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Sustainable Fire Engineering – 2016 End Of Year Report !

2016-12-28:  Happy New Year to One and All !

SUSTAINABLE FIRE ENGINEERING

‘ The creative, person-centred and ethical Fire Engineering response, in resilient built form and smart systems, to the concept of Sustainable Human and Social Development – the many aspects of which must receive balanced and synchronous consideration.’

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Organized by FireOx International (Ireland, Italy & Turkey), in joint collaboration with Glasgow Caledonian University’s School of Engineering & Built Environment (Scotland) … and having a widely multi-disciplinary attendance from the U.S.A., Hong Kong SAR (China), Spain, Finland, Scotland, Norway, Germany, England, The Netherlands and Ireland … SFE 2016 DUBLIN was a unique, and very successful, two-day gathering within the International Fire Engineering and Fire Service Communities.

The organizers are very grateful to our Supporters: CIB, FIDIC, iiSBE, and the UNEP’s Sustainable Buildings and Climate Initiative … and our Sponsor: Rockwool International.

SUSTAINABLE FIRE ENGINEERING fulfils a Critical Role in the realization of a Safe, Resilient and Sustainable Built Environment 4 ALL !

SUSTAINABLE FIRE ENGINEERING facilitates Positive Progress in implementing the United Nation’s 2030 Sustainable Development Agenda, which incorporates 17 Sustainable Development Goals and 169 Performance Targets !

SUSTAINABLE FIRE ENGINEERING fast-tracks Proper Compliance with the 7 Basic Performance Requirements – functional, fully integrated and indivisible – in Annex I of European Union Construction Products Regulation 305/2011 !

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A NECESSARY & LONG OVERDUE TRANSFORMATION !

A Building is a permanent construction, complying with basic performance requirements and capable of being easily adapted … comprising structure, essential electronic, information and communication technologies (EICT’s), and fabric (non-structure) … having a minimum life cycle of 100 years … and providing habitable, functional and flexible interior spaces for people to use.

Building Users have a wide and varied range of abilities and behaviours … some having discernible health conditions and/or physical, mental, cognitive, psychological impairments … while others, e.g. young children, women in the later stages of pregnancy and frail older people, are also particularly vulnerable in user-hostile, inaccessible environments.  Not everyone will self-identify as having an activity limitation because of the high level of social stigma associated with ‘disability’.  Building designers and fire engineers must accept that building users have rights and responsible needs ;  the real individual and group fire safety requirements of vulnerable building users must be given proper consideration by both design disciplines, working collaboratively together.

Real Building Users have a wide and varied range of abilities … and during a Fire Evacuation, they will NOT behave like ‘marbles or liquid in a computer model’ !  People with Disabilities, on their own, account for approximately 20% of populations in developed countries … more in developing and the least developed countries.

NOBODY LEFT BEHIND !

‘Fire Safety for ALL’ in Buildings – Not Just for SOME – A Priority Theme of Sustainable Fire Engineering

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

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Following the savage 2008 Mumbai Hive Attack in India, and the more recent 2015 and 2016 Attacks in Europe, i.e. Paris, Brussels, Istanbul and Berlin … it is entirely wrong to assume that the main and/or only targets will be specific high-risk buildings types, i.e. Tall/High-Rise, Iconic, Innovative and Critical Function Buildings (refer to 2005 & 2008 NIST WTC 9-11 Recommendations).  All buildings and adjoining/adjacent public spaces must be carefully assessed for the risk of direct or collateral involvement in an Extreme Man-Made Event.

It is a fundamental principle of reliable and resilient structural engineering that horizontal and vertical structural members/elements of construction are robustly connected together.  All buildings must, therefore, be capable of resisting Disproportionate Damage.  The restriction of this requirement, within some jurisdictions, to buildings of more than five storeys in height is purely arbitrary, cannot be substantiated technically … and ethically, must be disregarded.

Fire-Induced Progressive Damage is distinguished from Disproportionate Damage – a related but different structural concept – by the mode of damage initiation, not the final condition of building failure.  This phenomenon is poorly understood.  But, unless it is impeded, or resisted, by building design … Fire-Induced Progressive Damage will result in Disproportionate Damage … and may lead to a Collapse Level Event (CLE), which is entirely unacceptable to the general population of any community or society.  All buildings must, therefore, be capable of resisting Fire-Induced Progressive Damage.

