Sustainable Design International
NIST Recommendations 16-20 > Improved People Evacuation
Previous Posts in This Series …
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
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2011-11-30: SOME PRELIMINARY COMMENTS …
1. In the First Post of this Series, I wrote …
” As such a high level of performance is expected … indeed demanded … of a Sustainable Building … Sustainable Fire Engineering must be ‘reliability-based’ … in other words, it must have a rational, empirical and scientifically robust basis … “
Sustainable Fire Engineering must also be ‘person-centred’ … i.e. a design process (in whatever architectural or engineering discipline) which places ‘real’ people at the centre of creative endeavours and gives due consideration to their responsible needs, and their health, safety, welfare and security in the Human Environment.
In order to prolong, and if at all possible, significantly extend the Life Cycle of a Sustainable Building beyond 100 years … Fire Engineers must begin to feel at ease … and be comfortable … with the following mainstream Sustainable Design Concepts …
Flexibility: The extent to which a building interior is designed, when new, to be capable of being easily modified at any later stage during the life cycle of that building – with minimal cost and user inconvenience – because of a person’s changing living or working needs.
Adaptability: The extent to which a building, or a building component, is designed when new, or capable of being easily modified at any later stage, to meet the changing life and living needs of the broad range of potential users, who may or may not have activity limitations, or may develop a health condition during the life cycle of that building or component.
Accessibility of a Building: Ease of independent approach, entry, egress (during normal ambient conditions), evacuation (in the event of an emergency) and/or use of a building and its services and facilities, by all of the building’s potential users - with an assurance of individual health, safety and welfare during the course of those activities.
2. Group 5 of the 2005 NIST WTC Recommendations is, by far, the most important … introducing some innovative concepts of ‘real’ evacuation … with nothing too startling. Contrary to the impression given by NIST … these Recommendations are equally valid for complex building types and, in reality, for all but the most simple of low-rise buildings. It is interesting to note, however, that when discussing fire behaviour or structural performance in fire, for example … the NIST texts are confident and direct. Here, when dealing with ‘people’ issues … not so confident, prone to some rambling … and lacking clarity.
Shortly after the 2005 NIST Report (NCSTAR 1) was published, I stated the following on the SDI Corporate WebSite … at this FireOx International Page … http://www.sustainable-design.ie/fire/structdesfire.htm …
” In its treatment of ‘disability’ and ‘people with activity limitations’, the Report does not go far enough, and is seriously flawed.”
Let me explain why …
As you go scan down through NIST’s Recommendations 16-20, you will encounter 1 reference to ‘mobility impaired occupants’ and 2 references to the impersonal ‘mobility impaired’. IF (and that is still a very big ‘if’, because there is still so much rabid resistance to this topic !) … a New Post-9/11 Evacuation Model, or Construct, Dealing with ‘Disability’ is being developed … all of the major impairment groupings (i.e. visual impairment, hearing impairment, physical function impairment, mental/cognitive impairment, and psychological impairment) must be added to the mix from the beginning. In other words, our proper focus of attention must be ‘people with activity limitations’ … not just people with disabilities, but also frail older people (not all older people !), children under the age of 5 years, women in the later stages of pregnancy, people with a health condition, etc.
And … because of the social stigma still firmly attaching to ‘disability’ … many building occupants/users will not self-identify … not even if their lives depend on it !
Concentrating on one group only, i.e. people with mobility impairments, is simplistic and entirely inadequate … and we will all end up, in a few years time, having to graft on a consideration of the other impairment groups.
This is exactly what has already gone wrong with the development of Accessibility Design Guidance during the last 30 years … where ‘people with visual or hearing impairments’ received merely token attention … and ‘people with cognitive or psychological impairments’ received no attention at all ! And … we are now grappling with the challenge of having to graft on additional texts to try to re-balance International Design Guidance on Accessibility of the Built Environment. Been there – done that – I have all of the t-shirts !!
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.
The above Terms (in English and French) include …
- wheelchair users ;
- people who experience difficulty in walking, with or without a facilitation 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 ;
- people who suffer any partial or complete loss of language related abilities, i.e. aphasia ;
- people impaired following exposure to environmental pollution and/or other irresponsible human activities, e.g. war and terrorism ;
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.
3. So … what provision should be made for ‘people with activity limitations’ in typical Fire Engineering Design Projects ?
Equivalent to the concept of Maximum Credible Fire Scenario, which has already been discussed in this Series … at FireOx International, some years ago, we developed the concept of …
Maximum Credible User Scenario
Representing building user conditions which are also severe but reasonable to anticipate …
a) 10% of People Using the Building (occupants, visitors and other users) have an Impairment (visual or hearing, physical function, mental or cognitive, psychological, with some impairments not being identifiable) ;
[ This performance indicator appears in ISO FDIS 21542: 'Building Construction - Accessibility & Usability of the Built Environment', which will soon be published.]
b) The Number of People Using a Building increases, on occasions which cannot be specified, to 120% of designed/calculated maximum building capacity.
[ Generally ... the fire safety related texts contained in ISO 21542 are based on the 2005 & 2008 NIST WTC Recommendations.]
4. With regard to Recommendation 17 below, and NIST’s reference to the widths of evacuation staircases and door openings, etc … fire codes and regulations, fire authorities having jurisdiction (AHJ’s), and even the fire services themselves … still have a crazy mixed-up approach to defining the width of these building features … an approach which I am not even going to attempt to repeat ! Forget it !!
