Ar C.J. Walsh Technical Blog – Registered Architect, Fire Engineer & Independent Technical/Building Controller …… International Expert on Accessibility for All (including Fire Safety) + 'Real' Sustainability Implementation !
United Nations Convention on the Rights of Persons with Disabilities
It was a great pleasure to be invited to speak on the subject of Sustainable Fire Engineering at the 2010 ACRECONF in Delhi (Dilli), India. This ground breaking conference in Asia took place at the India Habitat Centre, Lodhi Road, Delhi … on the 8th & 9th January last. Back during August (2009) in Bengaluru … the ACRECONF Chairman, Mr. Ashish Rakheja, told me that he expected an attendance of somewhere between 500-600 people at the Delhi Conference. Over the two days of the actual conference, approximately 1800 delegates participated … an enormous response by architects, civil and service engineers, developers, client and construction organizations, etc., etc., from right across the country … and from the deep south.
Colour photograph showing some of the many participants at the 2010 ACRECONF in Delhi, as they enjoy talking and networking during the morning coffee break of the second day at the conference. The venue was the India Habitat Centre on Lodhi Road. The weather was chilly for the time of year, and there had been a heavy fog earlier in the morning. Click to enlarge. Photograph taken by CJ Walsh. 2010-01-09.
For me … refreshing, extremely impressive, and certainly the highlight of the conference … was a multi-media presentation … on the second morning, just after the coffee break … by Mr. Karan Grover, the renowned Indian Architect. He is quite an individual !
Before the break, delegates had been treated to an elaboration of the Environmental Design Innovations incorporated into the 71 storey Pearl River Tower (Guangzhou, China), by Mr. Varun Kohli of Skidmore, Owings & Merrill (SOM) in New York. Construction of the Tower is now well under way. Afterwards, however, an important discussion took place concerning the issue of fire safety, and fire engineering generally, in Sustainable Buildings. It became clear to all of the participants that this issue is a major oversight … an intentional gap … in the design of these buildings. I made the point, forcibly, that Sustainable Fire Engineeringis open to innovation and design creativity. There will be an important follow-up to this discussion.
Colour photograph showing a silly tourist on a bicycle rickshaw, as he is brought sightseeing around the Bazaar District in Old Delhi. Click to enlarge. Photograph taken by Mr. Daljeet Singh, Ministry of Tourism, with CJ Walsh's camera. 2010-01-09.
Unfortunately, the conference was peppered with references to ‘Green’ Buildings … an outdated marketing concept (!) … which, within its limited world-view, gives people the false comfort of not having to deal with thorny issues such as ‘social justice, solidarity & inclusion for all’. I have discussed this issue many times in previous posts.
Even more unfortunately, where the Brundtland Definition of ‘Sustainable Development’ was actually presented in one session … as usual, it was only the first half of the definition which made any appearance. The second, and more important, half of the definition had mysteriously vanished without trace … which made the whole effort a meaningless exercise ! What a waste !! No wonder there is such confusion over the concept … at all levels … in most countries !!!
It was not surprising, therefore, that what was not stressed enough, during the entire conference, was that Sustainable Design Solutions must be appropriate to local geography, climate, economy, culture, social need and language(s)/dialect(s), etc. The LEED Building Rating System (USA), for example, is not being properly adapted to local conditions in India !
A final issue … another major oversight … another intentional gap … in the design of buildings … Accessibility-for-All ! Even though India ratified the 2006 UN Convention on the Rights of Persons with Disabilities on 1st October 2007 … this essential aspect of design … certainly in Sustainable Buildings … received no mention whatever during the conference … except by yours truly, in my presentation.
Overall … a magnificent achievement for the organizers !
2009-12-16: ‘Chaotic’ is not the only word to describe what is happening right now in Copenhagen ! A few additional parliamentary expletives are required. Is it just me … or is it obvious to everyone … that the Danes could not organize an orgy at an International Golf Tournament ?
What the world urgently needed was an ambitious, legally binding agreement … a Kyoto II Protocol, for want of a better title … to slot into place when the 1st Commitment Period ends in 2012. What we may end up with is an ambiguous ‘political’ agreement … which will be worth approximately 1 cent more than the paper on which it will be scrawled.
There is something definitely rotten in the State of Denmark ! Multiple drafts of the same working document circulating at the same time … backroom meetings away from public scrutiny … greedy developed countries trying to avoid responsibility and action … strutting, self-important NGO’s thinking that they know all the answers … etc., etc … kill any confidence in the process stone dead. These are not the ways of Sustainable Social Partnership.
However … at a far distance from the hustle and bustle … it can be observed that Interesting Side Events are taking place … and Thought Provoking Reports are being presented … before, during and after the main gatherings between the 7th and 18th December 2009:
15th Session of the Conference of the Parties (COP-15) to the United Nations Framework Convention on Climate Change (UNFCCC) ;
5th Meeting of the Parties (MOP-5) to the Kyoto Protocol.
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African Countries are not the only Group having difficulty with what is/is not happening in Copenhagen …
Two recent Discussion Papers from The Energy & Resources Institute (TERI), in India, are worth bringing to your attention. Both raise issues which are not very popular in this part of the world. And … it so happens that Dr. Rajendra K Pachauri – Director-General of TERI … is also Chairman of the WMO-UNEP Intergovernmental Panel on Climate Change (IPCC) !
To gain worldwide acceptance – across developed, developing and least developed regions of the world – and to have a reasonable chance of reliable implementation in those disparate regions … mitigation of, and adaptation to, climate change, including variability and extremes, must be fully compatible with the concept of Sustainable Human & Social Development. This is clearly elaborated in both the 1992 UNFCCC and the 1997 Kyoto Protocol.
To be clear among ourselves on this island … Ireland is specifically named (without any qualification), among other Developed Countries … in Annex I and Annex II of the 1992 United Nations Framework Convention on Climate Change (UNFCCC) … and in Annex B of the 1997 Kyoto Protocol, which is legally binding. The European Union is not mentioned, at all, in either document.