All buildings must also be carefully assessed for the risk of involvement in a Severe Natural Event, e.g. earthquakes, floods, landslides, typhoons and tsunamis.

In all of the above Risk Assessments … the minimum Return Period (also known as Recurrence Interval or Repeat Interval) must never be less than 100 years.

Reacting to surging energy, environmental and planetary capacity pressures … with accelerating climate change … Sustainable Buildings are now presenting society with an innovative and exciting re-interpretation of how a building is designed, constructed and functions … an approach which is leaving the International Fire Engineering and Fire Service Communities far behind in its wake, struggling to keep up.

Colour ‘infographic’ showing the design features of 1 Bligh Street, Sydney CBD, Australia … ‘tall’/skyscraper commercial office building, completed in 2011 … designed by Ingenhoven Architects (Germany) and Architectus (Australia).  Can Fire Engineers understand this new design approach … and then collaborate, actively and creatively, within the Project Design Team ?

Black and white plan drawing of 1 Bligh Street (Level 26), Sydney CBD, Australia … a ‘sustainable’ office building … BUT … Effective ‘Fire Safety for All’ in this building ?  Has Firefighter Safety been considered ??  Property Protection ???  Business Continuity ????  The very harmful Environmental Impacts of Fire ?????

Passive and Active Fire Protection Measures, together with Building Management Systems (whether human and/or intelligent), are never 100% reliable.  Society must depend, therefore, on firefighters to fill this reliability ‘gap’ … and to enter buildings on fire in order to search for remaining or trapped building users.  This is in addition to their regular firefighting function.  Therefore, there is a strong ethical obligation on building designers, including fire engineers, to properly consider Firefighter Safety … should a fire incident occur at any time during the life cycle of a building.

Structural Serviceability, Fire Resistance Performance and ‘Fire Safety for All’ in a building must, therefore, be related directly to the local Fire Service Support Infrastructure … particularly in developing and the least developed countries.  AND … Fire Codes and Standards must always be adapted to a local context !

Colour photograph showing knotted sheets hanging from high-level windows which were used for ‘escape’ by guests … clearly indicating a catastrophic failure of fire protection measures and management within the building. Fire and smoke spread quickly throughout the multi-storey hotel, resulting in 12 dead, and over 100 injured (approximately 1/3 critically).

Colour photograph showing a guest rescue by ladder.  Notice the condition of the ladder and firefighter protection.  Fire safety in a building must be related directly to local Fire Service Support Infrastructure … particularly in developing and the least developed countries.

The fire safety objectives of current Fire Codes and Standards are limited, usually flawed … and will rarely satisfy the real needs of clients/client organizations, or properly protect society.  Fire code compliance, in isolation from other aspects of building performance, will involve a consideration of only a fraction of the issues discussed above.  There is once again, therefore, a strong ethical obligation on building designers, including fire engineers, to clearly differentiate between the limited fire safety objectives in Fire Codes and Standards … and Project-Specific Fire Engineering Design Objectives … and to explain these differences to a Client/Client Organization.  Facility Managers must also explain these differences directly to an Organization’s Senior Management … and directly inform the Organization’s Board of Directors … as appropriate.SFE Mission:  To ensure that there is an effective level of Fire Safety for ALL – not just for SOME – in the Built Environment … to dramatically reduce all direct and indirect fire losses in the Human Environment … and to protect the Natural Environment.

4 Key SFE Concepts:  Reality – Reliability – Redundancy – Resilience !

SFE Design Solutions:  Are …

  • Adapted to Local Context & Heritage ;
  • Reliability-Based ;
  • Person-Centred ;   and
  • Resilient.

