Accessibility-for-All
NIST Recommendations 16-20 > Improved People Evacuation
Previous Posts in This Series …
2011-10-25: NIST’s Recommendations on the 9-11 WTC Building Collapses … GROUP 1. Increased Structural Integrity – Recommendations 1, 2 & 3 (out of 30)
2011-11-18: NIST WTC Recommendations 4-7 > Structural Fire Endurance … GROUP 2. Enhanced Fire Endurance of Structures – Recommendations 4, 5, 6 & 7
2011-11-24: NIST WTC Recommendations 8-11 > New Design of Structures … GROUP 3. New Methods for Fire Resisting Design of Structures – Recommendations 8, 9, 10 & 11
2011-11-25: NIST WTC Recommendations 12-15 > Improved Active Protection … GROUP 4. Improved Active Fire Protection – Recommendations 12, 13, 14 & 15
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2011-11-30: SOME PRELIMINARY COMMENTS …
1. In the First Post of this Series, I wrote …
” As such a high level of performance is expected … indeed demanded … of a Sustainable Building … Sustainable Fire Engineering must be ‘reliability-based’ … in other words, it must have a rational, empirical and scientifically robust basis … “
Sustainable Fire Engineering must also be ‘person-centred’ … i.e. a design process (in whatever architectural or engineering discipline) which places ‘real’ people at the centre of creative endeavours and gives due consideration to their responsible needs, and their health, safety, welfare and security in the Human Environment.
In order to prolong, and if at all possible, significantly extend the Life Cycle of a Sustainable Building beyond 100 years … Fire Engineers must begin to feel at ease … and be comfortable … with the following mainstream Sustainable Design Concepts …
Flexibility: The extent to which a building interior is designed, when new, to be capable of being easily modified at any later stage during the life cycle of that building – with minimal cost and user inconvenience – because of a person’s changing living or working needs.
Adaptability: The extent to which a building, or a building component, is designed when new, or capable of being easily modified at any later stage, to meet the changing life and living needs of the broad range of potential users, who may or may not have activity limitations, or may develop a health condition during the life cycle of that building or component.
Accessibility of a Building: Ease of independent approach, entry, egress (during normal ambient conditions), evacuation (in the event of an emergency) and/or use of a building and its services and facilities, by all of the building’s potential users - with an assurance of individual health, safety and welfare during the course of those activities.
2. Group 5 of the 2005 NIST WTC Recommendations is, by far, the most important … introducing some innovative concepts of ‘real’ evacuation … with nothing too startling. Contrary to the impression given by NIST … these Recommendations are equally valid for complex building types and, in reality, for all but the most simple of low-rise buildings. It is interesting to note, however, that when discussing fire behaviour or structural performance in fire, for example … the NIST texts are confident and direct. Here, when dealing with ‘people’ issues … not so confident, prone to some rambling … and lacking clarity.
Shortly after the 2005 NIST Report (NCSTAR 1) was published, I stated the following on the SDI Corporate WebSite … at this FireOx International Page … http://www.sustainable-design.ie/fire/structdesfire.htm …
” In its treatment of ‘disability’ and ‘people with activity limitations’, the Report does not go far enough, and is seriously flawed.”
Let me explain why …
As you go scan down through NIST’s Recommendations 16-20, you will encounter 1 reference to ‘mobility impaired occupants’ and 2 references to the impersonal ‘mobility impaired’. IF (and that is still a very big ‘if’, because there is still so much rabid resistance to this topic !) … a New Post-9/11 Evacuation Model, or Construct, Dealing with ‘Disability’ is being developed … all of the major impairment groupings (i.e. visual impairment, hearing impairment, physical function impairment, mental/cognitive impairment, and psychological impairment) must be added to the mix from the beginning. In other words, our proper focus of attention must be ‘people with activity limitations’ … not just people with disabilities, but also frail older people (not all older people !), children under the age of 5 years, women in the later stages of pregnancy, people with a health condition, etc.
And … because of the social stigma still firmly attaching to ‘disability’ … many building occupants/users will not self-identify … not even if their lives depend on it !
Concentrating on one group only, i.e. people with mobility impairments, is simplistic and entirely inadequate … and we will all end up, in a few years time, having to graft on a consideration of the other impairment groups.
This is exactly what has already gone wrong with the development of Accessibility Design Guidance during the last 30 years … where ‘people with visual or hearing impairments’ received merely token attention … and ‘people with cognitive or psychological impairments’ received no attention at all ! And … we are now grappling with the challenge of having to graft on additional texts to try to re-balance International Design Guidance on Accessibility of the Built Environment. Been there – done that – I have all of the t-shirts !!
People with Activity Limitations (English) / Personnes à Performances Réduites (French): Those people, of all ages, who are unable to perform, independently and without aid, basic human activities or tasks – because of a health condition or physical/mental/cognitive/psychological impairment of a permanent or temporary nature.
The above Terms (in English and French) include …
- wheelchair users ;
- people who experience difficulty in walking, with or without a facilitation aid, e.g. stick, crutch, calliper or walking frame ;
- frail, older people ;
- the very young (people under the age of 5 years) ;
- people who suffer from arthritis, asthma, or a heart condition ;
- the visually and/or hearing impaired ;
- people who have a cognitive impairment disorder, including dementia, amnesia, brain injury, or delirium ;
- women in the later stages of pregnancy ;
- people impaired following the use of alcohol, other ‘social’ drugs e.g. cocaine and heroin, and some medicines ;
- people who suffer any partial or complete loss of language related abilities, i.e. aphasia ;
- people impaired following exposure to environmental pollution and/or other irresponsible human activities, e.g. war and terrorism ;
and …
- people who experience a panic attack in a fire situation or other emergency ;
- people, including firefighters, who suffer incapacitation as a result of exposure, during a fire, to poisonous or toxic substances, and/or elevated temperatures.
3. So … what provision should be made for ‘people with activity limitations’ in typical Fire Engineering Design Projects ?
Equivalent to the concept of Maximum Credible Fire Scenario, which has already been discussed in this Series … at FireOx International, some years ago, we developed the concept of …
Maximum Credible User Scenario
Representing building user conditions which are also severe but reasonable to anticipate …
a) 10% of People Using the Building (occupants, visitors and other users) have an Impairment (visual or hearing, physical function, mental or cognitive, psychological, with some impairments not being identifiable) ;
[ This performance indicator appears in ISO FDIS 21542: 'Building Construction - Accessibility & Usability of the Built Environment', which will soon be published.]
b) The Number of People Using a Building increases, on occasions which cannot be specified, to 120% of designed/calculated maximum building capacity.
[ Generally ... the fire safety related texts contained in ISO 21542 are based on the 2005 & 2008 NIST WTC Recommendations.]
4. With regard to Recommendation 17 below, and NIST’s reference to the widths of evacuation staircases and door openings, etc … fire codes and regulations, fire authorities having jurisdiction (AHJ’s), and even the fire services themselves … still have a crazy mixed-up approach to defining the width of these building features … an approach which I am not even going to attempt to repeat ! Forget it !!
Without Exception … all understandings of Evacuation Route Width, Evacuation Staircase Width and Evacuation Door Opening Width … must be harmonized with the following definitions of Unobstructed Width …
Unobstructed Width – General
Free, unobstructed space – clear of all obstacles below a height of 2.1 metres above finished floor level – necessary for passage along a circulation route, or other route component, e.g. a staircase.
[ For example ... the Unobstructed Width of a Staircase is the clear dimension from the edge of one handrail to the edge of the opposite handrail ... and there is always a continuous handrail on each side of an evacuation staircase ! ]
Unobstructed Width – Door Opening
Free, unobstructed space – clear of all obstacles below a height of 2.0 metres above finished floor level – necessary for passage through a door opening, measured when the door leaf is opened to an angle of 90°, or when a sliding or folding door leaf is opened to its fullest extent.
[ For example ... the Unobstructed Width of a Door Opening is the dimension from the edge of the door leaf (when open at an angle of 90°) to the nearest edge of the door frame.]
This FireOx International Page on the SDI Corporate WebSite provides more guidance … http://www.sustainable-design.ie/fire/appendixd.htm
5. With regard to Recommendation 20 below, and NIST’s reference to allowing “all occupants an equal opportunity for evacuation” … this is not just a ‘nice idea’, or an ‘idealistic notion’ … this is now a Human and Social Right which is backed up and supported by International Law ! And … it is no longer acceptable for the Fire Science and Engineering Community to continue its stubborn resistance in the face of this fact !!
For the benefit of my fire engineering colleagues … I will, once again here, reproduce the most relevant extracts from the United Nations Convention on the Rights of Persons with Disabilities …
UN CRPD Preamble Paragraph (g)
Emphasizing the importance of mainstreaming disability issues as an integral part of relevant strategies of sustainable development, …
UN CRPD Article 9 – Accessibility
1. To enable persons with disabilities to live independently and participate fully in all aspects of life, States Parties shall take appropriate measures to ensure to persons with disabilities access, on an equal basis with others, to the physical environment, to transportation, to information and communications, including information and communications technologies and systems, and to other facilities and services open or provided to the public, both in urban and in rural areas. These measures, which shall include the identification and elimination of obstacles and barriers to accessibility, shall apply to, inter alia:
(a) Buildings, roads, transportation and other indoor and outdoor facilities, including schools, housing, medical facilities and workplaces ;
(b) Information, communications and other services, including electronic services and emergency services.