It is of concern to note that although India ratified the 2006 United Nations Convention on the Rights of Persons with Disabilities (CRPD) in October 2007 – TERI (India) has very recently placed a Document (No.1 above) in the public domain, at Copenhagen, which actively forbids content extraction by people with activity limitations for the purposes of equitable accessibility ! Joined-up thinking !?!?
2009-10-31: Missing so far in Ireland … but an essential starting point for any discussion about Disability & Accessibility of the Built Environment in many other countries … is the 2006 United Nations Convention on the Rights of Persons with Disabilities, which entered into force, i.e. became an International Legal Instrument, on 3rd May 2008.
This Convention is important because it facilitates access, for a large group of people in all of our communities, to the Rights, i.e. basic needs, of all human beings … which were first elaborated in the 1948 Universal Declaration of Human Rights. Until now, access to Universal Rights has effectively been denied to people with disabilities.
How is Ireland responding to the UN Convention ?
Ireland signed the Convention on 30th March 2007 … but has still not signed the Convention’s Optional Protocol. Furthermore … even though other European Union Member States have proceeded to ratify both the Convention and the Optional Protocol on their own, without waiting for all Member States to act in unison … Ireland has not ratified either. Why is that ???
On the positive side … and at the time of writing …
143 countries, including Ireland, have signed the Convention ;
87 other countries have signed the Optional Protocol ;
71 other countries have ratified the Convention ;
45 other countries have ratified the Optional Protocol.
Click the Link above to read/download PDF File (215 Kb)
With regard to Accessibility … refer, initially and directly, to Preamble Paragraph (g) and Articles 9 & 11 of the Convention.
[As a matter of routine in all of our work, I prefer to go beyond the scope of the 2006 Disability Rights Convention … and to consider Accessibility for All, i.e. including People with Activity Limitations (2001 WHO ICF), to the Human Environment.]
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Accessibility Implementation in Ireland, and Toilet Facilities
How more basic can you get in every day life and living ?
The WC Cubicle shown in Diagram 13 of the existing Technical Guidance Document M does not work … a black and white / open and shut case. It has not worked for a long, long time. It is not ‘accessible’. Should this come as a sudden surprise to anybody ? No.
That toilet arrangement dates back to guidance documentation published by the Irish National Rehabilitation Board (NRB) in the early 1980’s. And since that guidance took a long time to produce … we are talking about well before the end of the 1970’s as its true date of origin. I know, because I was there … and I have the T-Shirt !
I am not going to show that Diagram here, because I don’t want to encourage anybody to reproduce it again in a ‘real’ building … for any reason whatsoever !
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Nearly 30 years later (!) … the Wheelchair Accessible Unisex WC shown in Diagram 12 of Draft Technical Guidance Document M (2009) is not a significant improvement on the earlier version. In fact, it is a miserable effort ! And … I am not going to show that Diagram here either … for the same reason.
What I would like to present, however, are Figures 43 & 44 from the Draft International Accessibility-for-All Standard ISO 21542. This is the level of accessibility performance which we should all be striving to achieve … as a minimum !
2 colour drawings showing, on top, an Accessible Toilet Facility, with corner WC arrangement … and, on the bottom, showing that there is sufficient space for a range of Wheelchair-to-WC transfer options. Click to enlarge.
N.B. A standard, large Wash Hand Basin must no longer be considered as an optional extra in a properly fitted out Accessible Toilet Facility.
Please also note the independent water supply, on the wall side of the corner WC, feeding a shower head type outlet which can be turned on or off at the outlet head … or within easy reach of the WC. This is Accessibility-for-All in action !
Colour photograph showing what is supposed to be an ‘Accessible’ Toilet Facility, with a combined Baby Change Facility. Inadequate management magnifies the already poor accessibility performance of the cramped space. Click to enlarge. Photograph taken by CJ Walsh. 2009-09-19.
Many building owners/managers wish to combine an Accessible WC Cubicle with a Baby Change Facility. More space is required, therefore, above and beyond that shown in the Figures above for the Baby Change fittings and associated ‘equipment’.
Without Proper Accessibility Management … Accessibility Performance will rapidly deteriorate … as shown in the above photograph.
Once we have mastered the minimum building accessibility performance required to meet the needs of a single person with an activity limitation … our next priority must be the Social Dimension of Accessibility. Existing Building & Fire Regulations, Standards and Design Guidance are still geared very much towards the single building user. However, for example, if 5 or 6 or 8 wheelchair users decide to use a building’s facilities … not a concept which is off-the-wall (!) … there is almost a complete breakdown and failure in accessibility. This is no longer acceptable !!
2009-10-24: As I have travelled around … not just Ireland, but many other countries as well … it still remains a puzzle to me, today, why so many Fire Emergency Assembly Areas are located just outside the main entrance of a building. These locations are not safe in a ‘real’ fire emergency … and they should not even be used for the purposes of test/drill evacuations !
Is the guidance contained in current Building & Fire Regulations, Codes and Standards on what is a ‘Place of Safety’ in a fire emergency clear, simple, direct and precise ? Are you joking ? No way ! Let us take a few examples close to home …
In Ireland:
When you look at the array of different Technical Guidance Documents (Building Regulations) at the same time … TGD B (Fire Safety) is way out of proportion, in size, compared to all of the others. You would expect, therefore, to find exactly what you were looking for in that document. Wouldn’t you ?
TGD B (2006), Paragraph #1.0.9 – Definitions
Place of Safety
A place, normally in the open air at ground level, in which persons are in no danger from fire.
Clear as mud ! If there is a fire on O’Connell Street in Dublin … a person is safe on Patrick Street in Cork ! But, how is any Building or Facilities Manager expected to work with such a vague definition ?
In England & Wales:
No practical definition, as such, is readily provided. The nearest thing to a definition is an amalgam of the following …
Building Regulations, Requirement B1 – Means of Warning & Escape
The building shall be designed and constructed so that there are appropriate provisions for the early warning of fire, and appropriate means of escape in case of fire from the building to a place of safety outside the building capable of being safely and effectively used at all material times.
Approved Document B: Volume 1 – Dwellinghouses & Volume 2 – Buildings Other Than Dwellinghouses
The ultimate place of safety is the open air clear of the effects of the fire.
