Accessibility of buildings for people with disabilities
Social Rights in Ireland – Why the Constant Struggle ?
Attention anybody who is screaming, struggling, protesting … being forced to revolt against an unjust and uncaring ‘system’ … so that Vulnerable Individuals and Groups … older people, children, people with disabilities, the homeless, etc., etc., etc … will be treated with dignity, equality and respect in our society … Ireland and the European Union. Pinch yourselves … we are Irish and Europeans !
It is helpful, as an introduction, if a distinction is made between human rights and social rights …
Social Rights: Rights to which an individual person is legally entitled, e.g. the right to free elementary education [Art.26(1), 1948 Universal Declaration of Human Rights], but which are only exercised in a social context with other people, and with the active support of a competent legal authority, e.g. a Nation State.
Commentary: In contrast to Human Rights, it is not protection from the State which is desired or achieved, but freedom with the State’s help.
Social Rights, as distinguished here, include and extend beyond current understandings of civil, political, economic, social and cultural rights.
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Early in the year 2000 … the European Parliament issued a Working Paper (reference PE 168.629) with the title: ‘Fundamental Social Rights in Europe’. The authors were Mark Eric Butt, Julia Kübert and Christiane Anne Schultz. The manuscript was completed in November 1999.
Without getting into the fine detail of the Working Paper … the following Table, on Page 31, is very enlightening …
Click to enlarge this Table.
In the Working Paper, the Table is explained …
‘ The following Table is an overview of the contents of the Member States’ constitutions. It shows what fundamental social rights are enshrined in the constitutions. It is impossible, however, to forge a link between the existence of fundamental social rights and the existence and level of social benefits and institutions in the Member States concerned. This is clear, primarily, from Austria and Great Britain, their columns being empty – whereas they do, of course, have social rights.
The symbol … simple black box … in the table means that the right concerned is referred to in the constitution. The other symbol … shadowed white box … means that, though not explicitly enshrined in the constitution, it is recognised.’
The Countries are listed in the order … Belgium (B), Denmark (DK), Germany (D), Greece (GR), Spain (E), France (F), Ireland (IRL), Italy (I), Luxembourg (L), The Netherlands (NL), Austria (A), Portugal (P), Finland (FIN), Sweden (S) and Great Britain (UK).
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Now … compare and contrast … paying particular attention to Ireland …
Interesting … isn’t it ?
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ISO/IEC Guide 71 & CEN/CENELEC Guide 6 – Flawed ?
International Guidance Document … ISO/IEC Guide 71 : Guidelines for Standards Developers to Address the Needs of Older Persons and Persons with Disabilities was issued in November 2001.
European Guidance Document … CEN/CENELEC Guide 6 : Guidelines for Standards Developers to Address the Needs of Older Persons and Persons with Disabilities … a similar document … was issued a little later, in January 2002.
These Guides provide basic guidance to people drafting International & European Standards on how to take into account the needs of people with activity limitations, particularly older persons and people with disabilities. While recognizing that some people with very extensive and complex impairments may have requirements beyond the level addressed in these documents, a very large number of people have minor impairments which can easily be addressed with a very small change of approach by people writing the Standards. Typically, the problem is solely a lack of awareness.
Unfortunately, few Standards Developers … in either organization … are paying the slightest bit of attention to these Guides.
People with Activity Limitations: Those people, of all ages, who are unable to perform, independently and without aid, basic human activities or tasks – because of a health condition or physical/mental/cognitive/psychological impairment of a permanent or temporary nature.
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1. A full six months before the appearance of ISO/IEC Guide 71 … all of the 191 Member States of the World Health Organization endorsed, and officially adopted, the International Classification of Functioning, Disability & Health (ICF) on 22nd May 2001 … which replaced the earlier International Classification of Impairment, Disability & Handicap (ICIDH), dating from 1980.
While the previous health indicators had been based on the mortality (i.e. death) rates of populations … the new 2001 WHO ICF dramatically shifted the focus to ‘life’ and ‘living’ … in other words, how everyone is living with his/her health condition(s) and how improvements can be made to ensure a productive, fulfilling life in society.
This had important implications for medical practice; for legal, social, economic, institutional, design and spatial planning policies to improve accessibility, equal opportunity for all and inclusion; and for the protection of the rights of all individuals and groups.
Of special interest for people involved in any of the technical fields mentioned above … the 2001 WHO ICF also introduced a new disability-related language and terminology.
BUT … But … but … ISO/IEC Guide 71 and CEN/CENELEC Guide 6 do not use the 2001 WHO ICF’s innovative language and terminology. Consequently, these International & European Guides are flawed.
For a very good example of WHAT MUST BE AVOIDED (!) in the drafting of International & European Standards … please examine the following text …
ISO DIS (Draft International Standard) 21542 : Building Construction – Accessibility and Usability of the Built Environment … dated November 2009 …
Section 3 Terms & Definitions
‘ #3.36 Impairment
Limitation in body function or structure such as a significant deviation or loss which can be temporary due, for example, to injury, or permanent, slight or severe and can fluctuate over time, in particular, deterioration due to ageing.
[ISO/TR 22411:2008]
NOTE 1 Body function can be a physiological or psychological function of a body system; body structure refers to an anatomic part of the body such as organs, limbs and their components (as defined in ICIDH-2 of July 1999).
NOTE 2 This definition differs from that in ISO 9999:2002 and, slightly, from ICIDH-2/ICF: May 2001, WHO: ‘any loss or abnormality of a body function, or body structure’.
NOTE 3 The word ‘abnormality’ is strictly used here to refer to a significant deviation from an established population mean, within measured statistical norms. Impairments can be physical, mental, cognitive or psychological.’
As clear as mud … what a mess ! This does nothing only sow needless confusion in the mind of a reader.