2. States Parties shall also take appropriate measures:
(a) To develop, promulgate and monitor the implementation of minimum standards and guidelines for the accessibility of facilities and services open or provided to the public ;
(b) To ensure that private entities that offer facilities and services which are open or provided to the public take into account all aspects of accessibility for persons with disabilities ;
(c) To provide training for stakeholders on accessibility issues facing persons with disabilities ;
(d) To provide in buildings and other facilities open to the public signage in Braille and in easy to read and understand forms ;
(e) To provide forms of live assistance and intermediaries, including guides, readers and professional sign language interpreters, to facilitate accessibility to buildings and other facilities open to the public ;
(f) To promote other appropriate forms of assistance and support to persons with disabilities to ensure their access to information ;
(g) To promote access for persons with disabilities to new information and communications technologies and systems, including the Internet ;
(h) To promote the design, development, production and distribution of accessible information and communications technologies and systems at an early stage, so that these technologies and systems become accessible at minimum cost.
UN CRPD Article 11 – Situations of Risk & Humanitarian Emergencies
States Parties shall take, in accordance with their obligations under international law, including international humanitarian law and international human rights law, all necessary measures to ensure the protection and safety of persons with disabilities in situations of risk, including situations of armed conflict, humanitarian emergencies and the occurrence of natural disasters.
[ Note: An outbreak of fire in a building is a situation of serious risk for all vulnerable building occupants/users.]
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At the time of writing, 153 Countries had signed the UN CRPD … while 106 Countries have ratified the Convention and are, therefore, the ‘State Parties’ referred to above.
These are just a few of the State Parties to the UN CRPD …
- Argentina (ratified the UN CRPD, 2008-09-02)
- Australia (ratified the UN CRPD, 2008-07-17)
- Brazil (ratified the UN CRPD, 2008-08-01)
- Canada (ratified the UN CRPD, 2010-03-11)
- China (ratified the UN CRPD, 2008-08-01)
- Cuba (ratified the UN CRPD, 2007-09-06)
- European Union (ratified the UN CRPD, 2010-12-23)
- India (ratified the UN CRPD, 2007-10-01)
- Malaysia (ratified the UN CRPD, 2010-07-19)
- Mexico (ratified the UN CRPD, 2007-12-17)
- Philippines (ratified the UN CRPD, 2008-04-15)
- South Africa (ratified the UN CRPD, 2007-11-30)
- Turkey (ratified the UN CRPD, 2009-09-28)
- United Arab Emirates (ratified the UN CRPD, 2010-03-19)
I wonder how implementation is proceeding in these countries !?!
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2005 NIST WTC RECOMMENDATIONS
GROUP 5. Improved Building Evacuation
Building evacuation should be improved to include system designs that facilitate safe and rapid egress, methods for ensuring clear and timely emergency communications to occupants, better occupant preparedness regarding their roles and duties for evacuation during emergencies, and incorporation of appropriate egress technologies.*
[ * F-36 This effort should include standards and guidelines for the development and evaluation of emergency evacuation plans, including best practices for both partial and full evacuation, and the development of contingency plans that account for expected conditions that may require adaptation, including the compromise of all or part of an egress path before or during evacuation, or conditions such as widespread power failure, earthquake, or security threat that restrict egress from the building. Evacuation planning should include the process from initial notification of the need to evacuate up to the point when occupants arrive at a place where their safety is ensured. These standards and guidelines should be suitable for assessing the adequacy of evacuation plans submitted for approval, and should require occupant training through the conduct of regular drills.]
NIST WTC Recommendation 16.
NIST recommends that public agencies, non-profit organizations concerned with building and fire safety, and building owners and managers develop and carry out public education and training campaigns, jointly and on a nationwide scale, to improve building occupants’ preparedness for evacuation in case of building emergencies. This effort should include better training and self-preparation of occupants, an effectively implemented system of floor wardens and building safety personnel, and needed improvements to standards. Occupant preparedness should include:
a. Improved training and drills for building occupants to ensure that they know evacuation procedures for a variety of emergency scenarios (e.g. including evacuation and shelter in place), are familiar with the egress route, and are sufficiently aware of what is necessary if evacuation is required with minimal notice (e.g. footwear consistent with the distance to be travelled, a flashlight/glow stick for pathway illumination, and dust masks).
b. Building owners and managers should educate tenants on the life safety systems present in their building(s), provide training materials explaining egress routes and stairwell and elevator information, and develop educational programmes explaining the most appropriate responses in emergency situations. It is further recommended that the owners and managers of office buildings implement the necessary systems for collecting and storing the training history of each building occupant.
c. Improved training and drills that routinely inform building occupants that roof rescue is not (or is) presently feasible as a standard evacuation option, that they should evacuate down the stairs in any full-building evacuation unless explicitly instructed otherwise by on-site incident commanders, and that elevators can be used if they are still in service and haven’t been recalled or stopped.
d. Improved codes, laws, and regulations that do not restrict or impede building occupants during evacuation drills from familiarizing themselves with the detailed layout of alternative egress routes for a full building evacuation.*
[ * F-37 New York City Local Law 5 prohibits requiring occupants to practice stairwell evacuation during drills.]
Affected Standard: ICC/ANSI A117-1. Model Building and Fire Codes: The standard should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard. Affected Organizations: NFPA, NIBS, NCSBCS, BOMA, and CTBUH.
NIST WTC Recommendation 17.
NIST recommends that tall buildings be designed to accommodate timely full building evacuation of occupants when required in building-specific or large-scale emergencies such as widespread power outages, major earthquakes, tornadoes, hurricanes without sufficient advance warning, fires, explosions, and terrorist attack. Building size, population, function, and iconic status should be taken into account in designing the egress system. Stairwell capacity and stair discharge door opening width* should be adequate to accommodate contraflow due to emergency access by responders.
[ * F-38 Egress capacity should be based on an all-hazards approach that considers the number and width of stairs (and door openings) as well as the possible use of scissor stairs credited as a single stair.]
a. Improved egress analysis models, design methodology, and supporting data should be developed to achieve a target evacuation performance (e.g. time for full building evacuation*) for the design building population by considering the building and egress system designs, and human factors such as occupant size, mobility status, stairwell tenability conditions, visibility, and congestion.
[ * F-39 Use of egress models is required to estimate the egress capacity for a range of different evacuation strategies, including full building evacuation. NIST found that the average surviving occupant in the WTC towers descended stairwells at about half the slowest speed previously measured for non-emergency evacuations.]
b. To the degree possible, mobility impaired occupants should be provided a means for self-evacuation in the event of a building emergency. Current strategies (and law) generally require the mobility impaired to shelter in place. New procedures, which provide redundancy in the event that the floor warden system or co-worker assistance (i.e. a buddy system) fails, should consider full building evacuation, and may include use of fire-protected and structurally hardened elevators,* motorized evacuation technology (e.g. a battery-operated evacuation chair), and/or dedicated communication technologies for the mobility impaired.
[ * F-40 Elevators should be explicitly designed to provide protection against large, but conventional, building fires. Fire-protected elevators also should be structurally hardened to withstand the range of foreseeable building-specific or large-scale emergencies. While progress has been made in developing the requirements and technologies for fire-protected elevators, similar criteria and designs for structurally hardened elevators remain to be developed.]
c. If protected/hardened elevators are provided for emergency responders but become unusable during an emergency, due to a malfunction or a conventional threat whose magnitude exceeds the magnitude considered in design, sufficient stairwell capacity should be provided to ensure timely emergency responder access to buildings that are undergoing full evacuation. Such capacity could be provided either via dedicated stairways for fire service use or by building sufficient stairway capacity (i.e. number and width of stairways and/or use of scissor stairs credited as a single stair) to accommodate the evacuation of building occupants while allowing access to emergency responders with minimal hindrance from occupant contraflow.
d. The egress allowance in assembly use spaces should be limited in state and local laws and regulations to no more than a doubling of the stairway capacity for the provision of a horizontal exit on a floor, as is the case now in the national model codes.* The use of a horizontal exit creates an area of refuge with a 2 hour fire rated separation, at least one stair on each side, and sufficient space for the expected occupant load.
[ * F-41 The New York City Building Code permits a doubling of allowed stair capacity when one area of refuge is provided on a floor, and a tripling of stair capacity for two or more areas of refuge on a floor. In the world after 11 September 2001, it is difficult to predict: (1) if, and for how long, occupants will be willing to wait in a refuge area before entering an egress stairway; and (2) what the impact would be of such a large group of people moving down the stairs on the orderly evacuation of lower floors.]
Affected Standards: NFPA 101, ASME A 17. Model Building and Fire Codes: The standards should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard.
NIST WTC Recommendation 18.
