United Nations Convention on the Rights of Persons with Disabilities

Grenfell Inquiry Recommendations (3) – Fire Alarms !!

Previous Posts In This New Series …

2019-10-31:  Grenfell Tower Fire Inquiry’s Phase 1 Report – Information

2019-11-11:   Grenfell Inquiry Recommendations (1) – Vulnerable People ?

2019-12-21:  Grenfell Inquiry Recommendations (2) – Fire Emergency Plans !

2020-03-23:  The Grenfell Fire Inquiry’s Phase 1 Recommendations (Part V in Volume 4 of the Phase 1 Report), were published on 30 October 2019.  The initial issues covered in those Recommendations are fragmentary, lack depth and coherence … and in the case of Fire Alarms, with just one indirect reference to them in Paragraph #33.22 … they are in serious error.

Colour image showing the Volume 4 Cover Page of the Grenfell Tower Inquiry Phase 1 Report.  The Phase 1 Recommendations are contained in Chapter #33, on Pages 771-780.  Click to enlarge.

[ Paragraph #33.22 ]  There were no plans in place for evacuating Grenfell Tower should the need arise.  I therefore recommend:

d. that all high-rise residential buildings (both those already in existence and those built in the future) be equipped with facilities for use by the fire and rescue services enabling them to send an evacuation signal to the whole or a selected part of the building by means of sounders or similar devices ;

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FUNDAMENTALS OF A SOLUTION

1.  A Fire Alarm (more precisely from here on, a Fire Detection & Warning System) is a critical safety feature in all buildings … ALL BUILDINGS … from the smallest and most simple, to the biggest and most complex … no exceptions !!

In order to survive in a fire emergency, Vulnerable Building Users need more time to react, and evacuate, than other occupants/users.  The valuable time provided by early, accurate and precise detection is the only way to effectively facilitate this.  The ‘Required Time’ to prepare for evacuation depends on many factors, e.g. building complexity, familiarity of users with evacuation routes, range and severity of user activity limitations, etc.

It follows, therefore, that if building occupants/users have to wait 15, or 20, or 30 minutes before firefighters arrive at the fire scene (Full Response Time*) and ‘an evacuation signal to the whole or a selected part of the building’ is only then sent by those firefighters … all of that valuable evacuation time for vulnerable building users has been lost.  This is ridiculous, and makes no sense whatsoever.  This Recommendation must be rejected out of hand, and ignored !

[ *Full Response Time: The time interval from the receipt of an emergency communication at the primary public safety answering point (#PSAP) to when emergency response units are initiating action or intervening to control a fire incident. ]

Colour photograph showing the Single, Narrow Staircase (1.040 metres in width between a handrail on one side of the staircase and a bare wall on the other side) in London’s Grenfell Residential Tower.  This staircase, which was inadequately protected from fire, heat and smoke, was not wide enough to facilitate the ‘contraflow’ circulation of firefighters entering, while occupants evacuated at the same time.  Without a Fire Alarm in the building, occupants could not have known that a serious Fire Emergency was in progress … especially Vulnerable Building Users accommodated high up in the Tower … and they remained in place (‘stayed put’).  Once firefighters arrived at the scene, occupant evacuation using this staircase became impossible or extremely difficult.  Click to enlarge.

Important Note:  In Chapter #34: ‘Looking Ahead to Phase 2’ of Moore-Bick’s Phase 1 Report, Volume 4 … Paragraph #34.14 states …

A question was raised about the width of the stairs, given that they provided the sole means of access to the upper floors of the tower for firefighters as well as the sole means of escape for the occupants.  However, the stairs appear to have complied with requirements of the legislation in force at the time of their construction and the expert evidence supports the conclusion that they had sufficient capacity to enable all the occupants of the building to escape within a reasonable time.  This aspect of the building will not, therefore, be the subject of further investigation in Phase 2.’

Astounding !  Absurd !!  FUBAR !!!

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All Fire Emergency Warning Systems must be designed to accommodate People with Hearing Impairments.  Audible and visual warning devices must be provided together, as a single combined unit.  This is particularly important in noisy and isolated building spaces, e.g. bathrooms, small meeting rooms.  Vibrating devices, such as pagers or mobile phones, can be integrated into a building’s fire emergency warning system in order to provide any individual with a tactile emergency alert.

Colour photograph showing a single combined visual-audible Fire Emergency Warning Device.  Click to enlarge.

Important Note:  Audible sounders, on their own, are never a sufficient Fire Emergency Warning !

2.  The Purpose of a Fire Emergency Warning System is to provoke calm, efficient and adaptable evacuation movement by ALL building users/occupants at the earliest possible stage in a fire incident, without causing user confusion, disorientation or panic. In all building types, therefore, a reliable, accurate and accessible fire emergency warning system must be installed, and such a system must always have a fire protected electrical supply.

Colour photograph showing the movement of building occupants and users.  The purpose of a Fire Emergency Warning System is to provoke calm, efficient and adaptable evacuation movement by ALL building occupants at the earliest possible stage in a fire incident, without causing user confusion, disorientation or panic.  During a Fire Emergency, STANDARD MOVEMENT TIMES DO NOT EXIST.  Click to enlarge.

3.  To provoke a Calm Response from Building Users … the output from Fire Emergency Warning Devices, e.g. light, sound and messages, must be adapted to the local context of people and building surroundings.

Fire Emergency Audible Warnings … A sufficient number of low-output audible sounders, i.e. between 60-80 dB, must be specified for effectiveness.  Small numbers of sounders with high output (in order to reduce costs) should never be specified, as this can lead to confusion, disorientation and panic attacks among some building users/occupants.  The output of sounders must be adapted to suit interior surroundings, e.g. in small spaces with hard surfaces a lower sound output will be adequate.

Colour image.  The output from Fire Emergency Audible Sounders must be between 60-80 dB.

Important Note:  When they are asleep, hearing-able children (around ten years of age and under) … and hearing-able older people (around 65 years of age and over) are more difficult to wake and rouse sufficiently for evacuation when alerted by an audible signal alone.

Fire Emergency Visual Warnings … Light strobes/beacons must be clearly visible.  To reinforce #1 above … light strobes/beacons must be placed in wash rooms and in other locations within buildings where people may be alone ; they must also be placed in noisy environments.

A sufficient number of low-output strobes/beacons must be specified for effectiveness.  Small numbers of strobes/beacons with high output (in order to reduce costs) should never be specified, as these produce a glare which may cause confusion, disorientation and panic attacks among some building users/occupants.  The light output of strobes/beacons must be adapted to suit interior surroundings, e.g. in dark rooms.

For light strobes/beacons, a slow rate of flash is important, i.e. no faster than once every two or three seconds, in order to encourage a calm response from building users/occupants and to avoid photosensitivity seizures.  Most importantly, the flash of one strobe/beacon must be synchronized with the flashes of all other light strobes/beacons in view.

Colour video clip (.gif).  The output from Fire Emergency Visual Strobes / Beacons must be no faster than one flash every two or three seconds.  The flash rate shown above is too fast !   Click to run video clip.

Fire Emergency Voice Message Warnings … Are essential to improve Warning Credibility.  In other words, building users are far less likely to sit around wondering, waiting to see whether this is a ‘real’ fire emergency, a false alarm, a practice evacuation, or an electrical error.  Verbal or voice messages must be short and contain appropriate warning information which is easily assimilated.  The speaker should be distinct and easy to understand.  Live messaging during a fire emergency is preferred over pre-recorded, standard messages.  In today’s multi-cultural social environment, messages must be transmitted in at least two to three different languages, as appropriate.

Fire Emergency Directional Warnings … Combination sounder, visible strobe/beacon, and voice messaging Fire Emergency Warning Devices are now a mainstream technology, are readily available, and are being specified in new and existing buildings.

Colour image showing a combination Fire Emergency Directional Audible Sounder, with Voice Messaging capability.  Click to enlarge.

Audible directional signalling must be installed when dealing with difficult building configurations, e.g. in large open office layouts/spaces with minimal signage … where building users/occupants are unfamiliar with their surroundings in modern shopping centres/malls and other complex building types … or visibility of high-level signage may be reduced because of smoke logging.

Directional sounders, which guide building users during a Fire Evacuation towards Exits, Areas of Rescue Assistance and Lift/Elevator Lobbies, must be positioned at carefully chosen, suitable locations.  Once reached, a directional sounder must also have a voice messaging capability in order to inform people about the next phase of evacuation.

4.  Fire Emergency Warning Systems must be Accessible (for People with Activity Limitations), i.e. capable of transmitting a warning in many formats in order to ensure that all users/occupants perceive and act upon the warning in a calm manner and, thereafter, that effective evacuation movement commences without delay. Warning Credibility improves in direct relation to the type and number of different warning formats.