Unless and Until … we properly harmonize, at a technical level, disability-related language and terminology … in order to improve communication … we will all continue to run around in circles and make little forward progress !!!
[ At the level of the individual, people should always be free to use whatever language they wish. ]
Our Guidance to All Standards Developers is … whether working within the International Standards Organizations (ISO & IEC) or the European Standards Organizations (CEN & CENELEC) … or both …
‘ People with Activity Limitations must be properly considered at all stages in the development of a Standard … and any disability-related terminology used … should be fully consistent with the World Health Organization’s 2001 International Classification of Functioning, Disability & Health (ICF). Confusing and contradictory texts should be avoided.’
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2. In relation to ISO/IEC Guide 71 & CEN/CENELEC Guide 6 – Table 7 (Page 13 in both Guides) … #8.23 Fire Resistance requires a complete re-assessment. On Page 21 of ISO/IEC Guide 71 and Page 22 of CEN/CENELEC Guide 6 … the supporting text for #8.23 has the different heading of ‘Fire Safety of Materials’ ?!? Confusing, isn’t it ?
The Revised Title in Table 7 and the supporting text should read … Fire Safety. ‘Fire Resistance’ is but one of many passive fire protection concepts … a very small sub-set in the wide technical field of ‘fire safety’ in buildings. ’Fire Resistance’ is not used in connection with the ignition and fire development behaviour of materials or fabrics.
Relevant Factors for #8.23 are not properly indicated, in Table 7, under Columns #9.2, #9.3, #9.4 (a glaring omission !) & #9.5.
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3. Pertinent to ‘fire safety’ in buildings … this text was removed from ISO CD (Committee Draft) 21542 … the previous version of the ISO Standard, dating from December 2008 …
ISO CD 21542 – Annex A.1.2 – 2nd Paragraph
‘ Building users should be skilled for evacuation to a place, or places, of safety remote from the building. In the case of people with a mental or cognitive impairment, there is a particular need to encourage, foster and regularly practice the adaptive thinking which will be necessary during a ‘real’ fire evacuation.’
The Definition for the Term Skill (#3.60) is still retained in the later ISO DIS 21542 version of the Standard …
‘ The ability of a person – resulting from training and regular practice – to carry out complex, well-organized patterns of behaviour efficiently and adaptively, in order to achieve some end or goal.’
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4. While there are eight references to ‘Cognitive Impairment’ in both Guides … nowhere is this term defined … or distinguished from ‘Mental Impairment’ …
Cognitive Impairment: A deficiency of neuropsychological function which can be related to injury or degeneration in specific area(s) of the brain.
Mental Impairment: A general term describing a slower than normal rate in a person’s cognitive developmental maturation, or where the cognitive processes themselves appear to be slower than normal – with an associated implication of reduced, overall mental potential.
A deeper understanding, at a technical level, of the many different types of health conditions and impairments (physical/mental/cognitive/psychological) … can only result in a better designed, more facilitating Human Environment.
One final important term … when considering Fire Safety in Buildings …
Panic Attack: A momentary period of intense fear or discomfort, accompanied by various symptoms which may include shortness of breath, dizziness, palpitations, trembling, sweating, nausea, and often a fear by a person that he/she is going mad.
I have long held the view that, in Fire Engineering, dramatic breakthroughs will result from a closer study of Cognitive Psychology.
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European Parliament’s URBAN InterGroup – Inaugural Meeting
On Wednesday afternoon, 24th February 2010, the URBAN InterGroup of the European Parliament met for the first time in the new Parliamentary Term … at 16.30 hrs … in Meeting Room 6Q2 of the Parliamentary Complex in Brussels, Belgium. Dr. Jan Olbrycht, Member of the European Parliament (MEP), chaired the proceedings. The attendance was large, and included a large proportion of the 50, or so, MEP’s who are directly involved with the InterGroup. Please forgive the jargon, but … many other URBAN InterGroup Partners, Sectoral Stakeholders and Interested Practitioners also attended. However … not one Irish MEP appears to show any interest in this important InterGroup. Why is that ?
Colour photograph showing the Inaugural Meeting of the European Parliament's URBAN InterGroup, in Brussels, on 24th February 2010. The Meeting, chaired by Mr. Jan Olbrycht MEP, had a large attendance. Click to enlarge. Photograph taken by CJ Walsh. 2010-02-24.
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I was very pleased to attend this Meeting, representing Sustainable Design International Ltd. (a Multi-Disciplinary Design & Research Practice in Europe, and a Micro-SME). Further to a series of interventions on my part, the following are some Comments on last Wednesday’s Meeting … and a few Suggestions …
1. Accountable & Representative Governance is an important component in the implementation of Sustainable Human and Social Development. It is not being too ambitious, therefore, to say that the URBAN InterGroup has an important task to fulfil within the ‘system’ of the European Parliament.
2. Within such a ‘system’ … it is a big advantage that the InterGroup’s Structure is informal and fluid. This allows the InterGroup to be cross-party and cross-committee at the Parliament … and to adopt a ‘flexible’ horizontal approach to Urban-Related Issues.
3. This same Horizontal Approach must, however, be applied to a proper consideration of the Urban Environment (City) itself … which is far more than the sum of its buildings, public spaces, transport systems, engineering infrastructure (roads, bridges, etc.), and service utilities, etc., etc.
4. In order to deal effectively with Urban-Related Issues and the many different Sectoral Stakeholders … it is essential that the Intergroup discusses and develops a comprehensive and coherent vision of what exactly is a Sustainable Urban Environment (City). Please see the previous post on this Blog, dated 2010-03-02.
And … even though the regular InterGroup Meetings will be of short duration … it will be of great benefit to link small, individual issues to that larger, coherent vision. Then, and only then, will the InterGroup always know where it is … and, more importantly, in which direction it is travelling … in order to monitor progress.
