‘A Gentle Whisper in Your Ear’

ISO/IEC Guide 71 & CEN/CENELEC Guide 6 – Flawed ?

International Guidance Document … ISO/IEC Guide 71 : Guidelines for Standards Developers to Address the Needs of Older Persons and Persons with Disabilities was issued in November 2001.

European Guidance Document … CEN/CENELEC Guide 6 : Guidelines for Standards Developers to Address the Needs of Older Persons and Persons with Disabilities … a similar document … was issued a little later, in January 2002.

These Guides provide basic guidance to people drafting International & European Standards on how to take into account the needs of people with activity limitations, particularly older persons and people with disabilities.  While recognizing that some people with very extensive and complex impairments may have requirements beyond the level addressed in these documents, a very large number of people have minor impairments which can easily be addressed with a very small change of approach by people writing the Standards.  Typically, the problem is solely a lack of awareness.

Unfortunately, few Standards Developers … in either organization … are paying the slightest bit of attention to these Guides.

People with Activity Limitations:  Those people, of all ages, who are unable to perform, independently and without aid, basic human activities or tasks – because of a health condition or physical/mental/cognitive/psychological impairment of a permanent or temporary nature.

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1.  A full six months before the appearance of ISO/IEC Guide 71 … all of the 191 Member States of the World Health Organization endorsed, and officially adopted, the International Classification of Functioning, Disability & Health (ICF) on 22nd May 2001 … which replaced the earlier International Classification of Impairment, Disability & Handicap (ICIDH), dating from 1980.

While the previous health indicators had been based on the mortality (i.e. death) rates of populations … the new 2001 WHO ICF dramatically shifted the focus to ‘life’ and ‘living’ … in other words, how everyone is living with his/her health condition(s) and how improvements can be made to ensure a productive, fulfilling life in society.

This had important implications for medical practice; for legal, social, economic, institutional, design and spatial planning policies to improve accessibility, equal opportunity for all and inclusion; and for the protection of the rights of all individuals and groups.

Of special interest for people involved in any of the technical fields mentioned above … the 2001 WHO ICF also introduced a new disability-related language and terminology.

BUT … But … but … ISO/IEC Guide 71 and CEN/CENELEC Guide 6 do not use the 2001 WHO ICF’s innovative language and terminology.  Consequently, these International & European Guides are flawed.

For a very good example of WHAT MUST BE AVOIDED (!) in the drafting of International & European Standards … please examine the following text …

ISO DIS (Draft International Standard) 21542 : Building Construction – Accessibility and Usability of the Built Environment … dated November 2009 …

Section 3   Terms & Definitions

‘ #3.36  Impairment

Limitation in body function or structure such as a significant deviation or loss which can be temporary due, for example, to injury, or permanent, slight or severe and can fluctuate over time, in particular, deterioration due to ageing.

[ISO/TR 22411:2008]

NOTE 1   Body function can be a physiological or psychological function of a body system; body structure refers to an anatomic part of the body such as organs, limbs and their components (as defined in ICIDH-2 of July 1999).

NOTE 2   This definition differs from that in ISO 9999:2002 and, slightly, from ICIDH-2/ICF: May 2001, WHO: ‘any loss or abnormality of a body function, or body structure’.

NOTE 3   The word ‘abnormality’ is strictly used here to refer to a significant deviation from an established population mean, within measured statistical norms. Impairments can be physical, mental, cognitive or psychological.’

As clear as mud … what a mess !   This does nothing only sow needless confusion in the mind of a reader.

Unless and Until … we properly harmonize, at a technical level, disability-related language and terminology … in order to improve communication … we will all continue to run around in circles and make little forward progress !!!

[ At the level of the individual, people should always be free to use whatever language they wish. ]

Our Guidance to All Standards Developers is … whether working within the International Standards Organizations (ISO & IEC) or the European Standards Organizations (CEN & CENELEC) … or both …

‘ People with Activity Limitations must be properly considered at all stages in the development of a Standard … and any disability-related terminology used … should be fully consistent with the World Health Organization’s 2001 International Classification of Functioning, Disability & Health (ICF).  Confusing and contradictory texts should be avoided.’

