2011-10-25:  NIST’s Recommendations on the 9-11 WTC Building Collapses … GROUP 1. Increased Structural Integrity – Recommendations 1, 2 & 3 (out of 30)

2011-11-18:  NIST WTC Recommendations 4-7 > Structural Fire Endurance … GROUP 2.  Enhanced Fire Endurance of Structures – Recommendations 4, 5, 6 & 7

2011-11-24:  NIST WTC Recommendations 8-11 > New Design of Structures … GROUP 3.  New Methods for Fire Resisting Design of Structures – Recommendations 8, 9, 10 & 11

2011-11-25:  NIST WTC Recommendations 12-15 > Improved Active Protection … GROUP 4.  Improved Active Fire Protection – Recommendations 12, 13, 14 & 15

2011-11-30:  NIST Recommendations 16-20 > Improved People Evacuation … GROUP 5.  Improved Building Evacuation – Recommendations 16, 17, 18, 19 & 20

2011-12-04:  NIST WTC Recommendations 21-24 > Improved Firefighting … GROUP 6.  Improved Emergency Response – Recommendations 21, 22, 23 & 24

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2011-12-07:  SOME PRELIMINARY COMMENTS …

  1.     Concerning Recommendation 25 below … yes, this Recommendation applies to the types of organizations identified in the text, but it should also be understood as applying to ALL Organizations … public or private, governmental or non-governmental or quasi-governmental, whatever, etc … ‘supported’ (see the text further down in Recommendation 25) with rigorous enforcement, in all cases, by publically appointed building control officials and/or by private, independent, competent technical control professionals.

Once more … and again and again (!) … confirmed by the sort of debacle seen at the Priory Hall Apartment Complex, in Dublin … Self-Certification / Self-Approval, i.e. ‘lite’ regulation, does not work.  For National Authorities Having Jurisdiction (AHJ’s), however, it is a cheap solution to a difficult, resource-devouring issue, i.e. protecting society and the consumer … in that order.

  2.     Concerning the Footnote to Recommendation 26 below … the choice should never be between either Fire Compartmentation or Sprinklers … or the other way around, whichever you prefer.  Neither is 100% reliable !

Fire Compartmentation

The division of a building into fire-tight compartments, by fire and smoke resisting elements of construction, in order …

• to contain an outbreak of fire, and to facilitate effective firefighting ;
• to prevent damage, within the building, to other adjoining compartments and/or spaces ;
• to protect a compartment interior from external fire attack, e.g. fire spread across the building’s facade or from an adjacent building ;
• to minimize adverse, or harmful, environmental impacts outside the building.

As developed as that definition is above, Fire Compartmentation should be regarded as just one Fire Safety Strategy / Fire Engineering Strategy … not the only strategy, and certainly not the main strategy.

Here are two reasons why not …

a)   The connection between compartment size and the ability to effectively fight a fire within a space of limited volume has been lost … so more and more, commercial pressure is being exerted on national authorities to expand the acceptable compartment sizes in buildings … which significantly increases the fire hazard ;

[ Remembering the difference between the limited Fire Safety Objectives of Building Codes/Regulations and the much broader Project-Specific Fire Engineering Objectives of Ethical Fire Engineering required to protect society and the full interests of our clients ... it is easy to understand why national authorities feel that they can respond positively to such commercial pressures.]

b)   In a Sustainable Building … it is a very common design strategy to take advantage of the natural patterns of air movement in a building, for either cooling or heating purposes, depending on local climate conditions.  So there is simply no compartmentation, as understood in conventional fire engineering terms … and this throws up a fundamental conflict between the two.  To be discussed in another post !

  3.     Concerning the 2nd Footnote to Recommendation 28 below … in the very same New York City … at 09.40 hrs on a Saturday morning, 28 July 1945 … lost in fog, a B-25 Bomber slammed head-on into the 79th Floor of the Empire State Building … and caused enormous damage.  That building is still standing today … and surprise, surprise … there was aviation fuel in the B-25 !

In a similar vein … Fire-Induced Progressive Collapse was not observed for the first time, in New York, on 11 September 2001 !

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2005 NIST WTC RECOMMENDATIONS

GROUP 7.  Improved Procedures and Practices

The procedures and practices used in the design, construction, maintenance, and operation of buildings should be improved to include encouraging code compliance by non-governmental and quasi-governmental entities, adoption and application of egress and sprinkler requirements in codes for existing buildings, and retention and availability of building documents over the life of a building.

NIST WTC Recommendation 25.

Non-governmental and quasi-governmental entities that own or lease buildings and are not subject to building and fire safety code requirements of any governmental jurisdiction are nevertheless concerned about the safety of building occupants and responding emergency personnel.  NIST recommends that such entities be encouraged to provide a level of safety that equals or exceeds the level of safety that would be provided by strict compliance with the code requirements of an appropriate governmental jurisdiction.  NIST further recommends that as-designed and as-built safety be certified by a qualified third party, independent of the building owner(s).  The process should not use self-approval for code enforcement in areas including interpretation of code provisions, design approval, product acceptance, certification of the final construction, and post-occupancy inspections over the life of the buildings.*

[ * F-46  The long-standing stated policy of the Port Authority of New York & New Jersey (PANYNJ) was to meet and, where appropriate, exceed the requirements of local building and fire codes, and it entered into agreements with the New York City Department of Buildings and the Fire Department of the City of New York in accordance with that policy.  Although the PANYNJ sought review and concurrence from New York City in the areas listed in the Recommendation, the PANYNJ was not required to yield, and appears not to have yielded, approval authority to New York City.  The PANYNJ was created as an interstate entity, a 'body corporate and politic', under its charter, pursuant to Article 1, Section 10 of the United States Constitution permitting compacts between states.  Further, there are many other similar non-governmental and quasi-governmental entities in the U.S.  A comprehensive review of documents conducted as part of this Investigation suggests that the WTC towers generally were designed and maintained consistent with the requirements of the 1968 New York City Building Code.  Areas of concern included fireproofing of the WTC floor system, height of tenant separation walls, and egress requirements for the assembly use spaces of 'Windows of the World' in WTC Tower 1 and the 'Top of the World' Observation Deck in WTC Tower 2.  These areas of concern did not play a significant role in determining the outcomes related to the events on 11th September 2001.]

NIST WTC Recommendation 26.

NIST recommends that state and local jurisdictions adopt and aggressively enforce available provisions in building codes to ensure that egress and sprinkler requirements are met by existing buildings.*  Further, occupancy requirements should be modified where needed (such as when there are assembly use spaces within an office building) to meet the requirements in model building codes.  Provisions related to egress and sprinkler requirements in existing buildings are available in such codes as the International Existing Building Code (IEBC), International Fire Code, NFPA 1, NFPA 101, and ASME A 17.3.  For example, the IEBC defines three levels of building alteration (removal and replacement or covering of existing materials and equipment, reconfiguration of space or system or installation of new equipment, and extending the work area in excess of 50% of the aggregate area of the building).  At the lowest level, there are no upgrade implications for sprinklers and the egress system.  At the next level, sprinklers are required in work areas serving greater than 30 people if certain other conditions related to building height and use such as shared exits also are met.  There are numerous requirements for means of egress, including number of exits, specification of doorsets, dead-end corridors and travel distances, lighting, signage, and handrails.  At the highest level, the sprinkler and egress requirements are identical to the second level without the minimum 30-person restriction and the other conditions related to building height and use.  The Life Safety Code (NFPA 101) applies retroactively to all buildings, independent of whether any work is currently being done on the building, and ASME A 17.3 applies retroactively to all elevators as a minimum set of requirements.

[ * F-47  The WTC towers were unsprinklered when built.  It took nearly 28 years after passage of New York City Local Law 5 in 1973, which required either compartmentation or sprinklering, for the buildings to be fully sprinklered (the Port Authority chose not to use the compartmentation option in Local Law 5).  This was about 13 years more than the 15-year period for full compliance with Local Law 5 that was set by Local Law 84 of 1979.]

NIST WTC Recommendation 27.

NIST recommends that building codes incorporate a provision that requires building owners to retain documents, including supporting calculations and test data, related to building design, construction, maintenance, and modifications over the entire life of the building.*  Means should be developed for off-site storage and maintenance of the documents.  In addition, NIST recommends that relevant information be made available in suitably designed hard copy or electronic formats for use by emergency responders.  Such information should be easily accessible by responders during emergencies.  Model Building Codes:  Model building codes should incorporate this Recommendation.  State and local jurisdictions should adopt and enforce these requirements.

[ * F-48  The availability of inexpensive electronic storage media and tools for creating large searchable databases makes this feasible.]

NIST WTC Recommendation 28.

NIST recommends that the role of the ‘Design Professional in Responsible Charge’* be clarified to ensure that:  (1) all appropriate design professionals (including, e.g. the fire protection engineer) are part of the design team providing the highest standard of care when designing buildings employing innovative or unusual fire safety systems;**  and (2) all appropriate design professionals (including, e.g. the structural engineer and the fire protection engineer) are part of the design team providing the highest standard of care when designing the structure to resist fires, in buildings that employ innovative or unusual structural and fire safety systems.  Affected Standards:  AIA Practice Guidelines.  Model Building Codes:  The International Building Code (IBC), which already defines ‘Design Professional in Responsible Charge’, should be clarified to address this Recommendation.  NFPA 5000 should incorporate the ‘Design Professional in Responsible Charge’ concept, and address this Recommendation.

[ * F-49  In projects involving a design team, the 'Design Professional in Responsible Charge' - usually the lead architect - ensures that the team members use consistent design data and assumptions, co-ordinates overlapping specifications, and serves as the liaison between the enforcement and reviewing officials and the owner.  This term is defined in the International Building Code (IBC) and in the International Code Council's Performance Code for Buildings and Facilities (where it is the Principal Design Professional).]

[ ** F-50  If the fire safety concepts in tall buildings had been sufficiently mature in the 1960's, it is possible that the risks associated with jet-fuel ignited multi-floor fires might have been recognized and taken into account when the impact of a Boeing 707 aircraft was considered by the structural engineer during the design of the WTC towers.]

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END

2011-10-25:  NIST’s Recommendations on the 9-11 WTC Building Collapses … GROUP 1. Increased Structural Integrity – Recommendations 1, 2 & 3 (out of 30)

2011-11-18:  NIST WTC Recommendations 4-7 > Structural Fire Endurance … GROUP 2.  Enhanced Fire Endurance of Structures – Recommendations 4, 5, 6 & 7

2011-11-24:  NIST WTC Recommendations 8-11 > New Design of Structures … GROUP 3.  New Methods for Fire Resisting Design of Structures – Recommendations 8, 9, 10 & 11

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2011-11-25:  SOME PRELIMINARY COMMENTS …

  1.     Reliability has always been an issue with Active Fire Protection Systems … but, it is neither acknowledged, nor fully understood, that … Reliability Is Equally An Issue With Passive Fire Protection Measures !

Furthermore, the following should always be taken into account when considering the Safety Factors to be applied in calculating the level of satisfactory fire safety and protection which is provided in a specific project … one of the design objectives in Ethical Fire Engineering.

For example, if Category C below is indicative of the design and construction quality on a particular building site … just think of the Priory Hall Apartment Development in Dublin (!) … the Safety Factors to be applied in the design should be high … and with regard to actual construction, it should be expected that the Reliability of both Active Fire Protection Systems and Passive Fire Protection Measures will be initially low … with Life Cycle Reliability being entirely non-existent.