5. It was not clear to me, at the Meeting, that the significant differences between the words ‘Sustainable’ and ‘Green’ are fully understood. This will cause problems for the InterGroup in the future, and should be examined in more detail.
The European Union (E.U.) Treaties refer to ‘Sustainable Development’ … not to ‘Greenness’ !!
6. It was also evident, at the Meeting, that there is a Lack of Communication between the European Parliament and the European Commission on Urban-Related Issues. Let me immediately say, however, that there is a worrying lack of communication (on any issue !) between the different Directorates-General within the Commission.
It must be a Priority for the InterGroup … a difficult one, I know … to have direct access to available Urban-Related Information … across all of the European Union’s Institutions. It is too wasteful of the InterGroup’s limited resources to be required to ‘re-invent wheels’ !
7. With regard to the URBAN InterGroup’s Work Programme … it is necessary to add a specific mention of the following Two Subjects:
(i) Proactive Climate Change Adaptation
Climate Change Adaptation, generally, encompasses actions to reduce the vulnerability and strengthen the resilience of the Human Environment, including ecological and social systems, institutions and economic sectors … to present and future adverse effects of climate change and the impacts of response measure implementation … in order to minimize the threats to life, human health, livelihoods, food security, assets, amenities, ecosystems and sustainable development.
Urban Environment Climate Change Adaptation, more precisely, means … reliably implementing policies, practices, projects and institutional reforms in the Urban Environment (City) … with the aim of reducing the adverse impacts and/or realizing the benefits directly/indirectly associated with climate change, including variability and extremes … in a manner which is compatible with Sustainable Human and Social Development.
Following detailed briefing meetings, in Dublin, from high-level participants in Copenhagen … the suggestion of this subject arises from what happened … or, more correctly, did not happen … to the European Union and its inadequate Climate Change Policies at the 2009 Climate Summit in December.
(ii) Accessibility for People with Activity Limitations (Personnes à Performances Réduites)
The 2006 United Nations Convention on the Rights of Persons with Disabilities entered into force on 3rd May 2008, i.e. it became an International Legal Instrument. European Union (E.U.) Member States are currently undertaking the process of ratifying this Convention at national level. At a certain stage in the near future, the Union (as a polity, post Lisbon Treaty) will certainly also ratify the Convention.
People with Activity Limitations now have a clearly defined right, under International Law, to be able to access and use the Urban Environment (City). They also have the right to receive an equal and meaningful consideration in situations of risk, e.g. when there is a fire in a building.
The InterGroup must fully take account of these rights ! This is no longer an option. In this regard and until now, the attitudes and performance of the E.U. Institutions has been nothing less than a complete and utter disgrace.
8. With regard to the Main Objectives of the URBAN InterGroup … it is necessary to add the following Preamble to those Objectives …
Adopting a long-term perspective, i.e. beyond the lifetime of any single parliamentary term … the Main Objectives of the InterGroup are to:
- monitor the legislative and non-legislative work of the European Parliament’s Committees on Urban-Related Issues ;
- work on common European Union Strategies – to put Urban Needs on the agenda of E.U. Policies ;
- be actively involved in the preparation of E.U. legislation ;
- constantly stay in contact with partners and practitioners ;
- be informed about the realization of E.U. Policies on the ground.
Please note well … that the short-term perspective of elected politicians, whether at European, National or Local Levels, is a Serious Impediment to the proper implementation of a Sustainable Urban Environment (City) !
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Accessibility-for-All at the Brussels European Parliament ?!?!
Last Wednesday (2010-02-24), I was very pleased to be in Brussels to attend the Inaugural Meeting of the European Parliament’s URBAN InterGroup for the New Parliamentary Term. Being very curious, however, there was no way … no way at all … that I could enter the Parliament Building without checking on a specific part of the Early Parliamentary Complex on Rue Wiertz … for any improvements to its past, woeful ‘accessibility’ performance. Please note that I am not referring, here, to transport issues … but to ‘accessibility’ for people with activity limitations.
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Colour photograph showing the same dangerous external ramp/stair combination near the Main Public Entrance to the European Parliament Building, on Rue Wiertz, in Brussels. During rush hour periods of the working day, this ramp/stair combination is a very busy public pedestrian route. Click to enlarge. This photograph taken by CJ Walsh. 2010-02-24. For more photographs of this architectural 'gem', dating from 2000-2001, see SDI's Corporate WebSite.
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Since the 2006 United Nations Convention on the Rights of Persons with Disabilities became an International Legal Instrument on 3rd May 2008 … people with activity limitations now have a clearly defined right, under international law, to be able to access and use the Built Environment. They also have the right to receive an equal and meaningful consideration in situations of risk, e.g. when there is a fire in a building. The language of the Convention is unusually strong.
Once upon a time … 9 or 10 years ago … at the beginning of this decade/century/millennium … a Properly Accessible Built Environment could only be wishful thinking. Yes, there was some legislation … usually very weak … at national level in the E.U. Member States … but nobody paid much attention to implementation. The least that could be expected, however, was that Iconic Buildings purposefully intended and designed for occupation by Institutions of the European Union would be examples of ‘good accessibility’ … as so much emphasis has always been placed in the E.U. Treaties, including the New Lisbon Treaty … on the foundation of the European Union being robustly rooted in Human and Social Rights for All … not just a privileged few, or a self-contented majority.
At this Page on Sustainable Design International’s Corporate WebSite … www.sustainable-design.ie/arch/inaccesseubuildings.htm … I recorded the dismal and depressing evidence on the ‘inaccessibility’ of both the Brussels and Strasbourg Parliament Buildings at that time.
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Colour photograph showing the 'special' entrance reserved for 'personnes a mobilite reduite' in another part of the Brussels European Parliamentary Complex. It's too bad if someone who must use this facility cannot understand the incorrectly printed French ! Click to enlarge. Photograph taken by CJ Walsh. 2010-02-24.
