inspection, and approval tasks for which they are responsible.

NIST WTC Recommendation 29.

NIST recommends that continuing education curricula be developed, and programmes be implemented for:  (1) training fire protection engineers and architects in structural engineering principles and design;  and (2) training structural engineers, architects, fire protection engineers, and code enforcement officials in modern fire protection principles and technologies, including the fire resisting design of structures;  and (3) training building regulatory and fire service personnel to upgrade their understanding and skills to conduct the review, inspection, and approval tasks for which they are responsible.  The outcome would further the integration of the disciplines in effective fire-safe design of buildings.  Affected Organizations:  AIA, SFPE, ASCE, ASME, AISC, ACI, and state licensing boards.  Model Building Codes:  Detailed criteria and requirements should be incorporated into the model building codes under the topic ‘Design Professional in Responsible Charge’.

NIST WTC Recommendation 30.

NIST recommends that academic, professional short-course, and web-based training materials in the use of computational fire dynamics and thermo-structural analysis tools be developed and delivered to strengthen the base of available technical capabilities and human resources.  Affected Organizations:  AIA, SFPE, ASCE, ASME, AISC, ACI, ICC, and NFPA.

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NIST WTC Recommendations 25-28 > Improved Practices

Previous Posts in This Series …

2011-10-25:  NIST’s Recommendations on the 9-11 WTC Building Collapses … GROUP 1. Increased Structural Integrity – Recommendations 1, 2 & 3 (out of 30)

2011-11-18:  NIST WTC Recommendations 4-7 > Structural Fire EnduranceGROUP 2.  Enhanced Fire Endurance of Structures – Recommendations 4, 5, 6 & 7

2011-11-24:  NIST WTC Recommendations 8-11 > New Design of StructuresGROUP 3.  New Methods for Fire Resisting Design of Structures – Recommendations 8, 9, 10 & 11

2011-11-25:  NIST WTC Recommendations 12-15 > Improved Active ProtectionGROUP 4.  Improved Active Fire Protection – Recommendations 12, 13, 14 & 15

2011-11-30:  NIST Recommendations 16-20 > Improved People EvacuationGROUP 5.  Improved Building Evacuation – Recommendations 16, 17, 18, 19 & 20

2011-12-04:  NIST WTC Recommendations 21-24 > Improved FirefightingGROUP 6.  Improved Emergency Response – Recommendations 21, 22, 23 & 24

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2011-12-07:  SOME PRELIMINARY COMMENTS …

  1.     Concerning Recommendation 25 below … yes, this Recommendation applies to the types of organizations identified in the text, but it should also be understood as applying to ALL Organizations … public or private, governmental or non-governmental or quasi-governmental, whatever, etc … ‘supported’ (see the text further down in Recommendation 25) with rigorous enforcement, in all cases, by publically appointed building control officials and/or by private, independent, competent technical control professionals.

Once more … and again and again (!) … confirmed by the sort of debacle seen at the Priory Hall Apartment Complex, in Dublin … Self-Certification / Self-Approval, i.e. ‘lite’ regulation, does not work.  For National Authorities Having Jurisdiction (AHJ’s), however, it is a cheap solution to a difficult, resource-devouring issue, i.e. protecting society and the consumer … in that order.

  2.     Concerning the Footnote to Recommendation 26 below … the choice should never be between either Fire Compartmentation or Sprinklers … or the other way around, whichever you prefer.  Neither is 100% reliable !

Fire Compartmentation

The division of a building into fire-tight compartments, by fire and smoke resisting elements of construction, in order …

  • to contain an outbreak of fire, and to facilitate effective firefighting ;
  • to prevent damage, within the building, to other adjoining compartments and/or spaces ;
  • to protect a compartment interior from external fire attack, e.g. fire spread across the building’s facade or from an adjacent building ;
  • to minimize adverse, or harmful, environmental impacts outside the building.

As developed as that definition is above, Fire Compartmentation should be regarded as just one Fire Safety Strategy / Fire Engineering Strategy … not the only strategy, and certainly not the main strategy.

Here are two reasons why not …

a)   The connection between compartment size and the ability to effectively fight a fire within a space of limited volume has been lost … so more and more, commercial pressure is being exerted on national authorities to expand the acceptable compartment sizes in buildings … which significantly increases the fire hazard ;

[ Remembering the difference between the limited Fire Safety Objectives of Building Codes/Regulations and the much broader Project-Specific Fire Engineering Objectives of Ethical Fire Engineering required to protect society and the full interests of our clients … it is easy to understand why national authorities feel that they can respond positively to such commercial pressures.]

b)   In a Sustainable Building … it is a very common design strategy to take advantage of the natural patterns of air movement in a building, for either cooling or heating purposes, depending on local climate conditions.  So there is simply no compartmentation, as understood in conventional fire engineering terms … and this throws up a fundamental conflict between the two.  To be discussed in another post !

  3.     Concerning the 2nd Footnote to Recommendation 28 below … in the very same New York City … at 09.40 hrs on a Saturday morning, 28 July 1945 … lost in fog, a B-25 Bomber slammed head-on into the 79th Floor of the Empire State Building … and caused enormous damage.  That building is still standing today … and surprise, surprise … there was aviation fuel in the B-25 !

In a similar vein … Fire-Induced Progressive Collapse was not observed for the first time, in New York, on 11 September 2001 !

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2005 NIST WTC RECOMMENDATIONS

GROUP 7.  Improved Procedures and Practices

The procedures and practices used in the design, construction, maintenance, and operation of buildings should be improved to include encouraging code compliance by non-governmental and quasi-governmental entities, adoption and application of egress and sprinkler requirements in codes for existing buildings, and retention and availability of building documents over the life of a building.

NIST WTC Recommendation 25.