SFE SUBSIDIARY OBJECTIVES

  1. To transform Conventional Fire Engineering, as practiced today, into an ethical and fully professional Sustainable Design Discipline which is fit for purpose in the 21st Century … meaning … that fire engineers can participate actively and collaboratively in the sustainable design process, and can respond creatively with sustainable fire engineering design solutions which result in Effective Fire Safety for All in a Safe, Resilient and Sustainable Built Environment.
  2. To bring together today’s disparate sectors within the International Fire Engineering (and Science) Community … to encourage better communication between each, and trans-disciplinary collaboration between all.
  3. To initiate discussion and foster mutual understanding between the International Sustainable Development, Climate Change and Urban Resilience Communities … and the International Fire Engineering and Fire Service Communities.

SFE DELIVERABLES

1.  2016 Dublin Code of Ethics: Design, Engineering, Construction & Operation of a Safe, Resilient & Sustainable Built Environment for All.  Download from: http://www.sustainable-firengineering.ie/sfe2016dublin/wp-content/uploads/2016/09/2016_Dublin-Code-of-Ethics.pdf

The realization of a Safe, Inclusive, Resilient & Sustainable Built Environment demands a concerted, collaborative, very creative and widely trans-disciplinary effort at national, local, regional and international levels across the whole planet – Our Common Home.  The informed operation of appropriate legislation, administrative procedures, performance monitoring and targeting, and incentives/disincentives, at all of these levels, will facilitate initial progress towards this objective … but not the quantity, quality or speed of progress necessary.  Our time is running out !

This Code of Ethics applies … for those who subscribe to its values … to policy and decision makers, and the many different individuals and organizations directly and indirectly involved in the design, engineering, construction, and operation (management and maintenance) of a Safe, Resilient & Sustainable Built Environment for All.

The Purpose of this Code of Ethics is to guide the work of competent individuals and organizations in a context where incomplete or inadequate legislation, administrative procedures and incentives/disincentives exist … but, more importantly, where they do not exist at all … and, amid much confusion and obfuscation of the terms, to ensure that implementation is authentically ‘sustainable’, and reliably ‘safe’ and ‘resilient’ for every person in the receiving community, society or culture … before it is too late !

2.  Sustainable Fire Engineering Network … Join the LinkedIn SFE Group at https://www.linkedin.com/groups/8390667.  Interested Individuals and Organizations are all very welcome.

And … Like the Facebook SFE Page at https://www.facebook.com/sfe2016/

3.  New CIB W14: ‘Fire Safety’ Research Working Group VI Reflection Document: ‘Sustainable Fire Engineering Design, Construction & Operation’, which will establish a framework for the future development of Sustainable Fire Engineering.

Preparation of this Document will soon begin, and the following issues will be explored:

  • Conceptual Framework for Sustainable Fire Engineering (SFE), with a necessary accompanying Generic SFE Terminology ;
  • Strategy for Future SFE Development ;
  • Implementation of 2005 & 2008 NIST WTC 9-11 Recommendations ;
  • Fresh, New SFE Research Agenda ;
  • Resilient Implementation of SFE Research Agenda.

4.  SFE Websitehttp://www.sfe-fire.eu

5.  SFE Twitter Accounts … @sfe2016dublin … and … @firesafety4all

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Wind Turbine Fires – Facing Up To The ‘Environmental Impact’ !?!

2016-04-19:  A Priority Theme of  SFE 2016 DUBLIN, next September, is the ‘Adverse Environmental Impact’ caused by Preventable Fires in the Built Environment.  Last year’s horrendous devastation of large tracts of land, air and ground waters in the Tianjin port region of North-Eastern China is one very obvious example.

BUT, consider also … Wind Turbine Fires.  As we move closer and closer towards a planetary environmental precipice … there IS enormous pressure to harvest more and more energy from renewable, non-carbon resources.  Windmills, of old, used wind energy to perform an important function in a local context.  Everybody could see what was happening inside.  Local people reaped the benefits.  Modern wind turbines, on the other hand … ?

The First Major Issue concerning Wind Turbines, which received only half-hearted attention at best, was their …

Environmental Impact:  Any effect caused by a given activity on the environment, including human health, safety and welfare, flora, fauna, soil, air, water, and especially representative samples of natural ecosystems, climate, landscape and historical monuments or other physical structures, or the interactions among these factors; it also includes effects on accessibility, cultural heritage or socio-economic conditions resulting from alterations to those factors.

