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

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

NEW INTERNATIONAL CONTEXT

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

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

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

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

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

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

Scope of ISO 21542 : 2011

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

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

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

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

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

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

Safety and Accessibility in Use

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

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

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

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SAME OLD PROBLEMS

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

     1.  Bad Product Design

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

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

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

Why can we not access these products in Ireland ??

     2.  No Product Approval

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

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

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

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

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

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

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

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

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

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‘Fire-Induced Progressive Damage’ – New CIB W14 Document

2012-04-16:  Following the 9-11 World Trade Center Extreme Fire Event, in New York City …

The National Institute of Standards & Technology (NIST), in the USA, recommended that Fire-Induced Progressive Collapse be particularly considered in the case of …

  • High-Rise Buildings ;
  • Iconic Buildings ;
  • Buildings Having a Critical Function ;
  • Buildings of Innovative Design.

However, as recently discussed … in order to avoid the wide confusion which the term ‘Fire-Induced Progressive Collapse’ is continuing to cause at international level … the preferred term should now be Fire-Induced Progressive Damage.

AND … CIB Working Commission 14: ‘Fire Safety’ – Research Working Group IV: ‘Structural Reliability & Fire-Induced Progressive Damage’ … would strongly caution that Fire-Induced Progressive Damage and Disproportionate Damage are fundamental concepts to be applied in the design of all building types.

[ A height threshold of 5 Storeys for the consideration of Disproportionate Damage, in the Building Codes/Regulations of many jurisdictions, including Ireland, is entirely arbitrary.]

So … what is Fire-Induced Progressive Damage ?   And what is the relationship between this structural concept … and Disproportionate Damage ?

Leaving aside all of the crazy conspiracy theories about the collapse of World Trade Center Building No. 7 … is it possible for Conventional Fire Engineering to directly confront what actually happened ?   Unfortunately … the reaction still, even today, is to bury the head, ostrich-like, in the sand … and ignore WTC 7 and the 2008 NIST WTC Recommendations (Final Report NCSTAR 1A) !

Colour photograph showing World Trade Center Building No. 7 in ruins, after 9-11 in New York City ... when Fire-Induced Progressive Damage led to Disproportionate Damage, and finally to total building failure ... a Collapse Level Event (CLE) which is entirely unacceptable to the general population of any community or society. Click to enlarge.
Colour photograph showing World Trade Center Building No. 7 in ruins, after 9-11 in New York City ... when Fire-Induced Progressive Damage led to Disproportionate Damage, and finally to total building failure ... a Collapse Level Event (CLE) which is entirely unacceptable to the general population of any community or society. Click to enlarge.

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Yesterday, on an adjoining page here … I uploaded a New CIB W14 International Reflection Document on ‘Structural Reliability & Fire-Induced Progressive Damage’, with 2 Appendices.  Scroll down to the section headed ‘April 2012’.

This is a Reflection Document issued by CIB W14 Research Working Group IV: ‘Structural Reliability & Fire-Induced Progressive Damage’;  its purpose is to examine the ‘hot form’ structural concept of Fire-Induced Progressive Damage, and to propose a critical update to fire engineering design practice.  It is also intended to encourage a wider discussion about some of fire engineering’s fundamental tenets, and the future direction of our profession in a rapidly evolving trans-disciplinary approach to the design, construction and operation of a Safe and Sustainable Built Environment.

The Document is written in a simple, generic language which is accessible to design disciplines outside the International Fire Science and Engineering Community.  The next phase of this CIB W14 Innovation & Research Project will certainly require the use of a more technical language, complex calculations, computer modelling, etc … and much closer liaison with CIB W14’s other Research Working Groups on Connections, Design Fires & Design Fire Scenarios, and Performance Criteria.

I wish to sincerely thank those individuals and organizations who have contributed to the work of our Research Working Group IV.

Finally, the myth surrounding NIST’s 9-11 WTC Recommendations, i.e. that they are only applicable in the case of Very Tall Buildings during rarely occurring extreme events … must be completely demolished, and obliterated from the face of the earth !