Quality of Fire Engineering Design & Related Construction 

Category A

(a)   Design of the works is exercised by an independent, appropriately qualified and experienced architect/engineer/fire engineer, with design competence relating to fire safety and protection in buildings ;

(b)   Installation/fitting of related construction products/systems is exercised by appropriately qualified and experienced personnel, with construction competence relating to fire safety and protection in buildings ;

(c)   Supervision of the works is exercised by appropriately qualified and experienced personnel from the principal construction organization ;

(d)   Regular inspections, by appropriately qualified and experienced personnel familiar with the design, and independent of the construction organization(s), are carried out to verify that the works are being executed in accordance with the fire engineering design.

Category B

(a)   Design of the works is exercised by an independent, appropriately qualified and experienced architect/engineer/fire engineer ;

(b)   Installation/fitting of fire-related construction products/systems is exercised by appropriately qualified and experienced personnel ;

(c)   Supervision of the works is exercised by appropriately qualified and experienced personnel from the principal construction organization.

Category C

This level of design and construction execution is assumed when the requirements for Category A or Category B are not met.

  2.     With regard to Recommendations 12 & 13 below … in an earlier post in this series, and elsewhere, I have defined Disproportionate Damage … and differentiated that structural concept from the related concept of Fire-Induced Progressive Collapse.

A significant number of countries include a requirement on Resistance to Disproportionate Damage in their national building codes.  Often, it is only necessary to consider this requirement in the case of buildings having 5 Storeys, or more … a completely arbitrary height threshold.  I would consider that adequately tying together the horizontal and vertical structural elements of a building … any building … is a fundamental principle of good structural engineering !!

Putting it simply … for the purpose of showing compliance with this structural requirement … it is necessary to demonstrate that a building will remain structurally stable if a portion of the building’s structure is removed … always remembering that every building comprises both structure and fabric, i.e. non-structure.

In reality this may happen, and quite often does happen, when, for example, a large truck runs into the side of a building, which can happen anywhere … or there is a gas explosion in some part of the building, which happened in Dublin’s Raglan House back in 1987, and many times in other countries … or a plane hits a high-rise building, which happened to Milan’s iconic Pirelli Tower in 2002, and to New York’s Empire State Building way back in 1945 … etc., etc.  Raglan House collapsed … the Pirelli Tower and the Empire State Building did not.

[ The World Trade Center Towers were originally designed to absorb the impact of a large plane and to remain structurally stable afterwards ... in ambient conditions.  However, what was not considered in the ambient structural design was 'fire', i.e. the fuel tanks were empty and no fire in the building would be initiated as a result of the mechanical damage caused by the plane impact ... which, on 11 September 2001, proved to be a ridiculous basis for any structural design !   This is why 9-11 should be regarded, at its core, as being a very serious 'real' fire incident.]

What I am leading up to is this … the concept of removing a portion of a building, and it remaining structurally stable afterwards … should now – logically and rationally – also be incorporated into the fire engineering design of Active Fire Protection Systems.  In other words, if a portion of a building is removed, will any particular Active Fire Protection System continue to operate effectively in the rest of the building ?   This has implications for the location and adequate protection of critical system components in a building … and for the necessary redundancy, zoning and back-up alternative routeing which must be designed into the system from the beginning !

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2005 NIST WTC RECOMMENDATIONS

GROUP 4.  Improved Active Fire Protection

Active fire protection systems (i.e. sprinklers, standpipes/hoses, fire alarms, and smoke management systems) should be enhanced through improvements to the design, performance, reliability, and redundancy of such systems.

NIST WTC Recommendation 12.

NIST recommends that the performance and possibly the redundancy of active fire protection systems (sprinklers, standpipes/hoses, fire alarms, and smoke management systems) in buildings be enhanced to accommodate the greater risks associated with increasing building height and population, increased use of open spaces, high-risk building activities, fire department response limits, transient fuel loads, and higher threat profile.  The performance attributes should deal realistically with the system design basis, reliability of automatic/manual operations, redundancy, and reduction of vulnerabilities due to single point failures.  Affected Standards:  NFPA 13, NFPA 14, NFPA 20, NFPA 72, NFPA 90A, NFPA 92A, NFPA 92B, and NFPA 101.  Model Building Codes:  The performance standards should be adopted in model building codes by mandatory reference to, or incorporation of, the latest edition of the standard.

NIST WTC Recommendation 13.

NIST recommends that fire alarm and communications systems in buildings be developed to provide continuous, reliable, and accurate information on the status of life safety conditions at a level of detail sufficient to manage the evacuation process in building fire emergencies;  all communication and control paths in buildings need to be designed and installed to have the same resistance to failure and increased survivability above that specified in present standards.  This should include means to maintain communications with evacuating occupants that can both reassure them and redirect them if conditions change.  Pre-installed fire warden telephone systems can serve a useful purpose and may be installed in buildings and, if so, they should be made available for use by emergency responders.  All communication and control paths in buildings need to be designed and installed to have the same resistance to failure and increased survivability above that specified in present standards.  Affected Standards:  NFPA 1, NFPA 72, and NFPA 101.  Model Building and Fire Codes:  The performance standards should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard.

NIST WTC Recommendation 14.

NIST recommends that control panels at fire/emergency command stations in buildings be adapted to accept and interpret a larger quantity of more reliable information from the active fire protection systems that provide tactical decision aids to fire ground commanders, including water flow rates from pressure and flow measurement devices, and that standards for their performance be developed.  Affected Standards:  NFPA 1, NFPA 72, and NFPA 101.  Model Building and Fire Codes:  The performance standards should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard.

NIST WTC Recommendation 15.

NIST recommends that systems be developed and implemented for:  (1) real time off-site secure transmission of valuable information from fire alarm and other monitored building systems for use by emergency responders, at any location, to enhance situational awareness and response decisions, and maintain safe and efficient operation;*  and (2) preservation of that information either off-site, or in a black box that will survive a fire or other building failure, for purposes of subsequent investigations and analysis.  Standards for the performance of such systems should be developed, and their use should be required.  Affected Standards:  NFPA 1, NFPA 72, and NFPA 101.  Model Building and Fire Codes:  The performance standards should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard.

[ * F-35  The alarm systems in the WTC towers were only capable of determining and displaying: (a) areas that had at some time reached alarm point conditions; and (b) areas that had not.  The quality and reliability of information available to emergency responders at the Fire Command Station was not sufficient to understand the fire conditions.  The only information transmitted outside the buildings was the fact that the buildings had gone into alarm.  Further, the fire alarm system in WTC Building 7, which was transmitted to a monitoring service, was on 'test mode' during the morning of 11 September 2001, because routine maintenance was being performed.  Under test mode conditions: (1) the system is typically disabled for the entire building, not just for the area where work is being performed; and (2) alarm signals typically do not show up on an operator console.]

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END

2011-10-25:  NIST’s Recommendations on the 9-11 WTC Building Collapses … GROUP 1. Increased Structural Integrity – Recommendations 1, 2 & 3 (out of 30)

2011-11-18:  NIST WTC Recommendations 4-7 > Structural Fire Endurance … GROUP 2.  Enhanced Fire Endurance of Structures – Recommendations 4, 5, 6 & 7

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2011-11-24:  SOME PRELIMINARY COMMENTS …

  1.     The first of two NIST Publications being referenced in this Series of Posts is as follows …

NIST (National Institute of Standards and Technology).  September 2005.  Federal Building and Fire Safety Investigation of the World Trade Center Disaster: Final Report on the Collapse of the World Trade Center Towers.  NIST NCSTAR 1.  Gaithersburg, MD, USA.

The 2005 NIST Report concludes, in Chapter 9, with a list of 30 Recommendations for Action, grouped together under the following 8 Subject Headings …

i)        Increased structural integrity ;

ii)       Enhanced fire endurance of structures ;

iii)      New methods for fire resisting design of structures ;

iv)      Enhanced active fire protection ;

v)       Improved building evacuation ;

vi)      Improved emergency response ;

vii)     Improved procedures and practices ;   and

viii)    Education and training.

NIST has clearly stated that “the numerical ordering (of the Recommendations) does not reflect any priority”.

From my point of view, the 2005 NIST Report is especially noteworthy for the emphasis placed on:

(a)     The 3 R’s … Reality – Reliability – Redundancy ;

(b)     Evacuation Way Finding … should be ‘intuitive and obvious’ … a major challenge for building designers, since buildings are still typically designed for ‘access’ only.  In order to find the evacuation routes in a building, it is usually necessary to have a compass, a map, a magnifying glass, a torch … and a prayer book !!!   More about this in later posts …

  2.     However, following on from NIST’s emphasis on Reality … and just between you, me and the World Wide Web … there is a lot of misunderstanding in the International Fire Science and Engineering Community about what exactly is the Realistic End Condition.  But, here it goes …

Realistic End Condition:  A ‘real’ fire in a ‘real’ building, which is used by ‘real’ people with varying abilities in relation to self-protection, independent evacuation to a ‘place of safety’, and participation in the Fire Defence Plan for the building.

It is strange, therefore … and quite unacceptable … to have to point out that the Realistic End Condition IS NOT … a test fire or an experimental fire in a laboratory … or a design fire in a computer model, even IF it is properly validated !

  3.     With regard to Recommendation 8 below … NIST’s contention that “Current methods for determining the fire resistance of structural assemblies do not explicitly specify a performance objective” is not strictly the case.

If we examine Technical Guidance Document B (Ireland) and Approved Document B (England & Wales) once again, as examples close to home … Part B: ‘Fire Safety’ in both jurisdictions should be read in conjunction with its associated Part A: ‘Structure’, which contains a requirement on Disproportionate Damage.

In everyday practice, however, this never happens.  Instead, people dealing with Part B in both jurisdictions enter a sort of bubble … a twilight zone … and, if there is anything to do with structural performance in fire, they immediately refer to the Appendices at the back of both Guidance Documents (ignoring Part A altogether) … where we find a ‘single element’ approach to design, no consideration of connections, etc., etc., etc.

And … this fundamental error is further reinforced in Ireland because, under the national system of Fire Safety Certification for buildings, it is only Part B which is relevant.

At European Level, I would make the same point … under EU Regulation 305/2011 on Construction Products … Basic Requirement for Construction Works 2: ‘Safety in Case of Fire’ must be read in conjunction with Basic Requirement 1: ‘Mechanical Resistance & Stability’ … where we will again find a direct reference to Disproportionate Damage … and an indirect, but explicit, reference to Serviceability Limit States under normal conditions of use … including fire !

A major gap … the missing link at international level … is the failure, still, to elaborate and flesh out the structural concept of Fire-Induced Progressive Collapse.  More about this in later posts …

  4.     With regard to Recommendation 10 below … and amplifying my earlier comments concerning Recommendation 6 … the manufacturers of all Lightweight Structural Fire Protection Systems … not just the Sprayed Systems … have a lot to answer for.

Major question marks concerning Life Cycle Durability, and Resistance to Mechanical Damage at any stage in a building’s life cycle, hang over all of these systems.

Fire testing, alone, does not show that a Lightweight Structural Fire Protection System is ‘fit for its intended use’ !   And manufacturers well know this !!!

And as for the Installation of Lightweight Structural Fire Protection Systems on site … it’s a hornets’ nest that nobody wants to touch !

Vested interests … vested interests … vested interests !!!