Without Exception … all understandings of Evacuation Route Width, Evacuation Staircase Width and Evacuation Door Opening Width … must be harmonized with the following definitions of Unobstructed Width …
Unobstructed Width – General
Free, unobstructed space – clear of all obstacles below a height of 2.1 metres above finished floor level – necessary for passage along a circulation route, or other route component, e.g. a staircase.
[ For example ... the Unobstructed Width of a Staircase is the clear dimension from the edge of one handrail to the edge of the opposite handrail ... and there is always a continuous handrail on each side of an evacuation staircase ! ]
Unobstructed Width – Door Opening
Free, unobstructed space – clear of all obstacles below a height of 2.0 metres above finished floor level – necessary for passage through a door opening, measured when the door leaf is opened to an angle of 90°, or when a sliding or folding door leaf is opened to its fullest extent.
[ For example ... the Unobstructed Width of a Door Opening is the dimension from the edge of the door leaf (when open at an angle of 90°) to the nearest edge of the door frame.]
This FireOx International Page on the SDI Corporate WebSite provides more guidance … http://www.sustainable-design.ie/fire/appendixd.htm
5. With regard to Recommendation 20 below, and NIST’s reference to allowing “all occupants an equal opportunity for evacuation” … this is not just a ‘nice idea’, or an ‘idealistic notion’ … this is now a Human and Social Right which is backed up and supported by International Law ! And … it is no longer acceptable for the Fire Science and Engineering Community to continue its stubborn resistance in the face of this fact !!
For the benefit of my fire engineering colleagues … I will, once again here, reproduce the most relevant extracts from the United Nations Convention on the Rights of Persons with Disabilities …
UN CRPD Preamble Paragraph (g)
Emphasizing the importance of mainstreaming disability issues as an integral part of relevant strategies of sustainable development, …
UN CRPD Article 9 – Accessibility
1. To enable persons with disabilities to live independently and participate fully in all aspects of life, States Parties shall take appropriate measures to ensure to persons with disabilities access, on an equal basis with others, to the physical environment, to transportation, to information and communications, including information and communications technologies and systems, and to other facilities and services open or provided to the public, both in urban and in rural areas. These measures, which shall include the identification and elimination of obstacles and barriers to accessibility, shall apply to, inter alia:
(a) Buildings, roads, transportation and other indoor and outdoor facilities, including schools, housing, medical facilities and workplaces ;
(b) Information, communications and other services, including electronic services and emergency services.
2. States Parties shall also take appropriate measures:
(a) To develop, promulgate and monitor the implementation of minimum standards and guidelines for the accessibility of facilities and services open or provided to the public ;
(b) To ensure that private entities that offer facilities and services which are open or provided to the public take into account all aspects of accessibility for persons with disabilities ;
(c) To provide training for stakeholders on accessibility issues facing persons with disabilities ;
(d) To provide in buildings and other facilities open to the public signage in Braille and in easy to read and understand forms ;
(e) To provide forms of live assistance and intermediaries, including guides, readers and professional sign language interpreters, to facilitate accessibility to buildings and other facilities open to the public ;
(f) To promote other appropriate forms of assistance and support to persons with disabilities to ensure their access to information ;
(g) To promote access for persons with disabilities to new information and communications technologies and systems, including the Internet ;
(h) To promote the design, development, production and distribution of accessible information and communications technologies and systems at an early stage, so that these technologies and systems become accessible at minimum cost.
UN CRPD Article 11 – Situations of Risk & Humanitarian Emergencies
States Parties shall take, in accordance with their obligations under international law, including international humanitarian law and international human rights law, all necessary measures to ensure the protection and safety of persons with disabilities in situations of risk, including situations of armed conflict, humanitarian emergencies and the occurrence of natural disasters.
[ Note: An outbreak of fire in a building is a situation of serious risk for all vulnerable building occupants/users.]
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At the time of writing, 153 Countries had signed the UN CRPD … while 106 Countries have ratified the Convention and are, therefore, the ‘State Parties’ referred to above.
These are just a few of the State Parties to the UN CRPD …
- Argentina (ratified the UN CRPD, 2008-09-02)
- Australia (ratified the UN CRPD, 2008-07-17)
- Brazil (ratified the UN CRPD, 2008-08-01)
- Canada (ratified the UN CRPD, 2010-03-11)
- China (ratified the UN CRPD, 2008-08-01)
- Cuba (ratified the UN CRPD, 2007-09-06)
- European Union (ratified the UN CRPD, 2010-12-23)
- India (ratified the UN CRPD, 2007-10-01)
- Malaysia (ratified the UN CRPD, 2010-07-19)
- Mexico (ratified the UN CRPD, 2007-12-17)
- Philippines (ratified the UN CRPD, 2008-04-15)
- South Africa (ratified the UN CRPD, 2007-11-30)
- Turkey (ratified the UN CRPD, 2009-09-28)
- United Arab Emirates (ratified the UN CRPD, 2010-03-19)
I wonder how implementation is proceeding in these countries !?!