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As well as indirectly referring to Fire Detection and Warning Systems, Paragraph #33.22 in Moore-Bick’s Phase 1 Recommendations has some other things to say about Evacuation.  So this is an opportune moment to discuss some practical and human issues concerning Fire Emergency Evacuation … and, straight away, to deal with an unexpected consequence arising from the current CoronaVirus/CoVID-19 Emergency …

CORONAVIRUS / CoVID-19 EMERGENCY

There have been widely reported instances, in many countries, of panic buying in shops because of the 2020 CoronaVirus/CoVID-19 Emergency … but the photograph below illustrates an example of a panic reaction by building management.  This appears to be a crime scene … the yellow and black tape is so dramatic.  In a real Fire Emergency, many building users/occupants will be reluctant to use this final fire exit ; they will not have the time to read the small print on a notice ; they will attempt to re-trace their path of evacuation and find another exit.

Colour photographs showing how, as a panic reaction to the 2020 CoronaVirus/CoVID-19 Emergency, a Final Fire Exit has been blocked off from normal, everyday use.  Click to enlarge.

This panic reaction by building management IS a serious impediment to Fire Evacuation !

Whatever the Motives of Building Management …

  • in countries which have Fire Codes / Regulations, this action is illegal ;   and
  • in these days, when a wide range of ‘smart’ technologies is readily available … this action is inexcusable.

SOME PRACTICAL FIRE EVACUATION ISSUES

A Skill is the ability of a person, resulting from competent training and regular practice, to carry out complex, well-organized patterns of behaviour efficiently and adaptively, in order to achieve some end or goal.  All building occupants/users must be skilled for evacuation to an external ‘place of safety’, which is at a safe and remote distance from the fire building.  Practice fire evacuations must be carried out sufficiently often to equip building users, particularly vulnerable users, with this skill, i.e. at least once every six months ; in complex building types, practices should be carried out more often.  Prior notification to occupants/users, and regular scheduling of practice evacuations should be avoided.

Familiarity with Fire Evacuation Routes will be fostered and greatly improved by means of normal, everyday use by occupants/users.  This is an important task for pro-active Building Management in existing buildings … and an important aspect of new building design for Architects and Fire Engineers.

While the transmission of fire emergency warnings in many formats will increase Warning Credibility, close observation of past tragic ‘real’ fire events, e.g. the WTC 9-11 Attacks in New York City, shows that initiation of evacuation and the actual process of evacuation itself can be problematic.  An interesting, easily assimilated and user-targeted skills programme of training should incorporate practical solutions to deal with the following typical problems:

  1. Fire Emergency Preparedness: Irregular attendance of building occupants/users at fire prevention and safety training sessions, and participation in practice fire evacuations. Users not being familiar with a building’s fire emergency management plan and not knowing who is in charge … not using a building’s fire evacuation route(s), particularly staircases, during practices … or having no information about where to assemble after evacuating … or, once at a place of safety, not having any head count or identification process ;
  2. Delaying Activities Inside The Fire Building: Once building occupants/users decide to evacuate, but before moving to evacuate, they gather personal effects … seek out friends/co-workers … search for others … make phone calls/send tweets … finish tasks/turn off computers … wait around for instructions … change shoes … and try to obtain permission to leave ;
  3. Delaying Activities Outside The Fire Building: Once outside the building’s final fire exit, but before moving directly to a place of safety, building occupants/users stop to see what is happening … look for friends/co-workers … look for a phone … do not know where to go … or, within the ‘danger zone’ of the fire building, stop to receive medical attention.

It may seem obvious that Fire Evacuation Routes must also be Accessible (for People with Activity Limitations), which also makes routes much safer for every other building user … and sufficiently wide to accommodate Contraflow (emergency access by firefighters or rescue teams into a building and towards a real fire, while building users are still moving away from the fire and evacuating the building) … a harsh lesson learned from the 2001 WTC 9-11 Attacks and the 2017 Grenfell Tower Fire. Since they are new, strange and unusual for many building designers, and most fire engineers … these aspects of building performance are overlooked in nearly every building.

Practice Evacuations should include exercise of the buddy system ; fire safety fittings, e.g. portable fire extinguishers ; and fire evacuation devices intended for use by people with activity limitations which will require more intensive training.

Colour image showing a range of personal Facilitation / Mobility Aids.  People with Activity Limitations must be allowed, and positively encouraged, to keep these Aids during practice and real fire evacuations.  Prior meaningful consultation (see below) is essential.  Click to enlarge.

Important Note:  During fire emergencies, People with Activity Limitations must be permitted to keep possession of their own personal Facilitation / Mobility Aids.

SOME HUMAN FIRE EVACUATION ISSUES

The actual people who use and occupy buildings are individuals.  They are different from each other, and they each have a different range of abilities (in relation to self-protection, independent evacuation to an external place of safety remote from a fire building, and active participation in a building’s fire emergency management plan), behaviour and manner of perceiving their surroundings.  Two apparently similar people will also show variations in how they react to and behave in any specific situation, particularly a fire emergency.

Ability / Disability is a Continuum – a gentle gradient on which every person functions and acts at different levels due to personal and environmental, i.e. external, factors.

In situations of severe stress, e.g. during a fire emergency in a building, where there is a lack of preparedness for such an event, a lack of familiarity with evacuation routes, lack of reliable evacuation information, lack of competent leadership and clear direction, and the presence of smoke, user/occupant confusion, disorientation and panic will occur.  Standard evacuation movement times will also be non-existent.  In addition, people with activity limitations must then deal with many physical barriers which routinely impede their evacuation from buildings, e.g. fire resisting doorsets which are difficult to open, steps along evacuation routes and at final fire exits.

In the case of people with a mental or cognitive impairment, there is a particular need to encourage, foster and regularly practice the adaptive thinking which will be necessary during evacuation a real fire incident.

People with respiratory health conditions will not be able to enter or pass through smoke.  People with visual impairments will require continuous, linked tactile and/or voice information during the whole process of fire evacuation.  People with psychological impairments, i.e. vertigo and agoraphobia, will be unable to use fire evacuation staircases with glass walls in high-rise buildings.  Because of the stigma still associated with disability in many countries, some users/occupants who will need assistance during a fire emergency will be reluctant to self-identify beforehand.  Other people may not even be able to recognize that they have an activity limitation or a health condition.

Meaningful Consultation with a person known to occupy or use a building, for the purposes of receiving his/her active co-operation and informed consent (involving a personal representative, if necessary), is an essential component of adequate pre-planning and preparation for a fire emergency.

Building Designers, Fire Engineers and Firefighters should be aware of the following human conditions:

Agoraphobia: A fear of open spaces.

Commentary: Agoraphobia is one of the most commonly cited phobic disorders of people seeking psychiatric or psychological treatment. It has a variety of manifestations, e.g. a deep fear of leaving a building, or of being caught alone in some public place. When placed in threatening situations, agoraphobics may experience a panic attack.

Anosognosia: A neurological disorder marked by the inability of a person to recognize that he/she has an activity limitation or a health condition.

Dementia: Any degenerative loss of intellectual capacity, to the extent that normal and occupational activities can no longer be carried out.

Panic: A sudden overwhelming feeling of anxiety, which may be of momentary or prolonged duration.

Panic Attack: A momentary period of intense fear or discomfort, accompanied by various symptoms which may include shortness of breath, dizziness, palpitations, trembling, sweating, nausea, and often a fear by a person that he/she is going mad.

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Fire Safety for All – Regional Implementation Model (Asia Pacific)

2019-10-21:  Following the very successful Rehabilitation International Asia-Pacific (AP) Conference in Macau, at the end of June 2019 … https://www.rimacau2019.org/ … I was invited by the United Nations Economic & Social Commission for Asia and the Pacific (UNESCAP – https://www.unescap.org/) to submit an Article on ‘Fire Safety for All’ to one of their upcoming publications.

Fire Safety for All … for vulnerable building users, including people with disabilities, young children, frail older people, people with health conditions, and women in late-stage pregnancy … is a critical component of Accessibility & Usability for All … the key factor in facilitating full social participation and inclusion.

Consistent with the philosophy and principles of Sustainable Human & Social Development, a concept which continues to evolve with robust resilience (despite many challenges) … and the 2015-2030 Sustainable Development Framework Agenda … implementation is most effective if carried out at Regional Level … adapted to a Local Context.

Full and effective implementation, in each separate jurisdiction, then requires:

  • a robust legal base ;
  • determined political will to implement ‘fire safety for all’ ;
  • sufficient public financial resources for implementation – ‘fire safety for all’ is a social*, as distinct from a human, right ;
  • a compassionate and understanding bureaucracy, at all institutional levels ;
  • competent spatial planners, architects, structural engineers, fire engineers, quantity surveyors, technical controllers, industrial designers, building/facility managers, and crafts/trades people at all levels in construction organizations ;
  • independent monitoring of ‘fire safety for all’ performance – self-regulation is NO regulation ;
  • innovative, well-designed fire safety related products, systems and fittings which can be shown to be ‘fit for their intended use’.

[ *Social Rights:  Rights to which an individual person is legally entitled, e.g. the right to free elementary education [Art.26(1), UDHR], but which are only exercised in a social context with other people, and with the active support of a competent legal authority, e.g. a nation state.