NIST recommends that egress systems be designed: (1) to maximize remoteness of egress components (i.e. stairs, elevators, exits) without negatively impacting on average travel distances; (2) to maintain their functional integrity and survivability under foreseeable building-specific or large-scale emergencies; and (3) with consistent layouts, standard signage, and guidance so that systems become intuitive and obvious to building occupants during evacuations.
a. Within a safety-based design hierarchy that should be developed, highest priority should be assigned to maintain the functional integrity, survivability, and remoteness of egress components and active fire protection systems (sprinklers, standpipes, associated water supply, fire alarms, and smoke management systems). The design hierarchy should consider the many systems (e.g. stairs, elevators, active fire protection, mechanical, electrical, plumbing, and structural) and system components, as well as functional integrity, tenant access, emergency responder access, building configuration, security, and structural design.
b. The design, functional integrity, and survivability of the egress and other life safety systems (e.g. stairwell and elevator shafts, and active fire protection systems) should be enhanced by considering accidental structural loads such as those induced by overpressures (e.g. gas explosions), impacts, or major hurricanes and earthquakes, in addition to fire separation requirements. In selected buildings, structural loads due to other risks such as those due to terrorism may need to be considered. While NIST does not believe that buildings should be designed for aircraft impact, as the last line of defence for life safety, the stairwells and elevator shafts individually, or the core if these egress components are contained within the core, should have adequate structural integrity to withstand accidental structural loads and anticipated risks.
c. Stairwell remoteness requirements should be met by a physical separation of the stairwells that provide a barrier to both fire and accidental structural loads. Maximizing stairwell remoteness, without negatively impacting on average travel distances, would allow a stairwell to maintain its structural integrity independent of any other stairwell that is subject to accidental loads, even if the stairwells are located within the same structural barrier such as the core. The current ‘walking path’ measurement allows stairwells to be physically next to each other, separated only by a fire barrier. Reducing the clustering of stairways that also contain standpipe water systems provides the fire service with increased options for formulating firefighting strategies. This should not preclude the use of scissor stairs* as a means of increasing stair capacity – provided the scissor stair is only credited as a single stair.
[ * F-42 Two separate stairways within the same enclosure and separated by a fire rated partition.]
d. Egress systems should have consistent layouts with standard signage and guidance so that the systems become intuitive and obvious to all building occupants, including visitors, during evacuations. Particular consideration should be given to unexpected deviations in the stairwells (e.g. floors with transfer hallways).
Affected Standard: NFPA 101. Model Building and Fire Codes: The standard should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard.
NIST WTC Recommendation 19.
NIST recommends that building owners, managers, and emergency responders develop a joint plan and take steps to ensure that accurate emergency information is communicated in a timely manner to enhance the situational awareness of building occupants and emergency responders affected by an event. This should be accomplished through better co-ordination of information among different emergency responder groups, efficient sharing of that information among building occupants and emergency responders, more robust design of emergency public address systems, improved emergency responder communication systems, and use of the Emergency Broadcast System (now known as the Integrated Public Alert and Warning System) and Community Emergency Alert Networks.
a. Situational awareness of building occupants and emergency responders in the form of information and event knowledge should be improved through better co-ordination of such information among emergency responder groups (9-1-1 dispatch, fire department or police department dispatch, emergency management dispatch, site security, and appropriate federal agencies), efficient sharing and communication of information between building occupants and emergency responders, and improved emergency responder communication systems (i.e. including effective communication within steel and reinforced concrete buildings, capacity commensurate with the scale of operations, and interoperability among different communication systems.
b. The emergency communications systems in buildings should be designed with sufficient robustness and redundancy to continue providing public address announcements or instructions in foreseeable building-specific or large-scale emergencies, including widespread power outage, major earthquakes, tornadoes, hurricanes, fires, and accidental explosions. Consideration should be given to placement of building announcement speakers in stairways in addition to other standard locations.
c. The Integrated Public Alert and Warning System (IPAWS) should be activated and used, especially during large-scale emergencies, as a means to rapidly and widely communicate information to building occupants and emergency responders to enhance their situational awareness and assist with evacuation.
d. Local jurisdictions (cities and counties or boroughs) should seriously consider establishing a Community Emergency Alert Network (CEAN), within the framework of IPAWS, and make it available to the citizens and emergency responders of their jurisdictions to enhance situational awareness in emergencies.* The network should deliver important emergency alerts, information and real time updates to all electronic communication systems or devices registered with the CEAN. These devices may include e-mail accounts, cell/mobile phones, text pagers, satellite phones, and wireless PDA’s.
[ * F-43 Types of emergency communications could include life safety information, severe weather warnings, disaster notifications (including information on terrorist attacks), directions for self-protection, locations of nearest available shelters, precautionary evacuation information, identification of available evacuation routes, and accidents or obstructions associated with roadways and utilities.]
Affected Standard: NFPA 101, and/or a new standard. Model Building and Fire Codes: The standard should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard to the extent it is within the scope of building and fire codes.
NIST WTC Recommendation 20.
NIST recommends that the full range of current and next generation evacuation technologies should be evaluated for future use, including protected/hardened elevators, exterior escape devices, and stairwell descent devices, which may allow all occupants an equal opportunity for evacuation and facilitate emergency response access. Affected Standards: NFPA 101, ASME A 17, ASTM E 06, ANSI A117.1. Model Building and Fire Codes: The standards should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard.
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Accessible Toilet Room in a Japanese Public Place – Kanazawa
2011-11-28: Further to my post, dated 20 October 2010 …
A valuable and essential facility in the grounds of Kanazawa Castle, Japan … entered directly from the exterior … is this Accessible Toilet Room / WC / Bathroom / Hygiene Room / Rest Room / Sanitary Room (whichever term you are familiar with) provided for public use. There is no attendant permanently present, and no camera surveillance of the external entrance area. However, it is regularly cleaned and properly maintained during the Castle’s opening hours.
Colour photograph showing Kanazawa Castle and its grounds, in Japan. Photograph by CJ Walsh. 2010-04-27. Click to enlarge.
The following photographs show a far more ‘developed’, ‘civilized’ and ‘person-centred’ approach to the design and fit-out of these public facilities (quite common in Japan) … than here in Europe.
Real Accessibility-for-All in action … with no messing around …
Colour photograph showing a Public Toilet Room in the grounds of Kanazawa Castle, Japan ... which is Accessible-for-All. Photograph by CJ Walsh. 2010-04-27. Click to enlarge.
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Colour photograph showing a Public Toilet Room in the grounds of Kanazawa Castle, Japan ... which is Accessible-for-All. Photograph by CJ Walsh. 2010-04-27. Click to enlarge.
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Colour photograph showing a Public Toilet Room in the grounds of Kanazawa Castle, Japan ... which is Accessible-for-All. Photograph by CJ Walsh. 2010-04-27. Click to enlarge.
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Colour photograph showing a Public Toilet Room in the grounds of Kanazawa Castle, Japan ... which is Accessible-for-All. Photograph by CJ Walsh. 2010-04-27. Click to enlarge.
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Colour photograph showing a Public Toilet Room in the grounds of Kanazawa Castle, Japan ... which is Accessible-for-All. Photograph by CJ Walsh. 2010-04-27. Click to enlarge.
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Colour photograph showing a Public Toilet Room in the grounds of Kanazawa Castle, Japan ... which is Accessible-for-All. Detailed view of toilet controls and accessories. Photograph by CJ Walsh. 2010-04-27. Click to enlarge.
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NIST WTC Recommendations 12-15 > Improved Active Protection
Previous Posts in This Series …
2011-10-25: NIST’s Recommendations on the 9-11 WTC Building Collapses … GROUP 1. Increased Structural Integrity – Recommendations 1, 2 & 3 (out of 30)
2011-11-18: NIST WTC Recommendations 4-7 > Structural Fire Endurance … GROUP 2. Enhanced Fire Endurance of Structures – Recommendations 4, 5, 6 & 7
2011-11-24: NIST WTC Recommendations 8-11 > New Design of Structures … GROUP 3. New Methods for Fire Resisting Design of Structures – Recommendations 8, 9, 10 & 11
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2011-11-25: SOME PRELIMINARY COMMENTS …
1. Reliability has always been an issue with Active Fire Protection Systems … but, it is neither acknowledged, nor fully understood, that … Reliability Is Equally An Issue With Passive Fire Protection Measures !
Furthermore, the following should always be taken into account when considering the Safety Factors to be applied in calculating the level of satisfactory fire safety and protection which is provided in a specific project … one of the design objectives in Ethical Fire Engineering.
For example, if Category C below is indicative of the design and construction quality on a particular building site … just think of the Priory Hall Apartment Development in Dublin (!) … the Safety Factors to be applied in the design should be high … and with regard to actual construction, it should be expected that the Reliability of both Active Fire Protection Systems and Passive Fire Protection Measures will be initially low … with Life Cycle Reliability being entirely non-existent.
Quality of Fire Engineering Design & Related Construction
Category A
(a) Design of the works is exercised by an independent, appropriately qualified and experienced architect/engineer/fire engineer, with design competence relating to fire safety and protection in buildings ;
(b) Installation/fitting of related construction products/systems is exercised by appropriately qualified and experienced personnel, with construction competence relating to fire safety and protection in buildings ;
(c) Supervision of the works is exercised by appropriately qualified and experienced personnel from the principal construction organization ;
(d) Regular inspections, by appropriately qualified and experienced personnel familiar with the design, and independent of the construction organization(s), are carried out to verify that the works are being executed in accordance with the fire engineering design.