British Standard BS 9999 : Code of Practice for Fire Safety in the Design, Management & Use of Buildings : 2008
Place of Ultimate Safety
Place in which there is no immediate or future danger from fire or from the effects of a fire.
Again … all as clear as mud ! Again … how is any Building or Facilities Manager expected to work with such vague guidance ? Have you also noticed the additional obfuscation introduced by use of the word ‘ultimate’ in BS 9999 ?
It is hard to escape the conclusion that what is urgently needed is a fundamental transformation and re-shaping of the tired, antiquated and flawed ad-hoc assembly of prescriptive ‘solutions’ contained in current national building and fire regulations, codes, standards and administrative provisions … whatever their origin !
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Now … try this for clarity, simplicity, directness and precision …
Place of Safety (Fire Incident in a Building, No Explosion Hazard*)
Any location beyond a perimeter which is [100]* metres from the fire building or a distance of [10]* times the height of such building, whichever is the greater
and
where necessary and effective medical care and attention can be provided, or organized, within one hour of injury
and
where people can be identified.
* Where there is a Risk of Explosion … multiply the numbers in square brackets above by 4.
Was that good for you ?
Furthermore …
The Route to any Place of Safety must be Accessible for All Building Users, including people who use wheelchairs, the visually impaired, frail older people, women in the later stages of pregnancy, children, etc., etc.
Colour photograph showing a Typical Scene at a Building Fire Emergency, with Fire Service Vehicles and Personnel in operation mode. The haphazard arrangement of firefighting water hoses on the ground makes access difficult for many Building Users to a ‘Place of Safety’ which is remote from the Fire Building. Click to enlarge.
With regard to an Adequate, never mind a Proper, Awareness of Disability-Related Issues at a Fire Scene … it is shocking to realize how almost non-existent this is among Fire Services … not just in Ireland and Britain … but in the rest of Europe and North America as well.
Even a hint of criticism will usually … not always … meet the Neanderthal Fire Service Response: “Have you ever been in a ‘real’ building fire ?”
My Response is: “Do you have to be a hen to know when an egg is bad ?”
This discussion will continue later … have no doubt … that is a promise !
2009-10-17: Some of you are already hitting the Internet Search Engines … with fierce intent altogether … about Disability Access Certificates (DAC’s) !
Is it Time to Panic ? No.
For a simple and direct hit, the 2 most relevant Irish Legal Instruments are:
1. Statutory Instrument No. 352 of 2009 – Building Control Act 2007 (Commencement) Order 2009.
This states …
” The 30 September 2009 is appointed as the day on which the provisions of Sections 5 and 6 of the Building Control Act 2007 shall come into operation.”
Section 5 covers the Amendment of Section 6 (Building Control Regulations) of the Building Control Act 1990.
Section 6 covers the Amendment of Section 7 (Appeals) of the Building Control Act 1990.
2. Statutory Instrument No. 351 of 2009 – Building Control (Amendment) Regulations 2009.
This states …
” These Regulations shall come into effect on 1 October 2009, except for the provisions of Article 8 which shall come into effect on 1 January 2009.”
For you, yourself, to properly examine all of the ‘ins and outs’ of this New Certification Scheme … download the PDF File below … and then search the document (making sure that it is not case-sensitive !) using the phrase ‘Disability Access Certificate’. You will find 99 instances where the phrase is used.
Click the Link above to read/download PDF File (223 Kb)
In order to make full sense of all that is happening, and is intended to happen in the not too distant future … there are a few other Legal Instruments, related to the two listed, which also need to be consulted … but that is an exercise meant for masochists !
In comparison, the European Union Lisbon Treaty was a sweet bedtime story ! Seriously !!
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Is it Time to Worry ? Yes.
Here are just a few random ideas for your cogitation …
If the Department of the Environment, Heritage & Local Government (DEHLG) pays little heed to Submissions made during and after this summer’s ‘consultation’ process … the proposed New Technical Guidance Document M: ‘Access & Use’ will end up looking like a real dog’s dinner of an absolute mess ! FUBAR.
Years were spent in the preparation of the New TGD M. When it does eventually appear, it will be an accurate reflection of technical capacities within both the Department and the National Disability Authority (NDA).
Deeply regretted is the absence of Mr. Kevin Spencer … a gentle soul … from the DEHLG. Things have not been the same since his departure. He knew what he was talking about.
Who will deal, at a technical level, with Applications for Disability Access Certificates in the Local Authorities ? Will they be competent to do so ? Will their interpretation of the Part M Legal Requirements be harmonized … not just with other/different Authorities … but even with other technical personnel in the same Authority ???
In order to make this new certification scheme work, will the Guidance Text in Technical Guidance Document M (whatever version appears !) be operated as if it were Prescriptive Regulation … which will be totally illegal ?
This has been exactly the story … for many years … with the Guidance Text in Technical Guidance Document B … in the course of operation of the Fire Safety Certification Scheme. FUBAR.
If, as I hinted above, the proposed New Technical Guidance Document M: ‘Access & Use’ will be a real dog’s dinner of a mess … falling far short of what can now be reasonably described as minimal accessibility performance (see the Draft International Accessibility-for-All Standard ISO 21542) … this will certainly open Building Owners/Managers of newly completed buildings to Complaints under Irish Equality Legislation. Why is the Disability Sector so inactive with regard to making complaints ?
and finally …
Are the relevant Irish Decision Makers, as I suggested might happen in a previous post, in the process of actually sleepwalking into an unquestioned acceptance of the inadequate British Standards BS 9999 : 2008 and BS 8300 : 2009 ??? Do they know how to do anything else ?
For some sublime moments of meditation, however, please chew on the information provided at these Pages on the SDI Support WebSite …
2009-09-08: It is really enjoyable to be back behind my desk, here in Dublin. Apologies for the prolonged absence.
Since the middle of June last, my travels have taken me to Turkey, France, Italy, the south-west of Ireland to attend my cousin’s wedding in Cork … and back again to Bengaluru (Bangalore) in Southern India to make an important Keynote Presentation at the 2009 Fire & Safety Association of India (FSAI) National Fire Seminar: ‘Engineering a Safe & Secure India’, which was held on Friday, 28th August, at the Leela Palace Hotel.