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So … what has changed in the intervening years ? Have there been any improvements to a situation which I originally described as being ‘stupid and ridiculous’ ? [I won't bore you with all of the reasons why.] Or, are things worse ? Have we, in fact, entered into some unknown region of The Twilight Zone ? Arise again GUBU (Grotesque, Unbelievable, Bizarre and Unprecedented) !!
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Colour photograph showing the Main Entrances associated with the 'special' entrance in the photograph above. They are located approximately 10 metres around the corner on a different side of the building. If the nosings of those steps have been highlighted in yellow, does that mean that these clumsy entrances are 'safe' ?? Click to enlarge. Photograph taken by CJ Walsh. 2010-02-24.
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Pinch yourselves, a few times, as you examine the photographs closely ! Try to remember that these buildings are not renovated or refurbished existing buildings. They were all designed and constructed, as ‘new’, on cleared sites within the city !!
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Although Architects, the Brussels Local Authorities and the E.U. Institutions are primarily responsible for ‘inaccessibility’ of the Brussels European Parliament Building … we cannot afford to be smug or complacent in Ireland. Just look around you !
Again, once upon a time … towards the end of the 1980′s this time … I submitted the following Proposal for a Resolution on Accessibility-for-All to the Council of the Royal Institute of the Architects of Ireland (RIAI) … please forgive the pre 2001 WHO ICF use of language and terminology …
Preamble
The elimination of architectural barriers to mobility of the disabled is an essential and preliminary condition for successful implementation of the principal that all people should be fully integrated into society, participating in and contributing to all aspects of economic and social life.
Resolution
Celebrating the 150th year of its establishment, Council of the Royal Institute of the Architects of Ireland asks all Members:-
(i) to note the principal that all people should be fully integrated into society, participating in and contributing to all aspects of economic and social life ;
(ii) to eliminate as far as reasonably practicable, in the design of buildings, architectural barriers to mobility of the disabled.
Was this Resolution passed ? I’ll give you one guess ! The reason given, at the time, was that the Profession might be viewed as being culpable … which it was … and remains to this day. The source of this culpability, however, is most definitely the Schools of Architecture.
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2010 ACRECONF in Delhi (Dilli), India – 8th & 9th January
It was a great pleasure to be invited to speak on the subject of Sustainable Fire Engineering at the 2010 ACRECONF in Delhi (Dilli), India. This ground breaking conference in Asia took place at the India Habitat Centre, Lodhi Road, Delhi … on the 8th & 9th January last. Back during August (2009) in Bengaluru … the ACRECONF Chairman, Mr. Ashish Rakheja, told me that he expected an attendance of somewhere between 500-600 people at the Delhi Conference. Over the two days of the actual conference, approximately 1800 delegates participated … an enormous response by architects, civil and service engineers, developers, client and construction organizations, etc., etc., from right across the country … and from the deep south.
Colour photograph showing some of the many participants at the 2010 ACRECONF in Delhi, as they enjoy talking and networking during the morning coffee break of the second day at the conference. The venue was the India Habitat Centre on Lodhi Road. The weather was chilly for the time of year, and there had been a heavy fog earlier in the morning. Click to enlarge. Photograph taken by CJ Walsh. 2010-01-09.
For me … refreshing, extremely impressive, and certainly the highlight of the conference … was a multi-media presentation … on the second morning, just after the coffee break … by Mr. Karan Grover, the renowned Indian Architect. He is quite an individual !
Before the break, delegates had been treated to an elaboration of the Environmental Design Innovations incorporated into the 71 storey Pearl River Tower (Guangzhou, China), by Mr. Varun Kohli of Skidmore, Owings & Merrill (SOM) in New York. Construction of the Tower is now well under way. Afterwards, however, an important discussion took place concerning the issue of fire safety, and fire engineering generally, in Sustainable Buildings. It became clear to all of the participants that this issue is a major oversight … an intentional gap … in the design of these buildings. I made the point, forcibly, that Sustainable Fire Engineering is open to innovation and design creativity. There will be an important follow-up to this discussion.
Colour photograph showing a silly tourist on a bicycle rickshaw, as he is brought sightseeing around the Bazaar District in Old Delhi. Click to enlarge. Photograph taken by Mr. Daljeet Singh, Ministry of Tourism, with CJ Walsh's camera. 2010-01-09.
Unfortunately, the conference was peppered with references to ‘Green’ Buildings … an outdated marketing concept (!) … which, within its limited world-view, gives people the false comfort of not having to deal with thorny issues such as ‘social justice, solidarity & inclusion for all’. I have discussed this issue many times in previous posts.
Even more unfortunately, where the Brundtland Definition of ‘Sustainable Development’ was actually presented in one session … as usual, it was only the first half of the definition which made any appearance. The second, and more important, half of the definition had mysteriously vanished without trace … which made the whole effort a meaningless exercise ! What a waste !! No wonder there is such confusion over the concept … at all levels … in most countries !!!
It was not surprising, therefore, that what was not stressed enough, during the entire conference, was that Sustainable Design Solutions must be appropriate to local geography, climate, economy, culture, social need and language(s)/dialect(s), etc. The LEED Building Rating System (USA), for example, is not being properly adapted to local conditions in India !
A final issue … another major oversight … another intentional gap … in the design of buildings … Accessibility-for-All ! Even though India ratified the 2006 UN Convention on the Rights of Persons with Disabilities on 1st October 2007 … this essential aspect of design … certainly in Sustainable Buildings … received no mention whatever during the conference … except by yours truly, in my presentation.
Overall … a magnificent achievement for the organizers !