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2005 NIST WTC RECOMMENDATIONS

GROUP 3.  New Methods for Fire Resisting Design of Structures

The procedures and practices used in the fire resisting design of structures should be enhanced by requiring an objective that uncontrolled fires result in burnout without partial or global (total) collapse.  Performance-based methods are an alternative to prescriptive design methods.  This effort should include the development and evaluation of new fire resisting coating materials and technologies, and evaluation of the fire performance of conventional and high-performance structural materials.

NIST WTC Recommendation 8.

NIST recommends that the fire resistance of structures be enhanced by requiring a performance objective that uncontrolled building fires result in burnout without partial or global (total) collapse.  Such a provision should recognize that sprinklers could be compromised, non-operational, or non-existent.  Current methods for determining the fire resistance of structural assemblies do not explicitly specify a performance objective.  The rating resulting from current test methods indicates that the assembly (component or sub-system) continued to support its superimposed load (simulating a maximum load condition) during the test exposure without collapse.  Model Building Codes:  This Recommendation should be included in the national model building codes as an objective, and adopted as an integral pert of the fire resistance design for structures.  The issue of non-operational sprinklers could be addressed using the existing concept of Design Scenario 8 of NFPA 5000, where such compromise is assumed and the result is required to be acceptable to the Authority Having Jurisdiction (AHJ).  Affected Standards:  ASCE-7, AISC Specifications, ACI 318, and ASCE/SFPE 29.

NIST WTC Recommendation 9.

NIST recommends the development of:  (1) performance-based standards and code provisions, as an alternative to current prescriptive design methods, to enable the design and retrofit of structures to resist real building fire conditions, including their ability to achieve the performance objective of burnout without structural or local fire collapse;  and (2) the tools, guidelines, and test methods necessary to evaluate the fire performance of the structure as a whole system.  Standards development organizations, including the American Institute of Steel Construction, have already begun developing performance-based provisions to consider the effects of fire in structural design.

This performance-based capability should include the development of, but not be limited to:

a.     Standard methodology, supported by performance criteria, analytical design tools, and practical design guidance;  related building standards and codes for fire resistance design and retrofit of structures, working through the consensus process for nationwide adoption;  comprehensive design rules and guidelines;  methodology for evaluating thermo-structural performance of structures;  and computational models and analysis procedures for use in routine design practice.

b.     Standard methodology for specifying multi-compartment, multi-floor fire scenarios for use in the design and analysis of structures to resist fires, accounting for building-specific conditions such as geometry, compartmentation, fuel load (e.g. building contents and any flammable fuels such as oil and gas), fire spread, and ventilation;  and methodology for rating the fire resistance of structural systems and barriers under realistic design-basis fire scenarios.

c.     Publicly available computational software to predict the effects of fires in buildings – developed, validated, and maintained through a national effort – for use in the design of fire protection systems and the analysis of building response to fires.  Improvements should include the fire behaviour and contribution of real combustibles;  the performance of openings, including door openings and window breakage, that controls the amount of oxygen available to support the growth and spread of fires and whether the fire is fuel-controlled or ventilation-controlled;  the floor-to-floor flame spread;  the temperature rise in both insulated and un-insulated structural members and fire barriers;  and the structural response of components, sub-systems, and the total building system due to the fire.

d.     Temperature-dependent thermal and mechanical property data for conventional and innovative construction materials.

e.     New test methods, together with associated conformance assessment criteria, to support the performance-based methods for fire resistance design and retrofit of structures.  The performance objective of burnout without collapse will require the development of standard fire exposures that differ from those currently used.

Affected National and International Standards:  ASCE-7, AISC Specifications, ACI 318, and ASCE/SFPE 29 for fire resistance design and retrofit of structures;  NFPA, SFPE, ASCE, and ISO TC92 SC4 for building-specific multi-compartment, multi-floor design basis fire scenarios;  and ASTM, NFPA, UL, and ISO for new test methods.  Model Building Codes:  The performance standards should be adopted as an alternative method in model building codes by mandatory reference to, or incorporation of, the latest edition of the standard.

NIST WTC Recommendation 10.

NIST recommends the development and evaluation of new fire resisting coating materials, systems, and technologies with significantly enhanced performance and durability to provide protection following major events.  This could include, for example, technologies with improved adhesion, double-layered materials, intumescent coatings, and more energy absorbing SFRM’s.*  Consideration should be given to pre-treatment of structural steel members with some type of mill-applied fire protection to minimize the uncertainties associated with field application and in-use damage.  If such an approach were feasible, only connections and any fire protection damaged during construction and fit-out would need to be field-treated.  Affected Standards:  Technical barriers, if any, to the introduction of new structural fire resisting materials, systems and technologies should be identified and eliminated in the AIA MasterSpec, AWCI Standard 12 and ASTM standards for field inspection, conformance criteria, and test methods.  Model Building Codes:  Technical barriers, if any, to the introduction of new structural fire resisting materials, systems, and technologies should be eliminated from the model building codes.

[ * F-34  Other possibilities include encapsulation of SFRM by highly elastic energy absorbing membranes or commodity grade carbon fibre or other wraps.  The membrane would remain intact under shock, vibration, and impact but may be compromised in a fire, yet allowing the SFRM to perform its thermal insulation function.  The carbon wrap would remain intact under shock, vibration, and impact, and possibly under fire conditions as well.]

NIST WTC Recommendation 11.

NIST recommends that the performance and suitability of advanced structural steels, reinforced and pre-stressed concrete, and other high-performance material systems be evaluated for use under conditions expected in building fires.  This evaluation should consider both presently available and new types of steels, concrete, and high-performance materials to establish the properties (e.g. yield and ultimate strength, modulus, creep behaviour, and failure) that are important for fire resistance, establish needed test protocols and acceptance criteria for such materials and systems, compare the performance of newer systems to conventional systems, and the cost-effectiveness of alternative approaches.  Technical and standards barriers to the introduction and use of such advanced steels, concrete, and other high-performance material systems should be identified and eliminated, or at least minimized, if they are found to exist.  Affected Standards:  AISC Specifications and ACI 318.  Technical barriers, if any, to the introduction of these advanced systems should be eliminated in ASTM E 119, NFPA 251, UL 263, ISO 834.  Model Building Codes:  Technical barriers, if any, to the introduction of these advanced systems should be eliminated from the model building codes.

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END

ILO – EU CEDEFOP

‘Skills for Green Jobs – A Global View’  (a synthesis report based on 21 country reports)

Click the Link Above to read and/or download PDF File (5.3 Mb)

The vision is positive … its advice is practical … and the writers actually sound as if they know what they are talking about.  And it is evident that the word ‘green’ is used, in this Report, as a simple means of communicating the far more complex concept of ‘sustainable human and social development’, with all of its many different aspects.  Judge for yourself by reading the extract from the Executive Summary below.

This Report’s contents also complement, very neatly, what has been said here in many posts … concerning the institutional infrastructure necessary, in societies, to properly implement an effective response to policies of energy conservation and security, climate change and sustainable development.

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WAYS FORWARD  [ Pages xxiv to xxvi, Executive Summary, ILO - EU CEDEFOP Report: 'Skills for Green Jobs - A Global View' ]

It is important to remember that skills are not a poor servant of the economy, expected merely to react and adjust to any change.  The availability of a suitably trained workforce capable of further learning inspires confidence that in turn encourages investment, technical innovation, economic diversification and job creation.

Policies Need to be Informed, Coherent and Co-Ordinated

When policies to green the economy and policies to develop skills are not well connected, skill bottlenecks will slow the green transformation, and potential new jobs will be lost.  Strategic, leadership and management skills that enable policy-makers in governments, employers’ associations and trade unions to set the right incentives and create enabling conditions for cleaner production and services are an absolute priority.

Environmental awareness as an integral part of education and training at all levels, introduced as a core skill from early childhood education onwards, will eventually push consumer behaviour and preferences and the market itself.

Labour market information for anticipating and monitoring skill needs for green jobs is the critical starting point for effective policy cycles.  This enables governments and businesses to anticipate changes in the labour market, identify the impact on skill requirements, incorporate changes into the system by revising training programmes and introducing new ones, and monitor the impact of training on the labour market.

The country studies that told the most successful stories prove the value of effective co-ordination among line ministries and social partners, achieved by creating task forces for human resource development for a greening economy, or by incorporating training and skills issues into a council for environmental development.  It is important that the platform for this dialogue has decision-making authority, can establish clear commitments among all those partners involved and allocate human and financial resources to them, and has agreed responsibilities not only for planning but for implementation.  A win–win situation can only be achieved if environment, jobs and skills are discussed, planned and implemented in conjunction with each other.

Decentralized approaches can actually promote policy co-ordination and coherence at sectoral and local levels.  Direct dialogue between national and regional governments and social partners can be translated into action when commitments and resource allocation occur at a smaller scale and where immediate dividends are obvious for all partners involved.  A good combination of top-down co-ordinated policy-making with bottom-up sectoral or local initiatives can support effective training-intensive green transitions.

Policies Need to be Targeted

The transformation to greener economies provides an opportunity to reduce social inequalities.  Social justice dictates that training initiatives target those who lose jobs during the transition, especially those who are typically at a disadvantage in the labour market and may require special assistance.  The growth dividend from greening the economy will be attained only if access to new training provided as part of green measures is made accessible to disadvantaged youth, persons with disabilities, rural communities and other vulnerable groups.  Incentives to increase women’s participation in technical training programmes will not only increase their participation in technology-driven occupations but also help solve the skill shortage problem in this segment of the labour market.

Green Transitions Affect the Entire Training System

Taking into account all three types of skills change – that resulting from employment shifts within and across sectors as the consequence of green restructuring, that associated with new and emerging occupations, and the massive change in the content of established occupations – it becomes clear that the whole training system must be mobilized.  Adjusting training programmes to green changes in the labour market is a transversal task across levels and types of education and training.

So far, compulsory level and tertiary education have been catching up rather well, whereas technical and vocational education and training has been lagging behind in adapting to the needs of the green economy.  Improving adjustment here can give new impetus to employment-centred and fair green transitions and requires the following key challenges to be met:

• Putting basic skills high on the policy agenda, as a foundation of flexibility and employability throughout the life cycle ;
• Matching classroom and practical training through apprenticeships, internships, job placements, projects on the job etc ;
• Adjusting the length and breadth of training provision according to different types of skills change ;
• Equipping teachers and trainers with up-to-date knowledge on environmental issues and on green technologies – education and training which deals with preparation of teachers and trainers should be one of the first priorities in skills response strategies ;
• Enabling active labour market policy measures (ALMP’s) to take into account green structural change and to provide access to relevant training and other employment activation measures ;    and
• Deploying public employment services (PES), as important players in job matching and training, to raise awareness about green business opportunities and related skill needs.

The linchpin of effective skills development for greening the economy is co-ordination.  The degree of co ordination between public and private stakeholders and the degree of involvement of social partners are decisive.  Concerted measures need to be undertaken by governments at different levels, including the community level, employers and workers, through institutional mechanisms of social dialogue, such as national or regional tripartite councils, sector or industry skills councils, public–private partnerships and the like.

Developing Countries Need Special Measures

Developing countries, and the workers and employers in them, have the least responsibility for climate change and environmental degradation but suffer their economic and social consequences disproportionately.  Special measures that can speed their employment-centred green transformations include:

-   capacity building for employers in the informal economy and micro- and small enterprises to enter green markets in localities where they are most needed ;

-   entrepreneurship training and business coaching for young people and adults to start up green businesses in conjunction with micro-finance projects ;

-   environmental awareness among decision-makers, business leaders and administrators as well as institutions of formal and non-formal training systems ;

-   capacity building of tripartite constituents to strengthen social dialogue mechanisms and to apply these to dialogue about accessibility of training for green jobs ;   and

-   increased capacity of formal education and training systems and institutions to provide basic skills for all and to raise the skills base of the national workforce ;  this includes improving apprenticeship systems and building synergies with NGO’s that provide education and training.