My Presentation Title & Abstract …
Sustainable Fire Engineering: Fire Safety, Protection & Evacuation for All
India, like other economically advanced developing countries, is at an important crossroads. Difficult, resource-dependent decisions must be made in the next few short years concerning the rapid implementation of a Sustainable Built Environment across a vast country, i.e. one which must serve local needs and meet regional performance requirements during a long life cycle … one which will be adaptable to climate change, variability and extremes … will be in harmony and dynamic balance with the Natural Environment … and, not least, will be super energy-efficient.
Citizens of Developed Nations also have legitimate expectations. They will express anger when they witness recently constructed buildings in seismic zones collapse, in an earthquake, like a deck of cards (China 2008, Italy 2009) … or they discover that federal/state authorities having jurisdiction, which are funded by their taxes, are ill-prepared to respond effectively to intentional traumatic disruptions to the Social Environment (New York 2001, Mumbai 2008). Retaining the public’s confidence in national institutions is a fundamental political priority.
In the case of all new High-Rise Buildings, Iconic Buildings, and Buildings of Innovative Design or having a Critical Function … Trans-Disciplinary Building Design Teams must, at a minimum, properly respond to the Recommendations of the 2005 & 2008 NIST(USA) Final Reports on the 9-11 WTC 1, 2, and 7 Collapses. In practice, the majority of these Recommendations should be applied to the design of all new buildings !
Fire Engineers, competent concerning the processes of ‘real’ building design and construction, must begin to understand the ‘real’ people who occupy or use buildings, every day of every week, in all parts of India … and that they each have widely differing ranges of human abilities and activity limitations. Just as they are different from each other, they will react differently than expected in a ‘real’ building fire emergency.
Based on a Keynote Presentation before International Council for Building Research (CIB) Working Commission 14 : Fire and Sub-Committee 3 & 4 Members of ISO Technical Committee 92 : Fire Safety, at Lund University in Sweden … and his fire safety texts which have been fully incorporated into International Standard ISO DIS 21542 on Accessibility-for-All, currently under development and due for publication before the end of 2010 … CJ Walsh’s Presentation, at the FSAI National Fire Seminar in Bengaluru, will focus on ‘Fire Safety, Protection & Evacuation for All’.
2009-06-14: Ireland has no national standards or codes of practice of its own covering Building Accessibility or Fire Safety in Buildings. Instead, many people and organizations in this country will just switch to automatic pilot and – without thinking or questioning – adopt the following two standards of another jurisdiction as the default Irish National Standards …
British Standard BS 9999:2008 – Code of Practice for Fire Safety in the Design, Management and Use of Buildings … was published on 31 October 2008.
British Standard BS 8300:2009 – Design of Buildings and Their Approaches to Meet the Needs of Disabled People. This Code of Practice was published on 28 February 2009.
If Ireland does not quickly open its eyes … we will be sleep walking into a very problematic legal environment, as far as building accessibility and fire safety in buildings is concerned.
1. An Immediate Challenge
A Sub-Group (established at a meeting of the NSAI Accessibility-for-All Standards Consultative Committee WG1 held on Tuesday 2009-05-19) was tasked with developing a common position, suitable for application in Ireland and compatible with European Technical Harmonization, on the following issues:
Clear Width of Internal & External Door Openings ;
Turning Circles for Occupied Wheelchairs ;
Car Parking Spaces ;
Fire Safety Issues.
A series of coherent proposals will be presented to the next NSAI AASCC WG1 Meeting, on Friday 19th June 2009 … and, given the absence of Irish National Standards, it will also be suggested how these proposals may be confirmed as best current practice here.
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2. Overview of BS 8300:2009 & BS 9999:2008
During the development of the Draft ISO Accessibility-for-All Standard, it has been unanimously agreed that Accessibility encompasses the full range of activity related to buildings: to approach, enter, use, egress from and evacuate a building independently, in an equitable and dignified manner (Introduction, 2nd Paragraph, Page 5). ‘Egress’ under normal, ambient conditions is distinguished from ‘Evacuation’ in the event of a fire emergency. Use of the word ‘Escape’ is discouraged in any circumstance. For the first time, fire safety texts have been fully incorporated into the main body of the Draft ISO Standard.
Accessibility within the British Standards Institution (BSI), on the other hand, is still segregated between BS 8300:2009 – approach, entry and use and BS 9999:2008 – fire evacuation. Conflicts and gaps in content naturally result from such a configuration, which can now be seen as outdated and fundamentally flawed.
This configuration has been replicated, in Irish Building Regulations, with the separate scopes of Part M / Technical Guidance Document M and Part B / Technical Guidance Document B. Integration between these 2 Technical Guidance Documents is very poor. In practice, fire safety for people with activity limitations is widely disregarded within the process of Fire Safety Certification in Ireland.
2.1 BS 8300:2009
BSI has arrogantly gone on a solo run, and decided to deviate from some very widely accepted concepts of accessibility, e.g. ‘clear width’ of a door opening (discussed in more detail later). The ‘Ergonomic Research’ supporting door opening forces of 30 N is at complete variance with earlier research in Britain and must, therefore, be strongly questioned. Perhaps, it is the case that the Fire Services in England & Wales re-asserted their authority, supported by reference to European Fire Product Standards with little if any input from the European Disability Sector, and insisted on a ‘definite’, i.e. high, closing force being exerted on the door leaves in fire resisting doorsets.
2.2 BS 9999:2008
People with disabilities have a right, recognized in international law after 3rd May 2008, to equal opportunity and non-discrimination in matters of building fire safety, protection and evacuation. A minimum response to Article 11 (Situations of Risk) in the 2006 United Nations Convention on the Rights of Persons with Disabilities is required, therefore, from fire regulators and code writers. Such a response is absent in British Standard BS 9999:2008.
A close examination of the fire safety texts relating to ‘disability’ in BS 9999:2008 shows that they have not been properly integrated into the ‘mainstream’ content. In fact, much of the content from the replaced BS 5588:Part 8 has just been grafted onto BS 9999, with very little change or alteration from the first version of Part 8 published in 1988 !