Non-governmental and quasi-governmental entities that own or lease buildings and are not subject to building and fire safety code requirements of any governmental jurisdiction are nevertheless concerned about the safety of building occupants and responding emergency personnel.  NIST recommends that such entities be encouraged to provide a level of safety that equals or exceeds the level of safety that would be provided by strict compliance with the code requirements of an appropriate governmental jurisdiction.  NIST further recommends that as-designed and as-built safety be certified by a qualified third party, independent of the building owner(s).  The process should not use self-approval for code enforcement in areas including interpretation of code provisions, design approval, product acceptance, certification of the final construction, and post-occupancy inspections over the life of the buildings.*

[ * F-46  The long-standing stated policy of the Port Authority of New York & New Jersey (PANYNJ) was to meet and, where appropriate, exceed the requirements of local building and fire codes, and it entered into agreements with the New York City Department of Buildings and the Fire Department of the City of New York in accordance with that policy.  Although the PANYNJ sought review and concurrence from New York City in the areas listed in the Recommendation, the PANYNJ was not required to yield, and appears not to have yielded, approval authority to New York City.  The PANYNJ was created as an interstate entity, a ‘body corporate and politic’, under its charter, pursuant to Article 1, Section 10 of the United States Constitution permitting compacts between states.  Further, there are many other similar non-governmental and quasi-governmental entities in the U.S.  A comprehensive review of documents conducted as part of this Investigation suggests that the WTC towers generally were designed and maintained consistent with the requirements of the 1968 New York City Building Code.  Areas of concern included fireproofing of the WTC floor system, height of tenant separation walls, and egress requirements for the assembly use spaces of ‘Windows of the World’ in WTC Tower 1 and the ‘Top of the World’ Observation Deck in WTC Tower 2.  These areas of concern did not play a significant role in determining the outcomes related to the events on 11th September 2001.]

NIST WTC Recommendation 26.

NIST recommends that state and local jurisdictions adopt and aggressively enforce available provisions in building codes to ensure that egress and sprinkler requirements are met by existing buildings.*  Further, occupancy requirements should be modified where needed (such as when there are assembly use spaces within an office building) to meet the requirements in model building codes.  Provisions related to egress and sprinkler requirements in existing buildings are available in such codes as the International Existing Building Code (IEBC), International Fire Code, NFPA 1, NFPA 101, and ASME A 17.3.  For example, the IEBC defines three levels of building alteration (removal and replacement or covering of existing materials and equipment, reconfiguration of space or system or installation of new equipment, and extending the work area in excess of 50% of the aggregate area of the building).  At the lowest level, there are no upgrade implications for sprinklers and the egress system.  At the next level, sprinklers are required in work areas serving greater than 30 people if certain other conditions related to building height and use such as shared exits also are met.  There are numerous requirements for means of egress, including number of exits, specification of doorsets, dead-end corridors and travel distances, lighting, signage, and handrails.  At the highest level, the sprinkler and egress requirements are identical to the second level without the minimum 30-person restriction and the other conditions related to building height and use.  The Life Safety Code (NFPA 101) applies retroactively to all buildings, independent of whether any work is currently being done on the building, and ASME A 17.3 applies retroactively to all elevators as a minimum set of requirements.

[ * F-47  The WTC towers were unsprinklered when built.  It took nearly 28 years after passage of New York City Local Law 5 in 1973, which required either compartmentation or sprinklering, for the buildings to be fully sprinklered (the Port Authority chose not to use the compartmentation option in Local Law 5).  This was about 13 years more than the 15-year period for full compliance with Local Law 5 that was set by Local Law 84 of 1979.]

NIST WTC Recommendation 27.

NIST recommends that building codes incorporate a provision that requires building owners to retain documents, including supporting calculations and test data, related to building design, construction, maintenance, and modifications over the entire life of the building.*  Means should be developed for off-site storage and maintenance of the documents.  In addition, NIST recommends that relevant information be made available in suitably designed hard copy or electronic formats for use by emergency responders.  Such information should be easily accessible by responders during emergencies.  Model Building Codes:  Model building codes should incorporate this Recommendation.  State and local jurisdictions should adopt and enforce these requirements.

[ * F-48  The availability of inexpensive electronic storage media and tools for creating large searchable databases makes this feasible.]

NIST WTC Recommendation 28.

NIST recommends that the role of the ‘Design Professional in Responsible Charge’* be clarified to ensure that:  (1) all appropriate design professionals (including, e.g. the fire protection engineer) are part of the design team providing the highest standard of care when designing buildings employing innovative or unusual fire safety systems;**  and (2) all appropriate design professionals (including, e.g. the structural engineer and the fire protection engineer) are part of the design team providing the highest standard of care when designing the structure to resist fires, in buildings that employ innovative or unusual structural and fire safety systems.  Affected Standards:  AIA Practice Guidelines.  Model Building Codes:  The International Building Code (IBC), which already defines ‘Design Professional in Responsible Charge’, should be clarified to address this Recommendation.  NFPA 5000 should incorporate the ‘Design Professional in Responsible Charge’ concept, and address this Recommendation.

[ * F-49  In projects involving a design team, the ‘Design Professional in Responsible Charge’ – usually the lead architect – ensures that the team members use consistent design data and assumptions, co-ordinates overlapping specifications, and serves as the liaison between the enforcement and reviewing officials and the owner.  This term is defined in the International Building Code (IBC) and in the International Code Council’s Performance Code for Buildings and Facilities (where it is the Principal Design Professional).]

[ ** F-50  If the fire safety concepts in tall buildings had been sufficiently mature in the 1960’s, it is possible that the risks associated with jet-fuel ignited multi-floor fires might have been recognized and taken into account when the impact of a Boeing 707 aircraft was considered by the structural engineer during the design of the WTC towers.]

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NIST Recommendations 16-20 > Improved People Evacuation

Previous Posts in This Series …

2011-10-25:  NIST’s Recommendations on the 9-11 WTC Building CollapsesGROUP 1. Increased Structural Integrity – Recommendations 1, 2 & 3 (out of 30)

2011-11-18:  NIST WTC Recommendations 4-7 > Structural Fire EnduranceGROUP 2.  Enhanced Fire Endurance of Structures – Recommendations 4, 5, 6 & 7

2011-11-24:  NIST WTC Recommendations 8-11 > New Design of StructuresGROUP 3.  New Methods for Fire Resisting Design of Structures – Recommendations 8, 9, 10 & 11

2011-11-25:  NIST WTC Recommendations 12-15 > Improved Active ProtectionGROUP 4.  Improved Active Fire Protection – Recommendations 12, 13, 14 & 15

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2011-11-30:  SOME PRELIMINARY COMMENTS …

  1.     In the First Post of this Series, I wrote …

” As such a high level of performance is expected … indeed demanded … of a Sustainable BuildingSustainable Fire Engineering must be ‘reliability-based’ … in other words, it must have a rational, empirical and scientifically robust basis … “

Sustainable Fire Engineering must also be ‘person-centred’ … i.e. a design process (in whatever architectural or engineering discipline) which places ‘real’ people at the centre of creative endeavours and gives due consideration to their responsible needs, and their health, safety, welfare and security in the Human Environment.

In order to prolong, and if at all possible, significantly extend the Life Cycle of a Sustainable Building beyond 100 years … Fire Engineers must begin to feel at ease … and be comfortable … with the following mainstream Sustainable Design Concepts

Flexibility:  The extent to which a building interior is designed, when new, to be capable of being easily modified at any later stage during the life cycle of that building – with minimal cost and user inconvenience – because of a person’s changing living or working needs.