Category B
(a) Design of the works is exercised by an independent, appropriately qualified and experienced architect/engineer/fire engineer ;
(b) Installation/fitting of fire-related construction products/systems is exercised by appropriately qualified and experienced personnel ;
(c) Supervision of the works is exercised by appropriately qualified and experienced personnel from the principal construction organization.
Category C
This level of design and construction execution is assumed when the requirements for Category A or Category B are not met.
2. With regard to Recommendations 12 & 13 below … in an earlier post in this series, and elsewhere, I have defined Disproportionate Damage … and differentiated that structural concept from the related concept of Fire-Induced Progressive Collapse.
A significant number of countries include a requirement on Resistance to Disproportionate Damage in their national building codes. Often, it is only necessary to consider this requirement in the case of buildings having 5 Storeys, or more … a completely arbitrary height threshold. I would consider that adequately tying together the horizontal and vertical structural elements of a building … any building … is a fundamental principle of good structural engineering !!
Putting it simply … for the purpose of showing compliance with this structural requirement … it is necessary to demonstrate that a building will remain structurally stable if a portion of the building’s structure is removed … always remembering that every building comprises both structure and fabric, i.e. non-structure.
In reality this may happen, and quite often does happen, when, for example, a large truck runs into the side of a building, which can happen anywhere … or there is a gas explosion in some part of the building, which happened in Dublin’s Raglan House back in 1987, and many times in other countries … or a plane hits a high-rise building, which happened to Milan’s iconic Pirelli Tower in 2002, and to New York’s Empire State Building way back in 1945 … etc., etc. Raglan House collapsed … the Pirelli Tower and the Empire State Building did not.
[ The World Trade Center Towers were originally designed to absorb the impact of a large plane and to remain structurally stable afterwards ... in ambient conditions. However, what was not considered in the ambient structural design was 'fire', i.e. the fuel tanks were empty and no fire in the building would be initiated as a result of the mechanical damage caused by the plane impact ... which, on 11 September 2001, proved to be a ridiculous basis for any structural design ! This is why 9-11 should be regarded, at its core, as being a very serious 'real' fire incident.]
What I am leading up to is this … the concept of removing a portion of a building, and it remaining structurally stable afterwards … should now – logically and rationally – also be incorporated into the fire engineering design of Active Fire Protection Systems. In other words, if a portion of a building is removed, will any particular Active Fire Protection System continue to operate effectively in the rest of the building ? This has implications for the location and adequate protection of critical system components in a building … and for the necessary redundancy, zoning and back-up alternative routeing which must be designed into the system from the beginning !
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2005 NIST WTC RECOMMENDATIONS
GROUP 4. Improved Active Fire Protection
Active fire protection systems (i.e. sprinklers, standpipes/hoses, fire alarms, and smoke management systems) should be enhanced through improvements to the design, performance, reliability, and redundancy of such systems.
NIST WTC Recommendation 12.
NIST recommends that the performance and possibly the redundancy of active fire protection systems (sprinklers, standpipes/hoses, fire alarms, and smoke management systems) in buildings be enhanced to accommodate the greater risks associated with increasing building height and population, increased use of open spaces, high-risk building activities, fire department response limits, transient fuel loads, and higher threat profile. The performance attributes should deal realistically with the system design basis, reliability of automatic/manual operations, redundancy, and reduction of vulnerabilities due to single point failures. Affected Standards: NFPA 13, NFPA 14, NFPA 20, NFPA 72, NFPA 90A, NFPA 92A, NFPA 92B, and NFPA 101. Model Building Codes: The performance standards should be adopted in model building codes by mandatory reference to, or incorporation of, the latest edition of the standard.
NIST WTC Recommendation 13.
NIST recommends that fire alarm and communications systems in buildings be developed to provide continuous, reliable, and accurate information on the status of life safety conditions at a level of detail sufficient to manage the evacuation process in building fire emergencies; all communication and control paths in buildings need to be designed and installed to have the same resistance to failure and increased survivability above that specified in present standards. This should include means to maintain communications with evacuating occupants that can both reassure them and redirect them if conditions change. Pre-installed fire warden telephone systems can serve a useful purpose and may be installed in buildings and, if so, they should be made available for use by emergency responders. All communication and control paths in buildings need to be designed and installed to have the same resistance to failure and increased survivability above that specified in present standards. Affected Standards: NFPA 1, NFPA 72, and NFPA 101. Model Building and Fire Codes: The performance standards should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard.
NIST WTC Recommendation 14.
NIST recommends that control panels at fire/emergency command stations in buildings be adapted to accept and interpret a larger quantity of more reliable information from the active fire protection systems that provide tactical decision aids to fire ground commanders, including water flow rates from pressure and flow measurement devices, and that standards for their performance be developed. Affected Standards: NFPA 1, NFPA 72, and NFPA 101. Model Building and Fire Codes: The performance standards should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard.
NIST WTC Recommendation 15.
NIST recommends that systems be developed and implemented for: (1) real time off-site secure transmission of valuable information from fire alarm and other monitored building systems for use by emergency responders, at any location, to enhance situational awareness and response decisions, and maintain safe and efficient operation;* and (2) preservation of that information either off-site, or in a black box that will survive a fire or other building failure, for purposes of subsequent investigations and analysis. Standards for the performance of such systems should be developed, and their use should be required. Affected Standards: NFPA 1, NFPA 72, and NFPA 101. Model Building and Fire Codes: The performance standards should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard.
[ * F-35 The alarm systems in the WTC towers were only capable of determining and displaying: (a) areas that had at some time reached alarm point conditions; and (b) areas that had not. The quality and reliability of information available to emergency responders at the Fire Command Station was not sufficient to understand the fire conditions. The only information transmitted outside the buildings was the fact that the buildings had gone into alarm. Further, the fire alarm system in WTC Building 7, which was transmitted to a monitoring service, was on 'test mode' during the morning of 11 September 2001, because routine maintenance was being performed. Under test mode conditions: (1) the system is typically disabled for the entire building, not just for the area where work is being performed; and (2) alarm signals typically do not show up on an operator console.]
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‘Greening’ Ireland’s Economy – Will Somebody Please Get Real ?
2011-11-21: The International Labour Office (ILO), in Geneva, and the European Union’s Centre for the Development of Vocational Training (CEDEFOP) … have recently published a Joint Report: ‘Skills for Green Jobs – A Global View’ …
ILO – EU CEDEFOP
‘Skills for Green Jobs – A Global View’ (a synthesis report based on 21 country reports)
Click the Link Above to read and/or download PDF File (5.3 Mb)
The vision is positive … its advice is practical … and the writers actually sound as if they know what they are talking about. And it is evident that the word ‘green’ is used, in this Report, as a simple means of communicating the far more complex concept of ‘sustainable human and social development’, with all of its many different aspects. Judge for yourself by reading the extract from the Executive Summary below.
This Report’s contents also complement, very neatly, what has been said here in many posts … concerning the institutional infrastructure necessary, in societies, to properly implement an effective response to policies of energy conservation and security, climate change and sustainable development.
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WAYS FORWARD [ Pages xxiv to xxvi, Executive Summary, ILO - EU CEDEFOP Report: 'Skills for Green Jobs - A Global View' ]
It is important to remember that skills are not a poor servant of the economy, expected merely to react and adjust to any change. The availability of a suitably trained workforce capable of further learning inspires confidence that in turn encourages investment, technical innovation, economic diversification and job creation.
Policies Need to be Informed, Coherent and Co-Ordinated
When policies to green the economy and policies to develop skills are not well connected, skill bottlenecks will slow the green transformation, and potential new jobs will be lost. Strategic, leadership and management skills that enable policy-makers in governments, employers’ associations and trade unions to set the right incentives and create enabling conditions for cleaner production and services are an absolute priority.
Environmental awareness as an integral part of education and training at all levels, introduced as a core skill from early childhood education onwards, will eventually push consumer behaviour and preferences and the market itself.
Labour market information for anticipating and monitoring skill needs for green jobs is the critical starting point for effective policy cycles. This enables governments and businesses to anticipate changes in the labour market, identify the impact on skill requirements, incorporate changes into the system by revising training programmes and introducing new ones, and monitor the impact of training on the labour market.
The country studies that told the most successful stories prove the value of effective co-ordination among line ministries and social partners, achieved by creating task forces for human resource development for a greening economy, or by incorporating training and skills issues into a council for environmental development. It is important that the platform for this dialogue has decision-making authority, can establish clear commitments among all those partners involved and allocate human and financial resources to them, and has agreed responsibilities not only for planning but for implementation. A win–win situation can only be achieved if environment, jobs and skills are discussed, planned and implemented in conjunction with each other.
Decentralized approaches can actually promote policy co-ordination and coherence at sectoral and local levels. Direct dialogue between national and regional governments and social partners can be translated into action when commitments and resource allocation occur at a smaller scale and where immediate dividends are obvious for all partners involved. A good combination of top-down co-ordinated policy-making with bottom-up sectoral or local initiatives can support effective training-intensive green transitions.
