Technical Guidance Document B (Fire Safety)

England’s 2017 Grenfell Tower Fire – Never Again Elsewhere ??

2018-06-12 …

As we approach the First Anniversary of the Grenfell Tower Fire Tragedy, in England, on 14 June … a few days ago, on 4 June 2018, the first batch of Grenfell Expert Witness Reports were uploaded (https://www.bbc.com/news/uk-44356660) to the Grenfell Tower Inquiry Website (https://www.grenfelltowerinquiry.org.uk/) for public view.

At this time, in London … multiple, fragmented investigations are taking place into the actual fire incident … the role of the Local Authority, and building management … those involved in the refurbishment (‘tarting up’) design and construction … the fire services, particularly their ‘Stay Put’ Policy and how it adversely impacted on vulnerable Tower occupants during the emergency … and the highly flawed regulatory model of Building and Fire Codes with light-touch Control, which is still operating in England.  One of Murphy’s Laws immediately springs to mind with regard to the intended ineffectiveness of this overly-complex process !

Colour photograph showing Grenfell Tower in the background … undergoing an almost complete ‘cover-up’ … with, in the foreground, mementos of the Fire Tragedy fixed to railings by local residents. Click to enlarge. Photograph taken by CJ Walsh. 2018-04-29.

Many other countries have adopted some or all of this modern English regulatory model which, after the repeal of an older Bye-Law format, has been shaped by political expediency, cost-effectiveness and general ineptitude … with little or no adaptation to local conditions in the adopting jurisdictions.  Ireland adopted this model with some, but not a lot, of adaptation.

Fire Safety In Ireland ?

On 6 June 2018 … while that investigative activity was hitting the headlines in England … Minister Eoghan Murphy, T.D., Ireland’s Minister for Housing, Planning and Local Government, quietly published the Report: ‘Fire Safety in Ireland’http://www.housing.gov.ie/local-government/fire-and-emergency-management/fire-safety/eoghan-murphy-publishes-report-fire … by a High-Level Task Force within his Department’s National Directorate for Fire and Emergency Management, after serious concerns and fears had been expressed in the public media that a similar fire tragedy might also occur in this jurisdiction.

To be crystal clear … this Report is a Bureaucratic Whitewash … an insult to the Public !  Nice sounding technical ‘blarney’ camouflages a failure to deal directly with critical issues, and answer concerns … while other important issues are avoided altogether.

.May 2018 – Ireland’s Department of Housing, Planning & Local Government Report

Fire Safety In Ireland    (PDF File, 2.55 MB)

Expanding on my comments in the Interview with Barry Lenihan, on RTE Radio 1’s Drive Time early evening news programme on Friday (2018-06-08) …

A.  Initially, Irish Local Authorities were requested to carry out a preliminary survey to identify all buildings of more than six storeys, or 18m in height.  Specifically, they were asked to identify those buildings which had an external cladding system which might be a cause for concern.

This height threshold of six storeys/18m is arbitrary … an external cladding system can be just as much a cause for concern in a building which is lower.  Imagine discarded cigarette butts or a rubbish fire at the base of such a system … and the resulting speed of fire spread and development across a building façade !

B.  The highly flawed regulatory model of Building and Fire Codes, with light-touch Control, which resulted in the Grenfell Tower Fire Tragedy … we also have.  Wake up and smell the coffee Ireland !

At the beginning of the 1990’s, when Ireland had been persuaded by the European Commission to finally introduce legal, national building regulations having a functional format … our National Authority Having Jurisdiction, in desperation, grabbed the then Approved Documents for England & Wales … brought them back to Ireland, put Irish covers on them, and originally called them ‘Technical Documents’ … but, after seeing a tiny ray of inspiring light, later changed their title to the more accurate ‘Technical Guidance Documents’ !  This hunger for adopting all things English which are fire safety related continues to this day … with a similar, ongoing division of Technical Guidance Document B: ‘Fire Safety’ into 2 Separate Volumes.

This may have been a convenient response under pressure … but it has been very short-sighted.  It has impeded the growth of a comprehensive and coherent philosophy on Safe, Inclusive, Age-Friendly, Resilient, Sustainable Planning, Design and Construction Codes/Controls which is suited to an Irish context and responsible local needs (not desires!).