Compare Figure G.1 on Page 360 of BS 9999:2008 … with … Figure 4 on Page 8 of BS 5588:Part 8:1988 … both are exactly the same …
Black and white drawing showing both a token and an inadequate ‘area of rescue assistance’ in BS 9999:2008 – exactly as shown in the first version of BS 5588:Part 8 published back in 1988 ! Click to enlarge.
Two Critical Observations in relation to the ‘area of rescue assistance’ shown above:
– This drawing in BS 9999:2008 is in direct conflict with the text located directly above it … ‘where the wheelchair space is within a protected stairway, access to the wheelchair space should not obstruct the flow of persons escaping’ ;
but, more importantly …
– In BS 9999:2008, fire safety for people with activity limitations receives treatment which is superficial and merely token. Many times in relation to buildings generally, it is stated in Annex G.1, Page 359 …
‘A refuge needs to be of sufficient size both to accommodate a wheelchair and to allow the user to manoeuvre into the wheelchair space without undue difficulty.’
‘ In most premises, it is considered reasonable to have refuges of a size where each one is able to accommodate one wheelchair user. Where it is reasonably foreseeable that the proportion of disabled users in a building will be relatively high, or where the use of the premises is likely to result in groups of wheelchair users being present (e.g. some types of sporting, entertainment, transport or public assembly buildings), consideration should be given to increasing the size and/or number of refuges accordingly.’
‘ NOTE 3 Managers of sporting or other venues where a number of disabled people might be present are advised not to restrict the number of disabled people who can be admitted to that venue on the grounds of the size of refuges, since some disabled people who use mobility aids such as a wheelchair will be able to self-evacuate in the case of a real fire.’
and again in Annex G.2.2 on Page 367 …
‘Where it is reasonably foreseeable that the refuges will be used by more than one user (e.g. some types of sporting, entertainment, transport or public assembly buildings), … ‘
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Within such an inadequate and token context, it is understandable that an unduly heavy reliance is placed on the practice of developing Personal Emergency Evacuation Plans (PEEPS) for individuals with activity limitations. See Paragraph #46.7a) on Page 248, which states …
‘ By taking into account the individual needs of a person when preparing a PEEP, management will be able to make any reasonable adjustments to the premises or procedures that are necessary.’
These Plans are flawed and discriminatory because they are:
– person specific ; and
– location specific ;
… with the underlying assumption in the text being that, beyond the specified location(s), the building is not properly accessible, i.e. does not meet the functional requirements of Parts B & M in the Building Regulations for England & Wales – or, in the case of Ireland, Parts B & M of our Building Regulations.
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There are silly technical errors in BS 9999:2008, e.g. in Annex G.2.3 on Page 368, it states …
‘Unless a different order has been agreed with the fire authority, evacuation should normally be in the following order:
1) the fire floor ;
2) the floor immediately above the fire floor ; [This should read ‘the floors immediately above and immediately below the fire floor’ !]
3) other floors above the fire floor starting at the top storey ;
4) all remaining floors.’
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A Technical Term is used in BS 9999:2008 – Place of Ultimate Safety – which complicates the already widely accepted term: ‘Place of Safety’. The definition provided for the British Term in Section 3: Terms & Definitions (#3.84, Page 17) is so vague that it is of no practical use to fire engineering designers, building managers or building users.
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3. Comments:i) Clear Width of Door Openings
Paragraph #6.4.1, on Page 36 of BS 8300:2009 introduces a new understanding of ‘clear width’ for door openings, which is illustrated in Figure 11 (Page 37) … and also a new term ‘effective clear width’.
The new understanding of ‘clear width’ is a complete departure from the standard understanding, widely accepted throughout the world, which is shown in the bottom left hand drawing of Figure 11.
The new term ‘effective clear width’ will complicate the already difficult concept of ‘clear width’. Wasn’t the ‘clear width’ of a door opening always supposed to be ‘effective’, i.e. properly permit circulation for wheelchair users ?
However, the issue raised in the top right hand drawing of Figure 11 is valid …
Colour photograph showing the Final Fire Exit from a building (somewhere in Ireland). The ‘clear width’ of the door opening is seriously compromised – the door leaf cannot be fully opened and the panic bar reduces the ‘clear width’ still more. Click to enlarge.
Solution: Retain the current international/European/national understanding of ‘clear width’ for door openings in Ireland … but include text, with supporting drawings, in Revised Technical Guidance Documents B & M to ensure that there is no encroachment on that ‘clear width’ caused by protruding door leaf ironmongery or, more importantly, where the door leaf itself cannot be fully opened to 90o-100o.
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4. Comments:i) Clear Width of Door Openings in Existing Buildings
Table 2, on Page 37 of BS 8300:2009, permits the ‘clear width’ for door openings in existing buildings to be reduced significantly below 800mm.
If buildings of historical, architectural and cultural importance are properly identified, and proper allowance is made for these specific building types in Revised Technical Guidance Documents B & M … there is no need to permit a general reduction in the ‘clear width’ for door openings in existing buildings.
Solution: Clearly indicate in the Revised Technical Guidance Document M that the last ‘Existing Buildings’ Column on the right of Table 2 in BS 8300 should be disregarded.
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5. Comments:ii) Turning Circles for Occupied Wheelchairs
Down through the years, it has been just possible to communicate the concept of the ‘wheelchair turning circle’ to building designers and urban planners … whether it be the older 1.5m diameter circle or the newer 1.8m diameter circle.
The new Figures and Tables in Annexes C.3 and C.4 of BS 8300:2009 will be difficult to communicate … and may be a complication too far ?
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6. Comments:iv) Fire Safety Issues
Colour photograph showing people trapped at the top of one of the WTC Towers. This Tower collapsed soon afterwards. Click to enlarge.
The Recommendations contained in the 2005 & 2008 National Institute of Standards & Technology (USA) Reports on the WTC 9-11 Incident in New York provide an invaluable and essential empirical basis for the practice of effective fire engineering design in today’s built environment.