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Disability Access Certificates & Accessible Toilet Facilities ? (III)
Missing so far in Ireland … but an essential starting point for any discussion about Disability & Accessibility of the Built Environment in many other countries … is the 2006 United Nations Convention on the Rights of Persons with Disabilities, which entered into force, i.e. became an International Legal Instrument, on 3rd May 2008.
This Convention is important because it facilitates access, for a large group of people in all of our communities, to the Rights, i.e. basic needs, of all human beings … which were first elaborated in the 1948 Universal Declaration of Human Rights. Until now, access to Universal Rights has effectively been denied to people with disabilities.
How is Ireland responding to the UN Convention ?
Ireland signed the Convention on 30th March 2007 … but has still not signed the Convention’s Optional Protocol. Furthermore … even though other European Union Member States have proceeded to ratify both the Convention and the Optional Protocol on their own, without waiting for all Member States to act in unison … Ireland has not ratified either. Why is that ???
On the positive side … and at the time of writing …
- 143 countries, including Ireland, have signed the Convention ;
- 87 other countries have signed the Optional Protocol ;
- 71 other countries have ratified the Convention ;
- 45 other countries have ratified the Optional Protocol.
2006 UN Convention on the Rights of Persons with Disabilities. PDF File. 215kb.
Click above to read and/or download PDF File
With regard to Accessibility … refer, initially and directly, to Preamble Paragraph (g) and Articles 9 & 11 of the Convention.
[As a matter of routine in all of our work, I prefer to go beyond the scope of the 2006 Disability Rights Convention ... and to consider Accessibility for All, i.e. including People with Activity Limitations (2001 WHO ICF), to the Human Environment.]
Accessibility Implementation in Ireland & Toilet Facilities
How more basic can you get in every day life and living ?
The WC Cubicle shown in Diagram 13 of the existing Technical Guidance Document M does not work … a black and white / open and shut case. It has not worked for a long, long time. It is not ‘accessible’. Should this come as a sudden surprise to anybody ? No.
That toilet arrangement dates back to guidance documentation published by the Irish National Rehabilitation Board (NRB) in the early 1980′s. And since that guidance took a long time to produce … we are talking about well before the end of the 1970′s as its true date of origin. I know, because I was there … and I have the T-Shirt !
I am not going to show that Diagram here, because I don’t want to encourage anybody to reproduce it again in a ‘real’ building … for any reason whatsoever !
Nearly 30 years later (!) … the Wheelchair Accessible Unisex WC shown in Diagram 12 of Draft Technical Guidance Document M (2009) is not a significant improvement on the earlier version. In fact, it is a miserable effort ! And … I am not going to show that Diagram here either … for the same reason.
What I would like to present, however, are Figures 43 & 44 from the Draft International Accessibility-for-All Standard ISO 21542. This is the level of accessibility performance which we should all be striving to achieve … as a minimum !
2 colour drawings showing, on top, an Accessible Toilet Facility, with corner WC arrangement ... and, on the bottom, showing that there is sufficient space for a range of wheelchair to WC transfer options.
N.B. A standard, large Wash Hand Basin must no longer be considered as an optional extra in a properly fitted out Accessible Toilet Facility.
Please also note the independent water supply, on the wall side of the corner WC, feeding a shower head type outlet which can be turned on or off at the outlet head … or within easy reach of the WC. This is Accessibility-for-All in action.
Colour photograph showing what is supposed to be an 'Accessible' Toilet Facility, with a combined Baby Change Facility. Inadequate management magnifies the already poor accessibility performance of the cramped space. Click to enlarge. Photograph taken by CJ Walsh. 2009-09-19.
Many building owners/managers wish to combine an Accessible WC Cubicle with a Baby Change Facility. More space is required, therefore, above and beyond that shown in the Figures above for the Baby Change fittings and associated ‘equipment’.
Without Proper Accessibility Management … Accessibility Performance will rapidly deteriorate … as shown in the above photograph.
Once we have mastered the minimum building accessibility performance required to meet the needs of a single person with an activity limitation … our next priority must be the Social Dimension of Accessibility. Existing Building & Fire Regulations, Standards and Design Guidance are still geared very much towards the single building user. However, for example, if 5 or 6 or 8 wheelchair users decide to use a building’s facilities … not a concept which is off-the-wall (!) … there is almost a complete breakdown and failure in accessibility. This is no longer acceptable !!
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Building Fire Emergencies – What is a ‘Place of Safety’ ?
As I have travelled around … not just Ireland, but many other countries as well … it still remains a puzzle to me, today, why so many Fire Emergency Assembly Areas are located just outside the main entrance of a building. These locations are not safe in a ‘real’ fire emergency … and they should not even be used for the purposes of test/drill evacuations !
Is the guidance contained in current Building & Fire Regulations, Codes and Standards on what is a ‘Place of Safety’ in a fire emergency clear, simple, direct and precise ? Are you joking ? No way ! Let us take a few examples close to home …
In Ireland:
When you look at the array of different Technical Guidance Documents (Building Regulations) at the same time … TGD B (Fire Safety) is way out of proportion, in size, compared to all of the others. You would expect, therefore, to find exactly what you were looking for in that document. Wouldn’t you ?
TGD B (2006), Paragraph #1.0.9 – Definitions
Place of Safety
A place, normally in the open air at ground level, in which persons are in no danger from fire.
Clear as mud ! If there is a fire on O’Connell Street in Dublin … a person is safe on Patrick Street in Cork ! But, how is any Building or Facilities Manager expected to work with such a vague definition ?
In England & Wales:
No practical definition, as such, is readily provided. The nearest thing to a definition is an amalgam of the following …
Building Regulations, Requirement B1 – Means of Warning & Escape
The building shall be designed and constructed so that there are appropriate provisions for the early warning of fire, and appropriate means of escape in case of fire from the building to a place of safety outside the building capable of being safely and effectively used at all material times.