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2.  In relation to ISO/IEC Guide 71 & CEN/CENELEC Guide 6 – Table 7 (Page 13 in both Guides) … #8.23 Fire Resistance requires a complete re-assessment.  On Page 21 of ISO/IEC Guide 71 and Page 22 of CEN/CENELEC Guide 6 … the supporting text for #8.23 has the different heading of ‘Fire Safety of Materials’ ?!?   Confusing, isn’t it ?

The Revised Title in Table 7 and the supporting text should read … Fire Safety.  ‘Fire Resistance’ is but one of many passive fire protection concepts … a very small sub-set in the wide technical field of ‘fire safety’ in buildings.  ’Fire Resistance’ is not used in connection with the ignition and fire development behaviour of materials or fabrics.

Relevant Factors for #8.23 are not properly indicated, in Table 7, under Columns #9.2, #9.3, #9.4 (a glaring omission !) & #9.5.

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3.  Pertinent to ‘fire safety’ in buildings … this text was removed from ISO CD (Committee Draft) 21542 … the previous version of the ISO Standard, dating from December 2008 …

ISO CD 21542 – Annex A.1.2 – 2nd Paragraph

‘ Building users should be skilled for evacuation to a place, or places, of safety remote from the building.  In the case of people with a mental or cognitive impairment, there is a particular need to encourage, foster and regularly practice the adaptive thinking which will be necessary during a ‘real’ fire evacuation.’

The Definition for the Term Skill (#3.60) is still retained in the later ISO DIS 21542 version of the Standard …

‘ The ability of a person – resulting from training and regular practice – to carry out complex, well-organized patterns of behaviour efficiently and adaptively, in order to achieve some end or goal.’

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4.  While there are eight references to ‘Cognitive Impairment’ in both Guides … nowhere is this term defined … or distinguished from ‘Mental Impairment’ …

Cognitive Impairment:  A deficiency of neuropsychological function which can be related to injury or degeneration in specific area(s) of the brain.

Mental Impairment:  A general term describing a slower than normal rate in a person’s cognitive developmental maturation, or where the cognitive processes themselves appear to be slower than normal – with an associated implication of reduced, overall mental potential. 

A deeper understanding, at a technical level, of the many different types of health conditions and impairments (physical/mental/cognitive/psychological) … can only result in a better designed, more facilitating Human Environment.

One final important term … when considering Fire Safety in Buildings …

Panic Attack:  A momentary period of intense fear or discomfort, accompanied by various symptoms which may include shortness of breath, dizziness, palpitations, trembling, sweating, nausea, and often a fear by a person that he/she is going mad.

I have long held the view that, in Fire Engineering, dramatic breakthroughs will result from a closer study of Cognitive Psychology.

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END

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People with Activity Limitations (2001 WHO ICF) ?

Or … in French: Personnes à Performances Réduites … a term which should be used much more often !

 

For many decades, the language of ‘disability’ has been all over the place, to put it mildly … others might suggest, however, that it lacks coherence, and is fragmented and chaotic !   As a result, it has been difficult to make any sort of solid progress on harmonization … at a technical level … in Europe.

 

Adopted on the 22nd May 2001, the World Health Organization’s International Classification of Functioning, Disability & Health (ICF), changed that situation for the better.  It is important to emphasise that the ICF is a classification of ‘Health’ … not of ‘Disability’.

 

 

People with Activity Limitations (English) /

Personnes à Performances Réduites (French):

 

Those people, of all ages, who are unable to perform, independently and without aid, basic human activities or tasks – because of a health condition or physical/mental/cognitive/psychological impairment of a permanent or temporary nature.