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2005 NIST WTC RECOMMENDATIONS
GROUP 5. Improved Building Evacuation
Building evacuation should be improved to include system designs that facilitate safe and rapid egress, methods for ensuring clear and timely emergency communications to occupants, better occupant preparedness regarding their roles and duties for evacuation during emergencies, and incorporation of appropriate egress technologies.*
[ * F-36 This effort should include standards and guidelines for the development and evaluation of emergency evacuation plans, including best practices for both partial and full evacuation, and the development of contingency plans that account for expected conditions that may require adaptation, including the compromise of all or part of an egress path before or during evacuation, or conditions such as widespread power failure, earthquake, or security threat that restrict egress from the building. Evacuation planning should include the process from initial notification of the need to evacuate up to the point when occupants arrive at a place where their safety is ensured. These standards and guidelines should be suitable for assessing the adequacy of evacuation plans submitted for approval, and should require occupant training through the conduct of regular drills.]
NIST WTC Recommendation 16.
NIST recommends that public agencies, non-profit organizations concerned with building and fire safety, and building owners and managers develop and carry out public education and training campaigns, jointly and on a nationwide scale, to improve building occupants’ preparedness for evacuation in case of building emergencies. This effort should include better training and self-preparation of occupants, an effectively implemented system of floor wardens and building safety personnel, and needed improvements to standards. Occupant preparedness should include:
a. Improved training and drills for building occupants to ensure that they know evacuation procedures for a variety of emergency scenarios (e.g. including evacuation and shelter in place), are familiar with the egress route, and are sufficiently aware of what is necessary if evacuation is required with minimal notice (e.g. footwear consistent with the distance to be travelled, a flashlight/glow stick for pathway illumination, and dust masks).
b. Building owners and managers should educate tenants on the life safety systems present in their building(s), provide training materials explaining egress routes and stairwell and elevator information, and develop educational programmes explaining the most appropriate responses in emergency situations. It is further recommended that the owners and managers of office buildings implement the necessary systems for collecting and storing the training history of each building occupant.
c. Improved training and drills that routinely inform building occupants that roof rescue is not (or is) presently feasible as a standard evacuation option, that they should evacuate down the stairs in any full-building evacuation unless explicitly instructed otherwise by on-site incident commanders, and that elevators can be used if they are still in service and haven’t been recalled or stopped.
d. Improved codes, laws, and regulations that do not restrict or impede building occupants during evacuation drills from familiarizing themselves with the detailed layout of alternative egress routes for a full building evacuation.*
[ * F-37 New York City Local Law 5 prohibits requiring occupants to practice stairwell evacuation during drills.]
Affected Standard: ICC/ANSI A117-1. Model Building and Fire Codes: The standard should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard. Affected Organizations: NFPA, NIBS, NCSBCS, BOMA, and CTBUH.
NIST WTC Recommendation 17.
NIST recommends that tall buildings be designed to accommodate timely full building evacuation of occupants when required in building-specific or large-scale emergencies such as widespread power outages, major earthquakes, tornadoes, hurricanes without sufficient advance warning, fires, explosions, and terrorist attack. Building size, population, function, and iconic status should be taken into account in designing the egress system. Stairwell capacity and stair discharge door opening width* should be adequate to accommodate contraflow due to emergency access by responders.
[ * F-38 Egress capacity should be based on an all-hazards approach that considers the number and width of stairs (and door openings) as well as the possible use of scissor stairs credited as a single stair.]
a. Improved egress analysis models, design methodology, and supporting data should be developed to achieve a target evacuation performance (e.g. time for full building evacuation*) for the design building population by considering the building and egress system designs, and human factors such as occupant size, mobility status, stairwell tenability conditions, visibility, and congestion.
[ * F-39 Use of egress models is required to estimate the egress capacity for a range of different evacuation strategies, including full building evacuation. NIST found that the average surviving occupant in the WTC towers descended stairwells at about half the slowest speed previously measured for non-emergency evacuations.]
b. To the degree possible, mobility impaired occupants should be provided a means for self-evacuation in the event of a building emergency. Current strategies (and law) generally require the mobility impaired to shelter in place. New procedures, which provide redundancy in the event that the floor warden system or co-worker assistance (i.e. a buddy system) fails, should consider full building evacuation, and may include use of fire-protected and structurally hardened elevators,* motorized evacuation technology (e.g. a battery-operated evacuation chair), and/or dedicated communication technologies for the mobility impaired.
[ * F-40 Elevators should be explicitly designed to provide protection against large, but conventional, building fires. Fire-protected elevators also should be structurally hardened to withstand the range of foreseeable building-specific or large-scale emergencies. While progress has been made in developing the requirements and technologies for fire-protected elevators, similar criteria and designs for structurally hardened elevators remain to be developed.]
c. If protected/hardened elevators are provided for emergency responders but become unusable during an emergency, due to a malfunction or a conventional threat whose magnitude exceeds the magnitude considered in design, sufficient stairwell capacity should be provided to ensure timely emergency responder access to buildings that are undergoing full evacuation. Such capacity could be provided either via dedicated stairways for fire service use or by building sufficient stairway capacity (i.e. number and width of stairways and/or use of scissor stairs credited as a single stair) to accommodate the evacuation of building occupants while allowing access to emergency responders with minimal hindrance from occupant contraflow.
d. The egress allowance in assembly use spaces should be limited in state and local laws and regulations to no more than a doubling of the stairway capacity for the provision of a horizontal exit on a floor, as is the case now in the national model codes.* The use of a horizontal exit creates an area of refuge with a 2 hour fire rated separation, at least one stair on each side, and sufficient space for the expected occupant load.