Commentary:  In contrast to human rights, it is not protection from the state which is desired or achieved, but freedom with the state’s help.]

If Policy and Decision Makers are serious, therefore, about meeting the Safety Needs of Vulnerable People in Fire Emergencies … This Is An Absolutely Minimum Threshold Of Practical Action To Bring About Urgent Change …

Article for UNESCAP

Fire Safety for AllNobody Left Behind !

The rising 21st Century Cities of the Asia-Pacific Region each encompass:

  1. a) an interwoven, densely constructed core ;
  2. b) a very large and widely diverse resident population ;
  3. c) a supporting hinterland of lands, waters and other natural resources ;

together functioning, under the freedoms and protection of law, as …

  • a complex living system ; and
  • a synergetic community capable of providing a high level of social wellbeing* for all of its inhabitants.

[ *Social Wellbeing for All:  A general condition – for every person in a community, society or culture – of health, happiness, creativity, responsible fulfilment, and sustainable development. ]

Colour photograph showing one of the oldest districts in Hong Kong … Sheung Wan … very high-rise development, with mixed commercial and residential activity.  Click to enlarge.  Photograph taken by CJ Walsh.  2019-06-24.

In all areas of life and living in this City Community, every person is equal before the law and is entitled, without any discrimination, to equal protection of the law*.  When they are in a building, for example, all of its occupants and users have an equal right to feel ‘fire safe’ as required by law.  This must also include vulnerable building users, particularly people with disabilities.

[ *Refer to Article 12 in the 2006 United Nations Convention on the Rights of Persons with Disabilities, which has been ratified by nearly every country in the world, including the European Union … and Article 7 in the 1948 Universal Declaration of Human Rights.]

Current national building codes – where they exist – do not protect vulnerable people in fire emergencies: many countries have no legal provisions answering this crucial need, while a small group of countries offer only token, i.e. inadequate, protection.  An ethical*, technical response is urgently required, therefore, at regional level in Asia-Pacific.  The social, political and institutional challenges blocking effective implementation are immense.

[ *Refer to the 2016 Dublin Code of Ethics: Design, Engineering, Construction & Operation of a Safe, Resilient & Sustainable Built Environment for All.  Download from: www.sfe-fire.eu ]

Note:  A Regional Implementation Strategy is already in the course of being developed for Asia-Pacific (AP).

Colour image illustrating the two concepts of social ‘equality’ and ‘equity’ … and, most importantly, the difference between the two.  Mainstream society must fully accept these concepts … and understand how, in order to achieve equality, the process of implementation must be equitable.  Click to enlarge.

Fire Safety for All … for vulnerable building users, including people with disabilities, young children, frail older people, people with health conditions, and women in late-stage pregnancy … is a critical component of Accessibility & Usability for All … the key factor in facilitating full social participation and inclusion.  This design objective is achieved by equitable fire prevention and fire protection measures, essential occupant/user practices, independent fire evacuation procedures, proactive management and, as a last but necessary resort, reliable assisted evacuation and/or firefighter rescue.

In the Smart City, nobody must be left behind !

During the first critical 10-15 minutes in a fire emergency – the time between when a fire is first accurately detected, warnings are transmitted, and firefighters arrive at the building – many people with disabilities are more than capable of independent evacuation using reliably functioning lift/elevator fire evacuation assemblies.  Independent use of lifts/elevators by people with disabilities is essential during a fire emergency … and must be facilitated.

The enormous benefit for those vulnerable individuals who are capable of negotiating horizontal and vertical circulation routes by themselves is being able to evacuate a building and reach a ‘place of safety’ in the company of other building occupants/users.  They remain independent, in control of their own evacuation, and able to leave without waiting for someone else to rescue them or render assistance.

Buildings must remain structurally ‘serviceable’ until all building occupants/users and firefighters have reached a remote ‘place of safety’.

Management systems and fire protection measures in buildings are never 100% reliable.  People with disabilities must, therefore, be trained to be self-aware in situations of risk, particularly in fire emergencies, and actively encouraged to develop the skills of self-protection and adaptive self-evacuation.

Essential Features At Building Design Stage

Fire Safety for All must be carefully considered at the initial stages of building design.  To be effective, however, the following essential passive and active fire protection measures must be incorporated in buildings …

A.  A smart ‘whole building’ fire emergency detection and multi-format warning system is an essential fire safety feature in all building types, new and existing. Vulnerable building occupants/users need much more time to react, and evacuate, than other users during a fire incident.

B.  All building occupants/users must be provided with alternative, intuitive and obvious evacuation routes away from a fire outbreak in a building. A significant number of building users will never pass through the smoke generated by fire.

C.  All fire evacuation routes in a building must be accessible for building occupants/users, and be sufficiently wide to accommodate contraflow, i.e. building users evacuating while firefighters enter the building at the same time. Under no circumstances must ‘stay put’ policies be normalized, or practiced.

D.  Phased horizontal evacuation must be facilitated, in design, by providing ‘buffer zones’ around fire compartments, and adjacent ‘places of relative safety’.

E.  All lifts/elevators in a building must be capable of being used during a fire emergency. This is already the case, in most countries, with firefighter lifts.

F.  Fire protected evacuation staircases must be sufficiently wide (1.5m between leading handrail edges) to facilitate contraflow and the assisted evacuation of manual wheelchair users; they must open into fire protected lift/elevator lobbies at every floor/storey level, and open directly to the exterior at ground level.

Black and white photograph showing the correct and best assisted evacuation technique for carrying a person in a manual wheelchair down a fire protected staircase, with handrails on both sides … 1 person behind the wheelchair and 2 other people at each side.  This illustration is from the Orientation Manual for First Responders on the Evacuation of People with Disabilities.  Federal Emergency Management Agency (USA).  Document Reference FA-235.  August 2002.  Click to enlarge.

Colour photograph showing the ‘contraflow’ circulation which must be facilitated during a fire emergency … as building occupants/users evacuate away from the fire towards a place of safety located a remote distance from the building … while heavily equipped firefighters are able to enter the building, unhindered, at the same time.  This ensures that firefighters can quickly locate people waiting in areas of rescue assistance and lift/elevator lobbies.  Click to enlarge.

G.  Sufficiently large, fire protected ‘areas of rescue assistance’, where people can safely wait during a fire emergency, must adjoin each evacuation staircase on every floor/storey above ground level. When calculating space provision for evacuation and waiting areas in buildings, the minimum reasonable provision for people with disabilities must be 10% of the design building occupant/user population; for people with activity limitations, minimum space provision must rise to 15% of the design occupant/user population.

Colour illustration of a sufficiently wide fire evacuation staircase, which will accommodate contraflow and the assisted evacuation of people in wheelchairs … with a sufficiently large, directly adjoining ‘area of rescue assistance’ … which will accommodate people unable to independently evacuate during a fire emergency.  The space provided in an area of rescue assistance, on each floor/storey, is calculated in relation to the design occupant/user population of a building.  Even if a building is fully sprinklered, an area of rescue assistance must adjoin every fire evacuation staircase.  Click to enlarge.  Staircase design by CJ Walsh.

Image of text showing the definition for ‘people with activity limitations’, with its equivalent French translation … also showing from where this term is derived … and who this term includes.  During a fire emergency, confused and/or confusing disability-related language costs lives !  Click to enlarge.

H.  Such is the universal level of fire compartment unreliability, that lift/elevator lobbies and ‘areas of rescue assistance’ must be fitted with an active fire suppression system, i.e. water mist … an environmentally clean suppression medium which is person-friendly, and will not greatly interfere with visibility.

I.  In tall, super-tall and mega-tall buildings, every 20th floor/storey must be an accessible ‘floor of temporary refuge’ … and the roofs of those buildings must be capable of being used for aerial evacuation.

J.  In health care facilities, e.g. hospitals, the fire safety strategy must always be to ‘protect in place’. Patient evacuation is highly hazardous, and unacceptable.

K.  Fire defence plans* must demonstrate a proper consideration for the fire safety, protection and evacuation of all building users/occupants, with a particular and integrated focus on people with activity limitations.

[ *Fire Defence Plan:  A pre-determined and co-ordinated use of available human and material means in order to maintain an adequate level of fire safety and protection within a building and, in the event of an outbreak of fire, to ensure that it is brought speedily under control and extinguished … with the aim of minimizing any adverse or harmful environmental impacts caused by the fire.

Commentary 1:  A Fire Defence Plan is developed for a specific building at design stage.  It later becomes the basis for an occupied building’s Fire Emergency Management Plan.

Commentary 2:  A Fire Defence Plan is usually in electronic format and/or hard copy and comprises fire engineering drawings, descriptive text, fire safety related product/system information, with supporting calculations, and the fire test/approval data to demonstrate ‘fitness for intended use’.]