 

This term includes …

 

-         wheelchair users ;

-         people who experience difficulty in walking, with or without aid, e.g. stick, crutch, calliper or walking frame ;

-         frail, older people ;

-         the very young (people under the age of 5 years) ;

-         people who suffer from arthritis, asthma, or a heart condition ;

-         the visually and/or hearing impaired ;

-         people who have a cognitive impairment disorder, including dementia, amnesia, brain injury, or delirium ;

-         women in the later stages of pregnancy ;

-         people impaired following the use of alcohol, other ‘social’ drugs, e.g. cocaine and heroin, and some medicines, e.g. psychotropic drugs ;

-         people who suffer any partial or complete loss of language related abilities, i.e. aphasia ;

-         people impaired following exposure to environmental pollution and/or irresponsible human activity ;

 

and

 

-         people who experience a panic attack in a fire situation or other emergency ;

-         people, including firefighters, who suffer incapacitation as a result of exposure, during a fire, to poisonous or toxic substances, and/or elevated temperatures.

 

 

Anosognosia:

 

A neurological disorder marked by the inability of a person to recognize that he/she has an activity limitation or a health condition.

 

 

 

What is the big deal here ?

 

Because of the stigma which still attaches to ‘disability’ … and because some people are unable to recognise that they have an activity limitation or a health condition … depending on self-declaration, alone, for the purposes of developing suitable Fire Safety Management Procedures in a building (of any type) is a recipe for certain failure of those procedures.

 

And … of very direct relevance to design practice generally … compare the weak and inadequate definition of people with disabilities in Part M4 of the Irish Building Regulations (there is no reason to suspect that there will be an earth shattering improvement to this definition in the Revised Technical Guidance Document M … whenever it eventually sees the light of day !) … with the definition of disability in Irish Equality Legislation.

 

Chalk and Cheese !   Or … from the ridiculous to the sublime !   Check it out for yourself.

 

The consequence of this remarkable difference in definitions for anyone involved in the design and/or construction of a building is that … while they might very well be satisfying the Functional Requirements of Parts M and B in the Building Regulations … they will, more than likely, be still leaving the owner and the person who controls or manages the new building open to a complaint under our Equality Legislation.

 

In the case of Workplaces … truly brave is the person who will design a ‘place of work’ just to meet the minimal performance requirements of Building Regulations !

 

 

As a Rule of Thumb, therefore … architects, engineers, facility managers, construction organizations, etc, etc … should become more comfortable working with the concept of People with Activity Limitations.

 

 

This practical Rule of Thumb is also what lies behind the concept of Maximum Credible User Scenario, i.e. building user conditions which are severe, but reasonable to anticipate …

 

-         the number of people using a building may increase, on occasions which cannot be specified, to 120% of calculated maximum building capacity ;   and

-         10% of people using the building (occupants, visitors and other users) may have an impairment (visual or hearing, physical function, mental, cognitive or psychological, with some impairments not being identifiable, e.g. in the case of anosognosia).

 

 

 

[ Please note well ... that miserable piece of legislation ... or, bureaucrats' charter .. the 2005 Disability Act (Number 14 of 2005) ... is irrelevant to the above discussion.  But ... when Irish Politicians, Senior Civil Servants and the National Disability Authority begin to take seriously the 2006 United Nations Charter on the Rights of Persons with Disabilities ... the 2005 Act will have to be scrapped altogether and/or dramatically re-drafted ! ]

 

 

 

 

Tags: 2005 Disability Act (Number 14 of 2005), Accessibility of buildings for people with disabilities, Accessible Fire Engineering, anosognosia, Client Organizations, Design/Construction Rule of Thumb, European Technical Harmonization, Fire Safety, Fire Safety Management Procedures, Firefighter, frail older people, Functional Requirements, health condition, International Legal Instrument, Ireland, maximum credible user scenario, mental/cognitive impairment, National Disability Authority, NDA, panic attack, Part B of the Irish Building Regulations, Part M of the Irish Building Regulations, People with Activity Limitations (2001 WHO ICF), Personnes à Performances Réduites (2001 WHO ICF), psychological impairment, Technical Guidance Document M, the very young (people under the age of 5 years), United Nations Convention on the Rights of Persons with Disabilities, visually and/or hearing impaired, wheelchair users, women in the later stages of pregnancy, Workplaces, World Health Organization's International Classification of Functioning Disability & Health (ICF)