[ * F-41 The New York City Building Code permits a doubling of allowed stair capacity when one area of refuge is provided on a floor, and a tripling of stair capacity for two or more areas of refuge on a floor. In the world after 11 September 2001, it is difficult to predict: (1) if, and for how long, occupants will be willing to wait in a refuge area before entering an egress stairway; and (2) what the impact would be of such a large group of people moving down the stairs on the orderly evacuation of lower floors.]
Affected Standards: NFPA 101, ASME A 17. Model Building and Fire Codes: The 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 18.
NIST recommends that egress systems be designed: (1) to maximize remoteness of egress components (i.e. stairs, elevators, exits) without negatively impacting on average travel distances; (2) to maintain their functional integrity and survivability under foreseeable building-specific or large-scale emergencies; and (3) with consistent layouts, standard signage, and guidance so that systems become intuitive and obvious to building occupants during evacuations.
a. Within a safety-based design hierarchy that should be developed, highest priority should be assigned to maintain the functional integrity, survivability, and remoteness of egress components and active fire protection systems (sprinklers, standpipes, associated water supply, fire alarms, and smoke management systems). The design hierarchy should consider the many systems (e.g. stairs, elevators, active fire protection, mechanical, electrical, plumbing, and structural) and system components, as well as functional integrity, tenant access, emergency responder access, building configuration, security, and structural design.
b. The design, functional integrity, and survivability of the egress and other life safety systems (e.g. stairwell and elevator shafts, and active fire protection systems) should be enhanced by considering accidental structural loads such as those induced by overpressures (e.g. gas explosions), impacts, or major hurricanes and earthquakes, in addition to fire separation requirements. In selected buildings, structural loads due to other risks such as those due to terrorism may need to be considered. While NIST does not believe that buildings should be designed for aircraft impact, as the last line of defence for life safety, the stairwells and elevator shafts individually, or the core if these egress components are contained within the core, should have adequate structural integrity to withstand accidental structural loads and anticipated risks.
c. Stairwell remoteness requirements should be met by a physical separation of the stairwells that provide a barrier to both fire and accidental structural loads. Maximizing stairwell remoteness, without negatively impacting on average travel distances, would allow a stairwell to maintain its structural integrity independent of any other stairwell that is subject to accidental loads, even if the stairwells are located within the same structural barrier such as the core. The current ‘walking path’ measurement allows stairwells to be physically next to each other, separated only by a fire barrier. Reducing the clustering of stairways that also contain standpipe water systems provides the fire service with increased options for formulating firefighting strategies. This should not preclude the use of scissor stairs* as a means of increasing stair capacity – provided the scissor stair is only credited as a single stair.
[ * F-42 Two separate stairways within the same enclosure and separated by a fire rated partition.]
d. Egress systems should have consistent layouts with standard signage and guidance so that the systems become intuitive and obvious to all building occupants, including visitors, during evacuations. Particular consideration should be given to unexpected deviations in the stairwells (e.g. floors with transfer hallways).
Affected Standard: NFPA 101. Model Building and Fire Codes: The standard 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 19.
NIST recommends that building owners, managers, and emergency responders develop a joint plan and take steps to ensure that accurate emergency information is communicated in a timely manner to enhance the situational awareness of building occupants and emergency responders affected by an event. This should be accomplished through better co-ordination of information among different emergency responder groups, efficient sharing of that information among building occupants and emergency responders, more robust design of emergency public address systems, improved emergency responder communication systems, and use of the Emergency Broadcast System (now known as the Integrated Public Alert and Warning System) and Community Emergency Alert Networks.
a. Situational awareness of building occupants and emergency responders in the form of information and event knowledge should be improved through better co-ordination of such information among emergency responder groups (9-1-1 dispatch, fire department or police department dispatch, emergency management dispatch, site security, and appropriate federal agencies), efficient sharing and communication of information between building occupants and emergency responders, and improved emergency responder communication systems (i.e. including effective communication within steel and reinforced concrete buildings, capacity commensurate with the scale of operations, and interoperability among different communication systems.
b. The emergency communications systems in buildings should be designed with sufficient robustness and redundancy to continue providing public address announcements or instructions in foreseeable building-specific or large-scale emergencies, including widespread power outage, major earthquakes, tornadoes, hurricanes, fires, and accidental explosions. Consideration should be given to placement of building announcement speakers in stairways in addition to other standard locations.
c. The Integrated Public Alert and Warning System (IPAWS) should be activated and used, especially during large-scale emergencies, as a means to rapidly and widely communicate information to building occupants and emergency responders to enhance their situational awareness and assist with evacuation.
d. Local jurisdictions (cities and counties or boroughs) should seriously consider establishing a Community Emergency Alert Network (CEAN), within the framework of IPAWS, and make it available to the citizens and emergency responders of their jurisdictions to enhance situational awareness in emergencies.* The network should deliver important emergency alerts, information and real time updates to all electronic communication systems or devices registered with the CEAN. These devices may include e-mail accounts, cell/mobile phones, text pagers, satellite phones, and wireless PDA’s.
[ * F-43 Types of emergency communications could include life safety information, severe weather warnings, disaster notifications (including information on terrorist attacks), directions for self-protection, locations of nearest available shelters, precautionary evacuation information, identification of available evacuation routes, and accidents or obstructions associated with roadways and utilities.]
Affected Standard: NFPA 101, and/or a new standard. Model Building and Fire Codes: The standard should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard to the extent it is within the scope of building and fire codes.
NIST WTC Recommendation 20.