The first of these two reports has special relevance for NSAI AASCC WG1 because the typical problems encountered by people with activity limitations during a ‘real’ building fire incident have been highlighted by NIST and closely investigated. As a result, three important fire engineering keywords have been re-stated with strong emphasis: ‘reality’ – ‘reliability’ – ‘redundancy’. And, a new key phrase in relation to way finding during evacuation has been introduced to the everyday practice of fire engineering design: ‘intuitive and obvious’.
The 2005 NIST Report, particularly, must be given proper consideration during the development of any reputable fire safety related standard or code of practice for the following reasons:
– at the time of the ‘real’ fire incident, approximately 8% of building users were people with disabilities, with 6% having mobility impairments ; [The percentage of ‘building users with activity limitations’ exceeded the 8% quoted above.]
– NIST found that the average surviving occupant in the buildings descended stairwells at about half the slowest speed previously measured for non-emergency/test evacuations. This raises a serious question over the use of standard movement times in fire engineering design calculations for evacuation ;
– NIST strongly recommended that fire-protected and structurally hardened lifts (elevators) should be installed in buildings to facilitate the evacuation of building users with disabilities, and to improve emergency response activities by providing timely emergency access to firefighters ; [In Ireland, building designers have already adopted this approach by constructing cores of reinforced concrete … even in the absence of European/national standards.]
– it was recommended that evacuation routes should have consistent layouts, and be ‘intuitive and obvious’ for all building users, including visitors who may be unfamiliar with the building, during evacuations ;
– NIST recommended that staircase capacity and stair discharge door widths should be adequate to accommodate contraflow in circulation spaces, i.e. the simultaneous emergency access by firefighters into a building and towards a fire, while building users are still moving away from the fire and evacuating the building. This has implications for the minimum clear width of all fire evacuation staircases. Wider staircases facilitate the assisted evacuation and rescue of people with disabilities.
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No consideration was given in BS 9999:2008, however, to any of the Recommendations contained in the 2005 & 2008 NIST Reports … there is not even a mention of either Report in the Bibliography (Pages 423-429).
– For such an important national standard in Europe – BS 9999:2008 – there is no understanding demonstrated of the Fundamental Functional Requirement for Public Safety in Buildings …
Buildings shall remain structurally stable and serviceable …
1. while people are waiting in ‘Areas of Rescue Assistance’ ; and
2. until all of these people can be rescued by Firefighters and can reach a ‘Place of Safety’, which is remote from a fire building – with an assurance of individual health, safety & welfare for the people involved ;
– There is a reference to ‘normal movement times’ which are used to calculate evacuation times in Mobility-Impaired People (Paragraph #46.2, Page 247), even though it was found by NIST that the average surviving occupant in the WTC Towers descended stairwells at about half the slowest speed previously measured for non-emergency evacuations. In a ‘real’ fire incident, there is no such thing as ‘normal’ or ‘standard’ evacuation movement times, and the idea that any building must be clear of occupants within a very short timeframe, e.g. 2.5-3.5 minutes, is ludicrous ;
– In the sensitive area of the Resistance to Damage of Enclosing and Separating Partitions (Paragraph #21.2.5 on Page 101) surrounding Firefighting Shafts, it is still permissible in BS 9999:2008 to use non-robust construction, e.g. lightweight plasterboard. Fire-Induced Progressive Collapse is not discussed in the BS 9999 … and neither is Disproportionate Collapse, which is one of the functional requirements – A3 – in Part A of the Building Regulations for England & Wales (and Ireland !) ;
– Although in Wheelchair Users (Paragraph #46.3 on Page 247), it is stated …
‘It should be noted that it can take as many as four people to use an evacuation chair safely and effectively.’
… the dimensions for the minimum width of staircases in Width of Escape Stairs (Table 14 on Page 88) and Firefighting Stairs (Paragraph #21.3.2 on Page 106) disregard the guidance given on Page 247 … and ignore the minimum clear staircase width (1.5m) required to safely assist the evacuation of a person in a manual wheelchair …
Black and white photograph (US FEMA 2002) showing the correct way to assist the fire evacuation of a wheelchair user in an evacuation staircase … one person at each side, with another person behind.
And … for some unexplained reason, handrails are permitted to intrude into the ‘clear width’ of a firefighting staircase in BS 9999:2008 (Paragraph #21.3.2, Page 106).
Please note well … this method (shown below) of assisting the evacuation of a person in a manual wheelchair is NOT correct. It is not possible to support any weight by holding the foot rests on a manual wheelchair, or by grasping the wheelchair by the front wheels …
Black & white sketch showing how definitely NOT to assist the fire evacuation of a wheelchair user in an evacuation staircase.
Manual handling of occupied wheelchairs in a fire evacuation staircase, even with adequate training for everyone directly and indirectly involved, is hazardous for the person in the wheelchair and those people – minimum three – giving assistance.
The weight of an average unoccupied powered wheelchair, alone, makes manual handling impractical. All lifts (elevators) in new buildings should, therefore, be capable of being used for evacuation in a fire situation. Lifts (elevators) in existing buildings, when being replaced or undergoing a major overhaul, should then be made capable of use for this purpose.
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Contraflow Circulation, i.e. the simultaneous emergency access by firefighters into a building and towards a fire, while building users are still moving away from the fire and evacuating the building, has not been considered at all in BS 9999:2008.
A clear staircase width of 1.5m provides sufficient space for a mobile person to evacuate (700 mm) and a heavily protected and equipped firefighter to simultaneously move in the opposite direction (800 mm) …
Colour drawing, with photograph insets, showing the symbiotic relationship between Contraflow Circulation and Proper Assisted Evacuation in a building. Click to enlarge.
Human Behaviour in Fires should have been discussed in far more detail in BS 9999:2008 … but wasn’t. It is important for fire engineering designers to understand that the ‘real’ people who use ‘real’ buildings every day of every week, in all parts of the world, have widely differing ranges of human abilities and activity limitations … they are different from each other, and they will react differently in a fire emergency.
Building users need to be Skilled for Evacuation to a place, or places, of safety remote from a fire building. 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 a ‘real’ fire evacuation.
Meaningful Consultation with every person known to occupy or use a building, for the purposes of receiving his/her active co-operation and obtaining his/her informed consent (involving a personal representative, if necessary), is an essential component of adequate pre-planning and preparation for a fire emergency.