Policies Need to be Targeted
The transformation to greener economies provides an opportunity to reduce social inequalities. Social justice dictates that training initiatives target those who lose jobs during the transition, especially those who are typically at a disadvantage in the labour market and may require special assistance. The growth dividend from greening the economy will be attained only if access to new training provided as part of green measures is made accessible to disadvantaged youth, persons with disabilities, rural communities and other vulnerable groups. Incentives to increase women’s participation in technical training programmes will not only increase their participation in technology-driven occupations but also help solve the skill shortage problem in this segment of the labour market.
Green Transitions Affect the Entire Training System
Taking into account all three types of skills change – that resulting from employment shifts within and across sectors as the consequence of green restructuring, that associated with new and emerging occupations, and the massive change in the content of established occupations – it becomes clear that the whole training system must be mobilized. Adjusting training programmes to green changes in the labour market is a transversal task across levels and types of education and training.
So far, compulsory level and tertiary education have been catching up rather well, whereas technical and vocational education and training has been lagging behind in adapting to the needs of the green economy. Improving adjustment here can give new impetus to employment-centred and fair green transitions and requires the following key challenges to be met:
- Putting basic skills high on the policy agenda, as a foundation of flexibility and employability throughout the life cycle ;
- Matching classroom and practical training through apprenticeships, internships, job placements, projects on the job etc ;
- Adjusting the length and breadth of training provision according to different types of skills change ;
- Equipping teachers and trainers with up-to-date knowledge on environmental issues and on green technologies – education and training which deals with preparation of teachers and trainers should be one of the first priorities in skills response strategies ;
- Enabling active labour market policy measures (ALMP’s) to take into account green structural change and to provide access to relevant training and other employment activation measures ; and
- Deploying public employment services (PES), as important players in job matching and training, to raise awareness about green business opportunities and related skill needs.
The linchpin of effective skills development for greening the economy is co-ordination. The degree of co ordination between public and private stakeholders and the degree of involvement of social partners are decisive. Concerted measures need to be undertaken by governments at different levels, including the community level, employers and workers, through institutional mechanisms of social dialogue, such as national or regional tripartite councils, sector or industry skills councils, public–private partnerships and the like.
Developing Countries Need Special Measures
Developing countries, and the workers and employers in them, have the least responsibility for climate change and environmental degradation but suffer their economic and social consequences disproportionately. Special measures that can speed their employment-centred green transformations include:
- capacity building for employers in the informal economy and micro- and small enterprises to enter green markets in localities where they are most needed ;
- entrepreneurship training and business coaching for young people and adults to start up green businesses in conjunction with micro-finance projects ;
- environmental awareness among decision-makers, business leaders and administrators as well as institutions of formal and non-formal training systems ;
- capacity building of tripartite constituents to strengthen social dialogue mechanisms and to apply these to dialogue about accessibility of training for green jobs ; and
- increased capacity of formal education and training systems and institutions to provide basic skills for all and to raise the skills base of the national workforce ; this includes improving apprenticeship systems and building synergies with NGO’s that provide education and training.
These measures can only be taken if resources are available. It is therefore recommended that not only national governments but also international partnerships in developing countries take these recommendations into account both in environment programmes and in skills development programmes.
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‘GREENING’ IRELAND’s ECONOMY ?
Ireland was not one of the countries examined in the ILO / EU CEDEFOP Project. That should tell us a lot !
BUT … just pause for a moment … and meditate on the many skill-related issues arising from the debacle at the Priory Hall Apartment Development, in Dublin.
AND NOW … read the following extracts from recent Irish National Reports … ‘high notions’ from goats in the Kerry Mountains …
The Overarching Vision – Forfás Report: ‘Future Skills Needs of Enterprise within the Green Economy in Ireland’ (November 2010) …
” For Ireland to be the benchmark ‘smart green’ economy for population centres under 20 million by 2015 – and to have the skills base and talent to drive innovative and high value products and services and maximise future business and employment growth potential.”
Final Paragraphs, #7 Conclusions – Review of National Climate Policy (November 2011) …
” In the wider-international context, there are also encouraging signs of a new ‘green growth’ paradigm which emphasises resource efficiency, the protection of natural resources and competitiveness along with the creation of new jobs. A long-term view of how Ireland aligns its economic development with the demands of the growth engines of global commerce should be at the core of a low-carbon development vision. In order to create enabling conditions for selling into these markets, many of which are already gearing up for the green economy, it will be necessary to ensure that the domestic conditions are right to encourage innovation. This can be done by showing environmental ambition and using tools that allow the market to identify solutions. That will require a combination of taking the best of what is working in other countries as well as devising domestically appropriate policies that will place Ireland in the vanguard of countries making the most of the opportunities presented by the green economy.
In terms of a long-term national vision of a carbon-constrained world, Ireland is faced with both the challenge of addressing a unique greenhouse gas emissions profile and the opportunity to position itself as an enlightened society with an environmentally sustainable and competitive, low-carbon economy. Developing the policies to put Ireland on a clear and definite path to achieve that vision is the immediate priority.”
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Who Are These Moráns ?!? Will Somebody Please Get Real !?!
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Corporate Social Responsibility – Updated EU Strategy 2011-14
2011-11-15: The European Commission, in Brussels, recently published a New European Union Policy Document on Corporate Social Responsibility (CSR) … COM(2011) 681 final – Brussels, 2011-10-25.
To access this document … just go down to the EUR-Lex Link on the right hand side of this Page.
The Updated EU CSR Strategy for 2011-2014 signals an important change of direction … more a re-balancing of emphasis … which enterprises, of all sizes, should immediately be aware of … and whether or not these enterprises are located within Europe … or outside, as far away as China, India, Japan, South Africa, the USA or Brazil, etc.
The Updated CSR Strategy also confirms how the merging of the different and interrelated aspects of Sustainable Human & Social Development, i.e. social, economic, environmental, institutional, political and legal … is progressing nicely, and gathering some momentum. We have discussed this issue here many times … and promoted it elsewhere in our work, particularly during the last decade. How time flies !
[ In this last regard, reference should also be made to the United Nations Development Programme (UNDP) 2011 Human Development Report: 'Sustainability and Equity - A Better Future for All', which was launched in Copenhagen on 2 November 2011.]
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A New Definition for Corporate Social Responsibility (CSR) …
The European Commission puts forward a new definition of CSR as ‘the responsibility of enterprises for their impacts on society’.
Respect for applicable legislation and for collective agreements between social partners are prerequisites for meeting that responsibility. To fully meet their corporate social responsibility, enterprises should have in place a process to integrate social - environmental - ethical - human rights and consumer concerns into their business operations and core strategy in close collaboration with their stakeholders, with the aim of:
- maximising the creation of shared value for their owners/shareholders, and for their other stakeholders and society at large ;
- identifying, preventing and mitigating their possible adverse impacts.
The complexity of that process will depend on factors such as the size of the enterprise and the nature of its operations. For most small and medium-sized enterprises, especially micro-enterprises, the CSR Process is likely to remain informal and intuitive.
To maximise the creation of shared value, enterprises are encouraged to adopt a long-term, strategic approach to CSR, and to explore the opportunities for developing innovative products, services and business models that contribute to Social Wellbeing and lead to higher quality and more productive jobs.
To identify, prevent and mitigate their possible adverse impacts, large enterprises, and enterprises at particular risk of having such impacts, are encouraged to carry out risk-based due diligence, including through their supply chains.
Certain types of enterprise, such as co-operatives, mutuals, and family-owned businesses, have ownership and governance structures that can be especially conducive to responsible business conduct.
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The Updated EU CSR Strategy elaborates an Action Agenda for 2011-2014 …
1. Improving Company Disclosure of Social and Environmental Information: the new strategy confirms the European Commission’s intention to bring forward a new legislative proposal on this issue.
2. Enhancing Market Reward for CSR: this means leveraging EU Policies in the fields of consumption, investment and public procurement in order to promote market reward for responsible business conduct.
3. Enhancing the Visibility of CSR and Disseminating Good Practices: this includes the creation of a European award, and the establishment of sector-based platforms for enterprises and stakeholders to make commitments and jointly monitor progress.
4. Improving and Tracking Levels of Trust in Business: the European Commission will launch a public debate on the role and potential of enterprises, and organise surveys on citizen trust in business.
5. Better Aligning European and International Approaches to CSR: the European Commission highlights the following …
- OECD Guidelines for Multinational Enterprises ;
- 10 Principles of the UN Global Compact ;
- UN Guiding Principles on Business and Human Rights ;
- ILO Tri-Partite Declaration of Principles on Multinational Enterprises and Social Policy ;
- ISO 26000 Guidance Standard on Social Responsibility.
6. Further Integrating CSR into Education, Training and Research: the European Commission will provide further support for education and training in the field of CSR, and explore opportunities for funding more research.
7. Improving Self- and Co-Regulation Processes: the European Commission proposes to develop a short protocol to guide the development of future self- and co-regulation initiatives.
8. Emphasising the Importance of National and Sub-National CSR Policies: the European Commission invites EU Member States to present or update their own plans for the promotion of CSR by mid 2012.
