Part D of the Irish Building Regulations

2017 Architecture & Building Expo – An Annoying Experience !!

2017-10-09:  On Saturday last, 7 October, I had the great misfortune to attend the Architecture & Building Expo … which was being held, in conjunction with the RIAI’s (Royal Institute of the Architects of Ireland) Annual Conference, at the RDS (Royal Dublin Society) Main Hall in Ballsbridge, Dublin …

Colour photograph showing the Entrance to the RDS Main Hall … and the 2017 Architecture & Building Exhibition.  Click to enlarge.

Colour photograph showing a high level view over the 2017 Architecture & Building Exhibition in the RDS Main Hall.  Click to enlarge.

Colour photograph showing some of the people who attended the 2017 Architecture & Building Exhibition in the RDS Main Hall.  Click to enlarge.

What was annoying … really annoying … and depressing, all at the same time … was having to introduce a senior individual on one Exhibition Stand to Part D of the Irish Building Regulations !   I even had to show that same individual where to find Technical Guidance Document D on the Irish DHPLG (Department of Housing, Planning & Local Government) Website.  And on more than a few other Stands … having to explain what is a CE Mark !!   This is entirely unacceptable.  FUBAR.

And let us all not forget that this Exhibition was being held in conjunction with the RIAI’s 2017 Annual Conference

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Sustainable Buildings – Design Agenda for the 21st Century ?

2009-05-06:  From the late 1980’s and the beginning of the 1990’s in European Union (EU) Research Programmes, it was noticeable that the more pressing early concerns about Energy-efficiency – logical after the oil crises of the 1970’s – were beginning to merge with those of Environment-friendliness, i.e. protection of the environment.  Even at that time, however, faint background references to Sustainability were becoming more common.

 

In 1995, therefore, Sustainable Design International developed and introduced the acronym ‘SEED’ … which stands for Sustainable, Environment-friendly, Energy-efficient Development … as a practical control, or check, on our own work output.

 

 

The next break-through came a few years later.  I briefly discussed the wide conceptual basis for our Corporate Design Philosophy in the post: ‘Sustainable Human & Social Development ?’, dated 2009-03-31.  This basis, while still continually evolving, is critical in terms of services provided, performance targets to be achieved, methods of working and relationships with client organizations, builders, craftsmen/women, manufacturers, etc.

 

This should explain the futility, in our humble view, of the ‘Green’ Agenda (as distinct from the ‘Sustainability’ Agenda) … and approaches based solely on Environmental Aspects of Sustainable Development.  They are a complete waste of time and resources.

 

 

Now in 2009, we remain fully convinced that Sustainable Design Solutions are appropriate to local geography, social need, climate, economy and culture … and are ‘person-centred’ and ‘reliability-based’.

 

Forget the images of mud housing and reading by candle light … the Future of our Built Environment is High-Tech, Smart … and Sustainable !   Let there be no doubt !!

 

 

 

Why not begin, so, by looking at a Simple Building Type … Sustainable Housing ?

 

With all of the current hype and fuss about German ‘Passiv’ Houses and Austrian High-Tech Timber Framed Construction … we have been in contact with a number of manufacturers in this region of Central Europe.  After many meetings and detailed discussions, we are disappointed … broken hearted !

 

Below follows our shopping list for the practical, commercial and affordable application, i.e. non-research, of Advanced Systems of Construction (small/medium/large scale projects – new-build and existing projects).

 

N.B.  Current Irish legal requirements and local authority technical control procedures are entirely inadequate.

 

Is anybody out there listening ???