NIST recommends that the full range of current and next generation evacuation technologies should be evaluated for future use, including protected/hardened elevators, exterior escape devices, and stairwell descent devices, which may allow all occupants an equal opportunity for evacuation and facilitate emergency response access. Affected Standards: NFPA 101, ASME A 17, ASTM E 06, ANSI A117.1. Model Building and Fire Codes: The standards should be adopted in model building and fire codes by mandatory reference to, or incorporation of, the latest edition of the standard.
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NIST WTC Recommendations 4-7 > Structural Fire Endurance
First Post in This Series …
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
The Future of Disability Policy in Ireland – Recent SDI Submission
2011-11-06 …
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
Fixing ‘Priory Hall’ in Dublin – Practical Solutions Needed Now !
2011-10-18: A large ‘can of worms’ has recently been opened in Ireland …
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 !)
Disability Access Certificates (DAC’s) in Ireland – Confused ??
2011-09-01: To say, bluntly, that there is confusion out there … at every level … would be a mild understatement ! Yes, the Disability Access Certificate (DAC) & Revised DAC Process is new … but that cannot explain what is happening … or, more precisely, what is not happening.
BUT … before jumping in at the deep end and examining the existing and operative Part M of the Irish Building Regulations … let me just mention, very briefly, two wider legal ‘niceties’ concerning Accessibility of Buildings for People with Disabilities …
1. The Black Hole between Building Regulations and Equality Law
The definition of People with Disabilities in the existing Part M is limited. It is inadequate. Compare, now, that definition with the definition of Disability in Irish Equality Legislation … which is the complete opposite, being very wide in scope. A deep chasm exists between the two. Check each of them out for yourself ! And because few people are aware of this chasm … a better description of that large space might be a Black Hole.
However, the clear consequence of the Black Hole for building owners … and building designers alike … is that the ‘act’ of merely going through the motions with regard to compliance with Part M … and being satisfied with getting ‘the’ piece of paper, i.e. a Disability Access Certificate … will, without any shadow of a doubt, open the building owner to a complaint under Equality Law. And when a building owner encounters this sort of problem … who will he, or she, hunt down for an explanation ??
Client Organizations beware … prevention is a far better strategy !! Check out the Level of Accessibility Performance required to avoid complaints under Equality Legislation.
[ You should also consider the following ... the Health & Safety Authority in Ireland is doing absolutely nothing to ensure that Workplaces are Accessible ... a requirement contained in all of the European Union (EU) Safety at Work Directives and the Irish National Legislation implementing those Directives. So, also cross check the Level of Accessibility Performance required to comply with Safety at Work Legislation. Compliance with Part M is not sufficient ! ]
2. European Union Ratification of the 2006 United Nations Convention on the Rights of Persons with Disabilities (CRPD)
For a sizeable group of vulnerable people in every EU Member State, the sole route of access to many, if not most, of the Human and Social Rights set down in the 1948 Universal Declaration of Human Rights (UDHR) is the UN Convention on the Rights of Persons with Disabilities (CRPD) … which became an International Legal Instrument on 3 May 2008, and was ratified by the European Union on 23 December 2010. That is precisely why Accessibility is such a critical component of the 2006 UN Convention !
Articles 31 & 33 of the 2006 UN Convention on the Rights of Persons with Disabilities – together – mandate that Accessibility Implementation is taken seriously … that it is competent and effective … and, most importantly, that independent monitoring and verification is a fundamental part of the process.
Ireland has not yet ratified the UN CRPD. And, as far as our National Authorities Having Jurisdiction (AHJ’s) are concerned … everything in the garden is beautiful … Ireland is doing just great and nothing much needs to be altered in our laws, administrative provisions or resourcing … to allow Ireland to ratify the Convention, and then properly implement it. Nothing could be further from the truth !
In Order to Protect your Organization and its many interests … Your Policy and Decision Makers, in Ireland, should study the implications flowing directly from EU Ratification of the UN CRPD … and then, the various Articles of the UN Convention should be examined and properly implemented … insofar as those Articles are relevant to you and your organization’s activities. See my earlier post, dated 5 February 2011.
To date … the quality of Accessibility Implementation in Irish Buildings has been dreadful !! For important reasons … which all parties involved should fully understand … this situation is longer acceptable.
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Colour photograph showing the front entrances to dwelling units in a New Inner City Housing Scheme in Dublin ... User Unfriendly ... Inaccessible for Many Vulnerable People in Our Society ... Dreadful Accessibility Implementation ! Photograph taken by CJ Walsh. 2003-09-13. Click to enlarge.
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Disability Access Certificates (DAC’s) & Part M
The submission of sufficient, quality information, i.e. detailed design documentation, at Disability Access Certificate (DAC) Application Stage typically signals the following to an experienced technical controller …
- The intent of the Applicant, and the Agent(s) acting on his/her/their behalf, with regard to properly and satisfactorily complying with the relevant building legislation, i.e. Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Irish Building Regulations ; and
- In the absence of an inspection by the Building Control Authority (BCA) during actual construction … whether or not it is likely that the completed works will match the DAC certified design documentation with regard to Accessibility Performance.
From the beginning, it is necessary to distinguish between Access and Accessibility.