Adequate Warning of a fire incident in a building should be communicated well in advance of the time when it is necessary to act and should continue for the full duration of the incident. Warnings should be informative, and easily assimilated in a form (e.g. oral, written, braille) and language understood by the people using the building.
Panic attacks, during evacuation in a ‘real’ fire incident, exist. The 2005 National Building Code of India refers extensively to this issue.
Solution: To resolve the technical inadequacies, inconsistencies and content gaps in BS 9999:2008 … it will be necessary to revise Technical Guidance Document B in Ireland. Fire safety, protection and evacuation from buildings for people with disabilities must be comprehensively included in the process of Fire Safety Certification.
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7. Conclusions – BS 9999:2008 & BS 8300:2009
There are many gaps and conflicts between these two British Standards, principally because … they are two separate standards … drafted by two different Technical Committees within the British Standards Institution (BSI).
Because of its deviation from widely accepted concepts of accessibility and its tortuous use of terminology, BS 8003:2009 will have an adverse impact on the practice of Accessibility Design in Ireland … and has already complicated the development of the ISO Accessibility-for-All Standard (DIS ISO 21542).
Arrogance within BSI is not the only reason for such deviations. Distorting the European Union Single Market, for the purpose of introducing technical barriers to trade, is common in Britain … refer to the ‘deemed-to-satisfy’ status of the Approved Documents in the Building Regulations for England & Wales … and the Fire Protection Association’s ‘LPC Sprinkler Rules’.
Input from the Disability Sector during the drafting of BS 9999:2008 was not at all sufficient to ensure that there was a meaningful consideration of the problems encountered by people with activity limitations during a ‘real’ building fire incident. The necessary range of available and effective fire engineering solutions has not, therefore, been presented in the standard.
In addition … the complete and abject failure to consider the important Recommendations contained in the 2005 & 2008 National Institute of Standards & Technology (USA) Reports on the WTC 9-11 Incident in New York was an inexcusable and unforgivable technical oversight.
The result is a crassly inadequate, discriminatory and deeply flawed national fire safety standard in Great Britain & Northern Ireland. BS 9999:2008 became obsolete on the very day of its publication !
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Postscript
Please refer to our 1999 Submission to the Department of the Environment & Local Government, in Dublin, concerning the use of British Standard BS 5588:Part 8 in Ireland …
Following this Submission, our understanding is that an ‘Internal’ Working Party was established within the Department. However, the Working Party never reported. No proper response to this Submission has ever been received from the Minister or the Department.
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On 29th November 2006, similar and very polite comments were sent directly to the British Standards Institution (BSI) by e-mail. Receipt of this e-mail was never acknowledged by anyone in BSI.
2009-05-12: Or … in French: Personnes à Performances Réduites … a term which should be used much more often !
For many decades, the language of ‘disability’ has been all over the place, to put it mildly … others might suggest, however, that it lacks coherence, and is fragmented and chaotic ! As a result, it has been difficult to make any sort of solid progress on harmonization … at a technical level … in Europe.
Adopted on the 22nd May 2001, the World Health Organization’s International Classification of Functioning, Disability & Health (ICF), changed that situation for the better.It is important to emphasise that the ICF is a classification of ‘Health’ … not of ‘Disability’.
People with Activity Limitations (English) /
Personnes à Performances Réduites (French):
Those people, of all ages, who are unable to perform, independently and without aid, basic human activities or tasks – because of a health condition or physical/mental/cognitive/psychological impairment of a permanent or temporary nature.
This term includes …
–wheelchair users ;
–people who experience difficulty in walking, with or without 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, e.g. psychotropic drugs ;
–people who suffer any partial or complete loss of language related abilities, i.e. aphasia ;
–people impaired following exposure to environmental pollution and/or irresponsible human activity ;
and
–people who experience a panic attack in a fire situation or other emergency ;
–people, including firefighters, who suffer incapacitation as a result of exposure, during a fire, to poisonous or toxic substances, and/or elevated temperatures.
Anosognosia:
A neurological disorder marked by the inability of a person to recognize that he/she has an activity limitation or a health condition.
What is the big deal here ?
Because of the stigma which still attaches to ‘disability’ … and because some people are unable to recognise that they have an activity limitation or a health condition … depending on self-declaration, alone, for the purposes of developing suitable Fire Safety Management Procedures in a building (of any type) is a recipe for certain failure of those procedures.
And … of very direct relevance to design practice generally … compare the weak and inadequate definition of people with disabilities in Part M4 of the Irish Building Regulations (there is no reason to suspect that there will be an earth shattering improvement to this definition in the Revised Technical Guidance Document M … whenever it eventually sees the light of day !) … with the definition of disability in Irish Equality Legislation.
Chalk and Cheese !Or … from the ridiculous to the sublime !Check it out for yourself.
The consequence of this remarkable difference in definitions for anyone involved in the design and/or construction of a building is that … while they might very well be satisfying the Functional Requirements of Parts M and B in the Building Regulations … they will, more than likely, be still leaving the owner and the person who controls or manages the new building open to a complaint under our Equality Legislation.
In the case of Workplaces … truly brave is the person who will design a ‘place of work’ just to meet the minimal performance requirements of Building Regulations !
As a Rule of Thumb, therefore … architects, engineers, facility managers, construction organizations, etc, etc … should become more comfortable working with the concept of People with Activity Limitations.
This practical Rule of Thumb is also what lies behind the concept of Maximum Credible User Scenario, i.e. building user conditions which are severe, but reasonable to anticipate …
–the number of people using a building may increase, on occasions which cannot be specified, to 120% of calculated maximum building capacity ;and
–10% of people using the building (occupants, visitors and other users) may have an impairment (visual or hearing, physical function, mental, cognitive or psychological, with some impairments not being identifiable, e.g. in the case of anosognosia).