 

 

 

To meet the urgency of Climate Change Adaptation and the challenge of Reliable Sustainability Implementation … a ‘SEED’ Building in Ireland must reach these performance targets:

 

         be set in Sustainable Landscaping (where appropriate) with Life Cycle Sustainable Drainage … and exhibit a considered, harmonious relationship between the building’s ‘interior’ environment and the ‘exterior’ built and social environments ;

 

         have a Minimum Building Life Cycle of 100 Years ;

 

         be Smart/Intelligent, Electronically Mature and facilitate Remote Building Management ;

 

         be properly shown to be Fit for Intended Use (in the Location of Use) … by CE Marking, using European Standards/Norms & European Technical Approvals (refer to Part D of the Irish Building Regulations and similar requirements in other European national building codes, European Union Safety at Work and Product Liability Legislation) ;

 

         be Super Energy-Efficient, with negligible thermal bridging and accidental air seepage … and promote and encourage, by design, Energy Conservation ;

 

         have a substantial component of Renewable Energy & Heat Technologies … sufficient to return a multiple of the building’s energy consumption to an Intelligent Regional or District Grid … and also incorporate Recycling, Rainwater Re-Use and Waste Management Technologies ;

 

         offer a high level of Indoor Air Quality, including proper protection from Natural Radon ;

 

         be Flexible and Adaptable with regard to internal layout, and Accessible for People with Activity Limitations (2001 WHO ICF) – in order to prolong Building Life Cycle and maximize Building Usability ;

 

         contain, as standard and for reasons of safety, a Domestic Sprinkler System and a remotely monitored Fire Detection System … plus a Carbon Monoxide (CO) Detection System, with a detection unit in the vicinity of each fuel burning appliance ;

 

and

 

         be Competently Built and Reliably Completed to project programme and cost estimate … with the building’s ‘Real’ Performance-in-Use capable of being tested, and continually monitored, over the complete building life cycle ;

 

and

 

         be simple and straightforward for Building Users/Occupiers to operate.

 

 

 

Principal Areas of Inadequate Performance …

 

1.  Showing Fitness for Intended Use.  Although a Single European Market for the Construction Sector exists on paper (not yet in reality) … this requirement is not well understood by manufacturers … particularly in Germany and Austria, where outdated national approaches to building product/system approval still take precedence over anything at European level.

 

2.  Domestic Sprinkler Systems.  There is a high level of resistance, among most manufacturers, to the installation of these systems.  Not acceptable !!

 

3.  Accessibility of Buildings for People with Activity Limitations.  Not well understood by manufacturers and building organizations (at all levels).  Although there is a lot of legislation in Europe covering this particular issue … it is routinely disregarded and/or very poorly implemented.  In Germany and Austria, for example, the long outdated term ‘barrier-free design’ is still in common use.  Can you believe that ?

 

4.  Radon Protection of Buildings.  Not considered important in Germany and Austria … so manufacturers just don’t bother.

 

5.  Fabric Thermal Performance.  Where building systems are ‘adapted’ for use in Ireland, I have seen thermal performance, as originally designed in Germany/Austria, seriously compromised by the installation of meter boxes and permanent ventilation openings in external walls.  Just the tip of the iceberg !

 

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Barcelona Accessibility Conference – European Issues ?

2009-03-24:  Permit me, first of all, to vigorously reclaim the word ‘accessibility’ back from the Transport Sector.  This important conference in Barcelona was not about transport networks or distances from the nearest transportation node … but about Accessibility of the Human Environment for People with Activity Limitations (2001 WHO ICF), i.e. Accessibility-for-All.

 

A 2-Day Conference organized by EuCAN – the European Concept for Accessibility Network co-ordinated from Luxembourg – it was held in the TRYP APOLO Hotel (Av. Paral-lel, 57-59), on the 19-20th March 2009 … an impressive start-up event for the next EuCAN Project … a publication elaborating the business opportunities being created by Design-for-All for manufacturers and service providers across Europe.

 

I was very pleased to make a presentation on the exciting business potential of Accessible Fire Engineering … a subset of Sustainable Fire Engineering …

 

 

Colour image showing the Title Page (only) of CJ Walsh's Presentation: 'Accessible Fire Engineering', at the recent 2-Day EuCAN Conference in Barcelona, Spain. Held on 19-20th March, 2009.