But, at least, ‘it’ was mentioned in conversations !

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Click image to enlarge.

The next major issue, the Fire Issue, is a different matter entirely.  This problem does NOT exist … NEVER happens … NOBODY KNOWS NOTHING !   And not just in Ireland or Europe … the ‘real’ fire statistics are either ignored, massaged or concealed.

Wind turbines differ from other forms of traditional power generation because of the inherent risk of total fire loss of the nacelle.  The main features of this risk include:

  • high concentration of value within the nacelle ;
  • high concentration of potential ignition sources within the nacelle, and increased risk of lightning strikes ;
  • unmanned operation ;
  • no possibility of fighting a fire in the nacelle by local fire service personnel, because they are too high up and/or there is no access for fire service vehicles ;
  • remote, sometimes very difficult to reach geographical locations of wind turbines, particularly in the case of offshore installations.

[ Nacelle:  A cover, or housing, for all of the generating components in a wind turbine, including the generator, gearbox, drive train, and brake assembly.]

The cost of wind turbines and their components, as well as restoration and repair costs after a fire, increase in proportion to installed generating capacity.  In addition, losses caused by service interruption also increase in a similar proportion.

According to the loss experience of Insurers, fires in wind turbines can cause significant damage to property and have very high post-fire costs.

Fire Loss in Wind Turbines Can Occur …

  • in the nacelle ;
  • in the tower ;
  • in the electrical sub-station of the wind turbine or wind farm.

Due to the high concentration of technical equipment and combustible material in the nacelle, fire can develop and spread rapidly.  There is also the danger that the upper tower segment will be damaged.  In the case of a total loss of the nacelle, restoration costs may well reach the original value of the whole turbine.

These ‘Preventable’ Fire Losses Are NOT Sustainable !

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PDF File, 601Kb – Click ‘CFPA-E Guideline’ link below to download.

Which is why, in September 2012, the European Fire Protection Associations decided to publish a common guideline in order to ensure similar interpretations in the different European countries … and to give examples of acceptable solutions, concepts and models.  The Confederation of Fire Protection Associations in Europe (CFPA-E) aims to facilitate and support fire protection work.

The European marketplace is constantly imposing new demands for quality and safety.  According to CFPA-E, fire protection forms an integral part of a modern business strategy for survival and competitiveness.  We thoroughly agree !

This CFPA-E Guideline (No.22 – September 2012) on Wind Turbine Fire Protection in Europe – produced by VdS Schadenverhütung and drafted by Hardy Rusch – is primarily intended for those people responsible for fire safety in companies and organizations.  It is also addressed to fire services, consultants, safety companies, etc … so that, in the course of their work, they may be able to assist companies and organizations in increasing levels of fire safety.

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Recent Fatal Fire at a Disabled Workshop in SW Germany

2012-11-28:  On Monday last, 26 November 2012 … Fire broke out at a Sheltered Workshop for People with Activity Limitations, located in the small municipality of  Titisee-Neustadt, south-western Germany … not too far from the borders of France and Switzerland.  It was approximately 14.00 hrs in the afternoon … in broad daylight.

German news reports put the death toll at 14 People, including 1 Carer … with 10 People injured.

News reports also state that it took 2 Hours for Firefighters to bring this incident under control.  At the time that Photograph 1, below, was taken … smoke had spread throughout a major part of the building.

Viewers should look closely at the top of the external staircase … then, ask yourselves how any person with an activity limitation can be safely rescued, or assisted to evacuate, by means of a ladder (obscured, at the end of the building on the left) … and, finally, notice the positioning of fire hoses on the ground and on the staircase … some of the many issues which have been discussed extensively here before …

Click to enlarge.

Click to enlarge.

Click to enlarge.

Click to enlarge.

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2005 NIST(USA) Final Report on 9-11 World Trade Center 1 & 2 Tower Collapses

–  Recommendation  #17b  –

 To the degree possible, people with activity limitations should be provided with a means for self-evacuation in the event of a building emergency.  Current strategies (and law) generally require these people to shelter-in-place and await assistance.  New procedures, which provide redundancy in the event that the fire warden system or co-worker assistance (e.g. the buddy system) fail, should consider full building evacuation, and may include use of fire-protected and structurally hardened elevators, motorized evacuation technology, and dedicated communication technologies.