C.  Everywhere … this Report has a lot – too much – to say about Fire Risk Assessment !  After the Grenfell Tower Fire, however, Fire Risk Assessments must only be carried out by competent persons … and the process of Fire Risk Assessment, itself, must be radically improved !  And of course, prior to any Risk Assessment … a proper Fire Hazard Appraisal must be carried out.

D.  To accurately present Fire Safety Trends in Ireland … it is not enough to furnish reliable fire fatality statistics.  It is also necessary to produce reliable fire injury statistics … and reliable information on direct/indirect socio-economic losses.

E.  The quality of fire safety related construction on Irish Building Sites continues to be very poor and problematic.  Fire Compartmentation is nowhere near being adequately – never mind acceptably – reliable !  And during the last few years we have had quite a number of close-calls concerning fire incidents in medium-rise residential buildings.

F.  Fire Evacuation for people with activity limitations is still handled atrociously in our current building regulations.  This is ironic because, on 20 March 2018 last, Ireland had to be dragged screaming to ratify the U.N. 2006 Convention on the Rights of Persons with Disabilities (CRPD) !

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Positive Progress By Another Path !

1.  Abandon the outdated English functional requirements in THEIR building regulations … and adopt a far better, more up-to-date body of functional requirements which is already on the Irish Statute Books … Annex I of the European Union’s Construction Products Regulation 305/2011.  And because there are important horizontal linkages between requirements … immediately finish the ridiculous current separation between Fire Safety requirements and all of the other requirements.  And yes … new Technical Guidance Documents will have to be drafted.

.Regulation (EU) No 305/2011 of the European Parliament and of the Council, of 9 March 2011, laying down harmonized conditions for the marketing of construction products and repealing Council Directive 89/106/EEC

EU Regulation 305/2011 – Construction Products.  See Annex I

(PDF File, 998 Kb)

2.  Yes … ‘Persons Having Control’ of buildings have responsibilities with regard to fire safety.  But that is only one side of the coin !  National and Local Authorities Having Jurisdiction have greater responsibilities.

If we are at all serious about Consumer Protection … bad, inadequate, faulty construction must be prevented beforehand … it is too late, too costly and, in many cases, too impractical to correct afterwards.  Self Regulation by building design professions and construction organizations is NO Regulation !  Stringent, independent technical control inspections must be carried out on all projects by Building Control personnel … which used to happen in Dublin City/County and Cork City/County prior to the introduction of legal building regulations in the early 1990’s … and, depending on complexity, must also be carried out at critical stages during the construction process.

Building Control Sections in all Local Authorities must be properly resourced with competent personnel, equipment, training and support infrastructure.

Inspections concerning compliance with all functional requirements in the building regulations, including fire safety, must be carried out only by Building Control Personnel.  Chief Fire Officers must not be allowed to manage or be involved in any aspect of Building Control.  On the same project … a Disability Access Certificate Application and a Fire Safety Certificate Application must be inter-linked and overlap sufficiently, showing no gaps in compliance.  Inspections must be carried out in connection with all Certificate Applications.  Building Control personnel must satisfy themselves that actual construction at least matches, if not improves upon, what is shown in design documentation.

Building Control Inspection Reports must be made available for public view.

3.  Firefighters are NOT a disposable Social Asset !  National and Local Authorities Having Jurisdiction … and some Chief Fire Officers … must begin to understand this fundamental truth !

Fire Services in all Local Authorities must each be properly resourced according to local needs … with competent personnel, equipment, training and support infrastructure.  Shared provision of resources looks very neat on paper but, in practice, works very badly.  Refer to the Grenfell Tower Fire and London Fire Brigade having to borrow firefighting equipment from other Fire Services.

After the 2015 Tianjin Regional Fire Devastation, in China, and the 2001 WTC Attacks on 9-11, in New York City … front line firefighters must be supported by Specialist Hazard Appraisal and Structural Engineering Units.

For Firefighter Safety in buildings and to quickly find people with activity limitations waiting in Areas of Rescue Assistance and/or other survivors in different locations … a portable and reliable Thermal Imaging Camera is an essential piece of every firefighter’s equipment.

And Firefighter Safety begins with good building design.  In all but the most simple building types, Circulation Routes must be designed for Contraflow … people moving away from a fire in a building and towards safety while, at the same time, heavily equipped firefighters are entering the building and moving towards the fire.

Colour photograph showing Contraflow on a building staircase … people moving down a staircase away from a fire and towards safety while, at the same time, heavily equipped firefighters are moving up the staircase towards the fire. Click to enlarge.