Colour illustration showing the ‘Fire Safety for All’ Matrix, which outlines the scope of its application in the Human Environment and the different social groups to be targeted.  Balanced consideration must be given to people who use wheelchairs (physical function impairment) … and to people with visual, hearing, psychological, and mental/cognitive impairments … and to other vulnerable building users, e.g. people with health conditions.  Click to enlarge.  Matrix developed by CJ Walsh.

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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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SFE 2016 DUBLIN – A Benchmark Fire Engineering Event !

2015-11-06 !   We are very pleased to announce that the Fire Safe Europe Alliancewww.firesafeeurope.eu … has become actively involved, together with Glasgow Caledonian University and FireOx International, in co-hosting SFE 2016 DUBLIN.  To facilitate the Network’s full engagement and provide sufficient time for promotion, etc … it was jointly agreed that the new dates for this Event shall be from 28-30 September 2016.

We have every confidence that SFE 2016 DUBLIN will now be a much better event … having a wider range of stakeholder participation.

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2015-06-29 …

Sustainable Fire Engineering – Effective Fire Safety for All in Sustainable Buildings !
28-30 September 2016      Dublin, Ireland
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www.sustainable-firengineering.ie  or  www.sfe-fire.eu
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Approved Regional Sustainable Built Environment Conference in the 2016-17 Series
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The Gresham Hotel, O’Connell Street, Dublin, Ireland

Céad Míle Fáilte (Hundred Thousand Welcomes) to Dublin, in Ireland … and to the First International Conference devoted to this complex subject !

The 21st Century has had a cruel and savage birth: extreme man-made events, hybrid disasters, severe natural events, complex humanitarian emergencies, with accelerating climate change and variability.  The old certainties are crumbling before our eyes …

The resolute Answer to these threats and the rapidly changing social and environmental needs of our world is Sustainable Fire Engineering !

•  SFE fulfils a critical role in the realization of a Safe, Resilient & Sustainable Built Environment for All ;
•  SFE facilitates positive progress towards the United Nation’s 17 Sustainable Development Goals & 169 Performance Targets, which were adopted in September 2015 ;
•  SFE fast-tracks proper compliance with the Basic Requirements for Construction Works in the European Union’s Construction Products Regulation 305/2011 (Annex I), specifically the interlinked Requirements 7, 2, 1, 3 & 4.

Please join us in an informal, multidisciplinary and pre-normative forum … as we examine Sustainable Fire Engineering more deeply.Event Logo for SFE 2016 DUBLIN

INTRODUCTION to SFE 2016 DUBLIN

Fire Losses – both direct and indirect – amount to a very significant percentage of GDP in all economies, whether they are rich or poor … and result in enormous environmental damage and social disruption.  Fire Engineering, including Fire Prevention and Protection in Buildings, is a major multi-billion Euro/Dollar component of the Construction Industrial Sector – worldwide.

Unfortunately … a fundamental conflict exists between Sustainable Building Design Strategies and the fire safety responses adopted in today’s Conventional Fire Engineering.  To take a simple example: for cooling, heating or ventilation purposes in a Sustainable Building, it is necessary to take advantage of natural unobstructed patterns of air movement in that building.  On the other hand, fire engineers in private practice and control personnel in Authorities Having Jurisdiction (AHJ’s) will demand that building spaces be tightly compartmented in order to limit the spread of fire and smoke … dramatically interfering with those natural patterns of air movement.

Unusual fire behaviour and a range of difficult fire safety issues (critical, in the case of firefighters) also arise from the Innovative Design Features (for example, ‘green’ roofs, elaborate intelligent façades) and Building Products / Systems (for example, photovoltaic panels) being installed in Sustainable Buildings.

A wide chasm separates the language and understanding of these two very different design disciplines.  As a result, the performance of Sustainable Buildings can be seriously compromised.  If, on the other hand, adequate independent technical control is absent on site … it is fire safety which is weakened.

And because, in most countries, the emphasis is placed on pre-construction design intent rather than the ‘real’ performance of the completed/occupied building … these problems are ignored and remain hidden … until a serious fire breaks out !

SUSTAINABLE FIRE ENGINEERING’s AIM

The Aim of Sustainable Fire Engineering is to dramatically reduce all direct and indirect fire losses in the Human Environment (including social, built, economic, environmental, virtual, and institutional) … and to protect the Natural Environment.

Towards Zero Preventable Fires in the Built Environment !

In essence … Sustainable Fire Engineering heavily front-loads Fire Prevention and Fire Protection Measures … above and beyond the minimal and very limited fire safety objectives mandated by current legislation.

SFE’s Key Concepts are … RealityReliabilityRedundancyResilience !

SFE Design Solutions are …

  • Adapted to local geography, climate change and variability, social need, economy, and culture ;
  • Reliability-based ;
  • Person-centred ;
  • Resilient.

SFE 2016 DUBLIN OBJECTIVES

1.  To initiate discussion and foster mutual understanding between the International Sustainable Development / Climate Change / Urban Resilience Communities and the International Fire Science & Engineering Community.
2.  To bring together today’s disparate Sectors within the International Fire Science and Engineering Community … to encourage better communication between each and trans-disciplinary collaboration between all.
3.  To transform Conventional Fire Engineering into an ethical and fully professional Sustainable Design Discipline which is fit for purpose in the 21st Century … meaning … that fire engineers can participate actively in a sustainable design process, and can respond creatively with sustainable fire engineering design solutions which result in Effective Fire Safety for All in Sustainable Buildings.
4.  To launch a CIB W14 Research Working Group VI Reflection Document: ‘Sustainable Fire Engineering Design & Construction’ … which will establish a framework for discussion on the future development of Sustainable Fire Engineering.

SFE 2016 DUBLIN WEBSITE

Today !   Visit the SFE 2016 DUBLIN Website at … www.sustainable-firengineering.ie  or  www.sfe-fire.eu

Download the Information on the Links Page … Review the wide range of Topics which will be examined and discussed at SFE 2016 DUBLIN … Submit an Abstract for a Paper … and Give serious consideration to becoming an Industry Exhibitor, or an Enlightened, Far-sighted Sponsor !!

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2015 Dublin Declaration on ‘Fire Safety for All’ Adopted !

2015-04-20:  After a lengthy, constructive and very interesting discussion which resulted in some important text revisions … on Friday afternoon in Dublin, 10 April 2015, at the ‘Fire Safety for All’ Conference (www.fire-safety-for-all.eu) … all participants voted to adopt, support and promote the 2015 Dublin Declaration on ‘Fire Safety for All’ in Buildings !

With regard to International Distribution and Promotion of the Declaration … many readers of this Technical Blog belong to varied professional, social and business networks.  I would earnestly ask you to circulate the Declaration widely within those networks, and to actively seek the support of as many organizations and individuals as possible.  This support should be confirmed by means of a simple e-mail message to: fireox@sustainable-design.ie … and I will then add the names of supporters to the Fire Safety for All WebSite (www.fire-safety-for-all.eu).  Copies of the Declaration, in PDF and WORD Formats, can also be downloaded from the WebSite.

Fire-Safety-4-All_smlThis Benchmark Declaration on Accessibility and Fire Safety for People with Activity Limitations … is an essential reference document for all stakeholders and interested parties.  It draws a long-awaited, broad, distinct and stable line in the shifting sands of a rapidly evolving Sustainable Human Environment (social, built, virtual, economic, and institutional) ….

1.   As of 14 July 2015 … 156 Countries, plus the European Union, have ratified the United Nations Convention on the Rights of Persons with Disabilities (CRPD).  Since the Convention became an international legal instrument in 2008, however, the UN CRPD Preamble’s Paragraph (g): ‘mainstreaming disability in sustainable development strategies’ … and Paragraph (v): ‘the importance of accessibility in enabling people to fully enjoy their rights and fundamental freedoms’ … have tended to receive insufficient public attention and scrutiny.  The Dublin Declaration on ‘Fire Safety for All’ in Buildings and the related CIB W14 Research Working Group 5’s Reflection Document have been drafted with those two paragraphs very much in mind.

2.   Although a situation of serious risk for vulnerable building users … it is not appropriate to deal with Fire Safety for All in Buildings under Article 11: ‘Situations of Risk & Humanitarian Emergencies’ of the U.N. Convention on the Rights of Persons with Disabilities … where situations of grave risk are handled, e.g. Extreme Man-Made Events, Hybrid Disasters, Severe Natural Events, Complex Humanitarian Emergencies … all amid Accelerating Climate Change & Variability.

Take the case of an earthquake, for example … where there will be large-scale serious building damage and many, many building collapses throughout an affected region.  On the other hand, when considering fire safety for all in any building … it is necessary that the building shall remain not just structurally stable, but serviceable.

3.   It is more appropriate, particularly since the publication of International Standard ISO 21542 (2011) with its expanded definition of Building Accessibility, that Fire Safety for All be incorporated into the meaning and implementation of Article 9: ‘Accessibility’ of the CRPD … in exactly the same manner that fire safety is fully integrated into everyday mainstream building use, and mainstream building fire safety codes and standards.