Adaptability:  The extent to which a building, or a building component, is designed when new, or capable of being easily modified at any later stage, to meet the changing life and living needs of the broad range of potential users, who may or may not have activity limitations, or may develop a health condition during the life cycle of that building or component.

Accessibility of a Building:  Ease of independent approach, entry, egress (during normal ambient conditions), evacuation (in the event of an emergency) and/or use of a building and its services and facilities, by all of the building’s potential users with an assurance of individual health, safety and welfare during the course of those activities.

  2.     Group 5 of the 2005 NIST WTC Recommendations is, by far, the most important … introducing some innovative concepts of ‘real’ evacuation … with nothing too startling.  Contrary to the impression given by NIST … these Recommendations are equally valid for complex building types and, in reality, for all but the most simple of low-rise buildings.  It is interesting to note, however, that when discussing fire behaviour or structural performance in fire, for example … the NIST texts are confident and direct.  Here, when dealing with ‘people’ issues … not so confident, prone to some rambling … and lacking clarity.

Shortly after the 2005 NIST Report (NCSTAR 1) was published, I stated the following on the SDI Corporate WebSite … at this FireOx International Pagehttp://www.sustainable-design.ie/fire/structdesfire.htm

” In its treatment of ‘disability’ and ‘people with activity limitations’, the Report does not go far enough, and is seriously flawed.”

Let me explain why …

As you go scan down through NIST’s Recommendations 16-20, you will encounter 1 reference to ‘mobility impaired occupants’ and  2 references to the impersonal ‘mobility impaired’.  IF (and that is still a very big ‘if’, because there is still so much rabid resistance to this topic !) … a New Post-9/11 Evacuation Model, or Construct, Dealing with ‘Disability’ is being developed … all of the major impairment groupings (i.e. visual impairment, hearing impairment, physical function impairment, mental/cognitive impairment, and psychological impairment) must be added to the mix from the beginning.  In other words, our proper focus of attention must be ‘people with activity limitations’ … not just people with disabilities, but also frail older people (not all older people !), children under the age of 5 years, women in the later stages of pregnancy, people with a health condition, etc.

And … because of the social stigma still firmly attaching to ‘disability’ … many building occupants/users will not self-identify … not even if their lives depend on it !

Concentrating on one group only, i.e. people with mobility impairments, is simplistic and entirely inadequate … and we will all end up, in a few years time, having to graft on a consideration of the other impairment groups.

This is exactly what has already gone wrong with the development of Accessibility Design Guidance during the last 30 years … where ‘people with visual or hearing impairments’ received merely token attention … and ‘people with cognitive or psychological impairments’ received no attention at all !   And … we are now grappling with the challenge of having to graft on additional texts to try to re-balance International Design Guidance on Accessibility of the Built Environment.  Been there – done that – I have all of the t-shirts !!

People with Activity Limitations (English) / Personnes à Performances Réduites (French):  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 Terms (in English and French) include …

  • wheelchair users ;
  • people who experience difficulty in walking, with or without a facilitation aid, e.g. stick, crutch, calliper or walking frame ;
  • frail, older people ;
  • the very young (people under the age of 5 years) ;
  • people who suffer from arthritis, asthma, or a heart condition ;
  • the visually and/or hearing impaired ;
  • people who have a cognitive impairment disorder, including dementia, amnesia, brain injury, or delirium ;
  • women in the later stages of pregnancy ;
  • people impaired following the use of alcohol, other ‘social’ drugs e.g. cocaine and heroin, and some medicines ;
  • people who suffer any partial or complete loss of language related abilities, i.e. aphasia ;
  • people impaired following exposure to environmental pollution and/or other irresponsible human activities, e.g. war and terrorism ;

and …

  • people who experience a panic attack in a fire situation or other emergency ;
  • people, including firefighters, who suffer incapacitation as a result of exposure, during a fire, to poisonous or toxic substances, and/or elevated  temperatures.

  3.     So … what provision should be made for ‘people with activity limitations’ in typical Fire Engineering Design Projects ?

Equivalent to the concept of Maximum Credible Fire Scenario, which has already been discussed in this Series … at FireOx International, some years ago, we developed the concept of …

Maximum Credible User Scenario

Representing building user conditions which are also severe but reasonable to anticipate …

a)   10% of People Using the Building (occupants, visitors and other users) have an Impairment (visual or hearing, physical function, mental or cognitive, psychological, with some impairments not being identifiable) ;

[ This performance indicator appears in ISO FDIS 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’, which will soon be published.]

b)   The Number of People Using a Building increases, on occasions which cannot be specified, to 120% of designed/calculated maximum building capacity.

[ Generally … the fire safety related texts contained in ISO 21542 are based on the 2005 & 2008 NIST WTC Recommendations.]

  4.     With regard to Recommendation 17 below, and NIST’s reference to the widths of evacuation staircases and door openings, etc … fire codes and regulations, fire authorities having jurisdiction (AHJ’s), and even the fire services themselves … still have a crazy mixed-up approach to defining the width of these building features … an approach which I am not even going to attempt to repeat !   Forget it !!

Without Exception … all understandings of Evacuation Route Width, Evacuation Staircase Width and Evacuation Door Opening Width … must be harmonized with the following definitions of Unobstructed Width

Unobstructed Width – General

Free, unobstructed space – clear of all obstacles below a height of 2.1 metres above finished floor level – necessary for passage along a circulation route, or other route component, e.g. a staircase.

[ For example … the Unobstructed Width of a Staircase is the clear dimension from the edge of one handrail to the edge of the opposite handrail … and there is always a continuous handrail on each side of an evacuation staircase ! ]

Unobstructed Width – Door Opening

Free, unobstructed space – clear of all obstacles below a height of 2.0 metres above finished floor level – necessary for passage through a door opening, measured when the door leaf is opened to an angle of 90°, or when a sliding or folding door leaf is opened to its fullest extent.

[ For example … the Unobstructed Width of a Door Opening is the dimension from the edge of the door leaf (when open at an angle of 90°) to the nearest edge of the door frame.]

This FireOx International Page on the SDI Corporate WebSite provides more guidance … http://www.sustainable-design.ie/fire/appendixd.htm

  5.     With regard to Recommendation 20 below, and NIST’s reference to allowing “all occupants an equal opportunity for evacuation” … this is not just a ‘nice idea’, or an ‘idealistic notion’ … this is now a Human and Social Right which is backed up and supported by International Law !   And … it is no longer acceptable for the Fire Science and Engineering Community to continue its stubborn resistance in the face of this fact !!