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European Commission COM(2011) 681 final – Brussels, 2011-10-25 (PDF File, 136 kb)
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Sustainable Fire Engineering – IABSE Lecture 1 December 2011
2011-11-14 …
On Thursday evening, 1st December 2011, at 19.00 hrs … in the Dublin Institute of Technology … I will present an IABSE-Ireland Sponsored Lecture on the subject: ‘Sustainable Fire Engineering IS THE FUTURE !’.
This Presentation has been in continuous development across a snaking international path … Dubayy (UAE) in 2008 … Lund (Sweden) and Bengaluru (India) in 2009 … Dilli (India), Zurich (Switzerland) and Dublin (Ireland) in 2010 … Paris (France), the IFE’s International Fire Conference in Cardiff (Wales) and the ASFP-Ireland Fire Seminar in 2011 … and on 1 December next, in Dublin, I will be introducing some tough new realities for fire engineering generally … not just in Ireland …
Colour photograph showing the impact of witnessing the 9-11 WTC Incident in New York. Sustainable Fire Engineering must be 'reliability-based' & 'person-centred'. But ... do building designers, including fire engineers, actually understand that the people who use their buildings are 'individuals' ... each having a different range of abilities ? Photograph by Marty Lederhandler/AP. Click to enlarge.
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IABSE Irish National Group Sponsored Lecture
Dublin Institute of Technology, Bolton Street – Michael O’Donnell Room (259)
Thursday, 1 December 2011 @ 19.00 hrs / 7.00 p.m.
CJ Walsh: Sustainable Fire Engineering IS THE FUTURE ! (Lecture Flyer, PDF File, 259 kb)
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The aim of Sustainable Fire Engineering is to realize a safe and sustainable built environment.
Responding ethically, in built and/or wrought form, to the still evolving concept of sustainable human and social development … a principal objective of Sustainable Fire Engineering is to design for maximum credible fire and user scenarios … in order to maintain a proper and satisfactory level of fire safety and protection over the full life cycle of, for example, a building … and for a Sustainable Building, that life cycle is 100 years minimum.
Sustainable Fire Engineering must, therefore, be ‘reliability-based’ & ‘person-centred’.
This presentation will examine the authentic language and meaning of sustainability … and will then track how this impacts on the professional practice of fire engineering. Special mention will be made of Fire-Induced Progressive Collapse.
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See you all there ! And I will be looking forward to a lot of challenging feedback on the night !!
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Complaints to the UN Disability Rights Convention Committee
2011-11-14: At the time of writing, this was the up-to-date position regarding the United Nations Convention on the Rights of Persons with Disabilities (CRPD) …
Convention … 153 Signatories … 106 Ratifications
Optional Protocol … 90 Signatories … 63 Ratifications
For reasons which can sometimes be complex … individuals and disability-related organizations are reluctant to make valid complaints … at local, regional or national levels in their countries.
This must stop ! If nobody complains … nothing will change !!
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The following documents should now be used as a Proper Model for Making a Complaint … at any level. And should all domestic remedies be exhausted at national level in a State Party … you will have saved yourself a lot of time and energy, should you decide to take matters further … because the complaint will already be in the correct CRPD format …
Committee on the Rights of Persons with Disabilities – 15 June 2011
UN CRPD/C/5/3 – Guidelines for Submission of Communications to the Committee on the Rights of Persons with Disabilities under the Optional Protocol to the Convention (PDF File, 47.5 kb)
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The Future of Disability Policy in Ireland – Recent SDI Submission
2011-11-06 …
Some time ago … Irish Minister of State at the Department of Health & Children, Ms. Kathleen Lynch T.D., released to the public a report on the future policy of disability in Ireland. The report was drawn up by an Expert Reference Group at the request of the Department. Submissions were sought from the public and interested groups on this document, entitled ‘Report of Disability Policy Review’.
The Report, and other ‘supporting’ information, can be downloaded from the Department’s WebSite at … http://www.dohc.ie/consultations/
Submissions had to be received by the Department, at the latest, on Friday 4 November 2011.
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As you read through the SDI Submission below, please also note well that on the 2 Web Pages of the Department’s Site …
- Background to Report of Disability Policy Review ; and
- Summary of Key Proposals from The Review of Disability Policy ;
… there is not one single mention of the word ‘rights’ !
In a post back on 17 February 2009 … concerning another disability matter, i.e. the complete lack of ‘accessible’ emergency services for people with a hearing impairment in our country, I wrote:
‘ Irish Politicians and Senior Civil Servants would all rather commit ritual suicide on Merrion Street (outside the Dáil and Government Buildings) than give people with disabilities their rights.’
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The following is the recent Submission made by Sustainable Design International … and submitted to the Department of Health & Children on 4 November 2011 …
Re: The Future of Disability Policy in Ireland – SDI Submission
Ms. Kathleen Lynch T.D., Minister of State, c/o Office for Disability & Mental Health, Department of Health & Children, Hawkins House, Dublin 2.
Dear Minister,
It is reassuring to see that the following two documents, available for download from the Department’s WebSite, contain extensive references to Human Rights and, particularly, the UN Convention on the Rights of Persons with Disabilities …
- Report of Disability Policy Review – Prepared by Ms. Fiona Keogh PhD, on behalf of the Expert Reference Group on Disability Policy (October 2011) ;
- Report on Public Consultation: Efficiency & Effectiveness of Disability Services in Ireland – Review of Disability Services under the Value for Money & Policy Review Initiative 2009-2011 (December 2010).
And yet … the following document, also available for download from the Department’s WebSite, does not make one single reference to Human Rights …
- Summary of Key Proposals from The Review of Disability Policy (October 2011).
It is a matter of deep concern how such a fundamental issue can suddenly, and with malign intent, be erased from view … and understanding !
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Whether or not Ireland has ratified the United Nations 2006 Convention on the Rights of Persons with Disabilities is no longer relevant.
The European Union (EU), having its own legal personality after the Lisbon Treaty, did ratify the UN Convention … back on 23 December 2010.
Therefore, Ireland is now bound by a Duty of Loyal Co-Operation, deriving from Article 4.3 of the Treaty on European Union (TEU).
This Duty embraces two sets of obligations: 1) All EU Member States shall take appropriate measures, whether general or particular, to ensure fulfilment of the obligations arising out of the EU Treaties or resulting from action taken by the EU Institutions; and 2) All EU Member States shall facilitate the achievement of the European Union’s tasks, and shall abstain from any measure which could jeopardise the attainment of the Union’s objectives.
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In complete contrast to Ireland’s Current Disability Policy … Future Disability Policy must now be re-drafted, and implemented, in a manner where:
a) Explicit reference is made, throughout, to the United Nations Convention on the Rights of Persons with Disabilities … and to the fact that there is now a robust rights-based foundation to Ireland’s National Disability Policy ;
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b) There is a full, comprehensive and correct response to all of the contents of the United Nations Convention on the Rights of Persons with Disabilities.
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I would specifically draw your attention to Articles 31 & 33 of the United Nations Convention on the Rights of Persons with Disabilities … which together mandate that implementation is taken seriously … that it is competent and effective … and, most importantly, that independent monitoring and verification is a fundamental part of the whole policy development and implementation process.
In closing, may I add that the treatment of ‘Accessibility’ in all of the documents is careless, and disgracefully inadequate !!
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Sustainable Design International is a professional and multi-disciplinary design, engineering, research and consultancy practice – specializing in the theory and implementation of a Sustainable Human Environment (social - built - virtual - economic).
Our Organization possesses a unique level of expertise on all aspects of Human Environment Accessibility for People with Activity Limitations.
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Yours,
C. J. Walsh, Consultant Architect, Fire Engineer & Technical Controller.
Managing Director, Sustainable Design International Ltd. – Ireland & Italy. Sürdürülebilir Tasarım Tic.Ltd.Şti. – Turkey.
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Buildings & Firefighters Not Yet Safer ! – 10 Years After 9-11 (II)
2011-09-20: Continuing on from where I left off on 11 September 2011 …
Applying the Recommendations contained in the 2005 & 2008 National Institute of Standards & Technology (NIST – USA) Reports on the 9-11 WTC Buildings 1, 2 & 7 Collapses to the everyday practice of Architecture and Fire Engineering has been a central part of our work for many years. Long discussions on this subject have taken place within CIB (International Council for Building Research) Working Commission 14: ‘Fire Safety’ … and I also chair Commission 14′s Research Working Group IV on ‘Fire-Induced Progressive Collapse’.
My particular interest in Disproportionate Damage and Progressive Collapse reaches back as far as the late 1980′s !
So I was intrigued, amused … and at the same time, highly concerned … to read the following Letter to the Editor of the Irish Times Newspaper, on Saturday 10 September 2011 …
Recalling 9/11
Sir, – One of the most important factors in the tragedy of 9/11, and one that has received scant attention, was the mode of failure of the towers.
They were struck high up on their structures and failed via progressive collapse. Had they been designed this side of the Atlantic, they would not have collapsed. These were flimsy structures. -
Yours, etc,
Jim Ryan, Chartered Structural Engineer,
Waterfall, Cork.
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JIM … If the WTC Towers (which were not flimsy structures !) had been designed on this side of the Atlantic … they would have collapsed.