As there are no references, at all, to either ‘fire’ or ‘safety’ in Articles 9 … there is much to be explained and clarified in the 2015 Dublin Declaration on ‘Fire Safety for All’ in Buildings, if ‘real’ implementation is to be both practical and successful.

An improved and updated definition of Building Accessibility is contained in Principle 3 of the Dublin Declaration …

‘Accessibility of a Building encompasses the complete cycle of independent use, in a dignified manner and on an equal basis with others … and includes the approach, entry and use of a building and its facilities, egress during normal conditions and removal from its vicinity … and, most importantly, safe evacuation during a fire incident to a place of safety which is remote from the building and reached by way of an accessible route.’

4.   The Dublin Declaration contains a Preamble, Principles 1-9 which are headlined below, and an Appendix with many Terms and Definitions …

Principle 1 – A Human Right
Principle 2 – Successful Implementation
Principle 3 – Building Accessibility
Principle 4 – Design for Safe Evacuation
Principle 5 – Accessible EICT’s
Principle 6 – Fire Safety Skills
Principle 7 – Reasonable Spatial Provision
Principle 8 – Building Management
Principle 9 – Firefighters

5.   Existing approaches to Fire Safety, Protection & Evacuation in Buildings for People with Activity Limitations … as described and illustrated in the notable examples of British Standard B.S. 9999 (2008), Singapore’s FSR 7 (2011), and Hong Kong’s Fire Safety Code Addendum (2014) … are technically inadequate, tokenistic, discriminatory, create barriers to social participation, and violate human rights.  Therefore, any further use or recourse to such existing approaches must be terminated immediately !

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2015  DUBLIN  DECLARATION  ON  ‘FIRE SAFETY FOR ALL’  IN  BUILDINGS
A Call to Action and Successful Implementation !

(Adopted in Dublin, 2015-04-10)

Meeting In  Dublin, Ireland … on Thursday and Friday, 9 and 10 April, 2015

In Co-Operation With  the International Council for Research & Innovation in Building & Construction (CIB), Rehabilitation International’s International Commission on Technology & Accessibility (RI-ICTA), the Global Alliance for Accessible Technologies & EnvironmentS (GAATES), and the EUropean Concept for Accessibility Network (EuCAN) ;

Recognizing  the integral and interdependent nature of the natural and human environments (social, built, virtual, economic and institutional) on this small planet Earth, our common home … and the need for harmonized principles to inspire and guide the peoples of the World in the enhancement of a human environment which cherishes the dignity, worth and many abilities of every person ;

Whereas  in the United Nations Charter, the U.N. Member States pledged their respect for, and the protection and observance of, fundamental human and social rights … and have determined to promote social development and better standards of living for all ;

Recalling  the Universal Declaration of Human Rights (UDHR), adopted on 10th December 1948 … which established a global framework of human and social rights – basic needs and protections – and fundamental freedoms for every person and communal gathering ;

Recalling Also  the Rio de Janeiro Declaration on Sustainable Social Development, Disability & Ageing, adopted on 11th December 2004 … which stressed the importance of the social aspects in Sustainable Human & Social Development ;

Mindful Especially  of the United Nations Convention on the Rights of Persons with Disabilities (CRPD), adopted on 13th December 2006 … the principal aim of which is to ensure that the human environment is sufficiently accessible to permit a vulnerable and major population group in all communities to safely exercise and enjoy the human and social rights and fundamental freedoms described in the 1948 UDHR ;

Working Towards  the achievement of justice, equality of opportunity, social inclusion, active participation and development for every person with an activity limitation in all communities … and recognizing that accessibility of the human environment is an essential prerequisite for the above, and that fire safety for all is a critical life safety component of that accessibility ;

Aware Always  of the universal reality that there is still a strong social stigma associated with disability and, particularly, mental ill-health … that much of the human environment is not accessible for all, and even where it is robustly mandated in law, the quality of that accessibility is poor … and that fire safety guidelines for people with activity limitations in buildings, if they exist, are inadequate and/or tokenistic, and rarely implemented ;

Welcoming the launch of the CIB Working Commission 14: Fire Safety – Research Working Group 5’s Reflection Document: Buildings & ‘Fire Incident Human Behaviour and Abilities’ which presents a practical examination and general overview of fire safety for all

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Addressed to every Country and the European Union – those many Voluntary Parties to the U.N. Convention on the Rights of Persons with Disabilities – and the Politicians, Authorities Having Jurisdiction, State Agencies, Professional Bodies & Institutions, Non-Governmental Organizations, Charitable & Private Organizations, etc., based within those separate jurisdictions:

We Declare That The Following Principles Must …

Be carefully studied, successfully implemented, and independently monitored … supported by Benchmarking, reliable Data and Statistics, and the informed use of pertinent Accessibility & Fire Safety Related Performance Indicators …

Principle 1 – A Human Right

Full and effective accessibility of the Human Environment (social, built, virtual, economic and institutional) is a fundamental human and social right, i.e. a basic need, for people with activity limitations – it is an essential prerequisite for the safe exercise and enjoyment of those rights, protections and freedoms set down in the 1948 Universal Declaration of Human Rights and subsequent international rights instruments … and crucially, for their health, participation, inclusion and development in all communities.

Principle 2 – Successful Implementation

Successful accessibility implementation … meaning high quality accessibility performance in the built environment … is reliant upon:

  • A robust legal base mandating accessibility for all and fire safety for all ;
  • Determined political will ;
  • Sufficient public financial resources ;
  • A compassionate and understanding bureaucracy at all levels ;
  • Competent … meaning duly educated, trained and experienced in accessibility and fire safety design … spatial planners, architects, structural engineers, fire engineers, quantity surveyors, technical controllers, industrial designers, building managers, and people at all levels in construction organizations ;
  • Independent monitoring of accessibility and fire safety performance ;
  • Innovative, well-designed accessibility and fire safety related products and systems which can be shown to be ‘fit for their intended use’.

Principle 3 – Building Accessibility

Accessibility of a Building encompasses the complete cycle of independent use, in a dignified manner and on an equal basis with others … and includes the approach, entry and use of a building and its facilities, egress during normal conditions and removal from its vicinity … and, most importantly, safe evacuation during a fire incident to a place of safety which is remote from the building and reached by way of an accessible route.

Principle 4 – Design for Safe Evacuation

Accessibility design criteria must be infused into all of the practical, day-to-day work of building designers and, especially, in the development of project-specific fire engineering design objectives … and be applied from the initial stages of building design, through to the construction and reliable life cycle operation of vertical and horizontal fire evacuation routes facilitating contraflow, areas of rescue assistance, fire safety related signage, controls and fittings, fire prevention and protection measures, fire safety management procedures, routes to and locations of places of safety, etc., etc.
• Evacuation way finding in buildings must be intuitive and obvious ;
• 3 Keywords for building designers must be: reality – reliability – redundancy.

Principle 5 – Accessible EICT’s

Electronic, information and communication technologies are ubiquitous in today’s complex built and virtual environments.  During a real fire incident in a building, they serve a function which is critical for the safety of all building users and firefighters, property protection, minimizing environmental damage and harm, and sustainability. For that reason, they must have a control and/or user interface which is accessible for all.

Principle 6 – Fire Safety Skills

People with activity limitations who occupy or use a building frequently must be included in all practice fire evacuations, in order to learn the skill of safe independent evacuation to an accessible place of safety remote from the building.  During a real fire incident, evacuation assistance provided by other building users or rescue by firefighters, and the time spent waiting for that assistance or rescue in the building must be kept to an absolute minimum.

People with activity limitations must be actively encouraged to participate in fire safety preparatory planning and regular practices … and, without exception, must be consulted and included in all activities concerning their own evacuation from a building.

Management systems and fire protection measures in buildings are never 100% reliable.  People with activity limitations must, therefore, be actively encouraged to be self-aware in situations of risk, and facilitated in learning the skill of self-protection.

Principle 7 – Reasonable Spatial Provision

Reasonable spatial provision must be allocated in a building for the needs of real users, who vary in the range of their individual behaviour and abilities … and for the real building user population profile which, avoiding discrimination, must reflect a society as a whole.  Concerning fire safety for all and the necessary size, for example, of an area of rescue assistance which adjoins a fire evacuation staircase on every floor in a building … the following indicators, exclusive of extra provision for assistants, must guide the architect and fire engineer in the collaborative design process:

(a)  Minimum reasonable provision for people with disabilities in a building – 10% of design occupant/user population ;

(b)  Minimum reasonable provision for people with activity limitations in a building … 15% of design occupant/user population.

Principle 8 – Building Management

Building managers must ensure that fire safety for all preparatory planning is effective, and that practices are held regularly … before any real fire incident occurs.  And as part of their normal, day-to-day functioning … managers must be fully aware that, without due attention to accessibility-related services, product maintenance and occupant/user welfare policies, the quality of accessibility in a building will rapidly deteriorate.

Personal Emergency Evacuation Plans (PEEPS) must not be used to limit or restrict access to any part of a building and its facilities.