For the benefit of my fire engineering colleagues … I will, once again here, reproduce the most relevant extracts from the United Nations Convention on the Rights of Persons with Disabilities …

UN CRPD  Preamble Paragraph (g)

Emphasizing the importance of mainstreaming disability issues as an integral part of relevant strategies of sustainable development, …

UN CRPD  Article 9 – Accessibility

1.  To enable persons with disabilities to live independently and participate fully in all aspects of life, States Parties shall take appropriate measures to ensure to persons with disabilities access, on an equal basis with others, to the physical environment, to transportation, to information and communications, including information and communications technologies and systems, and to other facilities and services open or provided to the public, both in urban and in rural areas.  These measures, which shall include the identification and elimination of obstacles and barriers to accessibility, shall apply to, inter alia:

(a)  Buildings, roads, transportation and other indoor and outdoor facilities, including schools, housing, medical facilities and workplaces ;

(b)  Information, communications and other services, including electronic services and emergency services.

2.  States Parties shall also take appropriate measures:

(a)  To develop, promulgate and monitor the implementation of minimum standards and guidelines for the accessibility of facilities and services open or provided to the public ;

(b)  To ensure that private entities that offer facilities and services which are open or provided to the public take into account all aspects of accessibility for persons with disabilities ;

(c)  To provide training for stakeholders on accessibility issues facing persons with disabilities ;

(d)  To provide in buildings and other facilities open to the public signage in Braille and in easy to read and understand forms ;

(e)  To provide forms of live assistance and intermediaries, including guides, readers and professional sign language interpreters, to facilitate accessibility to buildings and other facilities open to the public ;

(f)  To promote other appropriate forms of assistance and support to persons with disabilities to ensure their access to information ;

(g)  To promote access for persons with disabilities to new information and communications technologies and systems, including the Internet ;

(h)  To promote the design, development, production and distribution of accessible information and communications technologies and systems at an early stage, so that these technologies and systems become accessible at minimum cost.

UN CRPD  Article 11 – Situations of Risk & Humanitarian Emergencies

States Parties shall take, in accordance with their obligations under international law, including international humanitarian law and international human rights law, all necessary measures to ensure the protection and safety of persons with disabilities in situations of risk, including situations of armed conflict, humanitarian emergencies and the occurrence of natural disasters.

[ Note:  An outbreak of fire in a building is a situation of serious risk for all vulnerable building occupants/users.]

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At the time of writing, 153 Countries had signed the UN CRPD … while 106 Countries have ratified the Convention and are, therefore, the ‘State Parties’ referred to above.

These are just a few of the State Parties to the UN CRPD …

  • Argentina  (ratified the UN CRPD, 2008-09-02)
  • Australia  (ratified the UN CRPD, 2008-07-17)
  • Brazil  (ratified the UN CRPD, 2008-08-01)
  • Canada  (ratified the UN CRPD, 2010-03-11)
  • China  (ratified the UN CRPD, 2008-08-01)
  • Cuba  (ratified the UN CRPD, 2007-09-06)
  • European Union  (ratified the UN CRPD, 2010-12-23)
  • India  (ratified the UN CRPD, 2007-10-01)
  • Malaysia  (ratified the UN CRPD, 2010-07-19)
  • Mexico  (ratified the UN CRPD, 2007-12-17)
  • Philippines  (ratified the UN CRPD, 2008-04-15)
  • South Africa  (ratified the UN CRPD, 2007-11-30)
  • Turkey  (ratified the UN CRPD, 2009-09-28)
  • United Arab Emirates  (ratified the UN CRPD, 2010-03-19)

I wonder how implementation is proceeding in these countries !?!

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2005 NIST WTC RECOMMENDATIONS

GROUP 5.  Improved Building Evacuation

Building evacuation should be improved to include system designs that facilitate safe and rapid egress, methods for ensuring clear and timely emergency communications to occupants, better occupant preparedness regarding their roles and duties for evacuation during emergencies, and incorporation of appropriate egress technologies.*

[ * F-36  This effort should include standards and guidelines for the development and evaluation of emergency evacuation plans, including best practices for both partial and full evacuation, and the development of contingency plans that account for expected conditions that may require adaptation, including the compromise of all or part of an egress path before or during evacuation, or conditions such as widespread power failure, earthquake, or security threat that restrict egress from the building.  Evacuation planning should include the process from initial notification of the need to evacuate up to the point when occupants arrive at a place where their safety is ensured.  These standards and guidelines should be suitable for assessing the adequacy of evacuation plans submitted for approval, and should require occupant training through the conduct of regular drills.]

NIST WTC Recommendation 16.

NIST recommends that public agencies, non-profit organizations concerned with building and fire safety, and building owners and managers develop and carry out public education and training campaigns, jointly and on a nationwide scale, to improve building occupants’ preparedness for evacuation in case of building emergencies.  This effort should include better training and self-preparation of occupants, an effectively implemented system of floor wardens and building safety personnel, and needed improvements to standards.  Occupant preparedness should include:

a.     Improved training and drills for building occupants to ensure that they know evacuation procedures for a variety of emergency scenarios (e.g. including evacuation and shelter in place), are familiar with the egress route, and are sufficiently aware of what is necessary if evacuation is required with minimal notice (e.g. footwear consistent with the distance to be travelled, a flashlight/glow stick for pathway illumination, and dust masks).

b.     Building owners and managers should educate tenants on the life safety systems present in their building(s), provide training materials explaining egress routes and stairwell and elevator information, and develop educational programmes explaining the most appropriate responses in emergency situations.  It is further recommended that the owners and managers of office buildings implement the necessary systems for collecting and storing the training history of each building occupant.

c.     Improved training and drills that routinely inform building occupants that roof rescue is not (or is) presently feasible as a standard evacuation option, that they should evacuate down the stairs in any full-building evacuation unless explicitly instructed otherwise by on-site incident commanders, and that elevators can be used if they are still in service and haven’t been recalled or stopped.

d.     Improved codes, laws, and regulations that do not restrict or impede building occupants during evacuation drills from familiarizing themselves with the detailed layout of alternative egress routes for a full building evacuation.*

[ * F-37  New York City Local Law 5 prohibits requiring occupants to practice stairwell evacuation during drills.]

Affected Standard:  ICC/ANSI A117-1.  Model Building and Fire Codes:  The standard should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard.  Affected Organizations:  NFPA, NIBS, NCSBCS, BOMA, and CTBUH.

NIST WTC Recommendation 17.