Furthermore … If the Towers had only been completed last week in the USA, Ireland, England & Wales, India or China … they would still collapse, if a similar event were to occur next year.
To be crystal clear … What we witnessed, on Tuesday 11 September 2001, was a Collapse Level Event (CLE) which exposed, very harshly and cruelly, a catastrophic failure in all of our common Design and Construction Practices and Procedures used in/by/as …
- Architectural Design | (Ambient) Structural Engineering | Fire Engineering ;
- Building Management Systems ;
- Emergency Responders | Firefighters | Rescue Teams ;
- Technical Control Organizations Having Authority (AHJ’s) or Jurisdiction ;
- Fire Safety Objectives in Building Legislation, Codes and Standards.
To the average ‘person in the street’ … Whether he/she lives in Manhattan or Chicago in the USA, Dublin or Cork in Ireland, Cardiff or London in Britain, Dilli or Mumbai in India, Beijing or Shanghai or Hong Kong in China … it is unacceptable that buildings collapse … entirely unacceptable !!
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COLLAPSE OF WTC BUILDINGS 1, 2 & 7
JIM … Unless you believe in conspiracy theories, please study the 2005 & 2008 NIST(USA) Reports on the 9-11 WTC Buildings 1, 2 & 7 Collapses. The 2 Final Reports can be downloaded from this Page on Sustainable Design International’s Corporate WebSite … http://www.sustainable-design.ie/fire/structdesfire.htm … along with other key documents and links.
Some indication of the enormous quantity of 9-11 WTC Incident Documentation issued by NIST(USA) can be seen below …
Colour photograph showing the enormous quantity of 9-11 WTC Incident Documentation, issued by the U.S. National Institute of Standards & Technology, which is still readily available for the public to access and download.
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PUBLIC SAFETY 10 YEARS AFTER 9-11 ?
If it is entirely unacceptable to the Public that buildings collapse … in how many National Building Codes does the following Critical Public Safety Equation appear today ? The answer is NONE !
Colour image showing Page 21 from my Overhead Presentation on 'Sustainable Fire Engineering' ... scheduled for this Thursday, 22 September 2011, at the ASFP Ireland Fire Seminar & Workshop ... to be held at the RDS, in Ballsbridge, Dublin. Click to enlarge.
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Is there some fundamental reason why Levels of Safety for the Public should vary so much from one country to another ? NO, there is not !
Within Europe, and in relation to the New EU Construction Product Regulation 305/2011, which I discussed here a few days ago … the European Commission, in a discussion document dating back to the mid-1980′s, suggested that the only way to effectively realize a Single Market for Construction Products would be to introduce Harmonized EU Building Regulations in all of the EU Member States. Of course the Member States, at the time, went ballistic at the very mention of this idea … and it was quickly withdrawn. I take great pleasure in repeating that important idea today.
Jim … The Critical Public Safety Statement above is fully consistent with … and meets … the ‘Basic Requirements for Construction Works’ in Annex I of EU Regulation 305/2011.
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However, in relation to any one EU Member State … let’s take Ireland as an example … compare a situation where, in a remote rural location, it might take almost an hour for a sufficient fire service presence to arrive at the scene of a building fire emergency … with a similar situation in the middle of a city, or large town, where the time required will not be greater than 15 minutes … then, although the Level of Safety for the Public can be / should be / must be the same in both situations … I would expect, in the remote rural location having a poor fire service support infrastructure, that the range of Fire Protection Measures to be employed in a typical building would be more extensive, and the performance expected of those Measures would be higher … in order to achieve an Equivalent Level of Safety in both rural and urban locations. Is that not a rational idea ??
Unfortunately, that’s not how the present systems work … National or European ! Levels of Public Safety differ from one country to the next … and from one region, within any one country, to the next … without any good reason … and without meaningful consultation and the full understanding of the Public.
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BUILDINGS & FIREFIGHTERS ARE NOT YET SAFER
JIM … In spite of all of the spin coming from the other side of the Atlantic … and discounting criminality and fraud in construction practices … Buildings and Firefighters are not yet safer … because the large, difficult, complex flaws and failures in Conventional Fire Engineering have not yet been aggressively confronted … and properly solved.
In a post last year, on 18 October 2010 … I referred to the Cul-de-Sac of Current Fire Engineering … and illustrated a typical architectural detail in a Dublin Building – a common detail also to be found in India, China, USA, England & Wales, etc., etc – which demonstrates a Fundamental Flaw at the very core of conventional thinking and practice.
On Thursday next … 22 September 2011 … at the ASFP Ireland Fire Seminar and Workshop in the RDS, Dublin … I will present this flawed detail … and a solution which is fully compatible with … and answers … the NIST Recommendations !
BUT … would anybody like to show me where any National Building Codes have been revised and updated to solve this Fundamental Flaw ?
Colour image showing Page 33 from my Overhead Presentation on 'Sustainable Fire Engineering' ... scheduled for this Thursday, 22 September 2011, at the ASFP Ireland Fire Seminar & Workshop ... to be held at the RDS, in Ballsbridge, Dublin. Click to enlarge.
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Colour image showing Page 35 from my Overhead Presentation on 'Sustainable Fire Engineering' ... scheduled for this Thursday, 22 September 2011, at the ASFP Ireland Fire Seminar & Workshop ... to be held at the RDS, in Ballsbridge, Dublin. Click to enlarge.
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Colour image showing Page 36 from my Overhead Presentation on 'Sustainable Fire Engineering' ... scheduled for this Thursday, 22 September 2011, at the ASFP Ireland Fire Seminar & Workshop ... to be held at the RDS, in Ballsbridge, Dublin. Click to enlarge.
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Colour image showing Page 37 from my Overhead Presentation on 'Sustainable Fire Engineering' ... scheduled for this Thursday, 22 September 2011, at the ASFP Ireland Fire Seminar & Workshop ... to be held at the RDS, in Ballsbridge, Dublin. Click to enlarge.
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Colour image showing Page 38 from my Overhead Presentation on 'Sustainable Fire Engineering' ... scheduled for this Thursday, 22 September 2011, at the ASFP Ireland Fire Seminar & Workshop ... to be held at the RDS, in Ballsbridge, Dublin. Click to enlarge.
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A CASE STUDY OF ENGLAND & WALES
10 years after 9-11 … there are two reasons for taking a closer look at England & Wales (Britain) …
- The Building Regulations for England & Wales were used as the model for the Irish Building Regulations, which were first introduced here in the early 1990′s. And, in the absence of Harmonized European Standards … British National Standards tend, with only a few exceptions, to become the default Irish National Standard ;
- British National Standards are being applied in many different parts of the world outside England & Wales … in most cases, without any proper consideration of content … or adaptation to local conditions.
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Colour image showing the Cover Page of Approved Document B: 'Fire Safety' ... Volume 2 - Buildings Other Than Dwellinghouses ... from the Building Regulations for England & Wales. Click to enlarge.
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The Institution of Fire Engineers (Ireland) Annual Fire Conference, which was held last year, on Wednesday 20th October 2010 … in the Dublin Fire Brigade Training Centre, Marino, Dublin … threw up some interesting ‘notions’ for consideration by a diverse range of participants.
One curious proposition … repeated quite often during the day … was that Approved Document B, in the British System of Building Regulations, was basically still a sound document … and that it should pass an upcoming major review with little difficulty.
I don’t agree … Approved Document B is inadequate and dysfunctional !
With regard to Structural Performance in Fire … instead of referring to Approved Document A – Structure … the reader is referred to Appendices at the back of Approved Document B, which only reinforce the erroneous concept of Single Structural Element Fire Protection …
And along with its many other major problems … see my post, dated 2009-06-14 … British Standard BS 9999 takes no account of any of the 2005 & 2008 NIST Recommendations, Fire-Induced Progressive Collapse or Disproportionate Damage … and, in fact, directly conflicts with aspects of the Building Regulations for England & Wales …
Colour image showing Page 51 in the Appendix of my Overhead Presentation on 'Sustainable Fire Engineering' ... scheduled for this Thursday, 22 September 2011, at the ASFP Ireland Fire Seminar & Workshop ... to be held at the RDS, in Ballsbridge, Dublin. Click to enlarge.
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In order to take a close look at Approved Document B … I used the vehicle of a Notional Hotel Project in Cardiff, Wales … similar to the Early 1990′s Dublin Hotel Project shown above …
Colour image showing Page 52 in the Appendix of my Overhead Presentation on 'Sustainable Fire Engineering' ... scheduled for this Thursday, 22 September 2011, at the ASFP Ireland Fire Seminar & Workshop ... to be held at the RDS, in Ballsbridge, Dublin. Click to enlarge.
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With regard to properly showing Fitness for Intended Use of Fire Protection related Products and Building Systems … instead of referring to Regulation 7 … the reader is again referred to Appendices at the back of Approved Document B … which explains why we have such serious problems, i.e. lack of Durability and very low Resistance to Mechanical Damage, with the Thermal Insulation Products used for the Fire Protection of Structural Steelwork …
I also had to quote from Part D of the Irish Building Regulations to fill a gap in the British Regulation 7 …
Colour image showing Page 53 in the Appendix of my Overhead Presentation on 'Sustainable Fire Engineering' ... scheduled for this Thursday, 22 September 2011, at the ASFP Ireland Fire Seminar & Workshop ... to be held at the RDS, in Ballsbridge, Dublin. Click to enlarge.