There is no place for ‘Stay Put’ Policies in Irish Residential Buildings of any height.

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Ireland’s 2017 Oireachtas Report: ‘Safe As Houses’ …

December 2017 – Houses of the Oireachtas – Joint Committee on Housing, Planning & Local Government

Safe As Houses ?  A Report On Building Standards, Building Controls & Consumer Protection

(PDF File, 1.01 MB)

This was a good effort by our public representatives … but they missed core issues !

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After The Grenfell Tower Fire !

Further to my last Blog, dated 2017-10-10 …

The 2017 Fire in England was not an extraordinary fire.  Since the beginning of this decade, we continue to see a series of such fires: South Korea (2010) – UAE & France (2012) – Chechnya (2013) -Australia (2014) – UAE, Azerbaijan & UAE again (2015) – UAE (2016) – UAE & Russia (2017) – Turkey (2018).

With regard to Command & Control of Large Scale Emergencies … English AHJ’s should have paid attention to the 2005 & 2008 U.S. National Institute of Science & Technology (NIST) Recommendations following the 9-11 WTC Buildings 1, 2 & 7 Collapses.

The Fire Safety Objectives in current Building & Fire Codes/Regulations are very limited.  In Ireland, this is clearly stated in Technical Guidance Document B …

‘ Building Regulations are made for specific purposes.  Part B of the Second Schedule to the Building Regulations is therefore primarily concerned with the health, safety and welfare of persons.  The fire safety measures outlined in this guidance document are intended for the protection of life from fire.’

Only insofar as it is necessary to protect the lives of able-bodied building users/occupants … is there a concern for property protection.

There is only inadequate, token concern for the protection of people with disabilities.

Client organizations, facility managers, building designers, construction organizations … and journalists … must fully comprehend these limits.

In the photograph below … look closely at the External Firefighting Operations at the bottom of the Tower.  There are limits to what can be achieved from outside a building !

Colour photograph showing the developed fire at Grenfell Tower, in London. At the bottom of the Tower, external firefighting operations can be viewed. Click to enlarge.

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  • A Fire Suppression System (Water Sprinklers/Mist/Hybrid) is an essential Fire Protection Measure in ALL Medium and High-Rise Residential Buildings … which include Apartment Blocks, Hotels, Hostels, Student Accommodation & Social Housing, i.e. ANYWHERE there is a Sleeping Hazard.

 

  • A Reliable and Credible Fire Detection & Warning System is an essential Fire Protection Measure in ALL Buildings … and must be capable, under the control of Building Management, of transmitting warnings in many formats, i.e. Audible + Visual + Multi-Lingual Voice + Tactile.

 

  • Fire Evacuation Routes in Buildings must be designed for CONTRAFLOW … people moving away from a fire and towards safety while, at the same time, heavily equipped firefighters are entering the building and moving towards the fire.

 

  • Good Fire Evacuation Route Design is INTUITIVE and OBVIOUS.  In many buildings, however, this is not always the reality.  Effective Fire Evacuation Signage … comprising high-level signage, low-level signage, with both supplemented by photoluminescence … must be installed in ALL Buildings.

 

  • For the purpose of protecting Vulnerable Building Users in Fire Emergencies, ALL Lifts/Elevators in Buildings must be capable of being used for Evacuation.

 

  • Fire Risk Assessments must NO LONGER be carried out by people WITHOUT COMPETENCE in Fire Engineering AND Building Design & Construction … and the Fire Risk Assessment Process itself must be thoroughly re-examined and upgraded.

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Building Fire Emergencies – What is a ‘Place of Safety’ ?

2009-10-24:  As I have travelled around … not just Ireland, but many other countries as well … it still remains a puzzle to me, today, why so many Fire Emergency Assembly Areas are located just outside the main entrance of a building.  These locations are not safe in a ‘real’ fire emergency … and they should not even be used for the purposes of test/drill evacuations !

Is the guidance contained in current Building & Fire Regulations, Codes and Standards on what is a ‘Place of Safety’ in a fire emergency clear, simple, direct and precise ?   Are you joking ?   No way !   Let us take a few examples close to home …

In Ireland:

When you look at the array of different Technical Guidance Documents (Building Regulations) at the same time … TGD B (Fire Safety) is way out of proportion, in size, compared to all of the others.  You would expect, therefore, to find exactly what you were looking for in that document.  Wouldn’t you ?