Principle 9 – Firefighters

Firefighters must be trained to interact with and rescue people with activity limitations from buildings, using procedures and equipment which will not cause injury to either.  Fire services must ensure that they operate such procedures and possess such regularly serviced equipment.

Emergency service organizations must operate reliable systems to notify the fire services of emergency situations, which are accessible for all and useable by the public at all times.

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APPENDIX – Terms & Definitions

Area of Rescue Assistance:  A sufficiently large building space directly adjoining, and visible from, a main vertical evacuation route – robustly and reliably protected from heat, smoke and flame during and after a fire – where people may temporarily wait with confidence for further information, instructions, and evacuation assistance or rescue, without obstructing or interfering with the evacuation travel of other building users.

Contraflow Circulation in a Fire Building:  Emergency access by firefighters or rescue teams into a building and towards a real fire … while building users are still moving away from the fire and evacuating the building.

Evacuation from a Fire Building:  To withdraw, or cause to withdraw, all users from a building which is on fire … in pre-planned and orderly phased movements to an accessible place of safety remote from the building.

Fire Compartmentation:  The division of a building into fire-tight compartments by fire, smoke and heat resisting elements of construction, in order to …
a)  contain an outbreak of fire, including any smoke and heat generated by the fire ;
b)  prevent damage, within the building, to other adjoining compartments and spaces ;
c)  protect a compartment interior from external fire attack, e.g. fire spread across the building’s facade or from an adjacent building ;
d)  minimize adverse, or harmful, environmental impacts outside the building.

Human Health:  A state of complete physical, mental and social wellbeing, and not merely the absence of disease or infirmity.

People with Activity Limitations (E) / Personnes à Performances Réduites (F):  Those people, of all ages, who are unable to perform, independently and without aid, basic human activities or tasks – because of a health condition or physical / mental / cognitive / psychological impairment of a permanent or temporary nature.

The above Term includes …

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

Place of Safety:
•  Any accessible 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 triage can safely be rendered … and from where effective medical care and supervision can be organized and provided within one hour of injury (the ‘golden hour’) ;   and
•  Where people can be identified.

Note: If there is a risk of an explosion associated with a fire – multiply the numbers in square brackets above by 4.

Progressive Damage in Fire / Fire-Induced Progressive Damage:  The sequential growth and intensification of structural deformation and displacement, beyond fire engineering design parameters, and the eventual failure of elements of construction in a building – during a fire and the ‘cooling phase’ afterwards – which, if unchecked, will result in disproportionate damage, and may lead to total building collapse.

Note: Fire-induced progressive damage may commence long before there is any breach in the integrity of a fire compartment’s boundaries.

Real Fire:  A fire which develops in a building and is influenced by such factors as the type of building and its occupancy (numbers, abilities and activities) ;  the combustible content (fire load) ;  the ventilation, geometry and thermal properties of the fire compartment or building space (should no fire compartmentation exist) ;  the fire suppression systems in the building, and the actions of firefighters.

Skill:  The ability of a person – resulting from proper training and regular practice – to carry out complex, well-organized patterns of behaviour efficiently and adaptively, in order to achieve some end or goal.

Social Environment:  The complex network of real and virtual human interaction – at a communal or larger group level – which operates for reasons of tradition, culture, business, pleasure, information exchange, institutional organization, legal procedure, governance, human betterment, social progress and spiritual enlightenment, etc.

Social Rights:  Rights to which an individual person is legally entitled, e.g. the right to free elementary education (Art.26(1), UDHR), but which are only exercised in a social context with other people, and with the active support of a competent legal authority, e.g. a Nation State.

Social Wellbeing:  A general condition – in a community, society or culture – of health, happiness, creativity, responsible fulfilment, and sustainable development.

Virtual Environment:  A designed environment, electronically generated from within the built environment, which may have the appearance, form, functionality and impact – to the person perceiving and actually experiencing it – of a real, imagined and/or utopian world.

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‘Fire Safety for All’: Open Call for Innovative Products & Systems

2015-02-02:  This is NOT … I repeat NOT … a small niche market in the Global Multi-Billion Euro Fire Safety & Protection Related Construction Industrial Sector !   This IS the whole nine yards !!

This is an Open Call for Innovative, Well-Designed Fire Safety / Protection and Accessibility Related Construction Products and Systems, Other Measures and Means, Mechanical and Electronic Devices, ETC, ETC, ETC, ETC !

This Call is particularly aimed at Manufacturers, Suppliers and Distributors in China, India, Japan, and Mainland Europe !

We want to see ‘Real’ Products and Systems, Measures and Means, Mechanical and Electronic Devices, ETC, ETC, ETC, ETC … not flashy brochures … at the 2015 Dublin ‘Fire Safety for All’ Industrial Exhibition, on 9 & 10 April !

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An Accessible Building is Safer, Easier to Use and More Comfortable for ALL Building Users

If Fire Safety for All is properly considered at Building Design Stage :
• Buildings are easier to understand (intuitive) during a Real Fire Evacuation
Fire Evacuation Routes (obvious) are easier to find and to use
• Everyone can safely evacuate a Building on Fire – no more tragic tales about people being left behind in multi-storey schools and offices
RealityReliabilityRedundancy – are the 3 Essential Keywords

Client Organizations: A Building which is NOT Accessible is difficult, if not impossible, for everybody to evacuate during a real fire incident !

So …

Grab a Bicycle – Get a Horse – Take a Train or a Plane – Come to Dublin in April !

Fire-Safety-4-All_smlTo Exhibit / To Sponsor … please go to the Event WebSite: www.fire-safety-for-all.eu

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Open E-Mail to ISO TC 92 (Fire Safety) – Treatment of ‘Disability’

2014-11-05:  ISO TC 92: ‘Fire Safety’ is a long-established Technical Committee within the International Standards Organization (ISO) …  www.iso.org/iso/home/standards_development/list_of_iso_technical_committees/iso_technical_committee.htm?commid=50492  … and down through the many years of its existence, since 1958, it has laboriously constructed a robust foundation which has facilitated the modern evolution of Fire Science and Engineering and the development of many standard fire safety practices and procedures around the world.

BUT …  and in spite the existence of ISO/IEC Guide 71: ‘Guidelines for Standards Developers to Address the Needs of Older Persons and Persons with Disabilities’ (a weak document which is badly in need of revision and updating !)

Recently, having examined some draft standards being processed through ISO TC 92 … I have become very tired of the blatant incompetence … and lack of care and concern merging with feigned ignorance and/or stubborn resistance, within the Technical Committee, when it comes to the issue of ‘disability’ … in other words, the major matter of the real fire safety of vulnerable building users and occupants, i.e. people with activity limitations, in real buildings.

SO …  a few days ago, I wrote the following e-mail message to a Working Group Chairperson (who shall remain nameless, because this same problem pervades the whole TC) …

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Dear X,

With regard to All Aspects of the WG’s Work … one issue, in particular, sticks out like a sore thumb … how you treat ‘disability’.  There is no clarity here, only confusion.  There are no precise terms, only a garbled use of language and concepts.

Please allow me to suggest, with accompanying explanations, a suitable and necessary path forward.

I will circulate this e-mail message separately within ISO, and beyond.

Concerning Normative References … reference must be made to …

ISO 21542 (2011): ‘Building Construction – Accessibility & Usability of the Built Environment’

Within this document, Accessibility is understood to mean the full cycle of independent building use, in an equitable and dignified manner … and to include the approach, entry to and use of a building, egress during normal conditions and removal from the vicinity of the building … and, most importantly, evacuation during a fire incident to a ‘place of safety’ which is remote from the building.

Texts relating to ‘fire safety’ have been incorporated into the main body of this International Standard.  It is, however, just a small beginning.  Much work remains to be done.

Accessibility Design Criteria, as described in ISO 21542, must now be applied to the design and maintenance of all fire evacuation routes, fire safety related signage and fittings, etc., etc.

Use of the word escape, in any context, is strongly discouraged.

Concerning Terms & Definitions

People with Activity Limitations:  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.

Attached, please find the FireOx International ‘Fire Safety for All’ Matrix … which illustrates how the separate pieces, including ‘disability’, fit together.

Contraflow:  Emergency access by firefighters or rescue teams into a building and towards a fire, while people are still moving away from the fire and evacuating the building.

Concerning Building User/Occupant Numbers & Provision … ‘token’ is not only entirely unacceptable, it is a clear case of professional negligence …

And why, suddenly, all of these ‘musts’ ??

Cogently mandated in the United Nations Convention on the Rights of Persons with Disabilities (CRPD) … the UN CRPD’s principal aim is to ensure that the Built, Social, Economic and Virtual Environments are sufficiently ‘accessible’ to permit a vulnerable and major population group in all of our societies to enjoy the fundamental freedoms and human rights set down in the Universal Declaration of Human Rights (1948).