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At the heart of the impressive show of fire fighting equipment and technology … and the usual reassuring statements by local officials and other people in authority after the event … there is an equally impressive lie …

Photograph by Patrick Seeger(dpa). Click to enlarge.

Photograph by Patrick Seeger(dpa). Click to enlarge.

Current Building Codes and Regulations, Fire Safety Standards, Building Design Practices, and Building Management Procedures … do not seriously consider the safety of People with Activity Limitations … not properly – not adequately – not even INadequately.  Tokenism is the best offer available in just a few European countries.

Photograph by Patrick Seeger(dpa). Click to enlarge.

Photograph by Patrick Seeger(dpa). Click to enlarge.

According to Spiegel OnLine International …

The rescue was difficult because some people panicked, said Local Fire Chief Alexander Widmaier.  “We are dealing here with people who naturally do not respond rationally”, he said.

IF this is an accurate news report, and bearing in mind that it is also a translation … I SAY …

Let us be generous and kind … Local Fire Chief Alexander Widmaier has NO awareness or understanding of People with Activity Limitations and the daily challenges they face in moving around and using a built environment which is inaccessible and unsafe.

According to AFP OnLine …

Gotthard Benitz, of the Titisee-Neustadt fire service, told AFP earlier that the fire began on the ground floor of the building which also had a basement and an upper floor.

“The victims were all on the same floor where the fire was”, he said adding this was the only area to have sustained fire damage and the stairwell had remained smoke-free meaning those on the other two floors had been able to use it.

He also said firefighters were prepared for dealing with an emergency at the workshop as practice fire alarms were regularly carried out there, with the last one having been last year.

The head of Caritas in Germany, Peter Neher, told ZDF public television that emergency practice drills were done regularly.

IF this is an accurate news report, and bearing in mind that it is also a translation … I SAY …

Gotthard Benitz should also look at the top of the external staircase in Photograph 1 above.  IF there are no circulation hazards, e.g. ice, or obstacles, e.g. fire hoses … able-bodied people can easily go up or down a staircase … people who use wheelchairs or other mobility-aid devices cannot.

In their respective positions of responsibility … Gotthard Benitz and Peter Neher should both understand that all building occupants must be facilitated in acquiring the skill of evacuation to a ‘place of safety’, by way of a safe and accessible route.  An emergency practice drill, although carried out regularly once a year … is ENTIRELY inadequate … and will achieve Very Little.

Skill:  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.

Standard fire evacuation training and practice drill procedures must be adapted to the individual-specific abilities of People with Activity Limitations.

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BUT … the new International Standard ISO 21542 is a very small step in the right direction.  See yesterday’s post.

This situation will only improve to a significant degree, however, when People with Activity Limitations, and their Representative Organizations, begin to act decisively, in unison, and with serious intent …

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Self-Protection from Fire in Buildings – Personal Check List for People with Activity Limitations

1.     Upgrade ‘My’ understanding of Accessibility

Ease of independent approach, entry, egress, evacuation 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.     Be assertive (not aggressive) with regard to ‘My’ own self-protection in emergency situations ;

3.     Concerning ‘My’ safety … demand that Building Management actively engages in Meaningful Consultation – and receives your Informed Consent ;

4.     Become familiar with the Fire Defence Plan for the building, and know ‘My’ part well ;

5.     Practice – practice – practice … become skilled in evacuation to a Place of Safety ;

6.     Become involved, and participate directly in the Building’s Safety Procedures.

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Self-Protection from Fire in Buildings  – Must-Do List for Representative Organizations & Groups

1.     Upgrade ‘Our’ understanding of Accessibility in a Social Context, its Current Vocabulary, and its Complexity … groups of individuals wish to socialize together … this is now, afterall, a recognised human and social right !