Colour image showing the Title Page (only) of CJ Walsh’s Presentation: ‘Accessible Fire Engineering’, at the recent 2-Day EuCAN Conference in Barcelona, Spain. Held on 19-20th March, 2009. Click to enlarge.

 

There were, however, some developments at the conference which should be brought to wider public attention for consideration and discussion … here in Ireland, but also in other European countries …

 

 

Colour photograph showing the West/'Passion' Elevation of the Templo Expiatorio de la Sagrada Familia in Barcelona, Spain. An architectural wonder designed by Catalan Architect, Antoni Gaudí i Cornet (1852-1926), and still under construction. Click to enlarge. Photograph taken by CJ Walsh. 2009-03-20.

Colour photograph showing the West/’Passion’ Elevation of the Templo Expiatorio de la Sagrada Familia in Barcelona, Spain. An architectural wonder designed by Catalan Architect, Antoni Gaudí i Cornet (1852-1926), and still under construction. Click to enlarge. Photograph taken by CJ Walsh. 2009-03-20.

 

1.  News was announced at the conference that the Proposed International Accessibility-for-All Standard (at present ISO CD 21542.3) has been overwhelmingly supported (mid-March 2009) for progress to the Draft International Standard (DIS) stage in its development.  If everything goes well, we should see this International Standard being published sometime during the first half of 2010. 

The ISO Accessibility-for-All Standard, which will be an essential implementation tool for Articles 9 & 11 of the 2006 United Nations Convention on the Rights of Persons with Disabilities in relation to Buildings, is particularly important for 2 Reasons:

 

         ‘Fire Safety’ Texts are now included in the Main Body of the Standard ;

 

         ‘Fire Evacuation’ is fully integrated into the definition and meaning of ‘Accessibility’.

 

 

Colour photograph showing the Interior of the Templo Expiatorio de la Sagrada Familia in Barcelona, Spain. Current state of progress with the Nave. An architectural wonder designed by Catalan Architect, Antoni Gaudí i Cornet (1852-1926), and still under construction. Click to enlarge. Photograph taken by CJ Walsh. 2009-03-20.

Colour photograph showing the Interior of the Templo Expiatorio de la Sagrada Familia in Barcelona, Spain. Current state of progress with the Nave. An architectural wonder designed by Catalan Architect, Antoni Gaudí i Cornet (1852-1926), and still under construction. Click to enlarge. Photograph taken by CJ Walsh. 2009-03-20.

 

 

2.  A conversation during the conference morning coffee break, on Friday 20th March, with Bojana Rudić and Miodrag Počuč of the Centar Živeti Uspravno in Serbia, has finally convinced me that all of the various Accessibility Design Philosophies

 

         design-for-all (some attempts have been made to develop 6 Principles for this rather vague philosophy) … used by EU Institutions, and more widely throughout Europe in reaction to universal design ;

         universal design (with its 7 Principles/Commandments) … preached from the USA … but in Japan, for example, a more practical application can be seen.  Strangest of all is the relatively recent establishment in Ireland of the Centre for Universal Design, within the lumbering qwango that is the National Disability Authority (NDA) ;

         inclusive design (with its 5 Principles) … originating from Great Britain ;

         barrier-free design (a philosophy long out of date) … still widely referred to in Germany and other parts of Central Europe ;

         facilitation design (a newer philosophy based on 2 WHO ICF Terms: ‘Facilitator’ and ‘Environmental Factors’ and intended to update barrier-free design) … not yet well known ;

 

… are not only causing enormous confusion about accessibility among the ‘un-initiated’ and architectural students, to take just two examples … but are diverting scarce resources away from the process of ‘real’ accessibility implementation.

 

In some cases, devotion to these philosophies is so consuming that I have experienced, first-hand, a general tendency to discourage any talk about rights … with some prominent members of the International Accessibility Community (who shall remain nameless !) not even bothering to read the actual text of the 2006 UN Disability Rights Convention !