[ Please note well … that miserable piece of legislation … or, bureaucrats’ charter .. the 2005 Disability Act (Number 14 of 2005) … is irrelevant to the above discussion.But … when Irish Politicians, Senior Civil Servants and the National Disability Authority begin to take seriously the 2006 United Nations Charter on the Rights of Persons with Disabilities … the 2005 Act will have to be scrapped altogether and/or dramatically re-drafted ! ]
2009-05-04: At my request … Agenda Item #6 for the CIB W14 Meeting, recently held on the campus of Lund University in Sweden (see post: 2009-04-30), covered the following subject …
‘ 2005 & 2008 NIST Recommendations on WTC 9-11 Incident – Fundamental Implications for Fire Engineering Design & Practice ‘
I began the presentation by explaining that architects are frustrated people at the best of times …
[It is a never ending, soul-destroying struggle to faithfully realize an architectural ‘vision’ on a building site … especially in the absence of craftsmen/women and access to a wide range of well-designed, ‘approved’ construction products.]
… but, I have been intensely frustrated for some time … as a fire engineer … in particular, for the following reasons:
1.Negative, Irresponsible Attitude of European Lift Manufacturers
In order to effectively solve the issues of safe fire evacuation for people with activity limitations … and the timely evacuation of everyone in tall buildings … we must have lifts/elevators capable of being used for evacuation … all lifts/elevators … in all building types.This should be the norm … the standard specification.
Ever since 2003, however, when I was a Member of the European Union (EU) Expert Group on Accessibility, I have been pressing Mr. Luc Rivet, Secretary General of the European Lift Association (ELA) to ensure that the Association acts responsibly and makes this happen in Europe … now … not at any far distant point in the future.The time for ‘pretty’, meaningless talk at conferences, seminars and workshops has ended.
The ELA still refuses to act responsibly !
2.Crass Inadequacy of British Standard BS 9999 : 2008
Of interest to me … but not a cause for undue concern … except that far too many people in Ireland are already giving this Standard the status of Default Irish National Standard … and too many people in other countries are doing likewise …
On 31st October 2008, the British Standards Institute (BSI) published British Standard BS 9999 – Code of Practice for Fire Safety in the Design, Management and Use of Buildings.It took many years to draft this new national standard.
During all of that time, however, it is not clear to me that the simple idea of considering the Recommendations contained in the 2005 & 2008 NIST Reports on the WTC 9-11 Incident ever saw the light of day within the BSI Technical Committee which drafted BS 9999. The whole basis for the British Standard might have to be entirely re-examined … how awfully dreadful !?!
This amazing technical oversight has ensured that BS 9999 became inadequate on the very day that it was published.
Furthermore, although I had received assurances from certain people that British Standard 5588 : Part 8 would be properly incorporated into DD 9999 during the earlier stages of its development … in fact, this never happened.
Far too late in the drafting process, BS 5588 : Part 8 appears to have been shoe-horned into DD 9999.The resulting disability-related texts in the new Standard are vague … and represent a step backwards from BS 5588 : Part 8.And, there were many problems even with that earlier British Standard.
Finally, it has become blatantly obvious to me that nobody from BSI should ever again be allowed near the fire engineering terminology for any International or European Standards.BSI has polluted the international terminology of fire engineering.
Let me give you an irritating example which has had a seriously adverse impact on fire safety in buildings, in many countries, down through the years …
The term Fire Door has no meaning, and should not be used … Not Ever … Never !
It still leads to endless confusion on building sites … and very poor construction.It has been a disaster, in my own direct experience … and for everybody else associated with fire safety in buildings … including fire prevention officers in Local Authorities.
On the other hand, the term Fire Resisting Doorset / Shutter Assembly means:
‘ A doorset / shutter assembly, suitably installed or mounted on site, the function of which is to resist the passage of heat, smoke and flame for a specified time during a fire.’
A single concept … explained in simple language that anyone can understand.
I could go on about BSI and British Standards … but, I would rapidly bore myself to sleep !
Presentation at the CIB W14 Lund Meeting …
International Fire Engineering must – now – evolve as a direct result of the WTC 9-11 Incident in New York.This necessary evolution has been delayed for far too long by selfish vested interests.
And it is essential that an Empirical and Rational Basis is clearly identified for the practice of Fire Engineering Design in the 21st Century, i.e. after 9-11.Architects and Engineers, specifically, are desperately seeking reliable design guidance.
Colour image showing the Title Page (only) of CJ Walsh’s Presentation: ‘A Delayed Evolution in Fire Engineering ?’, at the recent CIB W14 Meeting in Lund, Sweden. Originally scheduled for 2 Days, all commission business was efficiently completed on 23rd April 2009. Click to enlarge.
The Recommendations of the 2005 & 2008 NIST Reports must, at the very least, be applied to the design of ‘High-Rise’, ‘Iconic’, ‘Critical Function’ & ‘Innovative Design’ Buildings.In a previous post, dated 2009-01-13, I had proposed that the Recommendations should generally be applied to High-Rise Buildings of more than 7 or 8 storeys and Iconic Buildings of more than 2 storeys. This is merely good fire engineering practice.
There are valuable lessons, from the NIST Reports, to be applied to the Fire Engineering Design of ALL buildings. This is demonstrated in the Lund Presentation … and, for any ‘Doubting Thomas’ out there, the collapse of WTC Building 7 makes this absolutely obvious.
For a more detailed discussion about the WTC 9-11 Incident and to download the 2005 & 2008 NIST Reports, please visit this Page on our Support WebSite …
Extensive content relating to other key words and phrases in the Lund Presentation can be found elsewhere on the Site.
Importance of the CIB W14 Lund Meeting …
The discussion which followed my Lund Presentation was lively and very interesting.This gave me an opportunity, throughout the rest of the meeting, to tweak the Proposed Future Work Programme of CIB W14 towards a more substantive consideration of the Recommendations from the 2 NIST Reports and the Continuing WTC Health Monitoring Studies.
Reluctantly … I will be the Project Leader for an International Team which will examine Fire-Induced Progressive Collapse over the next three years.
I will also be a Member of another Team which will examine Human Behaviour in Fire for a similar period.At the meeting, I indicated that I will be concentrating on Fire Evacuation for People with Activity Limitations (2001 WHO ICF).‘People with Activity Limitations’ is translated into French as ‘Personnes à Performances Réduites’.
Another Page on CIB W14 : Fire Engineering will soon be added to this Technical Blog.