NIST recommends that tall buildings be designed to accommodate timely full building evacuation of occupants when required in building-specific or large-scale emergencies such as widespread power outages, major earthquakes, tornadoes, hurricanes without sufficient advance warning, fires, explosions, and terrorist attack.  Building size, population, function, and iconic status should be taken into account in designing the egress system.  Stairwell capacity and stair discharge door opening width* should be adequate to accommodate contraflow due to emergency access by responders.

[ * F-38  Egress capacity should be based on an all-hazards approach that considers the number and width of stairs (and door openings) as well as the possible use of scissor stairs credited as a single stair.]

a.     Improved egress analysis models, design methodology, and supporting data should be developed to achieve a target evacuation performance (e.g. time for full building evacuation*) for the design building population by considering the building and egress system designs, and human factors such as occupant size, mobility status, stairwell tenability conditions, visibility, and congestion.

[ * F-39  Use of egress models is required to estimate the egress capacity for a range of different evacuation strategies, including full building evacuation.  NIST found that the average surviving occupant in the WTC towers descended stairwells at about half the slowest speed previously measured for non-emergency evacuations.]

b.     To the degree possible, mobility impaired occupants should be provided a means for self-evacuation in the event of a building emergency.  Current strategies (and law) generally require the mobility impaired to shelter in place.  New procedures, which provide redundancy in the event that the floor warden system or co-worker assistance (i.e. a buddy system) fails, should consider full building evacuation, and may include use of fire-protected and structurally hardened elevators,* motorized evacuation technology (e.g. a battery-operated evacuation chair), and/or dedicated communication technologies for the mobility impaired.

[ * F-40  Elevators should be explicitly designed to provide protection against large, but conventional, building fires.  Fire-protected elevators also should be structurally hardened to withstand the range of foreseeable building-specific or large-scale emergencies.  While progress has been made in developing the requirements and technologies for fire-protected elevators, similar criteria and designs for structurally hardened elevators remain to be developed.]

c.     If protected/hardened elevators are provided for emergency responders but become unusable during an emergency, due to a malfunction or a conventional threat whose magnitude exceeds the magnitude considered in design, sufficient stairwell capacity should be provided to ensure timely emergency responder access to buildings that are undergoing full evacuation.  Such capacity could be provided either via dedicated stairways for fire service use or by building sufficient stairway capacity (i.e. number and width of stairways and/or use of scissor stairs credited as a single stair) to accommodate the evacuation of building occupants while allowing access to emergency responders with minimal hindrance from occupant contraflow.

d.     The egress allowance in assembly use spaces should be limited in state and local laws and regulations to no more than a doubling of the stairway capacity for the provision of a horizontal exit on a floor, as is the case now in the national model codes.*  The use of a horizontal exit creates an area of refuge with a 2 hour fire rated separation, at least one stair on each side, and sufficient space for the expected occupant load.

[ * F-41  The New York City Building Code permits a doubling of allowed stair capacity when one area of refuge is provided on a floor, and a tripling of stair capacity for two or more areas of refuge on a floor.  In the world after 11 September 2001, it is difficult to predict: (1) if, and for how long, occupants will be willing to wait in a refuge area before entering an egress stairway; and (2) what the impact would be of such a large group of people moving down the stairs on the orderly evacuation of lower floors.]

Affected Standards:  NFPA 101, ASME A 17.  Model Building and Fire Codes:  The standards should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard.

NIST WTC Recommendation 18.

NIST recommends that egress systems be designed:  (1) to maximize remoteness of egress components (i.e. stairs, elevators, exits) without negatively impacting on average travel distances;  (2) to maintain their functional integrity and survivability under foreseeable building-specific or large-scale emergencies;  and (3) with consistent layouts, standard signage, and guidance so that systems become intuitive and obvious to building occupants during evacuations.

a.     Within a safety-based design hierarchy that should be developed, highest priority should be assigned to maintain the functional integrity, survivability, and remoteness of egress components and active fire protection systems (sprinklers, standpipes, associated water supply, fire alarms, and smoke management systems).  The design hierarchy should consider the many systems (e.g. stairs, elevators, active fire protection, mechanical, electrical, plumbing, and structural) and system components, as well as functional integrity, tenant access, emergency responder access, building configuration, security, and structural design.

b.     The design, functional integrity, and survivability of the egress and other life safety systems (e.g. stairwell and elevator shafts, and active fire protection systems) should be enhanced by considering accidental structural loads such as those induced by overpressures (e.g. gas explosions), impacts, or major hurricanes and earthquakes, in addition to fire separation requirements.  In selected buildings, structural loads due to other risks such as those due to terrorism may need to be considered.  While NIST does not believe that buildings should be designed for aircraft impact, as the last line of defence for life safety, the stairwells and elevator shafts individually, or the core if these egress components are contained within the core, should have adequate structural integrity to withstand accidental structural loads and anticipated risks.

c.     Stairwell remoteness requirements should be met by a physical separation of the stairwells that provide a barrier to both fire and accidental structural loads.  Maximizing stairwell remoteness, without negatively impacting on average travel distances, would allow a stairwell to maintain its structural integrity independent of any other stairwell that is subject to accidental loads, even if the stairwells are located within the same structural barrier such as the core.  The current ‘walking path’ measurement allows stairwells to be physically next to each other, separated only by a fire barrier.  Reducing the clustering of stairways that also contain standpipe water systems provides the fire service with increased options for formulating firefighting strategies.  This should not preclude the use of scissor stairs* as a means of increasing stair capacity – provided the scissor stair is only credited as a single stair.

[ * F-42  Two separate stairways within the same enclosure and separated by a fire rated partition.]

d.     Egress systems should have consistent layouts with standard signage and guidance so that the systems become intuitive and obvious to all building occupants, including visitors, during evacuations.  Particular consideration should be given to unexpected deviations in the stairwells (e.g. floors with transfer hallways).

Affected Standard:  NFPA 101.  Model Building and Fire Codes:  The standard should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard.

NIST WTC Recommendation 19.