Climate Change Adaptation is already demanding a much higher level of building resilience.

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Your Comments on this CIB W14 Reflection Document should be e-mailed to: fireox@sustainable-design.ie

C.J. Walsh, FireOx International – Ireland, Italy & Turkey.

Chair – CIB W14 Research WG IV.

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Update 2012-04-20 …

In response to a discourteous and unprofessional comment about the above CIB W14 WG IV Reflection Document, posted by Mr. Morgan Hurley (Technical Director at the Society of Fire Protection Engineers in the USA) on the LinkedIn SFPE Group WebPage … I wrote, as follows, this morning …

Good Man Morgan !

Relax … there is no need to become defensive quite yet.  WG IV’s Reflection Document is simply intended to raise issues … ask questions … and solicit comments from within and, more importantly, from outside the International Fire Science and Engineering Community.

Perhaps of more direct relevance to the SFPE Membership, in the USA, might be the following …

NIST Report: ‘Best Practices for Reducing the Potential for Progressive Collapse in Buildings’ (NISTIR 7396 – February 2007) … is a good document on ‘disproportionate damage’, but it has nothing to say about ‘fire-induced progressive damage’.  These two structural concepts are related, but they are not the same.

When discussing Multi-Storey Steel Frame Buildings, on pages 18 and 19, of NIST Report: ‘Best Practice Guidelines for Structural Fire Resistance Design of Concrete and Steel Buildings’ (NISTIR 7563 – February 2009) … what happened to WTC Building 7 on 9-11, and the 2008 NIST WTC Recommendations (NIST NCSTAR 1A), are conveniently and completely ignored.  Instead, there is a launch straight into the BRE Fire Tests at Cardington, and computer calculations, in order to justify a very flawed design approach.  How crazy is that ?

Hope to see you there next week … we missed you at the last CIB W14 Meeting in Paris !

C.J.

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Petrol/Gasoline Prices in Italy Now – Here Tomorrow !

2012-04-15:  A Worrying Interlude …

Further to last year’s post , on petrol/gasoline prices in Turkey … a recent few days of driving in Italy, over this Easter, was a shock to my financial system …

Colour photograph showing the prices of different grades of petrol and diesel at a Petrol Station in Ciampino Airport, Rome, Italy. Photograph taken by CJ Walsh. 2012-04-03. Click to enlarge.
Colour photograph showing the prices of different grades of petrol and diesel at a Petrol Station in Ciampino Airport, Rome, Italy. Photograph taken by CJ Walsh. 2012-04-03. Click to enlarge.

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The photograph above shows the prices for petrol (gasoline) on 3 April 2012 … in Italy.

Unleaded Petrol (Senza Pb) is a staggering € 1.938 !

As if that wasn’t bad enough … there were significant price differences across the regions of Central Italy … varying to as low as € 1.829 for unleaded petrol in some places.  Some petrol stations did not display prices at all … and you only discovered the price when you drove in and stopped at an individual pump.

Colour photograph showing our hired car stopped in front of a Petrol Station in Amandola, Le Marche, Italy ... just as we were leaving, at dawn, to drive back to Rome. Photograph taken by CJ Walsh. 2012-04-10. Click to enlarge.
Colour photograph showing our hired car stopped in front of a Petrol Station in Amandola, Le Marche, Italy ... just as we were leaving, at dawn, to drive back to Rome. Photograph taken by CJ Walsh. 2012-04-10. Click to enlarge.

BUT … just get a load of this …

Colour photograph showing the prices of different grades of petrol and diesel at a Petrol Station in Amandola, Le Marche, Italy. Photograph taken by CJ Walsh. 2012-04-10. Click to enlarge.
Colour photograph showing the prices of different grades of petrol and diesel at a Petrol Station in Amandola, Le Marche, Italy. Photograph taken by CJ Walsh. 2012-04-10. Click to enlarge.

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Unleaded Petrol (Senza Pb) is an unbelievable € 1.999 in Amandola !!

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