Approved Document B: Volume 1 – Dwellinghouses & Volume 2 – Buildings Other Than Dwellinghouses
The ultimate place of safety is the open air clear of the effects of the fire.
British Standard BS 9999 : Code of Practice for Fire Safety in the Design, Management & Use of Buildings : 2008
Place of Ultimate Safety
Place in which there is no immediate or future danger from fire or from the effects of a fire.
Again … all as clear as mud ! Again … how is any Building or Facilities Manager expected to work with such vague guidance ? Have you also noticed the additional obfuscation introduced by use of the word ‘ultimate’ in BS 9999 ?
It is hard to escape the conclusion that what is urgently needed is a fundamental transformation and re-shaping of the tired, antiquated and flawed ad-hoc assembly of prescriptive ‘solutions’ contained in current national building and fire regulations, codes, standards and administrative provisions … whatever their origin !
Now … try this for clarity, simplicity, directness and precision …
Place of Safety (Fire Incident in a Building, No Explosion Hazard*)
Any location beyond a perimeter which is [100]* metres from the fire building or a distance of [10]* times the height of such building, whichever is the greater
and
where necessary and effective medical care and attention can be provided, or organized, within one hour of injury
and
where people can be identified.
* Where there is a Risk of Explosion … multiply the numbers in square brackets above by 4.
Was that good for you ?
Furthermore …
The Route to any Place of Safety must be Accessible for All Building Users, including people who use wheelchairs, the visually impaired, frail older people, women in the later stages of pregnancy, children, etc., etc.
Colour photograph showing a Typical Scene at a Building Fire Emergency, with Fire Service Vehicles and Personnel in operation mode. The haphazard arrangement of firefighting water hoses on the ground makes access difficult for many Building Users to a 'Place of Safety' which is remote from the Fire Building.
With regard to an Adequate, never mind a Proper, Awareness of Disability-Related Issues at a Fire Scene … it is shocking to realize how almost non-existent this is among Fire Services … not just in Ireland and Britain … but in the rest of Europe and North America as well.
Even a hint of criticism will usually … not always … meet the Neanderthal Fire Service Response: “Have you ever been in a ‘real’ building fire ?”
My Response is: “Do you have to be a hen to know when an egg is bad ?”
This discussion will continue later … have no doubt … that is a promise !
END
Disability Access Certificates – Parts M & B ? (II)
In everyday practice, the usual short introductory text in Technical Guidance Document M (Ireland) which refers to a linkage between ‘access and use’ of a building with ‘fire safety’ has little impact, because it is not explained … and is typically ignored.
In general … the basic problem is that this issue is hardly dealt with … at all … by Local Fire Authorities right across the country in their handling of Fire Safety Certificates … and where it does become part of the process, it receives inadequate attention. There are exceptions.
A major drawback with the current vertical approach to our Building Regulations … each of the Parts has its own separate Supporting Technical Guidance Document … is that people are not sufficiently aware of the important horizontal linkages between the different Parts. For example, all of the other Parts must be linked to Part D. Quick, run to find out what Part D covers ! Another two examples … Part B must also be linked to Part A and Part M … and Part M must also be linked to Part K and Part B.
So … while grudgingly having to accept that the scope of TGD M should have some limit, under the current flawed system … a precise intervention with just one or two sentences, at critical places in the guidance text, would help to improve the overall consideration of fire safety issues, relevant to Part M, by building designers … and client or construction organizations.
Here are a Few Suggestions for Discussion …
1. Revise Paragraph #0.6 of Draft TGD M (2009) & Add a Title …
Fire Evacuation for All
” Accessibility encompasses the full range of activity related to buildings: to approach, enter, use, egress from under normal conditions, and evacuate a building independently during a fire emergency, in an equitable and dignified manner. Provision for access and use must, therefore, be linked to provision for fire evacuation. For guidance on design for evacuation, reference should be made to Technical Guidance Document B (Fire Safety).”
Note: No such guidance is contained in TGD B (2006). It would be a great wonder if any person with a disability could actually evacuate a building which had been designed in accordance with TGD B. To take a simple example … all of the ‘stairways’ in Table 1.5 of TGD B – Minimum Width of Escape Stairways will not facilitate contraflow or the assisted evacuation of mobility and visually impaired people. Furthermore, those minimum widths specified in the Table may have a clear width which is 200 mm less. See Methods of Measurement, Paragraph #1.0.10 (c) (iii) … ” a stairway is the clear width between the walls or balustrades, (strings and handrails intruding not more than 30 mm and 100 mm respectively may be ignored) ” ! What an incoherent mess !!
2. Insert New Sentence at the End of Paragraph #1.1.1 of Draft TGD M (2009) …
Objective (Approach to Buildings)
” Consideration should be given to the use of the approach and circulation routes around a building as accessible routes to a ‘place of safety’ during a fire emergency.”
3. Insert New Sentence at the End of Paragraph #1.2.1 of Draft TGD M (2009) …
Objective (Access to Buildings)
” Consideration should be given to the use of all entrances to a building as accessible fire exits during a fire emergency.”
4. Insert New Paragraph at the End of Paragraph #1.3.4.1 of Draft TGD M (2009) …
Passenger Lifts
” Manual handling of occupied wheelchairs in a fire evacuation staircase, even with adequate training for everyone directly and indirectly involved, is hazardous for the person in the wheelchair and those people – minimum three – giving assistance. The weight of an average unoccupied powered wheelchair, alone, makes manual handling impractical. Lifts in new buildings should, therefore, be capable of being used for evacuation in a fire situation. For guidance on the use of lifts for fire evacuation, reference should be made to Technical Guidance Document B (Fire Safety).”