NIST recommends that building owners, managers, and emergency responders develop a joint plan and take steps to ensure that accurate emergency information is communicated in a timely manner to enhance the situational awareness of building occupants and emergency responders affected by an event.  This should be accomplished through better co-ordination of information among different emergency responder groups, efficient sharing of that information among building occupants and emergency responders, more robust design of emergency public address systems, improved emergency responder communication systems, and use of the Emergency Broadcast System (now known as the Integrated Public Alert and Warning System) and Community Emergency Alert Networks.

a.     Situational awareness of building occupants and emergency responders in the form of information and event knowledge should be improved through better co-ordination of such information among emergency responder groups (9-1-1 dispatch, fire department or police department dispatch, emergency management dispatch, site security, and appropriate federal agencies), efficient sharing and communication of information between building occupants and emergency responders, and improved emergency responder communication systems (i.e. including effective communication within steel and reinforced concrete buildings, capacity commensurate with the scale of operations, and interoperability among different communication systems.

b.     The emergency communications systems in buildings should be designed with sufficient robustness and redundancy to continue providing public address announcements or instructions in foreseeable building-specific or large-scale emergencies, including widespread power outage, major earthquakes, tornadoes, hurricanes, fires, and accidental explosions.  Consideration should be given to placement of building announcement speakers in stairways in addition to other standard locations.

c.     The Integrated Public Alert and Warning System (IPAWS) should be activated and used, especially during large-scale emergencies, as a means to rapidly and widely communicate information to building occupants and emergency responders to enhance their situational awareness and assist with evacuation.

d.     Local jurisdictions (cities and counties or boroughs) should seriously consider establishing a Community Emergency Alert Network (CEAN), within the framework of IPAWS, and make it available to the citizens and emergency responders of their jurisdictions to enhance situational awareness in emergencies.*  The network should deliver important emergency alerts, information and real time updates to all electronic communication systems or devices registered with the CEAN.  These devices may include e-mail accounts, cell/mobile phones, text pagers, satellite phones, and wireless PDA’s.

[ * F-43  Types of emergency communications could include life safety information, severe weather warnings, disaster notifications (including information on terrorist attacks), directions for self-protection, locations of nearest available shelters, precautionary evacuation information, identification of available evacuation routes, and accidents or obstructions associated with roadways and utilities.]

Affected Standard:  NFPA 101, and/or a new standard.  Model Building and Fire Codes:  The standard should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard to the extent it is within the scope of building and fire codes.

NIST WTC Recommendation 20.

NIST recommends that the full range of current and next generation evacuation technologies should be evaluated for future use, including protected/hardened elevators, exterior escape devices, and stairwell descent devices, which may allow all occupants an equal opportunity for evacuation and facilitate emergency response access.  Affected Standards:  NFPA 101, ASME A 17, ASTM E 06, ANSI A117.1.  Model Building and Fire Codes:  The standards should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard.

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NIST WTC Recommendations 12-15 > Improved Active Protection

Previous Posts in This Series …

2011-10-25:  NIST’s Recommendations on the 9-11 WTC Building CollapsesGROUP 1. Increased Structural Integrity – Recommendations 1, 2 & 3 (out of 30)

2011-11-18:  NIST WTC Recommendations 4-7 > Structural Fire EnduranceGROUP 2.  Enhanced Fire Endurance of Structures – Recommendations 4, 5, 6 & 7

2011-11-24:  NIST WTC Recommendations 8-11 > New Design of StructuresGROUP 3.  New Methods for Fire Resisting Design of Structures – Recommendations 8, 9, 10 & 11

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2011-11-25:  SOME PRELIMINARY COMMENTS …

  1.     Reliability has always been an issue with Active Fire Protection Systems … but, it is neither acknowledged, nor fully understood, that … Reliability Is Equally An Issue With Passive Fire Protection Measures !

Furthermore, the following should always be taken into account when considering the Safety Factors to be applied in calculating the level of satisfactory fire safety and protection which is provided in a specific project … one of the design objectives in Ethical Fire Engineering.

For example, if Category C below is indicative of the design and construction quality on a particular building site … just think of the Priory Hall Apartment Development in Dublin (!) … the Safety Factors to be applied in the design should be high … and with regard to actual construction, it should be expected that the Reliability of both Active Fire Protection Systems and Passive Fire Protection Measures will be initially low … with Life Cycle Reliability being entirely non-existent.

Quality of Fire Engineering Design & Related Construction 

Category A

(a)   Design of the works is exercised by an independent, appropriately qualified and experienced architect/engineer/fire engineer, with design competence relating to fire safety and protection in buildings … and, most importantly, that he/she interacts directly with the Project Design Professional in Responsible Charge ;

(b)   Installation/fitting of related construction products/systems is exercised by appropriately qualified and experienced personnel, with construction competence relating to fire safety and protection in buildings ;

(c)   Supervision of the works is exercised by appropriately qualified and experienced personnel from the principal construction organization ;

(d)   Regular inspections, by appropriately qualified and experienced personnel familiar with the design, and independent of the construction organization(s), are carried out to verify that the works are being executed in accordance with the fire engineering design.

Category B

(a)   Design of the works is exercised by an independent, appropriately qualified and experienced architect/engineer/fire engineer ;

(b)   Installation/fitting of fire-related construction products/systems is exercised by appropriately qualified and experienced personnel ;

(c)   Supervision of the works is exercised by appropriately qualified and experienced personnel from the principal construction organization.

Category C

This level of design and construction execution is assumed when the requirements for Category A or Category B are not met.

  2.     With regard to Recommendations 12 & 13 below … in an earlier post in this series, and elsewhere, I have defined Disproportionate Damage … and differentiated that structural concept from the related concept of Fire-Induced Progressive Collapse.

A significant number of countries include a requirement on Resistance to Disproportionate Damage in their national building codes.  Often, it is only necessary to consider this requirement in the case of buildings having 5 Storeys, or more … a completely arbitrary height threshold.  I would consider that adequately tying together the horizontal and vertical structural elements of a building … any building … is a fundamental principle of good structural engineering !!

Putting it simply … for the purpose of showing compliance with this structural requirement … it is necessary to demonstrate that a building will remain structurally stable if a portion of the building’s structure is removed … always remembering that every building comprises both structure and fabric, i.e. non-structure.

In reality this may happen, and quite often does happen, when, for example, a large truck runs into the side of a building, which can happen anywhere … or there is a gas explosion in some part of the building, which happened in Dublin’s Raglan House back in 1987, and many times in other countries … or a plane hits a high-rise building, which happened to Milan’s iconic Pirelli Tower in 2002, and to New York’s Empire State Building way back in 1945 … etc., etc.  Raglan House collapsed … the Pirelli Tower and the Empire State Building did not.

[ The World Trade Center Towers were originally designed to absorb the impact of a large plane and to remain structurally stable afterwards … in ambient conditions.  However, what was not considered in the ambient structural design was ‘fire’, i.e. the fuel tanks were empty and no fire in the building would be initiated as a result of the mechanical damage caused by the plane impact … which, on 11 September 2001, proved to be a ridiculous basis for any structural design !   This is why 9-11 should be regarded, at its core, as being a very serious ‘real’ fire incident.]