These measures can only be taken if resources are available.  It is therefore recommended that not only national governments but also international partnerships in developing countries take these recommendations into account both in environment programmes and in skills development programmes.

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‘GREENING’ IRELAND’s ECONOMY ?

Ireland was not one of the countries examined in the ILO / EU CEDEFOP Project.  That should tell us a lot !

BUT … just pause for a moment … and meditate on the many skill-related issues arising from the debacle at the Priory Hall Apartment Development, in Dublin.

AND NOW … read the following extracts from recent Irish National Reports … ‘high notions’ from goats in the Kerry Mountains …

The Overarching Vision – Forfás Report: ‘Future Skills Needs of Enterprise within the Green Economy in Ireland’ (November 2010) …

” For Ireland to be the benchmark ‘smart green’ economy for population centres under 20 million by 2015 – and to have the skills base and talent to drive innovative and high value products and services and maximise future business and employment growth potential.”

Final Paragraphs, #7 Conclusions – Review of National Climate Policy (November 2011) …

” In the wider-international context, there are also encouraging signs of a new ‘green growth’ paradigm which emphasises resource efficiency, the protection of natural resources and competitiveness along with the creation of new jobs.  A long-term view of how Ireland aligns its economic development with the demands of the growth engines of global commerce should be at the core of a low-carbon development vision.  In order to create enabling conditions for selling into these markets, many of which are already gearing up for the green economy, it will be necessary to ensure that the domestic conditions are right to encourage innovation.  This can be done by showing environmental ambition and using tools that allow the market to identify solutions.  That will require a combination of taking the best of what is working in other countries as well as devising domestically appropriate policies that will place Ireland in the vanguard of countries making the most of the opportunities presented by the green economy.

In terms of a long-term national vision of a carbon-constrained world, Ireland is faced with both the challenge of addressing a unique greenhouse gas emissions profile and the opportunity to position itself as an enlightened society with an environmentally sustainable and competitive, low-carbon economy.  Developing the policies to put Ireland on a clear and definite path to achieve that vision is the immediate priority.”

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Who Are These Moráns ?!?   Will Somebody Please Get Real !?!

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END

2011-10-25:  NIST’s Recommendations on the 9-11 WTC Building Collapses … GROUP 1. Increased Structural Integrity – Recommendations 1, 2 & 3 (out of 30)

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2011-11-18:  SOME PRELIMINARY COMMENTS …

  1.     Before launching into the next Group of NIST WTC Recommendations, it would be useful to distinguish between the following technical terms … which have been adapted from ISO/TR 10158: ‘Principles and Rationale Underlying Calculation Methods in Relation to Fire Resistance of Structural Elements’ …

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

Real Fires are complex phenomena.  Consequently, in structural fire engineering, idealized versions of ‘real fires’ are employed.

Experimental Fire:  A full or reduced scale fire with specified and controlled characteristics.

Design Fire:  A fire with specified exposure data intended for use in connection with structural fire engineering calculations.

A Design Fire may either be representative of the thermal exposure described by the standard time-temperature-pressure relationship in an International/European/National Standard, or some non-standard exposure intended to simulate particular fire exposure conditions.

However, in SDI Technical Guidance Note 95/102: ‘Proper Evidence of a Fire Test Result within the European Economic Area (EEA)’, issued on 22 May 1995, I included the following caution …

#1.7  A Fire Test in a Fire Test Laboratory, involving exposure of a test specimen or prototype to ‘test fire’ conditions, gives only a limited indication of:  (a) the likely performance of a particular product, material or component when exposed to ‘real fire’ conditions;  and (b) the suitability of a product, material or component for a particular end use.

  2.     In conventional fire engineering, much confusion arises because of a failure to properly distinguish between these two concepts …

Fire Resistance

The inherent capability of a building assembly, or an ‘element of construction’, to resist the passage of heat, smoke and flame for a specified time during a fire.

Structural Reliability

The ability of a structural system to fulfil its design purpose, for a specified time, under the actual environmental conditions encountered in a building.

[ In structural fire engineering, the concern must be that the structure will fulfil its purpose, both during the fire - and for a minimum period afterwards, during the 'cooling phase'.]

  3.     Therefore, with regard to Recommendation 6 … it is more correct and precise to refer to ‘Steel Fire Protection Systems’, rather than to ‘steel fire resisting materials’ !   AND … the same questions must be asked about All Lightweight Steel Fire Protection Systems … not just the sprayed systems.

Lightweight Fire Protection Systems are also used to protect concrete in buildings and tunnels.

  4.     These 2005 NIST Recommendations will later be confirmed, and further reinforced, by the 2008 NIST Recommendations.  Bringing Recommendation 7, below, closer to home … it is interesting to note that a very necessary discussion on the technical adequacy of the approach taken to structural performance in fire … in both Technical Guidance Document B (Ireland) and Approved Document B (England & Wales) … has yet not even commenced !

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2005 NIST WTC RECOMMENDATIONS

GROUP 2.  Enhanced Fire Endurance of Structures

The procedures and practices used to ensure the fire endurance of structures should be enhanced by improving the technical basis for construction classifications and fire resistance ratings, improving the technical basis for standard fire resistance testing methods, use of the ‘structural frame’ approach to fire resistance ratings, and developing in-service performance requirements and conformance criteria for sprayed fire resisting materials.

NIST WTC Recommendation 4.

NIST recommends evaluating, and where needed improving, the technical basis for determining appropriate construction classifications and fire rating requirements (especially for tall buildings) – and making related code changes now, as much as possible – by explicitly considering factors including: *

[ * F-23  The construction classification and fire rating requirements should be risk-consistent with respect to the design-basis hazards and the consequences of those hazards.  The fire rating requirements, which were originally developed based on experience with buildings less than 20 storeys in height, have generally decreased over the past 80 years since historical fire data for buildings suggest considerable conservatism in those requirements.  For tall buildings, the likely consequences of a given threat to an occupant on the upper floors are more severe than the consequences to an occupant on the first floor or the lower floors.  For example, with non-functioning elevators, both of the time requirements are much greater for full building evacuation from upper floors and emergency responder access to those floors.  It is not clear how the current height and areas tables in building codes consider the technical basis for the progressively increasing risk to an occupant on the upper floors of tall buildings that are much greater than 20 storeys in height.]

• timely access by emergency responders and full evacuation of occupants, or the time required for burnout without partial collapse ;
• the extent to which redundancy in active fire protection systems (sprinklers and standpipe, fire alarm, and smoke management) should be credited for occupant life safety ; *

[ * F-24  Occupant life safety, prevention of fire spread, and structural integrity are considered separate safety objectives.]

• the need for redundancy in fire protection systems that are critical to structural integrity ; *

[ * F-25  The passive fire protection system (including fire protection insulation, compartmentation, and fire stopping) and the active sprinkler system each provide redundancy for maintaining structural integrity in a building fire, should one of the systems fail to perform its intended function.]

• the ability of the structure and local floor systems to withstand a maximum credible fire scenario* without collapse, recognizing that sprinklers could be compromised, not operational, or non-existent ;

[ * F-26  A maximum credible fire scenario includes conditions that are severe, but reasonable to anticipate, conditions related to building construction, occupancy, fire loads, ignition sources, compartment geometry, fire control methods, etc., as well as adverse, but reasonable to anticipate operating conditions.]

• compartmentation requirements (e.g. 1,200 sq.m *) to protect the structure, including fire rated doorsets and automatic enclosures, and limiting air supply (e.g. thermally resisting window assemblies) to retard fire spread in buildings with large, open floor plans ;

[ * F-27  Or a more appropriate limit, which represents a reasonable area for active fire fighting operations.]

• the effect of spaces containing unusually large fuel concentrations for the expected occupancy of the building ;   and
• the extent to which fire control systems, including suppression by automatic or manual means, should be credited as part of the prevention of fire spread.

Adoption of this Recommendation will allow building codes to distinguish the risks associated with different building heights, fuel concentrations, and fire protection systems.  Research is needed to develop the data and evaluate alternative proposals for construction classifications and fire ratings.  Model Building Codes:  A comprehensive review of current construction classifications and fire rating requirements and the establishment of a uniform set of revised thresholds with a firm technical basis that considers the factors identified above should be undertaken.*

[ * F-28  The National Fire Protection Association (NFPA) 5000 model code and the International Building Code (IBC) both recognize the risks associated with different building heights and accepted changes in 2001 and 2004, respectively.  Both model codes now require that buildings 126 metres and higher have a minimum 4 hour structural fire resistance rating.  The previous requirement was 2 hours.  The change provides increased fire resistance for the structural system leading to enhanced tenability of the structure and gives firefighters additional protection while fighting a fire.  While NIST supports these changes as an interim step, NIST believes that it is essential to complete a comprehensive review that will establish a firm technical basis for construction classifications and fire rating requirements.]

NIST WTC Recommendation 5.

NIST recommends that the technical basis for the century-old standard for fire resistance testing of components, assemblies and systems be improved through a national effort.  Necessary guidance also should be developed for extrapolating the results of tested assemblies to prototypical building systems.  A key step in fulfilling this Recommendation is to establish a capability for studying and testing components, assemblies, and systems under realistic fire and load conditions.

This effort should address the technical issues listed below: *

[ * F-29  The technical issues were identified from the series of four fire resistance tests of the WTC Floor system, and the review and analysis of relevant documents that were conducted as part of this Investigation.]

a.     Criteria and test methods for determining:

• structural limit states, including failure, and means for measurement ;
• effect of scale of test assembly versus prototype application, especially for long-span structures that significantly exceed the size of test furnaces ;
• effect of restraining thermal expansion (end-restraint conditions) on test results, especially for long-span structures that have greater flexibility ;
• fire resistance of structural connections, especially the fire protection required for a loaded connection to achieve a specified rating ; *

[ * F-30  There is a lack of test data on the fire resistance ratings of loaded connections.  The fire resistance of structural connections is not rated in current practice.  Also, standards and codes do not provide guidance on fire protection requirements for structural connections when the connected members have different fire resistance ratings.]

• effect of the combination of loading and exposure (time-temperature profile) required to adequately represent expected conditions ;
• the repeatability and reproducibility of test results (typically, results from a single test are used to determine the rating for a component or assembly) ;   and
• realistic ratings for structural assemblies made with materials that have improved elevated temperature properties (strength, modulus, creep behaviour).

b.     Improved procedures and guidance to analyze and evaluate existing data from fire resistance tests of building components and assemblies for use in qualifying an untested building element.

c.     Relationships between prescriptive ratings and performance of the assembly in real fires.

Affected National and International Standards: * ASTM E 119, NFPA 251, UL 263, and ISO 834.  Model Building Codes:  The standards should be adopted in model building codes by mandatory reference to, or incorporation of, the latest edition of the standard.

[ * F-31  While the NIST Recommendations are focused mainly on U.S. national standards, each U.S. standard has counterpart international standards.  In a recent report (ISO/TMB AGS N 46), the International Organization for Standardization (ISO), through its Advisory Group for Security (AGS), has recommended that since many of the ISO standards for the design of buildings date back to the 1980's, they should be reviewed and updated to make use of the studies done by NIST on the World Trade Center disaster, the applicability of new technology for rescue from high buildings, natural disasters, etc.  ISO's Technical Advisory Group 8 co-ordinates standards work for buildings.]