The language of the Convention is always very robust and very direct: ‘States Parties shall …’

Also attached, please find a United Nations Global Map showing the status of Convention Ratification back in July 2014.  At the time of writing this e-mail message, 151 Countries have ratified the UN CRPD.

Full and Effective Accessibility of the Built Environment is a human right.  Adequate provision must be made for people with disabilities to use all buildings … not just some buildings … and certainly not just limited parts of a building !

In practice, people with disabilities must be included in all practice evacuation drills … and they must be included in all activities related to ‘fire safety’ and/or necessary to prepare for safe evacuation.

Furthermore … because Electronic, Information and Communication Technologies (EICT’s) now serve a function which is critical, during a fire incident, for the safety of all building users and firefighters, property protection, minimizing environmental damage, and sustainability … they must have a user interface which is Accessible for All … from both ends.

With regard to ‘adequate’ provision … please find attached the 2010 USA Disability Statistics … which indicate:

  • Minimum Reasonable Provision for People with Disabilities in a Building … 10% of User/Occupant Population ;
  • Minimum Reasonable Provision for People with Activity Limitations in a Building … 15% of User/Occupant Population.

The numbers of people with disabilities in developing and the least developed economies far exceed numbers in developed economies !

Best wishes for the success of your meeting in Sydney.

C.J. Walsh – Consultant Architect, Fire Engineer & Technical Controller.

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FireOx ‘Fire Safety for All’ Matrix – Revised & Updated

2014-10-17:  Within the professional discipline of Fire Engineering … either a building is ‘fire safe’, or it is not.  The Design Philosophy of the Fire Engineer is irrelevant.  In fact, nearly everybody involved with fire safety in buildings would collapse in a fit of laughter at the delusional notion that a design philosophy was relevant.  People’s lives are at stake !

Similarly, now, we must begin to think and act in the simple terms of a building either being ‘accessible’, or not.  At stake, this time, is the quality of life and living for very many vulnerable people in all of our societies.

Accessibility for All, according to International Standard ISO 21542 (2011) … includes the approach, entry to and use of a building, egress during normal conditions and removal from the vicinity of the building … and, most importantly, evacuation during a fire incident to a ‘place of safety’ which is remote from the building.

Concerning that All above … FireOx International’s ‘Fire Safety for All’ Matrix shows who exactly we are talking about … and who must be considered in the development of a Fire Safety Strategy for every building … not just some buildings !

This is not just good design practice … it is also mandated in International Human Rights Law.

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Colour image showing FireOx International's 'Fire Safety for All' Matrix.  Revised and Updated in October 2014.  FireOx International is the Fire Engineering Division of Sustainable Design International Ltd. (Ireland, Italy & Turkey).  For a clearer and sharper print, download the PDF File below.  Matrix developed by CJ Walsh.  Latest revision suggested by Jo Kwan (Hong Kong).

Colour image showing FireOx International’s ‘Fire Safety for All’ Matrix.  Revised and Updated on 24 October 2014.  FireOx International is the Fire Engineering Division of Sustainable Design International Ltd. (Ireland, Italy & Turkey).  For a clearer and sharper print, download the PDF File below.  Matrix developed by CJ Walsh.  Latest revision suggested by Jo Kwan (Hong Kong).

FireOx International’s ‘Fire Safety for All’ Matrix (2014) – PDF File, 25 Kb

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Building Fire Safety Codes and Standards exist in almost every country.  However – IF they exist at all – those guidelines relating to the Fire Safety of People with Activity Limitations are technically inadequate, entirely tokenistic and/or blatantly discriminatory.

Refer to my previous post … BS 9999:2008 & BS 8300:2009 – Sleepwalking into Problems ?

It is time to Reboot this ridiculous, professionally negligent and obsolete old system … Reload with innovative and practical building design, construction, management and personal self-protection solutions … and Implement !

Fire Safety for All !

2015 ‘Fire Safety for All’ Global CSR Event – Dublin, 9 & 10 April

Register Now !

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Good Design Practice: ‘Fire Safety for All’ & EICT Accessibility

[ EICT’s = Electronic, Information & Communication Technologies ]

2014-10-13:  Electronic, Information and Communication Technologies have rapidly become an essential feature of the Built, Social and Economic Environments; they are everywhere.  During a fire incident, however, these e-Technologies serve a function which is critical for the safety of all building users and firefighters, property protection, minimizing environmental damage, and sustainability.  They must, therefore, have a user interface which is Accessible for All … from both ends.

This is a requirement of International Law … and an unambiguous National Requirement (expressed in the form of law and/or mandatory administrative provisions) in those jurisdictions which are States Parties to the United Nations Convention on the Rights of Persons with Disabilities (CRPD).

There is no European Standard (EN) on e-Technology Accessibility … and, in the European Union (EU), a coherent approach to the accessibility of even a modest range of EICT’s has not yet even been developed.

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Electronic, Information and Communication Technologies (EICT’s) must comply with Section 508 of the United States Rehabilitation Act Amendments of 1998 … or with a suitable Standard/Guidance Document of another country which details an equivalent level of e-Accessibility performance.

U.S. Section 508 covers the following range of e-Technologies:

  • Software Applications & Operating Systems (1194.21) ;
  • Web-based Intranet and Internet Information and Applications (1194.22) ;
  • Telecommunications Products (1194.23) ;
  • Video and Multimedia Products (1194.24) ;
  • Self Contained, Closed Products (1194.25) ;
  • Desktop and Portable Computers (1194.26)

Source WebSite, Helpful Guidance & Support …

www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-section-508-standards

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‘Sustainability’ – New Part 11 in India’s National Building Code !

2013-03-17:  Happy Saint Patrick’s Day !!

Submissions on India’s Draft Amendment No.1 to the 2005 National Building Code (SP 7:2005) concerning the Proposed Incorporation of a New Part 11: ‘Approach to Sustainability’ had to arrive at the Bureau of Indian Standards (BIS), in Dilli … by e-mail … no later than Friday last, 15 March 2013 …

Indian National Building Code Proposed New Part 11: 'Approach to Sustainability' - Cover Memo

Click to enlarge.

Indian NBC, Proposed Part 11 on ‘Sustainability’ – December 2012 Consultation

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Extract From Foreword (Page 7):

‘ Developed nations’ approach to sustainability generally concentrates on energy conservation through high technology innovations, and use of products, materials and designs with lower embodied energy.  Their green ratings are based on intent, which implies expert inputs and simulation.  The Indian construction industry will do better using our traditional wisdom and practices, building in harmony with nature through regional common knowledge, consuming as little as necessary, applying low cost technology innovations, using recycled materials, and recognizing performance (not intent) through easily measurable parameters wherever feasible.’

How Right They Are About Prioritizing ‘Real’ Performance !!

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And Just Before That Extract Above:

‘ The authentic (my insert !) Indian way of life is aparigraha (minimum possessions), conservation (minimum consumption), and recycling (minimum waste).  These three attributes are the guiding principles for sustainable buildings as well.  With these attributes and its rich heritage, India can make a substantial contribution in this field and eventually lead the world on the path of sustainability.’

An Overly Ambitious Target ?   Perhaps Not.

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SDI Supporting India’s National Sustainable Buildings Strategy …

We very much welcome this opportunity to make a Submission on India’s Draft Amendment No.1 to the 2005 National Building Code (SP 7:2005) concerning the Proposed Inclusion of a New Part 11 ‘Approach to Sustainability’.

This IS an important development for India … and it DOES mark a substantial contribution to this field, at international level.  We wish that other countries would follow your example … particularly China, the other mushrooming economies in South-East Asia, and the Arab Gulf States.

You may not be aware that Sustainable Design International (SDI) has been specializing in the theory and implementation of a Sustainable Human Environment (social, built, virtual, and economic) since the mid-1990’s.

And, for example … in September 2007, we were invited to make a series of Keynote Presentations to 20 Senior National Decision-Makers, from both the public and private sectors, at a 2-Day Workshop which was organized for us in Lisboa, Portugal.  If invited, we would be delighted to repeat this valuable exercise in Dilli, Bengaluru, and other suitable venues in India.

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IF India is to lead the world on this particular track, i.e. Sustainable Buildings, a coherent philosophy must be outlined in the Proposed New Part 11 of the National Building Code, and a clear direction must also be given there to decision-makers, e.g. clients/client organizations, and designers.

Certain essential content must be included in Part 11.  With regard to an improved layout of Part 11, please review the attached  SDI Document: ‘SEED Building Life Cycle’ (PDF File, 55 Kb) .

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Because you have prioritized ‘real’ building performance over pre-construction design ‘intent’, it is appropriate to begin our comments here …

1.   Sustainability Performance Indicators

In order to prioritize ‘real’ performance, the monitoring of actual sustainability performance in completed and occupied buildings must be comprehensive, accurate and reliable.  Indicators of sustainability performance must, therefore, be included in all sections of the Proposed New Part 11.