Ease of independent approach, entry, egress, evacuation 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, and group Wellbeing, during the course of those activities ;

2.     Be assertive (and aggressive) with regard to the availability of proper Data and Statistics – we must clearly identify ‘Our’ problem with the many restrictions placed on our participation in local communities ;

3.     Produce a working statement of an Individual’s Rights – on 1 Page (!) ;

4.     Issue clear guidelines on Reliable Advocacy ;

5.     Become involved, and participate directly in the improvement of Building Codes and Regulations, Fire Safety Standards, Building Design Practices, and Building Management Procedures ;

6.      Demand resources to Monitor ‘Effective’ Implementation … and Target Relevant and ‘Practical’ Research.

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Accessibility-for-All … New Context … Same Old Problems !

2012-04-21:  The context for considering and properly implementing Accessibility-for-All has changed … changed utterly … but some old problems persist, and stubbornly remain …

NEW INTERNATIONAL CONTEXT

     A.  At the time of writing, the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) has been ratified by 111 Countries and the European Union.

Concerning Accessibility of the Built Environment … UN CRPD Preamble Paragraph (g), and Articles 9 – 11 – 12 are the most immediately relevant.  These texts can be easily found elsewhere on this BLOG … please use the ‘search’ facility at the top, right-hand corner of the WebPage.

With the innovative, and internationally accepted, understanding of ‘Accessibility’ – as distinct from ‘Access’ – contained in ISO 21542 : 2011 … the concept meaning: approach and entry to a building, circulation within and use of all the building’s facilities, egress from and removal from the building’s vicinity during normal circumstances, or evacuation in the event of an emergency and movement – via a safe and accessible route – to a place of safety which is remote from the building … it is now possible to deal with Fire Evacuation of Buildings through Article 9 (Accessibility) of the UN CRPD, where it is more in scale … more at home, so to speak … rather than through Article 11 (Situations of Risk & Humanitarian Emergencies), which had to be the case before.

     B.  ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’ … is the important new International Standard mentioned above.  It was published in December 2011.

Ireland has no National Standard (or Code of Practice) on Accessibility.  So, in the absence of an appropriate Harmonized European Standard, ISO 21542 must take precedence over the National Standards of any other European Union Member State.

Here, however, there is a very large fly in the ointment … the guidance text in the 2010 Technical Guidance Document M has been ‘lifted’, almost en masse, from a British National Standard on ‘Access’ … not ‘Accessibility’.  And this flawed process has imported some serious errors into Irish Accessibility Design and Construction Practice … despite my warnings to the relevant authorities.  Please refer back to this post , dated 2009-06-14.

Scope of ISO 21542 : 2011

ISO 21542:2011 specifies a range of requirements and recommendations for many of the elements of construction, assemblies, components and fittings which comprise the built environment.  These requirements relate to the constructional aspects of access to buildings, to circulation within buildings, to egress from buildings in the normal course of events and evacuation in the event of an emergency.  It also deals with aspects of accessibility management in buildings.

ISO 21542:2011  contains provisions with respect to features in the external environment directly concerned with access to a building or group of buildings from the edge of the relevant site boundary or between such groups of buildings within a common site.  It does not deal with those elements of the external environment, such as public open spaces, whose function is self-contained and unrelated to the use of one specific building, nor does it deal with single family dwellings, other than those circulation spaces and fittings that are common to two or more such dwellings.

     C.  Of direct commercial interest within the European Union (and in any countries outside the EU who wish to trade with the EU and the European Economic Area) … Accessibility-Related Construction Products are now included in the framework of the (relatively) new European Union Regulation No.305/2011 of the European Parliament and of the Council, of 9 March 2011, laying down Harmonized Conditions for the Marketing of Construction Products and Repealing Council Directive 89/106/EEC.  [The old EU Directive 89/106/EEC has been repealed … it is finished, it is gone, it is no more !   There will, however, be a suitable transition period from old to new.]

Construction Product (EU Reg.305/2011)  means any product or kit which is produced and placed on the market for incorporation in a permanent manner in construction works or parts thereof and the performance of which has an effect on the performance of the construction works with respect to the basic requirements for construction works.

Construction Works (EU Reg.305/2011)  means buildings and civil engineering works.