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END
Disability Access Certificates (DAC’s) in Ireland – Confused ??
2011-09-01: To say, bluntly, that there is confusion out there … at every level … would be a mild understatement ! Yes, the Disability Access Certificate (DAC) & Revised DAC Process is new … but that cannot explain what is happening … or, more precisely, what is not happening.
BUT … before jumping in at the deep end and examining the existing and operative Part M of the Irish Building Regulations … let me just mention, very briefly, two wider legal ‘niceties’ concerning Accessibility of Buildings for People with Disabilities …
1. The Black Hole between Building Regulations and Equality Law
The definition of People with Disabilities in the existing Part M is limited. It is inadequate. Compare, now, that definition with the definition of Disability in Irish Equality Legislation … which is the complete opposite, being very wide in scope. A deep chasm exists between the two. Check each of them out for yourself ! And because few people are aware of this chasm … a better description of that large space might be a Black Hole.
However, the clear consequence of the Black Hole for building owners … and building designers alike … is that the ‘act’ of merely going through the motions with regard to compliance with Part M … and being satisfied with getting ‘the’ piece of paper, i.e. a Disability Access Certificate … will, without any shadow of a doubt, open the building owner to a complaint under Equality Law. And when a building owner encounters this sort of problem … who will he, or she, hunt down for an explanation ??
Client Organizations beware … prevention is a far better strategy !! Check out the Level of Accessibility Performance required to avoid complaints under Equality Legislation.
[ You should also consider the following ... the Health & Safety Authority in Ireland is doing absolutely nothing to ensure that Workplaces are Accessible ... a requirement contained in all of the European Union (EU) Safety at Work Directives and the Irish National Legislation implementing those Directives. So, also cross check the Level of Accessibility Performance required to comply with Safety at Work Legislation. Compliance with Part M is not sufficient ! ]
2. European Union Ratification of the 2006 United Nations Convention on the Rights of Persons with Disabilities (CRPD)
For a sizeable group of vulnerable people in every EU Member State, the sole route of access to many, if not most, of the Human and Social Rights set down in the 1948 Universal Declaration of Human Rights (UDHR) is the UN Convention on the Rights of Persons with Disabilities (CRPD) … which became an International Legal Instrument on 3 May 2008, and was ratified by the European Union on 23 December 2010. That is precisely why Accessibility is such a critical component of the 2006 UN Convention !
Articles 31 & 33 of the 2006 UN Convention on the Rights of Persons with Disabilities – together – mandate that Accessibility Implementation is taken seriously … that it is competent and effective … and, most importantly, that independent monitoring and verification is a fundamental part of the process.
Ireland has not yet ratified the UN CRPD. And, as far as our National Authorities Having Jurisdiction (AHJ’s) are concerned … everything in the garden is beautiful … Ireland is doing just great and nothing much needs to be altered in our laws, administrative provisions or resourcing … to allow Ireland to ratify the Convention, and then properly implement it. Nothing could be further from the truth !
In Order to Protect your Organization and its many interests … Your Policy and Decision Makers, in Ireland, should study the implications flowing directly from EU Ratification of the UN CRPD … and then, the various Articles of the UN Convention should be examined and properly implemented … insofar as those Articles are relevant to you and your organization’s activities. See my earlier post, dated 5 February 2011.
To date … the quality of Accessibility Implementation in Irish Buildings has been dreadful !! For important reasons … which all parties involved should fully understand … this situation is longer acceptable.
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Colour photograph showing the front entrances to dwelling units in a New Inner City Housing Scheme in Dublin ... User Unfriendly ... Inaccessible for Many Vulnerable People in Our Society ... Dreadful Accessibility Implementation ! Photograph taken by CJ Walsh. 2003-09-13. Click to enlarge.
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Disability Access Certificates (DAC’s) & Part M
The submission of sufficient, quality information, i.e. detailed design documentation, at Disability Access Certificate (DAC) Application Stage typically signals the following to an experienced technical controller …
- The intent of the Applicant, and the Agent(s) acting on his/her/their behalf, with regard to properly and satisfactorily complying with the relevant building legislation, i.e. Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Irish Building Regulations ; and
- In the absence of an inspection by the Building Control Authority (BCA) during actual construction … whether or not it is likely that the completed works will match the DAC certified design documentation with regard to Accessibility Performance.
From the beginning, it is necessary to distinguish between Access and Accessibility.
To be written in stone when International Standard ISO 21542 is soon published … the components of Building Accessibility comprise …
- Approach to the building ;
- Entry ;
- Use of the building, its services and facilities ;
- Egress from the building (during normal conditions) ;
- Removal from the vicinity of the building (during normal conditions) ;
and
- Evacuation from the building (during, for example, a fire emergency) ;
- Safe Movement to a ‘place of safety’ (during, for example, a fire emergency), which is remote from the building.
This is also a useful guideline with regard to segregating those aspects of Accessibility Design which relate to Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Irish Building Regulations, and which should be considered in any application for a Disability Access Certificate (DAC) … and those, after ‘and‘ … which relate to Part B: ‘Fire Safety’, and which should be considered in every application for a Fire Safety Certificate (FSC).
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The 2000 Building Regulations (Amendment) Regulations … Statutory Instrument No. 179 of 2000 … elaborate the relevant Irish Building Legislation concerning building access, i.e. Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Building Regulations …
“Access and Use
M1 Adequate provision shall be made to enable people with disabilities to safely and independently access and use a building.
Sanitary Conveniences
M2 If sanitary conveniences are provided in a building, adequate provision shall be made for people with disabilities.
Audience or Spectator Facilities
M3 If a building contains fixed seating for audience or spectators, adequate provision shall be made for people with disabilities.
Definition for This Part
M4 In this Part, ‘people with disabilities’ means people who have an impairment of hearing or sight or an impairment which limits their ability to walk, or which restricts them to a wheelchair.
Application of This Part
M5 Part M does not apply to works in connection with extensions to and the material alterations of existing dwellings, provided that such works do not create a new dwelling.”
My Note 1: In order to safely and independently use a building … it is also necessary, under normal conditions, to use the egress routes of a building.
My Note 2: The limited definition of ‘people with disabilities’ in Requirement M4 does not include, for example, a person without arms … or those people with a mental, cognitive or psychological impairment.
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Technical Guidance Document M (2000, re-printed in 2005) provides guidance in relation to Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Irish Building Regulations. TGD M was issued by the Department of the Environment, under Article 7 of the 1997 Building Regulations … Statutory Instrument No. 497 of 1997 … which states …
” 7. (1) The Minister may publish, or arrange to have published on his behalf, documents to be known as ‘technical guidance documents’ for the purpose of providing guidance with respect to compliance with the requirements of any of the provisions of the Second Schedule.
(2) Subject to the provisions of sub-article (3), where works or a building to which these Regulations apply is or are designed and constructed in accordance with any guidance contained in a technical guidance document, this shall, prima facie, indicate compliance with the relevant requirements of these Regulations.
(3) The provisions of any guidance contained in a technical guidance document published under sub-article (1) concerning the use of a particular material, method of construction or specification, shall not be construed as prohibiting compliance with a requirement of these Regulations by the use of any other suitable material, method of construction or specification.”
My Note 3: Since the introduction of national legal building legislation in the early 1990′s, the Irish Building Regulations have a Functional Format, as required by European Union (EU) Law. In other words, satisfactory compliance with short functional statements is mandated by law … and provided the requirements of those short statements are properly shown to be complied with, it is entirely optional as to which materials, methods of construction, standards and other specifications (including technical specifications) are used. In this way, the free movement of products and services within the EU is facilitated and encouraged while, at the same time, technical barriers to trade are avoided.
My Note 4: For the convenience of readers, the short functional statements mandated by law are reproduced, in a shaded box, at the beginning of each of the Technical Guidance Documents. The Guidance Texts in each Technical Guidance Document, however, are not Prescriptive Regulations. These texts are merely an indicator of what is likely to be suitable for the purposes of compliance with the Regulations … they are, prima facie (i.e. on ‘first appearance’ only), an indication of compliance ; they are not ‘deemed-to-satisfy’ the Requirements of Part M.
My Note 5: Where gaps are identified in the guidance texts of Technical Guidance Document M … and in the absence of an Irish National Standard on Building Access or Accessibility … a suggested hierarchy of approach should be to source an appropriate European Standard (EN) or, if such a standard does not yet exist, then an appropriate International Standard (ISO), or then a National Standard of any country which is a contracting party to the Agreement on the European Economic Area (EEA) which provides in use an appropriate level of Access/Accessibility Performance (refer to Part D of the Second Schedule to the Building Regulations). In the unlikely absence of any of the above, an appropriate Design Guidance Document – national or otherwise – should be referenced which provides in use an appropriate level of Access/Accessibility Performance.
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Our Organization – Sustainable Design International – provides an independent (and confidential) Accessibility Monitoring and Verification Service.
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END
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