Sustainability Performance Indicators provide important signposts for decision-making and design in many ways.  They can translate physical and social science knowledge into manageable units of information which facilitate the decision-making and design processes.  They can help to measure and calibrate progress towards sustainable development goals, and sectoral sustainability targets.  They can provide an early warning to prevent economic, social and environmental damage and harm.  They are also important tools to communicate ideas, thoughts and values because, as statisticians say: “We measure what we value, and value what we measure”.

Performance Indicators may be both quantitative and qualitative … but must cover all stages of the building process, i.e. project feasibility and performance specification, spatial planning, design, construction, management, operation, maintenance and servicing, de-construction, disposal, final site clean-up and sustainable repair.

While many, though not all, types of building performance can be successfully monitored using lightweight portable equipment … a certain number of monitoring devices must also be permanently installed in the building during construction.  A facility to reliably feed the output from these devices back to data collection points, on site and remote, must also be incorporated in the Building’s Intelligent Management System.

Management and collation of sustainability performance data must be reliable.  Uncertainty is always present.  Therefore, Statements of Uncertainty should always be attached to ‘reliable’ data.

Safety Factors should always be included when targeting critical ‘health and safety’ related types of performance.

Sustainability Performance Indicators must be directly comparable across different Global Regions … within Asia, across different countries … and within India, across different States.  A Balanced, Harmonized Core Set of Indian Performance Indicators should be quickly developed.  A Balanced ‘Local’ Set of Performance Indicators will always be necessary.

People tasked with monitoring sustainable building performance must be competent … and independent, i.e. be unconnected to client, design and construction organizations.

Specifically in relation to Energy Performance, the targets to be achieved in new buildings must be far more ambitious.  Please review the attached  SDI Document: ‘SEED Positive Energy Buildings’ (PDF File, 29 Kb) .

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2.   Properly Defining ‘Sustainable Development’

As currently drafted … Definition 2.26 Sustainable Development, on Page 13 of the Proposed New Part 11, is not only ambiguous, it is inadequate for India’s needs … and it is barely the first half of the full, correct definition …

Sustainable Development  is development that meets the needs of the present without compromising the ability of future generations to meet their own needs.  It contains within it two key concepts:

  • the concept of ‘needs’, in particular the essential needs of the world’s poor, to which overriding priority should be given ;  and
  • the idea of limitations imposed by the state of technology and social organization on the environment’s ability to meet present and future needs.

[ Please refer to the 1987 Report of the World Commission on Environment & Development (WCED): ‘Our Common Future’ – Chapter 2, Paragraph 1.]

This original definition in the 1987 WCED Report IS appropriate for India … and it must become the core definition at the heart of India’s National Sustainable Buildings Strategy !

A careful reading of the full definition makes it clear that there are Many Aspects to this intricate, open, dynamic and still evolving concept … the most important of which are:  Social, Economic, Environmental, Institutional, Political, and Legal.

It is a Fundamental Principle of Sustainability, and one of its Primary Values … that Implementation must be Synchronous, Balanced and Equitable across All Aspects of Sustainability.

The ‘Green Agenda’ merely considers Environmental Aspects of Sustainability … in isolation from all of the other Aspects !   This is a fatal flaw which must be avoided in the Proposed New Part 11 !!

[ I made many references to this issue during the FSAI Conferences in India ! ]

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3.   Sustainability Impact Assessment (SIA) for India !

Rather than Environmental Impact Assessment … surely the Proposed New Part 11: ‘Approach to Sustainability’ must now use, explain and discuss Sustainability Impact Assessment instead !?!

Sustainability Impact Assessment (SIA)

A continual evaluation and optimization assessment – informing initial decision-making, or design, and shaping activity/product/service realization, useful life and termination, or final disposal – of the interrelated positive and negative social, economic, environmental, institutional, political and legal impacts on the synchronous, balanced and equitable implementation of Sustainable Human & Social Development.

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4.   A Robust Legal Foundation for ‘Sustainable Human & Social Development’

Paragraph 4 (Chapter 2, 1987 WCED Report) states …

‘ The satisfaction of human needs and aspirations is the major objective of development.  The essential needs of vast numbers of people in developing countries – for food, clothing, shelter, jobs – are not being met, and beyond their basic needs these people have legitimate aspirations for an improved quality of life.  A world in which poverty and inequity are endemic will always be prone to ecological and other crises.  Sustainable development requires meeting the basic needs of all and extending to all the opportunity to satisfy their aspirations for a better life.’

Trying to list the essential needs of people / the basic needs of all is a very difficult task … but it is work which has been on-going, at international level, since just after the Second World War.

The essential needs of people / the basic needs of all … are specified as being Human Rights and Fundamental Freedoms, and are already fully described within the extensive framework of International Legal Rights Instruments.

Which is why, many years ago, SDI developed this definition for Sustainable Human & Social Development … in order:

  • to give this concept a robust legal foundation ;   and
  • (because of widespread confusion in media, political and academic circles) … to clearly establish that we are talking about sustainable human and social development, and not sustainable economic development, or any other type of development !

Sustainable Human & Social Development

Development which meets the responsible needs, i.e. the Human & Social Rights*, of this generation – without stealing the life and living resources from future generations … especially our children, and their children … and the next five generations of children.

*As defined in the 1948 Universal Declaration of Human Rights.

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5.   Climate Change Adaptation & Resilient Buildings in India ?

Atmospheric Ozone Depletion and Climate Change are mentioned, here and there, in the Proposed New Part 11.  The important implications of these phenomena for Sustainable Building Design in India are not explained … at all.  Why not ?

To properly respond to these phenomena, both must be integrated into India’s National Sustainability Strategies & Policies.

At the very least … we strongly recommend that Design Guidance on Climate Resilient Buildings be immediately drafted.  This guidance must be appropriate for implementation in each of the different climatic regions of India.

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6.   A Sustainable Indian Built Environment which is Accessible for All !

Barrier Free is mentioned, here and there, in the Proposed New Part 11.  This is to be warmly welcomed and congratulated.  Under Social Aspects of Sustainable Human & Social Development … this is an essential attribute of a Sustainable Built Environment !   However, no guidance on this subject is given to decision-makers or designers.  Why not ?

However, you should be aware that India ratified the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) on 1 October 2007.  For your convenience, I have attached copies of the Convention in English, Hindi and Tamil.

You should also be aware that, in December 2011, the International Standards Organization (ISO) published ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’.  In its Introduction, ISO 21542 is directly linked to the U.N. Convention … almost like an umbilical cord.  The scope of this Standard currently covers public buildings.  As the Accessibility Agenda in the U.N. Convention is very broad … much standardization work remains to be finished at international level.

The correct term … Accessibility for All … has been defined in ISO 21542 as including … ‘access to buildings, circulation within buildings and their use, egress from buildings in the normal course of events, and evacuation in the event of an emergency’.

A note at the beginning of the standard also clarifies that Accessibility is an independent activity, i.e. assistance from another person should not be necessary … and that there should be an assurance of individual health, safety and welfare during the course of those (accessibility-related) activities.

In order to fulfil India’s legal obligations as a State Party to the U.N. Convention on the Rights of Persons with Disabilities … adequate Design Guidance on Accessibility must be included in the Proposed New Part 11, supported by ISO 21542.

In addition, the Bureau of Indian Standards (BIS) should immediately adopt ISO 21542 as the Indian National Standard on Accessibility for All … IS / ISO 21542.

[ I made many references to this issue during the FSAI Conferences in India ! ]

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7.   Fire Safety & Protection for All in Sustainable Indian Buildings ?

Yes … there is 1 mention of ‘fire safety’ and 40 other references to ‘fire’ in the Proposed New Part 11 … but no design guidance.  Why not ?

You should be aware that there is a fundamental conflict between Sustainable Building Design Strategies and the current state-of-the-art in Fire Engineering Design.  As a good example … for cooling, heating and/or ventilation purposes in a sustainable building, it is necessary to take advantage of natural patterns of air movement in that building.  On the other hand, fire engineers in private practice, and fire prevention officers in Authorities Having Jurisdiction (AHJ’s), will demand that building spaces be strictly compartmented in order to limit the spread of fire and smoke … thereby dramatically interfering with those natural patterns of air movement.

In everyday practice, there is a vast chasm in understanding and communication between these two very different design disciplines.  As a result, serious compromises are being enforced on Sustainability Building Performance.  If, on the other hand, adequate independent technical control is absent on the site of a Sustainable Building … it is the fire safety and protection which is being seriously compromised.

A range of critical fire safety issues (fatal, in the case of firefighters) are also arising with the Innovative Building Products and Systems being installed in Sustainable Buildings.

Because the emphasis is on pre-construction design ‘intent’ rather than the ‘real’ performance of the completed and occupied building … all of these problems are being conveniently ignored, and they remain hidden from everybody’s view.

This must be addressed in the Proposed New Part 11.

[ I made many references to this issue during the FSAI Conferences in India ! ]

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C. J. Walsh – Consultant Architect, Fire Engineer & Technical Controller – Managing Director, Sustainable Design International Ltd. – Ireland, Italy & Turkey.

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