To be written in stone when International Standard ISO 21542 is soon published … the components of Building Accessibility comprise …
- Approach to the building ;
- Entry ;
- Use of the building, its services and facilities ;
- Egress from the building (during normal conditions) ;
- Removal from the vicinity of the building (during normal conditions) ;
and
- Evacuation from the building (during, for example, a fire emergency) ;
- Safe Movement to a ‘place of safety’ (during, for example, a fire emergency), which is remote from the building.
This is also a useful guideline with regard to segregating those aspects of Accessibility Design which relate to Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Irish Building Regulations, and which should be considered in any application for a Disability Access Certificate (DAC) … and those, after ‘and‘ … which relate to Part B: ‘Fire Safety’, and which should be considered in every application for a Fire Safety Certificate (FSC).
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The 2000 Building Regulations (Amendment) Regulations … Statutory Instrument No. 179 of 2000 … elaborate the relevant Irish Building Legislation concerning building access, i.e. Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Building Regulations …
“Access and Use
M1 Adequate provision shall be made to enable people with disabilities to safely and independently access and use a building.
Sanitary Conveniences
M2 If sanitary conveniences are provided in a building, adequate provision shall be made for people with disabilities.
Audience or Spectator Facilities
M3 If a building contains fixed seating for audience or spectators, adequate provision shall be made for people with disabilities.
Definition for This Part
M4 In this Part, ‘people with disabilities’ means people who have an impairment of hearing or sight or an impairment which limits their ability to walk, or which restricts them to a wheelchair.
Application of This Part
M5 Part M does not apply to works in connection with extensions to and the material alterations of existing dwellings, provided that such works do not create a new dwelling.”
My Note 1: In order to safely and independently use a building … it is also necessary, under normal conditions, to use the egress routes of a building.
My Note 2: The limited definition of ‘people with disabilities’ in Requirement M4 does not include, for example, a person without arms … or those people with a mental, cognitive or psychological impairment.
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Technical Guidance Document M (2000, re-printed in 2005) provides guidance in relation to Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Irish Building Regulations. TGD M was issued by the Department of the Environment, under Article 7 of the 1997 Building Regulations … Statutory Instrument No. 497 of 1997 … which states …
” 7. (1) The Minister may publish, or arrange to have published on his behalf, documents to be known as ‘technical guidance documents’ for the purpose of providing guidance with respect to compliance with the requirements of any of the provisions of the Second Schedule.
(2) Subject to the provisions of sub-article (3), where works or a building to which these Regulations apply is or are designed and constructed in accordance with any guidance contained in a technical guidance document, this shall, prima facie, indicate compliance with the relevant requirements of these Regulations.
(3) The provisions of any guidance contained in a technical guidance document published under sub-article (1) concerning the use of a particular material, method of construction or specification, shall not be construed as prohibiting compliance with a requirement of these Regulations by the use of any other suitable material, method of construction or specification.”
My Note 3: Since the introduction of national legal building legislation in the early 1990′s, the Irish Building Regulations have a Functional Format, as required by European Union (EU) Law. In other words, satisfactory compliance with short functional statements is mandated by law … and provided the requirements of those short statements are properly shown to be complied with, it is entirely optional as to which materials, methods of construction, standards and other specifications (including technical specifications) are used. In this way, the free movement of products and services within the EU is facilitated and encouraged while, at the same time, technical barriers to trade are avoided.
My Note 4: For the convenience of readers, the short functional statements mandated by law are reproduced, in a shaded box, at the beginning of each of the Technical Guidance Documents. The Guidance Texts in each Technical Guidance Document, however, are not Prescriptive Regulations. These texts are merely an indicator of what is likely to be suitable for the purposes of compliance with the Regulations … they are, prima facie (i.e. on ‘first appearance’ only), an indication of compliance ; they are not ‘deemed-to-satisfy’ the Requirements of Part M.
My Note 5: Where gaps are identified in the guidance texts of Technical Guidance Document M … and in the absence of an Irish National Standard on Building Access or Accessibility … a suggested hierarchy of approach should be to source an appropriate European Standard (EN) or, if such a standard does not yet exist, then an appropriate International Standard (ISO), or then a National Standard of any country which is a contracting party to the Agreement on the European Economic Area (EEA) which provides in use an appropriate level of Access/Accessibility Performance (refer to Part D of the Second Schedule to the Building Regulations). In the unlikely absence of any of the above, an appropriate Design Guidance Document – national or otherwise – should be referenced which provides in use an appropriate level of Access/Accessibility Performance.
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Our Organization – Sustainable Design International – provides an independent (and confidential) Accessibility Monitoring and Verification Service.
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END
‘Accessibility-for-All’ – Post EU Ratification of the 2006 UN CRPD
2011-02-28: Further to my posts, dated 15 January 2011 and 5 February 2011 …
There is an easy way to understand the 2006 United Nations Convention on the Rights of Persons with Disabilities (CRPD), which was ratified by the European Union (EU) just before Christmas Day 2010:
For a sizeable group of vulnerable people in all of our societies, the sole route of access to many, if not most, of the Human and Social Rights set down in the 1948 Universal Declaration of Human Rights (UDHR) … is the UN CRPD … which only became an International Legal Instrument on 3 May 2008 … just short of 60 Years after the UDHR was adopted on 10 December 1948 !
That is precisely why Accessibility is such a critical component of the 2006 UN Convention … which has already been described, here, as a ‘Mixed Agreement’ (see the post of 5 February 2011).
Accessibility is the principal, common ingredient in ‘fields that fall in part within the competence of the European Union, in part within that of the Member States and in part within the shared competence of the EU and its Member States’. Accessibility has an impact … and always will have an impact … on all of these fields.