NIST WTC Recommendation 6.

NIST recommends the development of criteria, test methods, and standards:  (1) for the in-service performance of Sprayed Fire Resisting Materials (SFRM, also commonly referred to as fire protection insulation) used to protect structural components;  and (2) to ensure that these materials, as installed, conform to conditions in tests used to establish the fire resistance rating of components, assemblies, and systems.

This should include:

• Improved criteria and testing methodologies for the performance and durability of SFRM (e.g. adhesion, cohesion, abrasion, and impact resistance) under in-service exposure conditions (e.g. temperature, humidity, vibration, impact, with/without primer paint on steel*) for use in acceptance and quality control.  The current test method to measure the bond strength, for example, does not distinguish the cohesive strength from the tensile and shear adhesive strengths.  Nor does it consider the effect of primer paint on the steel surface.  Test requirements that explicitly consider the effects of abrasion, vibration, shock, and impact under normal service conditions are limited or do not exist.  Also, the effects of elevated temperatures on thermal properties and bond strength are not considered in evaluating the performance and durability of SFRM.

[ * F-32  NIST tests show that the adhesive strength of SFRM on steel coated with primer paint was a third to half of the adhesive strength on steel that had not been coated with primer paint.  The SFRM products used in the WTC towers were applied to steel components coated with primer paint.]

• Inspection procedures, including measurement techniques and practical conformance criteria, for SFRM in both the building codes and fire codes for use after installation, renovation, or modification of all mechanical and electrical systems and by fire inspectors over the life of the building.  Existing standards of practice (AIA MasterSpec and AWCI Standard 12), often required by codes for some buildings need to be broadly applied to both new and existing buildings.  These standards may require improvements to address the issues identified in this Recommendation.
• Criteria for determining the effective uniform SFRM thickness – thermally equivalent to the variable thickness of the product as it is actually applied – that can be used to ensure that the product in the field conforms to the near uniform thickness conditions in the tests used to establish the fire resistance rating of the component, assembly, or system.  Such criteria are needed to ensure that the SFRM, as installed, will provide the intended performance.
• Methods for predicting the effectiveness of SFRM insulation as a function of its properties, the application characteristics, and the duration and intensity of the fire.
• Methods for predicting service life performance of SFRM under in-service conditions.

Affected Standards:  AIA MasterSpec and AWCI Standard 12 for field inspection and conformance criteria; ASTM standards for SFRM performance criteria and test methods.  Model Building Codes:  The standards should be adopted in model building codes by mandatory reference to, or incorporation of, the latest edition of the standard.  (See Recommendation 10 for more on this issue.)

NIST WTC Recommendation 7.

NIST recommends the adoption and use of the ‘structural frame’ approach to fire resistance ratings.  This approach requires that structural members – such as girders, beams, trusses, and spandrels having direct connection to the columns, and bracing members designed to carry gravity loads – be fire protected to the same fire resistance rating as columns.  This approach is currently required by the International Building Code (IBC), one of the model codes, and is in the process of adoption by NFPA 5000, the other model code.  This requirement ensures consistency in the fire protection provided to all of the structural elements that contribute to overall structural stability.*  State and local jurisdictions should adopt and enforce this requirement.

[ * F-33  Had this requirement been adopted by the 1968 New York City building code, the WTC floor system, including its connections, would have had the 3 hour rating required for the columns since the floors braced the columns.]

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END

On Thursday evening, 1st December 2011, at 19.00 hrs … in the Dublin Institute of Technology … I will present an IABSE-Ireland Sponsored Lecture on the subject: ‘Sustainable Fire Engineering IS THE FUTURE !’.

This Presentation has been in continuous development across a snaking international path … Dubayy (UAE) in 2008 … Lund (Sweden) and Bengaluru (India) in 2009 … Dilli (India), Zurich (Switzerland) and Dublin (Ireland) in 2010 … Paris (France), the IFE’s International Fire Conference in Cardiff (Wales) and the ASFP-Ireland Fire Seminar in 2011 … and on 1 December next, in Dublin, I will be introducing some tough new realities for fire engineering generally … not just in Ireland …

Colour photograph showing the impact of witnessing the 9-11 WTC Incident in New York. Sustainable Fire Engineering must be 'reliability-based' & 'person-centred'. But ... do building designers, including fire engineers, actually understand that the people who use their buildings are 'individuals' ... each having a different range of abilities ? Photograph by Marty Lederhandler/AP. Click to enlarge.

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IABSE Irish National Group Sponsored Lecture

Dublin Institute of Technology, Bolton Street – Michael O’Donnell Room (259)

Thursday, 1 December 2011 @ 19.00 hrs / 7.00 p.m.

CJ Walsh: Sustainable Fire Engineering IS THE FUTURE !  (Lecture Flyer, PDF File, 259 kb)

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The aim of Sustainable Fire Engineering is to realize a safe and sustainable built environment.

Responding ethically, in built and/or wrought form, to the still evolving concept of sustainable human and social development … a principal objective of Sustainable Fire Engineering is to design for maximum credible fire and user scenarios … in order to maintain a proper and satisfactory level of fire safety and protection over the full life cycle of, for example, a building … and for a Sustainable Building, that life cycle is 100 years minimum.

Sustainable Fire Engineering must, therefore, be ‘reliability-based’ & ‘person-centred’.

This presentation will examine the authentic language and meaning of sustainability … and will then track how this impacts on the professional practice of fire engineering.  Special mention will be made of Fire-Induced Progressive Collapse.

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See you all there !   And I will be looking forward to a lot of challenging feedback on the night !!

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END

Some time ago … Irish Minister of State at the Department of Health & Children, Ms. Kathleen Lynch T.D., released to the public a report on the future policy of disability in Ireland.  The report was drawn up by an Expert Reference Group at the request of the Department.  Submissions were sought from the public and interested groups on this document, entitled ‘Report of Disability Policy Review’.

The Report, and other ‘supporting’ information, can be downloaded from the Department’s WebSite at … http://www.dohc.ie/consultations/

Submissions had to be received by the Department, at the latest, on Friday 4 November 2011.

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As you read through the SDI Submission below, please also note well that on the 2 Web Pages of the Department’s Site …

• Background to Report of Disability Policy Review ;   and
• Summary of Key Proposals from The Review of Disability Policy ;

… there is not one single mention of the word ‘rights’ !

In a post back on 17 February 2009 … concerning another disability matter, i.e. the complete lack of ‘accessible’ emergency services for people with a hearing impairment in our country, I wrote:

‘ Irish Politicians and Senior Civil Servants would all rather commit ritual suicide on Merrion Street (outside the Dáil and Government Buildings) than give people with disabilities their rights.’

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The following is the recent Submission made by Sustainable Design International … and submitted to the Department of Health & Children on 4 November 2011 …

Re: The Future of Disability Policy in Ireland – SDI Submission

Ms. Kathleen Lynch T.D., Minister of State,  c/o Office for Disability & Mental Health, Department of Health & Children, Hawkins House, Dublin 2.

Dear Minister,

It is reassuring to see that the following two documents, available for download from the Department’s WebSite, contain extensive references to Human Rights and, particularly, the UN Convention on the Rights of Persons with Disabilities …

     -  Report of Disability Policy Review – Prepared by Ms. Fiona Keogh PhD, on behalf of the Expert Reference Group on Disability Policy (October 2011) ;

     -  Report on Public Consultation: Efficiency & Effectiveness of Disability Services in Ireland – Review of Disability Services under the Value for Money & Policy Review Initiative 2009-2011 (December 2010).

And yet … the following document, also available for download from the Department’s WebSite, does not make one single reference to Human Rights …

     -  Summary of Key Proposals from The Review of Disability Policy (October 2011).

It is a matter of deep concern how such a fundamental issue can suddenly, and with malign intent, be erased from view … and understanding !

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Whether or not Ireland has ratified the United Nations 2006 Convention on the Rights of Persons with Disabilities is no longer relevant.

The European Union (EU), having its own legal personality after the Lisbon Treaty, did ratify the UN Convention … back on 23 December 2010.

Therefore, Ireland is now bound by a Duty of Loyal Co-Operation, deriving from Article 4.3 of the Treaty on European Union (TEU).

This Duty embraces two sets of obligations:  1) All EU Member States shall take appropriate measures, whether general or particular, to ensure fulfilment of the obligations arising out of the EU Treaties or resulting from action taken by the EU Institutions;  and 2) All EU Member States shall facilitate the achievement of the European Union’s tasks, and shall abstain from any measure which could jeopardise the attainment of the Union’s objectives.

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In complete contrast to Ireland’s Current Disability Policy … Future Disability Policy must now be re-drafted, and implemented, in a manner where:

a)  Explicit reference is made, throughout, to the United Nations Convention on the Rights of Persons with Disabilities … and to the fact that there is now a robust rights-based foundation to Ireland’s National Disability Policy ;

and

b)  There is a full, comprehensive and correct response to all of the contents of the United Nations Convention on the Rights of Persons with Disabilities.

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I would specifically draw your attention to Articles 31 & 33 of the United Nations Convention on the Rights of Persons with Disabilities … which together mandate that implementation is taken seriously … that it is competent and effective … and, most importantly, that independent monitoring and verification is a fundamental part of the whole policy development and implementation process.

In closing, may I add that the treatment of ‘Accessibility’ in all of the documents is careless, and disgracefully inadequate !!

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Sustainable Design International  is a professional and multi-disciplinary design, engineering, research and consultancy practice – specializing in the theory and implementation of a Sustainable Human Environment (social - built - virtual - economic).

Our Organization possesses a unique level of expertise on all aspects of Human Environment Accessibility for People with Activity Limitations.

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Yours,

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

Managing Director, Sustainable Design International Ltd. – Ireland & Italy.  Sürdürülebilir Tasarım Tic.Ltd.Şti. – Turkey.

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END

Has anybody’s interests been protected by what has happened at the ‘Priory Hall’ Apartment Development, in Donaghmede, Dublin 13 ?   NO.

Now that the buildings there have been completed … will it be possible to effectively repair the most serious fire protection, sound transmission and energy conservation problems with the buildings ??   NO.

At the heart of these problems lie Fundamental Design and Construction Flaws … because, back in the 1990′s and early 2000′s, indigenous builders of simple two storey semi-detached houses suddenly became ‘developers’ of apartment complexes … and these were very different building animals altogether, requiring a degree of technical competence well beyond their reach.  And, of course, during the actual construction process everything had to be finished ‘yesterday’, and as cheaply as possible (a policy of cheap product substitution was the un-stated national norm !).  In fact, so many corners were cut on Irish Building Sites, at the time, that we should refer to almost the entire construction output from this era as: The Celtic Tiger Round Towers !

And guess who is going to carry out the Corrective/Repair/Refurbishment Works at ‘Priory Hall’ ?   The very same Construction Organization which created the mess in the first place !!   Can you believe it ??

Furthermore … once these Corrective/Repair/Refurbishment Works are eventually finished … the performance of the Fire Protection Measures in ‘Priory Hall’ will still be compromised, because you can only do so much, physically, when a building is completed.  BUT … it would be possible to achieve a Proper Level of Fire Safety in ‘Priory Hall’ … by installing a Fire Suppression System (sprinklers or mist) throughout the development.  That’s what it will take !!