 

 

Colour photograph showing a General View, from within, of the 1929 Barcelona Pavilion - a Master Statement of Modern Architecture - designed by German Architect, Ludwig Mies van der Rohe (1886-1969). De-constructed in early 1930 after the Barcelona International Exposition, it was constructed again in 1986. Click to enlarge. Photograph taken by CJ Walsh. 2009-03-20.

Colour photograph showing a General View, from within, of the 1929 Barcelona Pavilion – a Master Statement of Modern Architecture – designed by German Architect, Ludwig Mies van der Rohe (1886-1969). De-constructed in early 1930 after the Barcelona International Exposition, it was constructed again in 1986. Click to enlarge. Photograph taken by CJ Walsh. 2009-03-20.

   

3.  Concerning the development of a European Accessibility Business Strategy

 

         2006 UN Convention on the Rights of Persons with Disabilities

 

Yes … Accessibility-for-All is about much more than making life and living easier for people with disabilities.  Children, frail older people (not all older people !), women in the later stages of pregnancy, people who have a health condition, etc., all now need to be included in a more Person-Centred Approach to the design and sustainable transformation of our Human Environment.  This is absolutely essential.

 

But … the 2006 UN Convention must be used as a Product & Service Checklist which covers the basic, i.e. minimum, responsible needs of people with disabilities … a sizeable social group in all of our societies.  Failure to complete this simple task is a fundamental strategic error !

 

The 2006 UN Convention on the Rights of Persons with Disabilities is also their sole route of access to the human and social rights set down in the 1948 Universal Declaration of Human Rights.

 

 

         Integration of Accessibility-for-All Performance

 

Building Accessibility, to take a specific example, is now more complex … and includes …

 

         Approach to the building from the site boundary ;

         Entry through principal entrance(s) ;

         Health, Safety, Convenience & Comfort In Use, including thermal and acoustic comfort, good indoor air quality, protection from fire, etc ;

         Egress under normal conditions ;

         Evacuation in the Event of a Fire, or other emergency ;

         Removal from the vicinity of the building back to the site boundary ;

 

and …

 

         Each stage of a Work Process, at every level, in places of work ;

         Use of Electronic, Information & Communication Technologies (EICT’s) – at minimum, those permanently fixed in/to the building ;

 

and …

 

         Management, Services & Attitudes of People in the organization using the building ;

         Recruitment, Employment, Promotion & Training Practices within the same organization.

 

 

Performance in all of these different, and up until now separate, components must be brought together and properly integrated.

 

 

         Accessibility-related Products

 

In Ireland, we suffer from an over-supply of British manufactured accessibility-related products which are badly-designed and inadequately tested … or not tested at all.  Inability to show compliance with Part D of the Irish Building Regulations is a big issue … that is, if those manufacturers even realize that we have our own separate building legislation over here.

 

By the way, failure to be able to show compliance with Regulation 7 of the Building Regulations for England & Wales is an issue across the water as well !

 

The situation isn’t much better in the rest of Europe.  Yes … the quality of design is much, much better, but there is still enormous confusion about CE Marking.

 

Accessibility-related Products are still, and always have been, industrial products which are being placed on the Single European Market.  Normal rules apply !

 

 

         Accessibility-related Services

 

Hopefully, we will soon see the demise of the Access Consultant … a plentiful species, particularly in Great Britain … an individual who only deals with ‘approach to’, ‘entry’ and ‘use’ of a building or facility … and nothing about ‘fire evacuation’.  Their days are slowly numbered !

 

The rest of us, however, need to familiarize ourselves with necessary new services …

 

         Accessibility Impact Assessment ;

         Accessibility Performance Indicators ;

         Accessibility Benchmarking, Target Setting and Progress Evaluation ;

         Independent Accessibility Verification ;

         Etc.

 

Accessibility-related Services must be dragged out of prehistoric caves … screaming, if necessary.  Services must become much more professional !

 

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