5. Insert New Paragraph and New Sentence at the End of Paragraph #1.3.4.2 of Draft TGD M (2009) …
Internal Stairs
” To allow sufficient space to safely carry an occupied wheelchair down or up a fire evacuation staircase, and to accommodate contraflow, i.e. emergency access by firefighters entering a building and moving towards a fire, while people are still evacuating from the building to a ‘place of safety remote from the building, the clear unobstructed width (exclusive of handrails and any other projections, e.g. portable fire extinguishers, notice boards, etc.) of the flight of a single, or multi-channelled, stairs should not be less than 1 500 mm. The surface width of a flight of stairs should not be less than 1 700 mm.”
Note: See Footnote (5) to Table 1.5 in TGD B (2006) … ” The minimum widths given in the table may need to be increased in accordance with the guidance in TGD M: Access for People with Disabilities.” DUH ?
And …
” For the purpose of safe assisted fire evacuation of people, the rise of a step should not have a height greater than 150 mm, and the going of a step should not have a depth less than 300 mm.”
6. Insert New Sentence at the End of Paragraph #1.5.1 of Draft TGD M (2009) …
Objective (Facilities in Buildings)
” Consideration should be given to the use of relevant facilities within a building, by people with disabilities, for the purposes of fire safety, protection and evacuation.”
7. Insert New Sentence at the End of Paragraph #1.6.1 of Draft TGD M (2009) …
Objective (Aids to Communication)
” Consideration should be given to the use of relevant aids to communication, by people with disabilities, for the purposes of fire safety, protection and evacuation.”
Note: More guidance could be provided under each of the individual paragraphs of Section #1.6 of Draft TGD M (2009). See Draft International Accessibility-for-All Standard ISO 21542.
8. Insert New Section #2.6 of Draft TGD M (2009) …
Fire Safety in Dwellings for People with Disabilities
END
Disability Access Certificates – A Time to Worry ? (I)
Some of you are already hitting the Internet Search Engines … with fierce intent altogether … about Disability Access Certificates (DAC’s) ! Is it time to panic ? No.
For a simple and direct hit, the 2 most relevant Irish Legal Instruments are:
1. Statutory Instrument No. 352 of 2009 – Building Control Act 2007 (Commencement) Order 2009.
This states …
” The 30 September 2009 is appointed as the day on which the provisions of Sections 5 and 6 of the Building Control Act 2007 shall come into operation.”
Section 5 covers the Amendment of Section 6 (Building Control Regulations) of the Building Control Act 1990.
Section 6 covers the Amendment of Section 7 (Appeals) of the Building Control Act 1990.
2. Statutory Instrument No. 351 of 2009 – Building Control (Amendment) Regulations 2009.
This states …
” These Regulations shall come into effect on 1 October 2009, except for the provisions of Article 8 which shall come into effect on 1 January 2009.”
Article 8 covers Disability Access Certificates and Revised Disability Access Certificates.
For you, yourself, to properly examine all of the ‘ins and outs’ of this New Certification Scheme … download the PDF File below … and then search the document (making sure that it is not case-sensitive !) using the phrase ‘Disability Access Certificate’. You will find 99 instances where the phrase is used.
Enjoy !
Click above to view and/or download PDF File
In order to make full sense of all that is happening, and is intended to happen in the not too distant future … there are a few other Legal Instruments, related to the two listed, which also need to be consulted … but that is an exercise meant for masochists !
In comparison, the European Union Lisbon Treaty was a sweet bedtime story ! Seriously !!
Is it time to worry ? Yes.
Here are just a few random ideas for your cogitation …
- If the Department of the Environment, Heritage & Local Government (DEHLG) pays little heed to Submissions made during and after this summer’s ‘consultation’ process … the proposed New Technical Guidance Document M: ‘Access & Use’ will end up looking like a real dog’s dinner of an absolute mess ! FUBAR.
Years were spent in the preparation of the New TGD M. When it does eventually appear, it will be an accurate reflection of technical capacities within both the Department and the National Disability Authority (NDA).
Deeply regretted is the absence of Mr. Kevin Spencer … a gentle soul … from the DEHLG. Things have not been the same since his departure. He knew what he was talking about.
- Who will deal, at a technical level, with Applications for Disability Access Certificates in the Local Authorities ? Will they be competent to do so ? Will their interpretation of the Part M Legal Requirements be harmonized … not just with other/different Authorities … but even with other technical personnel in the same Authority ???
- In order to make this new certification scheme work, will the Guidance Text in Technical Guidance Document M (whatever version appears !) be operated as if it were Prescriptive Regulation … which will be totally illegal ?
This has been exactly the story … for many years … with the Guidance Text in Technical Guidance Document B … in the course of operation of the Fire Safety Certification Scheme. FUBAR.
- If, as I hinted above, the proposed New Technical Guidance Document M: ‘Access & Use’ will be a real dog’s dinner of a mess … falling far short of what can now be reasonably described as minimal accessibility performance (see the Draft International Accessibility-for-All Standard ISO 21542) … this will certainly open Building Owners/Managers of newly completed buildings to Complaints under Irish Equality Legislation. Why is the Disability Sector so inactive with regard to making complaints ?
and finally …
- Are the relevant Irish Decision Makers, as I suggested might happen in a previous post, in the process of actually sleepwalking into an unquestioned acceptance of the inadequate British Standards BS 9999 : 2008 and BS 8300 : 2009 ??? Do they know how to do anything else ?
For some sublime moments of meditation, however, please chew on the information provided at these Pages on the SDI Support WebSite …
Disability Rights & Removing Physical Restrictions on Participation in Society ;
Towards a Sustainable Social Environment, Accessibility-for-All & Facilitation Design (2001 WHO ICF) ;
Fire Evacuation-for-All & Principles of Fire Engineering.
END
Buildings of Historical, Architectural & Cultural Importance !