What I am leading up to is this … the concept of removing a portion of a building, and it remaining structurally stable afterwards … should now – logically and rationally – also be incorporated into the fire engineering design of Active Fire Protection Systems.  In other words, if a portion of a building is removed, will any particular Active Fire Protection System continue to operate effectively in the rest of the building ?   This has implications for the location and adequate protection of critical system components in a building … and for the necessary redundancy, zoning and back-up alternative routeing which must be designed into the system from the beginning !

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2005 NIST WTC RECOMMENDATIONS

GROUP 4.  Improved Active Fire Protection

Active fire protection systems (i.e. sprinklers, standpipes/hoses, fire alarms, and smoke management systems) should be enhanced through improvements to the design, performance, reliability, and redundancy of such systems.

NIST WTC Recommendation 12.

NIST recommends that the performance and possibly the redundancy of active fire protection systems (sprinklers, standpipes/hoses, fire alarms, and smoke management systems) in buildings be enhanced to accommodate the greater risks associated with increasing building height and population, increased use of open spaces, high-risk building activities, fire department response limits, transient fuel loads, and higher threat profile.  The performance attributes should deal realistically with the system design basis, reliability of automatic/manual operations, redundancy, and reduction of vulnerabilities due to single point failures.  Affected Standards:  NFPA 13, NFPA 14, NFPA 20, NFPA 72, NFPA 90A, NFPA 92A, NFPA 92B, and NFPA 101.  Model Building Codes:  The performance standards should be adopted in model building codes by mandatory reference to, or incorporation of, the latest edition of the standard.

NIST WTC Recommendation 13.

NIST recommends that fire alarm and communications systems in buildings be developed to provide continuous, reliable, and accurate information on the status of life safety conditions at a level of detail sufficient to manage the evacuation process in building fire emergencies;  all communication and control paths in buildings need to be designed and installed to have the same resistance to failure and increased survivability above that specified in present standards.  This should include means to maintain communications with evacuating occupants that can both reassure them and redirect them if conditions change.  Pre-installed fire warden telephone systems can serve a useful purpose and may be installed in buildings and, if so, they should be made available for use by emergency responders.  All communication and control paths in buildings need to be designed and installed to have the same resistance to failure and increased survivability above that specified in present standards.  Affected Standards:  NFPA 1, NFPA 72, and NFPA 101.  Model Building and Fire Codes:  The performance standards should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard.

NIST WTC Recommendation 14.

NIST recommends that control panels at fire/emergency command stations in buildings be adapted to accept and interpret a larger quantity of more reliable information from the active fire protection systems that provide tactical decision aids to fire ground commanders, including water flow rates from pressure and flow measurement devices, and that standards for their performance be developed.  Affected Standards:  NFPA 1, NFPA 72, and NFPA 101.  Model Building and Fire Codes:  The performance standards should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard.

NIST WTC Recommendation 15.

NIST recommends that systems be developed and implemented for:  (1) real time off-site secure transmission of valuable information from fire alarm and other monitored building systems for use by emergency responders, at any location, to enhance situational awareness and response decisions, and maintain safe and efficient operation;*  and (2) preservation of that information either off-site, or in a black box that will survive a fire or other building failure, for purposes of subsequent investigations and analysis.  Standards for the performance of such systems should be developed, and their use should be required.  Affected Standards:  NFPA 1, NFPA 72, and NFPA 101.  Model Building and Fire Codes:  The performance standards should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard.

[ * F-35  The alarm systems in the WTC towers were only capable of determining and displaying: (a) areas that had at some time reached alarm point conditions; and (b) areas that had not.  The quality and reliability of information available to emergency responders at the Fire Command Station was not sufficient to understand the fire conditions.  The only information transmitted outside the buildings was the fact that the buildings had gone into alarm.  Further, the fire alarm system in WTC Building 7, which was transmitted to a monitoring service, was on ‘test mode’ during the morning of 11 September 2001, because routine maintenance was being performed.  Under test mode conditions: (1) the system is typically disabled for the entire building, not just for the area where work is being performed; and (2) alarm signals typically do not show up on an operator console.]

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Disability Access Certificates (DAC’s) in Ireland – Confused ??

2011-09-01:  To say, bluntly, that there is confusion out there … at every level … would be a mild understatement !   Yes, the Disability Access Certificate (DAC) & Revised DAC Process is new … but that cannot explain what is happening … or, more precisely, what is not happening.

BUT … before jumping in at the deep end and examining the existing and operative Part M of the Irish Building Regulations … let me just mention, very briefly, two wider legal ‘niceties’ concerning Accessibility of Buildings for People with Disabilities

     1.  The Black Hole between Building Regulations and Equality Law

The definition of People with Disabilities in the existing Part M is limited.  It is inadequate.  Compare, now, that definition with the definition of Disability in Irish Equality Legislation … which is the complete opposite, being very wide in scope.  A deep chasm exists between the two.  Check each of them out for yourself !   And because few people are aware of this chasm … a better description of that large space might be a Black Hole.

However, the clear consequence of the Black Hole for building owners … and building designers alike … is that the ‘act’ of merely going through the motions with regard to compliance with Part M … and being satisfied with getting ‘the’ piece of paper, i.e. a Disability Access Certificate … will, without any shadow of a doubt, open the building owner to a complaint under Equality Law.  And when a building owner encounters this sort of problem … who will he, or she, hunt down for an explanation ??

Client Organizations beware … prevention is a far better strategy !!   Check out the Level of Accessibility Performance required to avoid complaints under Equality Legislation.

[ You should also consider the following … the Health & Safety Authority in Ireland is doing absolutely nothing to ensure that Workplaces are Accessible … a requirement contained in all of the European Union (EU) Safety at Work Directives and the Irish National Legislation implementing those Directives.  So, also cross check the Level of Accessibility Performance required to comply with Safety at Work Legislation.  Compliance with Part M is not sufficient ! ]

     2.  European Union Ratification of the 2006 United Nations Convention on the Rights of Persons with Disabilities (CRPD)

For a sizeable group of vulnerable people in every EU Member State, the sole route of access to many, if not most, of the Human and Social Rights set down in the 1948 Universal Declaration of Human Rights (UDHR) is the UN Convention on the Rights of Persons with Disabilities (CRPD) … which became an International Legal Instrument on 3 May 2008, and was ratified by the European Union on 23 December 2010.  That is precisely why Accessibility is such a critical component of the 2006 UN Convention !

Articles 31 & 33 of the 2006 UN Convention on the Rights of Persons with Disabilities – together – mandate that Accessibility Implementation is taken seriously … that it is competent and effective … and, most importantly, that independent monitoring and verification is a fundamental part of the process.