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Tremendous fire damage was caused to the local environment in Buncefield ... but SOCIETY can no longer suffer this scale of damage ... and these Criminal Human Acts! Click to enlarge.

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WHO IS PROTECTING SOCIETY ?

So extensive is the damage caused by fire … throughout Europe … that not all of the Direct and Indirect Fire Losses have yet been identified.

Pause, to consider this definition …

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.

And this means, of course, that our current Fire Loss Data and Statistics are unreliable.

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It is not well known, or widely publicised, that the Fire Safety Objectives of Building Regulations are limited to protecting building occupants.  The Objectives are only concerned with protecting property, insofar as it is relevant to the protection of those building occupants.

Can you image the look of astonishment on the face of a Managing Director, after his/her factory has been entirely destroyed by a fire, when told by a fire consultant …

” We complied with Part B of the Building Regulations, and here is your Fire Safety Certificate to prove it”  ??

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What should be happening instead ?

     1.  Fire Engineering Design & Practice cannot … and must not … be concerned merely with the ‘cost-effective’ compliance with minimal (which they most certainly are !) Fire Safety Objectives mandated by Building Legislation.

     2.  To properly protect the interests of Society and Clients/Client Organizations … Fire Engineering Design & Practice must also take into account: Safety at Work Legislation; Rights, Equality & Anti-Discrimination Legislation; Environmental Impact Legislation; Public Procurement Legislation; Product Liability Legislation; etc., etc.

     3.  There is an evolving realization in Ethical Fire Engineering Design & Practice, however, that there is still a significant gap to be bridged.  There is no legislation (effective, or otherwise) yet in place, anywhere, which deals with such issues as …

• Resistance to Fire-Induced Progressive Collapse – as very strongly recommended in the 2005 & 2008 U.S. NIST Final Reports on the 9-11 World Trade Center Building 1, 2 & 7 Collapses ;
• Protection of Vulnerable Building Users in ‘Situations of Risk’ – as required, for example, by Article 11 of the UN Convention on the Rights of Persons with Disabilities (CRPD) ;
• Safety of Firefighters/Rescue Teams – as specified in Basic Requirement for Construction Works No.2, in Annex I of European Union Construction Product Regulation 305/2011 ;
• Adaptation to Climate Change and Severe Weather Events – the Developed World Economies appear to have no interest, whatsoever, in these issues ;
• Sustainable Human & Social Development !

     4.  We must clearly distinguish, therefore, between the Fire Safety Objectives of Building Regulations/Codes … and Project-Specific Fire Engineering Design Objectives.  This difference must be fully understood by the Fire Engineer himself/herself … and then, in all circumstances, properly explained to the Client/Client Organization.

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In designing a Building for conditions of fire, and its aftermath … which may take place at any time during the Life Cycle of that Building … Project-Specific Fire Engineering Design Objectives should cover the following spectrum of concerns … in order to properly protect the interests of Society and our Clients/Client Organizations …

  -   Protection of the Health & Safety of All Building Users … including People with Activity Limitations (2001 WHO ICF), visitors to the building who may be unfamiliar with its layout, and contractors or product/service suppliers temporarily engaged in work or business transactions on the premises ;

  -   Protection of Property … including the building, its contents, and adjoining or adjacent properties … from loss or damage ;

  -   Protection of the Health & Safety of Firefighters, Rescue Teams & Other Emergency First Response Personnel ;

  -   Facility, Ease & Efficient Cost of Carrying Out Effective Reconstruction, Refurbishment or Repair Works after a Fire ;

  -   Sustainability of the Human Environment (social, built, virtual, economic, …) – including Fitness for Intended Use and Life Cycle Costing of fire engineering related products, components, systems, etc., fixed, installed or incorporated in the building ;

  -   Protection of the Natural Environment from Harm, i.e. Adverse Impacts.

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CRIMINAL RESPONSE TO 1981 DUBLIN STARDUST TRAGEDY !

As I write … a stampede has just commenced by the various Construction-Related Professional Institutes and Organizations … to demand closer independent monitoring of what is happening on Irish Building Sites.  Far too little … and definitely, far too late !   Back in the early 1990′s, everybody stood by … and co-operated with the installation of an entirely ineffective and dysfunctional system of National Building Control in Ireland … which, let us not forget, survives intact to this day … while, at the same time, the strong long-established and well-resourced Building Control Sections in Dublin and Cork were being quietly dismantled.

The Minister for the Environment, Community & Local Government, Mr. Phil Hogan T.D. … is also chirping in from his ivory tower !

Crocodile Tears !!

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Take a Fire Safety Certificate for a Building, for example …

With or Without Conditions … this document confirms that the Local Building Control/Fire Authority is satisfied that the Design Documentation for that building shows proper compliance with the Legal Requirements of Part B of the Irish Building Regulations.

Focus in on the relevant wording of a Fire Safety Certificate, which is as follows …

‘ … hereby certify that the works or building to which the application relates, will, if constructed in accordance with the plans, calculations, specifications and particulars submitted, comply with the requirements of Part B of the Second Schedule to the Building Regulations 1997 to 2008.’

Fire Safety Related Inspections of Construction Projects are not carried out by Competent Local Authority Personnel, or by Competent Independent Technical Controllers.  Therefore … a Fire Safety Certificate cannot give, and is not intended to give, any indication with regard to Fire Safety in the Completed Building.  The ‘Fire’ Establishment in Ireland knows full well that this is the situation !

Is this any sort of a reasonable, caring or competent response to the 1981 Stardust Discotheque Fire Tragedy in Dublin ??

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END

For the last few days, including today, I have been listening intently to Joe Duffy on the RTE Radio ‘Liveline’ Programme at lunchtime.  Joe is being very cautious because he cannot quite believe his ears … either about the unfolding harrowing events for occupants in ‘Priory Hall’, Donaghmede, Dublin 13 – a Private, Multi-Storey Apartment Development – or the tales and anecdotes about Irish Building Sites during the Celtic Tiger Years.

This will be of no consolation to anybody … but the big surprise, for me, is that there is so much public shock.  ‘Priory Hall’ is the Tip of the Iceberg !   Ireland’s current dysfunctional approach to the development of Our(!) Built Environment … has been designed (for want of a better word) in a chaotic, haphazard and malevolent way … to end up in exactly the sort of mess which we are all now witnessing in North County Dublin.

Just to be clear … what has been happening in the Irish Construction Industry, during the boom years, has been happening for twenty years all over the country … more precisely, since the introduction of Legal National Building Regulations, with NO Effective Building Control, in 1991 … and, before that again, in those parts of this jurisdiction, outside of the major urban areas having Legal Building Bye-Laws, and Effective Building Control, i.e. mandatory inspections by competent local authority personnel at the foundation level and drainage level of all building sites … and, depending on the type of project, occasional or frequent inspections above ground level.

[ 1991:  Statutory Instrument No.304 of 1991 - Building Control Act, 1990 (Commencement Order), 1991;  Statutory Instrument No.305 of 1991 - Building Control Regulations, 1991;  Statutory Instrument No.306 of 1991 - Building Regulations, 1991 ]

And the biggest joke of all … is that the sum of the many resources, both human and material, required to repair sub-standard construction throughout Ireland … will count as a positive contribution towards the economic indicator of GDP (Gross Domestic Product) !   FUBAR

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Colour photograph showing 'Priory Hall' ... a private, multi-storey apartment development located in North County Dublin, Ireland. Click to enlarge.

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PRACTICAL SOLUTIONS NEEDED NOW

What I have not been hearing from the radio, or reading in the newspapers, is practical solutions.

Lest there be any doubt … this is one of the professional services we provide at Sustainable Design International !

So … how do we fix Priory Hall as the situation now presents itself … in such a way that, as soon as it is practicable, a satisfactory level of long-term safety, protection, convenience and comfort will be provided for the occupants of Priory Hall … and the social wellbeing of the local community, there, can be restored.

Afterwards … we can worry about who’s responsible, and about the reasons for the many ‘system’ failures in Ireland.

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FIXING ‘PRIORY HALL’ IN DUBLIN

The following list of practical suggestions … a simple roadmap … is addressed to the Owners and Occupants of Apartments in Priory Hall.

As they have a large vested interest in the problems of Priory Hall … either directly or indirectly … no assurances or undertakings should be accepted, on face value, from either Dublin City Council (DCC) or the Department of the Environment, Community & Local Government (DECLG) … or their representatives.

     1.  Informed Consent of Apartment Owners and Occupants

Demand that the Informed Consent of the Owner/Occupant of an Apartment is required, in writing, before any necessary Corrective/Repair/Refurbishment Works are carried out …

Informed Consent:  Consent freely obtained – without threats or improper inducements – after appropriate disclosure to a person of relevant, adequate and easily assimilated information in a form and language understood by that person.

     2.  ‘As Constructed’ Drawings & Specification of Entire Development

If they exist … we’re on the way !   But, if they don’t exist … and they may not … demand that an ‘As Constructed’ Survey of the Entire Development be carried out immediately.

Demand to see a copy of the Detailed ‘As Constructed’ Drawings, and Specification, for the Entire Development.

CHECK the adequacy of the Detailed Drawings and Specification !

At this stage, remember … all of the emphasis must now be placed on actual construction … not on paperwork !   The ‘As Constructed’ Survey Drawings and Specification are only a means towards a satisfactory end … that’s all !!

     3.  Failures to Properly Comply with Current Building Regulation Requirements A to M (Second Schedule to Irish Building Regulations)

Demand to see a Detailed Schedule of the many failures to properly comply with current Building Regulation Requirements, i.e. Parts A to M in the Second Schedule to the Building Regulations, as amended.

Do not entertain, even for a moment, any discussion about past legal building regulation requirements, which were in force at the time of initial design or construction !

An important point to note !   The Guidance Texts in, for example, Technical Guidance Document B: ‘Fire Safety’ are merely that … GUIDANCE !   This guidance is not infallible … and in a few respects, is entirely inadequate … for example, when dealing with the structural performance of buildings during conditions of fire, and the ‘cooling phase’ immediately afterwards … and the fire evacuation of people with activity limitations, in which case the guidance actually ensures that fire evacuation is made extremely difficult, if not prevented altogether !

Do not be sucked in to any conversations about what is stated, or not stated, in the Technical Guidance Documents.  This is irrelevant.  The Law mandates proper compliance with the Requirements !

Some people may even attempt to quote from the Building Regulation Approved Documents for England & Wales.  Just tell them to take a long jump off a short pier … suggest Howth Harbour !

Become very, very suspicious whenever there is a use of, or reference to, the term ‘Substantial Compliance’ !!

CHECK the adequacy of this Detailed Schedule !   And … ensure that it is Comprehensive !!

     4.  The Necessary Corrective/Repair/Refurbishment Works

Demand to see Full Detailed Information, in the form of annotated drawings and descriptive texts, etc., etc … on the exact nature, timetable and phasing of all of the Corrective/Repair/Refurbishment Works which are necessary to effectively solve the serious problems in the Development.

Beware of decorative solutions, which look good to a superficial visual inspection in ambient conditions … but don’t actually solve anything !

CHECK the adequacy of this Full Detailed Information !

     5.  Independent Technical Control of Construction Works

Demand only Category A Construction Execution of the necessary Corrective/Repair/Refurbishment Works …

Category A Construction Execution:

(a)  Supervision of the works is exercised by appropriately qualified and experienced personnel from the principal construction organization ;

(b)  Regular inspections, by appropriately qualified and experienced personnel familiar with the design and independent of the construction organization(s) … and other vested interests … are carried out to verify that the works are being executed in accordance with the design.