Policy and Decision Makers at every level within the European Union and the EU Member States would need to become accustomed to this new concept very, very quickly.
It is also essential, therefore, for the EU and the Member States to closely co-operate in implementing legislation which stems from the UN CRPD in a coherent manner … and to ensure unity in the international representation of the Union.
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APPROACHING THE TASK OF ACCESSIBILITY IMPLEMENTATION
1. Establishing an Initial Framework …
Exactly how should we make sense of … bring order and assign priorities to … the Accessibility-related Articles in the UN Convention … using the different terms ‘Accessibility’ and ‘Accessibility-for-All’ … ‘People/Persons with Disabilities’ and ‘People with Activity Limitations’ (2001 WHO ICF) … in relation to the different components of the Human Environment, i.e. the Built, Social, Virtual and Economic Environments ???
Our recommendation … SDI’s Recommendation … is to refer, in the first instance, to this ‘Accessibility-for-All’ Matrix … which we developed a few years ago … in preparation for this crucial period of implementation …
Colour image showing Sustainable Design International's 'Accessibility-for-All' Matrix. The Goal is a Sustainable Human Environment which is Accessible-for-All. Click to enlarge.
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If we then drill down … in order to fully understand ‘Accessibility of a Building’, for example … this then comprises:
- Approach to the building ;
- Entry ;
- Use ;
- Egress from the building (during normal conditions) ;
- Removal from the vicinity of the building (during normal conditions) ;
and
- Evacuation from the building (during, for example, a fire emergency) ;
- Safe Movement to a ‘place of safety’ (during, for example, a fire emergency), which is remote from the building.
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2. Overlaying UN CRPD Article 9 – Accessibility …
Onto the Initial Framework outlined above … overlay Article 9 … and crosscheck in detail. Note well the strong language used … ‘States Parties shall’ … and do not forget that this is not a Wish List … but a clear delineation of the Scope of an Important Human and Social Right which now has a proper basis in both International and European Union Law !
1. To enable persons with disabilities to live independently and participate fully in all aspects of life, States Parties shall take appropriate measures to ensure to persons with disabilities access, on an equal basis with others, to the physical environment, to transportation, to information and communications, including information and communications technologies and systems, and to other facilities and services open or provided to the public, both in urban and in rural areas. These measures, which shall include the identification and elimination of obstacles and barriers to accessibility, shall apply to, inter alia:
(a) Buildings, roads, transportation and other indoor and outdoor facilities, including schools, housing, medical facilities and workplaces ;
(b) Information, communications and other services, including electronic services and emergency services.
2. States Parties shall also take appropriate measures:
(a) To develop, promulgate and monitor the implementation of minimum standards and guidelines for the accessibility of facilities and services open or provided to the public ;
(b) To ensure that private entities that offer facilities and services which are open or provided to the public take into account all aspects of accessibility for persons with disabilities ;
(c) To provide training for stakeholders on accessibility issues facing persons with disabilities ;
(d) To provide in buildings and other facilities open to the public signage in Braille and in easy to read and understand forms ;
(e) To provide forms of live assistance and intermediaries, including guides, readers and professional sign language interpreters, to facilitate accessibility to buildings and other facilities open to the public ;
(f) To promote other appropriate forms of assistance and support to persons with disabilities to ensure their access to information ;
(g) To promote access for persons with disabilities to new information and communications technologies and systems, including the Internet ;
(h) To promote the design, development, production and distribution of accessible information and communications technologies and systems at an early stage, so that these technologies and systems become accessible at minimum cost.
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So … what is the situation in the Member States of the European Union ?
In an upcoming post … let’s take Ireland as a case in point, just for the hell of it … and discuss some of the consequences … stemming from the EU’s ratification of the UN CRPD … on the operation of the Building Regulations and Disability Access Certificates (DAC’s).
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Sustainable Development – International Law & Personal Ethics
At the level of the Individual … ‘sustainability’ urgently requires a revolution in professional and personal ethics.
However, at levels above or beyond the Individual … reference must be made to a common understanding of Sustainable Human & Social Development which has a foundation in a robust Framework of International Law. It is this approach which continues to facilitate, at Sustainable Design International, our development of the theory of ‘sustainability’ … and its more effective application to frontline design practice.
Sustainable Human and Social Development: Development which meets the responsible needs, i.e. the Human and Social Rights1, of this generation – without stealing the life and living resources from future generations, especially our children … their children … and the next five generations of children.
[1] As defined, in International Law, by the 1948 Universal Declaration of Human Rights (UN OHCHR).
Inspired by the Culture of the North American Indigenous Peoples … this definition also incorporates the concept of ’7 Generation Thinking’.
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Sustainable Design2: The ethical design response, in built or wrought form, to the concept of Sustainable Human and Social Development.
[2] Includes Spatial Planning, Architectural/Engineering/Interior/Industrial Design and e-Design, etc.
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Sustainable Design Solutions must be appropriate to local geography, climate and future climate change, economy, culture, social need and language(s)/dialect(s), etc.
Our Ultimate Goal, however, must be to achieve a dynamic and harmonious balance between a Sustainable Human Environment (including the social, built, virtual and economic environments …) and a flourishing, not just a surviving, Natural Environment … with the Overall Aim of achieving Social Wellbeing for All.