Deeply interested … and ‘luuuving’ … a hands-on and direct involvement in the Sustainable Restoration of Buildings which are of Historical, Architectural or Cultural Importance … or even those buildings which are not so important … I am deeply frustrated and angry when I look around at what has happened … and continues to happen … in Ireland … horrible, damaging interventions and alterations of all kinds … too many of which cannot be undone.
Certain guru-like organizations and individuals must be robustly challenged !
Yes … in everyday practice, there are pressures concerning an improvement of energy performance (BER Certificates !) … an improvement of accessibility performance for people with activity limitations (2001 WHO ICF) … an improvement of fire safety performance, etc., etc. … and, in the next few short years, adaptation to climate change will require serious attention.
BUT – BUT – BUT … in dealing with these buildings (a priceless heritage for our children, and their children, which cannot be replaced !) … some absolutely core principles must influence the minds of decision-makers in client and construction organizations, regulators and, most importantly, the minds and souls of architects and engineers. Do engineers have souls ?
ICOMOS – International Council on Monuments & Sites / Conseil International des Monuments et des Sites – works for the conservation and protection of cultural heritage places and is the only global, non-governmental organization of its kind. It is dedicated to promoting the application of theory, methodology, and scientific techniques to the conservation of the architectural and archaeological heritage. Its work is based on the principles enshrined in the 1964 International Charter on the Conservation and Restoration of Monuments and Sites (Venice Charter).
From practical experience, I have found the 16 Principles of the 1964 Venice Charter to be enormously helpful …
ARTICLE 1 The concept of an historic monument embraces not only the single architectural work but also the urban or rural setting in which is found the evidence of a particular civilization, a significant development or an historic event. This applies not only to great works of art but also to more modest works of the past which have acquired cultural significance with the passing of time.
ARTICLE 2 The conservation and restoration of monuments must have recourse to all the sciences and techniques which can contribute to the study and safeguarding of the architectural heritage.
ARTICLE 3 The intention in conserving and restoring monuments is to safeguard them no less as works of art than as historical evidence.
ARTICLE 4 It is essential to the conservation of monuments that they be maintained on a permanent basis.
ARTICLE 5 The conservation of monuments is always facilitated by making use of them for some socially useful purpose. Such use is therefore desirable but it must not change the lay-out or decoration of the building. It is within these limits only that modifications demanded by a change of function should be envisaged and may be permitted.
ARTICLE 6 The conservation of a monument implies preserving a setting which is not out of scale. Wherever the traditional setting exists, it must be kept. No new construction, demolition or modification which would alter the relations of mass and colour must be allowed.
ARTICLE 7 A monument is inseparable from the history to which it bears witness and from the setting in which it occurs. The moving of all or part of a monument cannot be allowed except where the safeguarding of that monument demands it or where it is justified by national or international interest of paramount importance.
ARTICLE 8 Items of sculpture, painting or decoration which form an integral part of a monument may only be removed from it if this is the sole means of ensuring their preservation.
ARTICLE 9 The process of restoration is a highly specialized operation. Its aim is to preserve and reveal the aesthetic and historic value of the monument and is based on respect for original material and authentic documents. It must stop at the point where conjecture begins, and in this case moreover any extra work which is indispensable must be distinct from the architectural composition and must bear a contemporary stamp. The restoration in any case must be preceded and followed by an archaeological and historical study of the monument.
ARTICLE 10 Where traditional techniques prove inadequate, the consolidation of a monument can be achieved by the use of any modem technique for conservation and construction, the efficacy of which has been shown by scientific data and proved by experience.
ARTICLE 11 The valid contributions of all periods to the building of a monument must be respected, since unity of style is not the aim of a restoration. When a building includes the superimposed work of different periods, the revealing of the underlying state can only be justified in exceptional circumstances and when what is removed is of little interest and the material which is brought to light is of great historical, archaeological or aesthetic value, and its state of preservation good enough to justify the action. Evaluation of the importance of the elements involved and the decision as to what may be destroyed cannot rest solely on the individual in charge of the work.
ARTICLE 12 Replacements of missing parts must integrate harmoniously with the whole, but at the same time must be distinguishable from the original so that restoration does not falsify the artistic or historic evidence.
ARTICLE 13 Additions cannot be allowed except in so far as they do not detract from the interesting parts of the building, its traditional setting, the balance of its composition and its relation with its surroundings.
ARTICLE 14 The sites of monuments must be the object of special care in order to safeguard their integrity and ensure that they are cleared and presented in a seemly manner. The work of conservation and restoration carried out in such places should be inspired by the principles set forth in the foregoing articles.
ARTICLE 15 Excavations should be carried out in accordance with scientific standards and the recommendation defining international principles to be applied in the case of archaeological excavation adopted by UNESCO in 1956.
Ruins must be maintained and measures necessary for the permanent conservation and protection of architectural features and of objects discovered must be taken. Furthermore, every means must be taken to facilitate the understanding of the monument and to reveal it without ever distorting its meaning.
All reconstruction work should however be ruled out ‘a priori’. Only anastylosis, that is to say, the reassembling of existing but dismembered parts can be permitted. The material used for integration should always be recognizable and its use should be the least that will ensure the conservation of a monument and the reinstatement of its form.
ARTICLE 16 In all works of preservation, restoration or excavation, there should always be precise documentation in the form of analytical and critical reports, illustrated with drawings and photographs. Every stage of the work of clearing, consolidation, rearrangement and integration, as well as technical and formal features identified during the course of the work, should be included. This record should be placed in the archives of a public institution and made available to research workers. It is recommended that the report should be published.
Footnote on Building Energy Rating (BER) Certificates in Ireland
Unless and until that magnificent marketing and public relations firm … Energy Ireland (SEI) … can openly show that the DEAP Software has been properly modified to handle buildings of historical, architectural or cultural importance … and this modification is fully transparent … BER Certification for these building types must be put on hold.
END
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