Demand receipt of a clear undertaking, in writing, that this will be the case … before any Corrective/Repair/Refurbishment Works commence.

And remember these words from the 2005 Final Report of the U.S. National Institute of Standards & Technology (NIST) on the 9-11 World Trade Center Tower Collapses …

” NIST urges state and local agencies to rigorously enforce building codes and standards since such enforcement is critical to ensure the expected level of safety.  Unless they are complied with, the best codes and standards cannot protect occupants, emergency responders, or buildings.”

CHECK the adequacy of the Proposed Method of Independent Technical Control during execution of the Corrective/Repair/Refurbishment Works !

     6.  Meeting & Discussion with Other Owners/Occupants

Do not act alone … meet the other Owners/Occupants, and discuss issues with them.  Share and collate all available information together.  Try to identify information gaps.  If you do not understand something … ask !

When, and only when, you are happy … signal your Informed Consent that works should commence.

     7.  Commencement of Corrective/Repair/Refurbishment Works

Visit the Construction Site Office regularly … to show that you are taking a keen interest in what is happening.  Keep your eyes and ears wide open.

Expect that you will not be permitted to just wander around the Site.  Construction Sites are one of the most hazardous ‘workplaces’ in this country !

CHECK the adequacy of the Independent Technical Control actually being undertaken.

Demand to be updated, regularly, and at the very least on the progress of Corrective/Repair/Refurbishment Works at your Apartment … in the Common Areas of your Block … and throughout the full extent of the Approach Routes to your Block Entrances and Exits.

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Advisory Note:  Should you, or the Residents’ Committee of your Building or Development, be concerned about any matter discussed in this Post … please contact C.J. Walsh  by e-mail: cjwalsh@sustainable-design.ie  or by phone: (01) 8386078 / +353 1 8386078.

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END  (for now, but to be continued soon !)

The European Commission has recently proposed that suitable instruments be developed which will permit the operation of the Accessibility / Design for All Requirements in EU Public Procurement Directives to commence, with full effect.  This process is proving to be problematic … and it is certainly not as open and transparent as it should be.

Leaving aside the utilities sectors (water, energy, transport and postal services) … recall that EU Directive 2004/18/EC of the European Parliament and of the Council, of 31 March 2004, on the Co-Ordination of Procedures for the Award of Public Works Contracts, Public Supply Contracts and Public Service Contracts had to be implemented, at national level in all of the EU Member States, no later than 31 January 2006.  This Directive was amended, in a minor way, by Directives 2005/51/EC and 2005/75/EC.  In spite of these amendments, 31 January 2006 remained the target date for national implementation.

[ Ireland's national implementing legislation ... European Communities (Award of Public Authorities' Contracts) Regulations 2006 ... came into operation on 22 June 2006.]

In addition, each Member State had to ensure that Directive 2004/18/EC was properly implemented by using effective, available and transparent Monitoring Mechanisms.

With regard to specific rules governing specifications and contract documents … Article 23.1 of Directive 2004/18/EC stated, and still does state …

‘ The technical specifications as defined in point 1 of Annex VI shall be set out in the contract documentation, such as contract notices, contract documents or additional documents.  Whenever possible these technical specifications should be defined so as to take into account accessibility criteria for people with disabilities or design for all users.’

Not the strongest possible language to encourage ‘accessibility’ … there’s nothing quite like a shall to concentrate minds !

[ However, in Ireland ... with regard to the same specific rules governing specifications and contract documents ... Section 23 (2) of the European Communities (Award of Public Authorities' Contracts) Regulations 2006 states ...

' In awarding a public contract, a contracting authority shall, as far as practicable, ensure that the technical specifications for the contract take account of the need to prescribe accessibility criteria for all persons who are likely to use the relevant works, products or service, particularly those who have disabilities.' ]

As already discussed in my post, dated 2 November 2010 … many people in the European Union Institutions would prefer to steer completely away from the Social Aspects of Sustainable Human and Social Development … fuzzy areas, not capable of easy quantification … leaving small, peripheral groups in the Institutions (neither well connected to the mainstream, nor fully aware of the ‘ins’ and ‘outs’ of that mainstream) to look after the Social Aspects.

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Public Procurement in the European Union (EU)

The Award of Public Works Contracts, Public Supply Contracts and Public Service Contracts concluded in the EU Member States on behalf of State, Regional or Local Authorities and other bodies governed by public law entities, is subject to the respect of Principles enshrined in the EU Treaties and, in particular, to …

• the principle of freedom of movement of goods ;
• the principle of freedom of establishment ;
• the principle of freedom to provide services ;   and
• the principles deriving therefrom, such as the principle of equal treatment, the principle of non-discrimination, the principle of mutual recognition, the principle of proportionality and the principle of transparency.

For Public Contracts Above A Certain Value … it has been deemed necessary to draw up provisions of Community Co-Ordination of National Procedures for the award of such contracts, which are based on these principles so as to ensure the effects of them and to guarantee the opening-up of public procurement to competition.

- Adapted from Preamble Paragraph #2, EU Directive 2004/18/EC

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Is Europe Serious about Implementing the Public Procurement Accessibility / Design for All Requirements ?

Before looking at how Accessibility / Design for All is being handled within the fast evolving European Public Procurement Framework … it is sobering to compare and contrast how DG Environment (ENV), in the European Commission, is promoting and actively supporting Green Public Procurement, i.e. Public Procurement which is environment-friendly … http://ec.europa.eu/environment/gpp/index_en.htm … no messing about there !

If we (speaking as a European) are serious, therefore, about the ‘real’ implementation of Accessibility for All / Design for All / Inclusive Design / Universal Design / Barrier-Free Design in the Built Environment … it is of fundamental importance that an easily assimilated Standard (as defined in Paragraph #2, ANNEX VI of Directive 2004/18/EC) be produced ‘on the table’ for reference by Public Contracting Authorities … NOW !!!

Built Environment:  Anywhere there is, or has been, a man-made or wrought (worked) intervention in the natural environment, e.g. cities, towns, villages, rural settlements, service utilities, transport systems, roads, bridges, tunnels, and cultivated lands, lakes, rivers, coasts, and seas, etc … including the Virtual Environment.

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

The Built and Virtual Environments continue to merge into a new Augmented Reality.

A comprehensive document capable of answering a major portion of Europe’s current needs in this area is on the verge of being published as a full International Standard … ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’.  And … as is the case with hundreds of ISO Standards in other sectors, this standard could easily be approved by CEN, one of Europe’s Standards Organisations, as an EN (European Standard) … under the Vienna Agreement on Technical Co-Operation between ISO and CEN, which was confirmed by both organizations in 2001 … and the period to practical application of ISO 21542 on the ground would be relatively swift.

Every delay represents not only a precious opportunity missed to improve the Accessibility of the Built Environment … but another blatant Denial of Human and Social Rights to vulnerable groups of people in all our communities !

Yes, this document was badly managed at the beginning of its very long gestation period, and its contents were a bit of a mess for the first few years … AND European countries were indignant, then, at the prospect of it becoming a European Standard.  However, walking around any major city in any country in Europe today, and witnessing the universally appalling and miserable efforts at Accessibility Implementation … you would have to be outraged at the level of hypocrisy and blatant self-delusion practiced by Europeans !

BUT NOW … ISO FDIS 21542 … the Final Draft of the International Standard which was issued for voting, beginning on 22 September 2011 … is a very respectable looking document altogether.  It makes important statements about ‘creating a sustainable built environment which is accessible’.  Its purpose is ‘to define how the built environment should be designed, constructed and managed to enable people to approach, enter, use, egress from and evacuate a building independently, in an equitable and dignified manner and to the greatest extent possible’ … ‘principles which are supported by Preamble (g) and Articles 9, 10 and 11 of the United Nations Convention on the Rights of Persons with Disabilities’.  I could go on, and on … but I will resist the temptation, since I was heavily involved in the development of this ISO Standard !

The point is … there is no longer any reason for European countries to complain about the inadequacy of this International Standard … and it should be the preferred instrument of choice to facilitate the immediate operation of the Accessibility / Design for All Requirements in EU Public Procurement Directive 2004/18/EC.

Unfortunately, this may not happen !

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Years too late, near the end of 2007 … DG Employment, Social Affairs & Inclusion (EMPL), in the European Commission, issued the following Mandate …

M/420 EN – Brussels, 21 December 2007

Standardization Mandate 420 to CEN, CENELEC and ETSI in Support of European Accessibility Requirements for Public Procurement in the Built Environment

Click the Link Above to read and/or download PDF File (67.4 kb)

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This Mandate covers 2 Phases of Work.  Phase I deals with compiling an inventory of existing accessibility-related standards and an analysis of any gaps … as well as with issues of accessibility implementation monitoring and conformity assessment.  Phase II is the actual accessibility standard(s) development phase.

However … Mandate M/420 EN is a flawed document, and it should have received much closer scrutiny from the European Standards Organizations named in the document title … before any work in Phase I commenced.  Failing that … the first work item on the Phase I Agenda should certainly have been a critical examination of the mandate.

In a post, dated 15 January 2011 … I wrote …

” The European Union’s Accessibility Strategy, related Policies and Programmes … and the monitoring, targeting and independent verification of Accessibility Implementation … all require a radical overhaul !

All those Officials in the European Commission who are involved, in any way, shape or form, with Accessibility of the ‘Human Environment’ would do well to RE-READ AND MEDITATE DEEPLY on the contents of the 2003 Final Report from the Group of Accessibility Experts, which was established by the European Commission itself … “

The Final Report from the 2003 EU Group of Accessibility Experts, of which I was a Member, can be downloaded towards the end of that post.

The Officials who drafted Commission Mandate M/420 EN paid little, if any, attention to that 2003 Expert Group Report.

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At the end of Phase I … in response to the European Commission’s Mandate M/420 EN … a long, rambling CEN Joint Report (document ref. CEN/BT/WG 207 N 29) of 425 Pages was issued, dated 8 August 2011, for general discussion and comment.

Some Comments on the CEN Joint Report …

1.  Terminology

CEN Joint Report – CEN/BT/WG 207 N 29

3.4     Conclusions View, Findings and Recommendations

3.4.1  Overview

Terms such as ‘procurement’, ‘inclusion’, ‘accessibility’ and ‘compliance’ are difficult to define precisely, and they are often not fully understood by those responsible for managing or providing the products or environments people use.  They are also not readily understood by those administrating and triggering the procurement process.

It is strange, therefore … and unacceptable … that this Report does not attempt to reduce and/or remove the ambiguity surrounding these terms … by providing a clear definition, with a supporting explanatory text, for each of the terms listed above.

I’m not even sure that the large numbers of people who helped to draft the CEN Joint Report fully understand those terms !

Most importantly, the Report is not at all precise about … and in fact appears to be completely confused by … the clear distinction which must be made between ‘accessibility’ and ‘access’.

2.  ‘Accessibility’ & UN CRPD

Accessibility does not begin and end with Article 9 of the United Nations 2006 Convention on the Rights of Persons with Disabilities (CRPD) !!!   See my post, dated 15 January 2011 … and #6 below.

3.  EU Ratification of UN CRPD

The full implications arising from European Union (EU) Ratification, on 23 December 2010, of the United Nations 2006 Convention on the Rights of Persons with Disabilities (CRPD) … for both EU Institutions, and the EU Member States (whether or not they have individually ratified the UN Convention) … have not been properly examined in the CEN Joint Report.