Please see previous Posts on this Technical Blog … www.cjwalsh.ie … for supporting definitions to the above text.
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Sustainable Buildings – Design Agenda for the 21st Century ?
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 !
An Open Letter to President Barack Obama – Questions !?!
2009-02-14 …
Dear Barack,
Please allow me to extend a warm welcome to you onto the International Stage … and an even warmer welcome for the United States of America back into the International Fold of Nations.
The last 8 Years have been a nightmare for concerned observers outside your country. I should immediately add that a large branch of my extended family has been living in New York City and State since the mid-1950s. And that you are now affectionately known in Ireland, because some of your roots are based here, as President O’Bama !
Being a pragmatic person, however, you will want me to come quickly to the point … and be direct.
You will shortly be signing into law a 787.2 Billion Dollar Economic Stimulus Package of spending increases and tax relief, which is intended to encourage an economic recovery in your country and to create jobs. It is surprising that you have permitted significant funds earmarked for school construction, and for colleges and universities, to be removed from the Package during the ‘Compromise’ Negotiations. Funding to provide health insurance for the unemployed has been sharply reduced, while funds for the ‘Greening’ (?) of Federal Buildings have also been scaled back.
The political imperative of successfully steering this Stimulus Package through Congress, at this time, is understood … but the final shape of the Package does not augur well for the future of your Presidency.
Taken together with the outcome from another recent event in my country, Ireland … and my surprise is turning to worry …
In Dublin, towards the end of January 2009, I attended a Round Table Discussion with a key individual who works in the US Department of Energy’s Office of Energy Efficiency & Renewable Energy (EERE) – Federal Energy Management Program (FEMP).
Having posed 2 Questions after his presentation with regard to US Federal Policy on the ‘Green’ (i.e. environmental & energy) Performance of Federal Buildings, I discovered the following …
- The individual concerned was completely unaware that there is a considerable difference between the ‘Green’ Agenda, i.e. a limitation of considerations to environmental aspects of Sustainable Human & Social Development alone (an outdated concept belonging more properly to the 1990s) … and the ‘Sustainability’ Agenda, which is far broader in scope and absolutely essential if we are to meet the great challenges being posed since the beginning of this 21st Century … for example, the World Trade Center Incident (9-11) in New York ;
- There would appear to be no independent technical controls monitoring the ‘real’ environmental and energy performance in US Federal Buildings, no penalties for failure to meet performance targets, no horizontal integration between Federal Institutions dealing with procurement and building/system/product operation, and a systemic lack of proper accountability.
If it is your wish that the USA takes up a position of global leadership on some or all of the above issues, we – at Sustainable Design International – would like some information and assurances concerning the following matters …
- When will you, and your Administration, begin to properly appreciate the considerable difference between a ‘Green’ Agenda and a ‘Sustainability’ Agenda … and the significant Institutional Re-Engineering required to implement US Federal, State and City Policies geared towards Sustainable Human & Social Development ? How would you then intend to dramatically raise awareness … and mobilize all of the people in your country for action … at Federal, State and City Levels ?
- If your Administration enters into negotiations on an International Kyoto II (post 2012) Agreement under the United Nations Framework Convention on Climate Change (UNFCCC) … will US National Performance be open and transparent … and be seen to be ‘reliable’ by other countries, particularly Brazil, Russia, India, China and South Africa ?
- When, precisely, will the US Senate ratify the United Nations Convention on the Rights of Persons with Disabilities, with its Optional Protocol ? When will you arrange to fund the implementation of this Convention, with its Optional Protocol … and then arrange that a coherent and comprehensive programme of implementation, which must have a short timescale, be initiated ? How long will that implementation timescale be ?
Effective International Law and Lasting Peace are 2 Prerequisite Essential Requirements for Sustainable Human & Social Development. In order to free up current ‘process’ log-jams and bring lasting peace to the regions of the Caribbean and the Middle East … it is you who must make the first substantive moves …
- When will you arrange for the immediate cessation of all aggressive and hostile activities against one of your close neighbours – the small island of Cuba – and a complete end to the economic, social & political choke-hold on its small population ? When will your Administration finally arrange for the termination of the illegal occupation of Guantánamo Bay – an international act of piracy facilitated by the 1901 Platt Amendment ? When will you finally ‘curtail’ the rabid behaviour of some of the more fanatical Cuban Exile Elements in Florida … and release the Miami 5 ?
- When will you, and your Administration, bring your considerable authority and power to bear on the Criminal State of Israel … and force it to comply with International Law and Universal Human & Social Rights ?
We patiently await your considered response.
Many thanks for your attention.
Signed: C. J. Walsh, Managing Director, Sustainable Design International Ltd. – Ireland, Italy & Turkey.
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Postscript 2012-01-16:
Dear Barack … Apologies are Meaningless … and who these Individual Soldiers are is not important. This recent image from Afghanistan betrays an in-grained national mindset !
The Guantánamo Bay Detention Centre, in illegally occupied Cuba, is still operating … the Criminal Blockade of this small Caribbean Island continues with full bullying force … and The Miami 5 are still rotting in U.S. Jails, with access for family members made particularly difficult, if not impossible.
Your Administration is still aggressively frustrating the widespread International Consensus on Climate Change … Your Offspring, the Apartheid State of Israel has now replaced South Africa as the No.1 Maverick Rogue in the International Community … etc., etc., etc.
The United States of America continues to urinate on International Law !!
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END
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