TGD B (2006), Paragraph #1.0.9 – Definitions

Place of Safety

A place, normally in the open air at ground level, in which persons are in no danger from fire.

Clear as mud !   If there is a fire on O’Connell Street in Dublin … a person is safe on Patrick Street in Cork !   But, how is any Building or Facilities Manager expected to work with such a vague definition ? 

In England & Wales:

No practical definition, as such, is readily provided.  The nearest thing to a definition is an amalgam of the following …

Building Regulations, Requirement B1 – Means of Warning & Escape

The building shall be designed and constructed so that there are appropriate provisions for the early warning of fire, and appropriate means of escape in case of fire from the building to a place of safety outside the building capable of being safely and effectively used at all material times.

Approved Document B: Volume 1 – Dwellinghouses & Volume 2 – Buildings Other Than Dwellinghouses

The ultimate place of safety is the open air clear of the effects of the fire.

British Standard BS 9999 : Code of Practice for Fire Safety in the Design, Management & Use of Buildings : 2008

Place of Ultimate Safety

Place in which there is no immediate or future danger from fire or from the effects of a fire.

Again … all as clear as mud !   Again … how is any Building or Facilities Manager expected to work with such vague guidance ?   Have you also noticed the additional obfuscation introduced by use of the word ‘ultimate’ in BS 9999 ?

It is hard to escape the conclusion that what is urgently needed is a fundamental transformation and re-shaping of the tired, antiquated and flawed ad-hoc assembly of prescriptive ‘solutions’ contained in current national building and fire regulations, codes, standards and administrative provisions … whatever their origin !

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Now … try this for clarity, simplicity, directness and precision …

Place of Safety (Fire Incident in a Building, No Explosion Hazard*)

Any location beyond a perimeter which is [100]* metres from the fire building or a distance of [10]* times the height of such building, whichever is the greater

and

where necessary and effective medical care and attention can be provided, or organized, within one hour of injury

and

where people can be identified.

* Where there is a Risk of Explosion … multiply the numbers in square brackets above by 4.

Was that good for you ?

Furthermore …

The Route to any Place of Safety must be Accessible for All Building Users, including people who use wheelchairs, the visually impaired, frail older people, women in the later stages of pregnancy, children, etc., etc.

Colour photograph showing a Typical Scene at a Building Fire Emergency, with Fire Service Vehicles and Personnel in operation mode.  The haphazard arrangement of firefighting water hoses on the ground makes access difficult for many Building Users to a 'Place of Safety' which is remote from the Fire Building.

Colour photograph showing a Typical Scene at a Building Fire Emergency, with Fire Service Vehicles and Personnel in operation mode. The haphazard arrangement of firefighting water hoses on the ground makes access difficult for many Building Users to a ‘Place of Safety’ which is remote from the Fire Building. Click to enlarge.

With regard to an Adequate, never mind a Proper, Awareness of Disability-Related Issues at a Fire Scene … it is shocking to realize how almost non-existent this is among Fire Services … not just in Ireland and Britain … but in the rest of Europe and North America as well.

Even a hint of criticism will usually … not always … meet the Neanderthal Fire Service Response: “Have you ever been in a ‘real’ building fire ?”

My Response is: “Do you have to be a hen to know when an egg is bad ?”

This discussion will continue later … have no doubt … that is a promise !

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Disability Access Certificates (DAC’s) – Parts M & B ? (II)

2009-10-18:  In everyday practice, the usual short introductory text in Technical Guidance Document M (Ireland) which refers to a linkage between ‘access and use’ of a building with ‘fire safety’ has little impact, because it is not explained … and is typically ignored.

In general … the basic problem is that this issue is hardly dealt with … at all … by Local Fire Authorities right across the country in their handling of Fire Safety Certificates … and where it does become part of the process, it receives inadequate attention.  There are exceptions.

A major drawback with the current vertical approach to our Building Regulations … each of the Parts has its own separate Supporting Technical Guidance Document … is that people are not sufficiently aware of the important horizontal linkages between the different Parts.  For example, all of the other Parts must be linked to Part D.  Quick, run to find out what Part D covers !   Another two examples … Part B must also be linked to Part A and Part M … and Part M must also be linked to Part K and Part B.