See my post, dated 5 February 2011 .

4.  Mainstreaming ‘Accessibility’

For the majority of people involved in the spatial planning, design and development of the European Built Environment, Accessibility is all about transport issues … for example, how far a proposed new building is from a transportation node.

We are communicating such a confused message (is it Accessibility for All, Design for All, Inclusive Design, Universal Design, or Barrier-Free Design ?) … that many policy and decision makers just could not be bothered.  And who, in Europe, is really concerned with the quality of Accessibility Implementation ???

In addition … the CEN Joint Report neglected to deal adequately … or at all … with a major body of EU Legislation which has been implemented at national level, in the Member States, many years ago … Safety at Work Legislation !   All of the EU Directives require that workplaces be accessible.  Yet, I know for a fact that, in Ireland, the Health & Safety Authority (HSA) is doing absolutely nothing to check whether this requirement is being complied with or not.

A Sustainable Built Environment is Accessible for All !   So many different types of International/European/National Legislation mandate that the Built Environment shall be Accessible for All !!   Good Design demands that the Built Environment is Accessible for All !!!

So why is Accessibility not being properly integrated into the operation of Environmental Impact Assessment (EIA) Legislation ?

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.

No case need be made for the integration of Accessibility into Sustainability Impact Assessment (SIA) … it self-evidently must be !

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

5.  What Is The Overriding European Social Priority ?

The overriding European Social Priority is to commence operation, with full effect, of the Accessibility / Design for All Requirements within the fast evolving European Public Procurement Framework … as quickly as possible.

Do we have to wait another 2 or 3 years, at least, for the production of an ‘acceptable’ European Accessibility Standard ??   Instead, why not approve ISO 21542 as the European Standard when it is published as a full standard … which will be very soon ?   ISO 21542 is already being used as the benchmark in the CEN Joint Report !

AND … do we have to wait, for who knows how long … before Effective Monitoring Procedures … and Independent Verification Procedures … are put in place at European and National/Regional/Local Levels ???

Quality of European Accessibility Implementation … is critical !

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2011-10-17 …

6.  Post UN CRPD – A More Demanding Scope & Quality of Implementation

Not unexpected … but it has still been a most enlightening experience to read the recent UN CRPD Committee Report on Spain … selected extracts from which are reproduced below.  The language used by the Committee is strong and direct … finally !

This is not a good report and, in places, it makes for unpleasant reading … a concrete example of the ‘hypocrisy and blatant self-delusion practiced by Europeans’, which I talked about earlier.

In accordance with Article 36.3 of the UN Convention on the Rights of Persons with Disabilities (CRPD) … the UN Secretary-General will be making this Report available to all States Parties.

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United Nations Committee on the Rights of Persons with Disabilities

Sixth Session – 19 to 23 September 2011

Concluding Observations on Initial Report of Spain

(Article 35 of UN CRPD)

The Committee considered the initial report of Spain (CRPD/C/ESP/1) at its 56th and 57th meetings, held on 20 September 2011, and adopted the following concluding observations at its 62nd meeting, held on 23 September 2011.

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III.  Principal Areas of Concern & Recommendations

A.  General Principles & Obligations (Articles 1 & 4)

11.  The Committee takes note of the adoption of Act 26/2011 which introduces the concept of ‘person with disabilities’ as defined in the Convention and expands the protection of persons with disabilities.  However, it is concerned that not all persons with disabilities are covered by the law.

12.  The Committee urges the State Party to ensure that all persons with disabilities enjoy protection against discrimination and have access to equal opportunities irrespective of their level of disability.

13.  The Committee welcomes Act 49/2007, dated 26 December 2007, establishing the Permanent Specialized Office to deal with offences and sanctions in equal opportunities, non-discrimination and universal accessibility by persons with disabilities.  However, it is concerned by the slow development and lack of promotion of this arbitration system at the regional government level; by the lack of information on the number of sanctions submitted and resolved; and by the failure of the State Party to report on actions undertaken to implement this law.  The Committee is concerned about the overall effectiveness of the system.

14.  The Committee recommends that the State Party raise awareness among persons with disabilities about the system of arbitration; increase the level of free legal aid; and ensure the regulation of offences and sanctions at the regional government level.

15.  The Committee regrets the lack of information on the meaningful participation of persons with disabilities and their representative organisations at the regional level in designing, and evaluating the implementation of legislation, policy and decision-making processes; and the participation of children with disabilities at all levels.

16.  The Committee recommends that the State Party take specific measures to: ensure the active participation of persons with disabilities in public decision-making processes at the regional level; and to include children with disabilities at all levels.

17.  The Committee takes note of Act 2/2010 of 3 March 2010 on sexual and reproductive health decriminalizing voluntary termination of pregnancy, allowing  pregnancy to be terminated up to 14 weeks and including two specific cases in which abortion is allowed for longer time limits due to the fact that the foetus has a disability:  until 22 weeks of gestation, provided there is ‘a risk of serious anomalies in the foetus’, and beyond week 22 when, inter alia, ‘an extremely serious and incurable illness is detected in the foetus’.  It also notes the explanations provided by the State Party for maintaining this distinction.

18.  The Committee recommends that the State Party abolish the distinction made in Act 2/2010 in the period allowed under law within which a pregnancy can be terminated, based solely on disability.

B. Specific Rights (Articles 5-30)

Equality and non-discrimination (Article 5)

19.  The Committee welcomes the adoption of Act 26/2011 amending regulations which will abolish the need to have a disability certificate to bring a discrimination claim before a judicial body.  However, it regrets the lack of information on cases of discrimination, and it is concerned that persons with disabilities will still be marginalized.  The Committee is further concerned by the lack of information on reasonable accommodation.  It is also concerned that in practice disability affects parents’ guardianship or custody of their children and that legal protection against discrimination on the grounds of disability is not enforceable in cases of discrimination due to perceived disability or association with a person with a disability.

20.  The Committee urges the State Party to expand the protection of discrimination on the grounds of disability to explicitly cover multiple disability, perceived disability and association with a person with a disability, and to ensure the protection from denial of reasonable accommodation, as a form of discrimination, regardless of the level of disability.  Moreover guidance, awareness raising and training should be given to ensure a better comprehension by all stakeholders, including persons with disabilities, of the concept of reasonable accommodation and prevention of discrimination.

Article 8 – Awareness-Raising

25.  The Committee commends the many initiatives taken by the State Party to implement the Convention.  However, it notes that more needs to be done to increase awareness in society, in the media and amongst persons with disabilities themselves of the right of persons with disabilities.

26.  The Committee calls upon the State Party to take proactive measures to enhance awareness of the Convention and its Optional Protocol at all levels, in particular among the judiciary and the legal profession, political parties, Parliament and Government officials, civil society, media, persons with disabilities, as well as the general public.

Article 9 – Accessibility

27.  The Committee takes note that Act 26/2011 amends regulations which will shorten the timelines for meeting accessibility requirements in public facilities; and goods and services available to the public.  However, it remains concerned at the low level of compliance with these requirements, in particular, at regional and local levels, in the private sector, and in relation to existing facilities.  The Committee is aware of situations of discrimination faced by air passengers with disabilities, including situations of denial of boarding.  The Committee reminds the State Party that Article 9 of the Convention also demands access to information and communication.

28.  The Committee recommends that sufficient financial and human resources be allocated as soon as possible to implement, promote and monitor compliance with accessibility legislation through national measures as well as through international cooperation.

Article 11 – Situations of Risk & Humanitarian Emergencies

31.  The Committee is concerned at the insufficiency of specific protocols for persons with disabilities in emergency situations.

32.  The Committee calls upon the State Party to review its laws and policies related to emergency situations with a view to including provisions guaranteeing the security and protection of persons with disabilities.

[ My Comment:  This is a gross understatement of a serious problem which continues to fester not only in Spain but, more generally, in Europe ! ]

Article 19 – Living Independently & Being Included in the Community

39.  The Committee is concerned at the lack of resources and services to guarantee the right to live independently and to be included in the community, in particular in rural areas.  It is further concerned that the choice of residence of persons with disabilities is limited by the availability of the necessary services, and that those living in residential institutions are reported to have no alternative to institutionalization.  Finally, the Committee is concerned about linking eligibility of social services to a specific grade of disability.

40.  The Committee encourages the State Party to ensure that an adequate level of funding is made available to effectively enable persons with disabilities to: enjoy the freedom to choose their residence on an equal basis with others; access a full range of in-home, residential and other community services for daily life, including personal assistance; and to enjoy reasonable accommodation so as to better integrate into their communities.

41.  The Committee is concerned that the law for the promotion of autonomy limits the resources to hire personal assistants only to those persons who have level 3 disabilities and only for education and work.

42.  The Committee encourages the State Party to expand resources for personal assistants for all persons with disabilities in accordance with their requirements.

Article 24 – Education

43.  The Committee welcomes the fact that the principle of inclusion governs the schooling of pupils with special educational needs; that discrimination in education is prohibited; and that most children with disabilities are included in the regular education system.  It commends the enactment of Organic Act 2/2006 on Education, which obliges the education authorities to provide specialist teachers, qualified professionals and the necessary materials and resources, as well as the laws that oblige schools to make necessary curricular adjustments and diversifications for pupils with disabilities.  However, the Committee is concerned by the implementation of these laws in practice, in view of reported cases of failure to provide reasonable accommodation, of continued segregation and exclusion, of financial arguments used as justification for discrimination, and of the cases of children enrolled in special education against their parents’ will.  The Committee notes with concern that parents challenging the placement of their children with disabilities in special education have no possibility of appeal and that their only alternative is to educate them at their own expense or pay for the reasonable accommodation of their child in the regular education system.

44.  The Committee reiterates that denial of reasonable accommodation constitutes discrimination and the duty to provide reasonable accommodation is immediately applicable and not subject to progressive realisation.  It recommends the State Party to:

     (a)  Increase its efforts to provide reasonable accommodation in education, allocating sufficient financial and human resources to implement the right to inclusive education; paying particular attention to assessing the availability of teachers with specialist qualifications; and ensuring that educational departments of local governments understand their obligations under the Convention and act in conformity with its provisions ;

     (b)  Ensure that the decisions to place children with a disability in a special school or in special classes, or to offer them solely a reduced standard curriculum, are taken in consultation with the parents ;

     (c)  Ensure that the parents of children with disabilities are not obliged to pay for the education or for the measures of reasonable accommodation in mainstream schools ;

     (d)  Ensure that decisions on placing children in segregated settings can be appealed swiftly and effectively.

C.  Specific Obligations (Articles 31-33)

Statistics and data collection (Article 31)

49.  The Committee regrets the low level of disaggregated data on persons with disabilities.  The Committee recalls that such information is indispensable to: understanding the situations of specific groups of persons with disabilities in the State Party who may be subject to varying degrees of vulnerability; developing laws, policies and programmes adapted to their situations; and assessing the implementation of the Convention.

50.  The Committee recommends that the State party systematize the collection, analysis and dissemination of data, disaggregated by sex, age and disability; enhance capacity building in this regard; and develop gender-sensitive indicators to support legislative developments, policymaking and institutional strengthening for monitoring and reporting on progress made with regard to the implementation of the various provisions of the Convention.

51.  The Committee regrets that the situation of children with disabilities is not reflected in the data on the protection of children.

52.  The Committee recommends that the State Party systematically collect, analyse and disseminate data, disaggregated by sex, age and disability, on abuse and violence against children.

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END