Ireland has not yet ratified the UN CRPD.  And, as far as our National Authorities Having Jurisdiction (AHJ’s) are concerned … everything in the garden is beautiful … Ireland is doing just great and nothing much needs to be altered in our laws, administrative provisions or resourcing … to allow Ireland to ratify the Convention, and then properly implement it.  Nothing could be further from the truth !

In Order to Protect your Organization and its many interests … Your Policy and Decision Makers, in Ireland, should study the implications flowing directly from EU Ratification of the UN CRPD … and then, the various Articles of the UN Convention should be examined and properly implemented … insofar as those Articles are relevant to you and your organization’s activities.  See my earlier post, dated 5 February 2011.

To date … the quality of Accessibility Implementation in Irish Buildings has been dreadful !!   For important reasons … which all parties involved should fully understand … this situation is longer acceptable.

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Colour photograph showing the front entrances to dwelling units in a New Inner City Housing Scheme in Dublin ... User Unfriendly ... Inaccessible for Many Vulnerable People in Our Society ... Dreadful Accessibility Implementation ! Photograph taken by CJ Walsh. 2003-09-13. Click to enlarge.

Colour photograph showing the front entrances to dwelling units in a New Inner City Housing Scheme in Dublin ... User Unfriendly ... Inaccessible for Many Vulnerable People in Our Society ... Dreadful Accessibility Implementation ! Photograph taken by CJ Walsh. 2003-09-13. Click to enlarge.

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Disability Access Certificates (DAC’s) & Part M

The submission of sufficient, quality information, i.e. detailed design documentation, at Disability Access Certificate (DAC) Application Stage typically signals the following to an experienced technical controller …

  • The intent of the Applicant, and the Agent(s) acting on his/her/their behalf, with regard to properly and satisfactorily complying with the relevant building legislation, i.e. Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Irish Building Regulations ;  and
  • In the absence of an inspection by the Building Control Authority (BCA) during actual construction … whether or not it is likely that the completed works will match the DAC certified design documentation with regard to Accessibility Performance.

From the beginning, it is necessary to distinguish between Access and Accessibility.

To be written in stone when International Standard ISO 21542 is soon published … the components of Building Accessibility comprise …

  • Approach to the building ;
  • Entry ;
  • Use of the building, its services and facilities ;
  • Egress from the building (during normal conditions) ;
  • Removal from the vicinity of the building (during normal conditions) ;

and

  • Evacuation from the building (during, for example, a fire emergency) ;
  • Safe Movement to a ‘place of safety’ (during, for example, a fire emergency), which is remote from the building.

This is also a useful guideline with regard to segregating those aspects of Accessibility Design which relate to Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Irish Building Regulations, and which should be considered in any application for a Disability Access Certificate (DAC) … and those, after ‘and‘ … which relate to Part B: ‘Fire Safety’, and which should be considered in every application for a Fire Safety Certificate (FSC).

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The 2000 Building Regulations (Amendment) Regulations … Statutory Instrument No. 179 of 2000 … elaborate the relevant Irish Building Legislation concerning building access, i.e. Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Building Regulations …

Access and Use

M1     Adequate provision shall be made to enable people with disabilities to safely and independently access and use a building.

Sanitary Conveniences

M2     If sanitary conveniences are provided in a building, adequate provision shall be made for people with disabilities.

Audience or Spectator Facilities

M3     If a building contains fixed seating for audience or spectators, adequate provision shall be made for people with disabilities.

Definition for This Part

M4     In this Part, ‘people with disabilities’ means people who have an impairment of hearing or sight or an impairment which limits their ability to walk, or which restricts them to a wheelchair.

Application of This Part

M5     Part M does not apply to works in connection with extensions to and the material alterations of existing dwellings, provided that such works do not create a new dwelling.”

My Note 1:  In order to safely and independently use a building … it is also necessary, under normal conditions, to use the egress routes of a building.

My Note 2:  The limited definition of ‘people with disabilities’ in Requirement M4 does not include, for example, a person without arms … or those people with a mental, cognitive or psychological impairment.

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Technical Guidance Document M (2000, re-printed in 2005) provides guidance in relation to Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Irish Building Regulations.  TGD M was issued by the Department of the Environment, under Article 7 of the 1997 Building Regulations … Statutory Instrument No. 497 of 1997 … which states …

” 7.     (1)  The Minister may publish, or arrange to have published on his behalf, documents to be known as ‘technical guidance documents’ for the purpose of providing guidance with respect to compliance with the requirements of any of the provisions of the Second Schedule.

          (2)  Subject to the provisions of sub-article (3), where works or a building to which these Regulations apply is or are designed and constructed in accordance with any guidance contained in a technical guidance document, this shall, prima facie, indicate compliance with the relevant requirements of these Regulations.

          (3)  The provisions of any guidance contained in a technical guidance document published under sub-article (1) concerning the use of a particular material, method of construction or specification, shall not be construed as prohibiting compliance with a requirement of these Regulations by the use of any other suitable material, method of construction or specification.”

My Note 3:  Since the introduction of national legal building legislation in the early 1990’s, the Irish Building Regulations have a Functional Format, as required by European Union (EU) Law.  In other words, satisfactory compliance with short functional statements is mandated by law … and provided the requirements of those short statements are properly shown to be complied with, it is entirely optional as to which materials, methods of construction, standards and other specifications (including technical specifications) are used.  In this way, the free movement of products and services within the EU is facilitated and encouraged while, at the same time, technical barriers to trade are avoided.

My Note 4:  For the convenience of readers, the short functional statements mandated by law are reproduced, in a shaded box, at the beginning of each of the Technical Guidance Documents.  The Guidance Texts in each Technical Guidance Document, however, are not Prescriptive Regulations.  These texts are merely an indicator of what is likely to be suitable for the purposes of compliance with the Regulations … they are, prima facie (i.e. on ‘first appearance’ only), an indication of compliance ;  they are not ‘deemed-to-satisfy’ the Requirements of Part M.

My Note 5:  Where gaps are identified in the guidance texts of Technical Guidance Document M … and in the absence of an Irish National Standard on Building Access or Accessibility … a suggested hierarchy of approach should be to source an appropriate European Standard (EN) or, if such a standard does not yet exist, then an appropriate International Standard (ISO), or then a National Standard of any country which is a contracting party to the Agreement on the European Economic Area (EEA) which provides in use an appropriate level of Access/Accessibility Performance (refer to Part D of the Second Schedule to the Building Regulations).  In the unlikely absence of any of the above, an appropriate Design Guidance Document – national or otherwise – should be referenced which provides in use an appropriate level of Access/Accessibility Performance.

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Our Organization – Sustainable Design International – provides an independent (and confidential) Accessibility Monitoring and Verification Service.

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