So … while grudgingly having to accept that the scope of TGD M should have some limit, under the current flawed system … a precise intervention with just one or two sentences, at critical places in the guidance text, would help to improve the overall consideration of fire safety issues, relevant to Part M, by building designers … and client or construction organizations.

Here are a Few Suggestions for Discussion …

1.  Revise Paragraph #0.6 of Draft TGD M (2009) & Add a Title …

Fire Evacuation for All

” Accessibility encompasses the full range of activity related to buildings: to approach, enter, use, egress from under normal conditions, and evacuate a building independently during a fire emergency, in an equitable and dignified manner.  Provision for access and use must, therefore, be linked to provision for fire evacuation.  For guidance on design for evacuation, reference should be made to Technical Guidance Document B (Fire Safety).”

Note:  No such guidance is contained in TGD B (2006).  It would be a great wonder if any person with a disability could actually evacuate a building which had been designed in accordance with TGD B.  To take a simple example … all of the ‘stairways’ in Table 1.5 of TGD B – Minimum Width of Escape Stairways will not facilitate contraflow or the assisted evacuation of mobility and visually impaired people.  Furthermore, those minimum widths specified in the Table may have a clear width which is 200 mm less.  See Methods of Measurement, Paragraph #1.0.10 (c) (iii) … ” a stairway is the clear width between the walls or balustrades, (strings and handrails intruding not more than 30 mm and 100 mm respectively may be ignored) ” !   What an incoherent mess !!

2.  Insert New Sentence at the End of Paragraph #1.1.1 of Draft TGD M (2009) …

Objective (Approach to Buildings)

” Consideration should be given to the use of the approach and circulation routes around a building as accessible routes to a ‘place of safety’ during a fire emergency.”

3.  Insert New Sentence at the End of Paragraph #1.2.1 of Draft TGD M (2009) …

Objective (Access to Buildings)

” Consideration should be given to the use of all entrances to a building as accessible fire exits during a fire emergency.”

4.  Insert New Paragraph at the End of Paragraph #1.3.4.1 of Draft TGD M (2009) …

Passenger Lifts

” Manual handling of occupied wheelchairs in a fire evacuation staircase, even with adequate training for everyone directly and indirectly involved, is hazardous for the person in the wheelchair and those people – minimum three – giving assistance.  The weight of an average unoccupied powered wheelchair, alone, makes manual handling impractical.  Lifts in new buildings should, therefore, be capable of being used for evacuation in a fire situation.  For guidance on the use of lifts for fire evacuation, reference should be made to Technical Guidance Document B (Fire Safety).”

5.  Insert New Paragraph and New Sentence at the End of Paragraph #1.3.4.2 of Draft TGD M (2009) …

Internal Stairs

” To allow sufficient space to safely carry an occupied wheelchair down or up a fire evacuation staircase, and to accommodate contraflow, i.e. emergency access by firefighters entering a building and moving towards a fire, while people are still evacuating from the building to a ‘place of safety remote from the building, the clear unobstructed width (exclusive of handrails and any other projections, e.g. portable fire extinguishers, notice boards, etc.) of the flight of a single, or multi-channelled, stairs should not be less than 1 500 mm.  The surface width of a flight of stairs should not be less than 1 700 mm.”

Note:  See Footnote (5) to Table 1.5 in TGD B (2006) … ” The minimum widths given in the table may need to be increased in accordance with the guidance in TGD M: Access for People with Disabilities.”   DUH ?

And …

” For the purpose of safe assisted fire evacuation of people, the rise of a step should not have a height greater than 150 mm, and the going of a step should not have a depth less than 300 mm.”

6.  Insert New Sentence at the End of Paragraph #1.5.1 of Draft TGD M (2009) …

Objective (Facilities in Buildings)

” Consideration should be given to the use of relevant facilities within a building, by people with disabilities, for the purposes of fire safety, protection and evacuation.”

7.  Insert New Sentence at the End of Paragraph #1.6.1 of Draft TGD M (2009) …

Objective (Aids to Communication)

” Consideration should be given to the use of relevant aids to communication, by people with disabilities, for the purposes of fire safety, protection and evacuation.”

Note:  More guidance could be provided under each of the individual paragraphs of Section #1.6 of Draft TGD M (2009).  See Draft International Accessibility-for-All Standard ISO 21542.

8.  Insert New Section #2.6 of Draft TGD M (2009) …

Fire Safety in Dwellings for People with Disabilities

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