Basic Requirement for Construction Works No. 4  in Annex I of the new EU Regulation 305/2011, states the following …

Safety and Accessibility in Use

The construction works must be designed and built in such a way that they do not present unacceptable risks of accidents or damage in service or in operation such as slipping, falling, collision, burns, electrocution, injury from explosion and burglaries.  In particular, construction works must be designed and built taking into consideration accessibility and use for disabled persons.

This is a suitable location for ‘Accessibility’ in Annex I … intimately connected to ‘Safety in Use’.  However, there is one potential drawback.  Specifying the level of safety in an EU Member State is the sole responsibility of the Authorities Having Jurisdiction (AHJ’s) in that Member State.

An Accessible Building is a Safer Building … but a Safe Building is not necessarily ‘Accessible’.  ‘Accessibility’ is a completely different concept to ‘Safety’.  EU Member States have no basis in EU Law … no justification whatever … for arbitrarily deciding on which level of ‘Accessibility’ is appropriate within their territories !

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SAME OLD PROBLEMS

With all of this New International Context on Accessibility finally in place … I continue to encounter the same old problems …

     1.  Bad Product Design

An enormous quantity of cheap, atrociously designed … you could almost use the word ‘ugly’ … Accessibility-Related Construction Products are imported every year into Ireland, from Britain.  This is one good reason, although not a very satisfactory reason, why architects hate ‘accessibility’ in buildings.  Building users notice fittings and fixtures … and if the fittings and fixtures are ugly … the building is ugly !   But occupational therapists, for example, are also specifying these types of products every day of the week here.

This has got to stop.  Proper attention must be paid to Good Design of Accessibility-Related Construction Products.  An Accessible Building does not have to look like a Hospital Ward !   And Good Design does not have to mean ‘expensive’ !!

I have seen many well designed Accessibility-Related Construction Products, available in the EU marketplace, which have been manufactured in countries such as France, Germany, Italy, and China.

Why can we not access these products in Ireland ??

     2.  No Product Approval

The National Building Regulations/Codes of EU Member States … and all EU Safety at Work legislation … demand that building products and systems must be properly shown to be ‘fit for their intended use in the location of use’.  End of story … very simple !   Regrettably, few people take any notice of this legal requirement.

Late last year, however, I encountered a Chinese Company which manufactured some nicely designed Accessibility-Related Construction Products.  I suggested to one of their sales personnel that, in order to place their products on the market anywhere in the European Union (or the European Economic Area) … there was an urgent need to update their existing ‘CE Mark’ Product Approval Documentation.  When I checked more closely, this Documentation was dubious.  I then suggested that they should place a correct, up-to-date and relevant CE Mark on their construction products … as a matter of priority.  And I received the following reply …

” i’d like to suggest that maybe you can pay for the cost to do this CE, and after you place orders in our factory, we promise return that back to you, and if you like, maybe you can act as our agency in Ireland, will you ? “

[ The sum of money being discussed here was €1,000.]

This proposal was off-the-wall, as we say here in Ireland.  But, I found it impossible to get annoyed … because this strange and weird understanding of the CE Mark, particularly in relation to Accessibility-Related Construction Products, is rife among European Manufacturers also … and European Notified Bodies.  How crazy is that ?

Perhaps my most unusual experience, back in the mid-1990’s, was having to explain to a Manager in a TÜV Laboratory, in Germany, that a Full Test Report must be issued to a Test Sponsor … after the test(s) has/have been completed.  This task required two to three hours of heated discussion !

And … in the absence of any reference to ‘Accessibility’ in the now repealed EU Directive 89/106/EEC … I have encountered some European Manufacturers of Accessibility-Related Construction Products … who, being fully aware of the value of a CE Mark, have used the backdoor method of the EU Medical Devices Directive in order to obtain a CE Mark.  And these were definitely not medical devices !

There is no effective control over the CE Marking of Construction Products within the European Union.  This is no reason to ignore the system … or to abuse the system.

However … if many more people paid attention to the legal requirement, and necessity, of Proper Product Approval and the CE Marking of Accessibility-Related Construction Products … and the professional duty and responsibility to check that compliance/conformity is properly shown … we would have a more Accessible and much Safer Built Environment !!!

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