national law

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

Posted 2012-04-21 by CJ Walsh

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 !

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 !!!

END

Stop Press ! … ISO 21542 on Accessibility-for-All Published !!

Posted 2012-03-25 by CJ Walsh

2012-03-25: No news about this momentous development, yet, on the International Design and Disability Networks … (why is that ? – are they all asleep out there ?) … but International Standard ISO 21542: ‘Building Construction – Accessibility and Usability of the Built Environment’ was finally published by the International Standards Organization (ISO) in December 2011 ! Even ISO, and national standards organizations, have been slow with an official notification.

This International Standard now provides building users, architects, designers, engineers, builders, building owners and managers, manufacturers, policy makers and legislators with the requirements and recommendations to create a Sustainable Built Environment which is Accessible.

The First Edition of ISO 21542, dated 2011-12-15, represents an agreement reached by strong consensus between different countries all over the world … an agreement patiently constructed and pieced together by a small, dedicated international group of Accessibility Experts. As one of those experts, I am tremendously relieved that this main task has been accomplished … but the process must continue … there are still errors in the document … and the fire safety texts must be expanded.

This is also an agreement which signals that uniform implementation of the main provisions (accessibility-related) in the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) can commence across the globe, not just in the developed economic regions.

The purpose of this International Standard is to define how the built environment … in particular, public buildings … should be designed, constructed and managed to enable people to approach, enter, use, egress from and evacuate a building independently, in an equitable and dignified manner and to the greatest extent possible.

Colour image showing an Accessible Fire Evacuation Route Sign. From now on, Building Users should expect that these routes will be Accessible-for-All, throughout their full extent, until they reach a Place of Safety which is remote from the Building. Otherwise, they will be able to find accommodation in a suitable Area of Rescue Assistance along the route. Click to enlarge.

A new international understanding of ‘Building Accessibility’ is hereby established … ‘Access’ (approach, entry and use) can no longer be divorced from ‘Egress’ (in the normal course of events) and ‘Evacuation’ (in the event of an emergency).

The concept of ‘Access’, in isolation, and the role of the ‘Access Consultant’ are, therefore, outdated and obsolete ! And use of the word ‘Escape’, in any context, is to be firmly and rigorously discouraged !!

The intention of this International Standard is to meet the needs of the majority of people. This goal is achieved by agreement on minimum standards of accessibility and usability which are generally accepted to accommodate diversities of age and the human condition.

In future … proper emphasis must be placed on Real and Effective Implementation of Accessibility-for-All in the built environment … to meet the needs of real people in all of our communities.

In the past … too many scarce human resources have been diverted into pointless discussions and arguments about accessibility design philosophies. And, particularly in Europe, we have been far too fond of ‘talk’, instead of ‘action’ ! No more !!

ISO 21542 : 2011 applies to new and existing buildings.

IF this Standard’s requirements and recommendations are taken into consideration during the earliest stages of New Building Design … the costs of providing satisfactory accessibility and usability in a building will be minimal.

Yes, there are problems with improving the accessibility performance of Existing Buildings … just as there are problems, for example, with improving their energy performance. However … creativity, design flexibility, and an in-depth understanding of the principles of Accessibility-for-All … will ensure that the functional requirements of this Standard are properly met.

Mindful of the 1964 Venice Charter and other similar international instruments … accessibility must also be facilitated in Existing Buildings of Historical, Architectural and Cultural Importance. In such cases, it will be necessary for national authorities having jurisdiction to allow some relaxation of the requirements in this International Standard … as well as to proactively recommend appropriate alternative accessibility measures.

This new approach to Accessibility-for-All in the Built Environment … as set down in ISO 21542 … was directly informed by Preamble Paragraph (g) and Articles 9, 10 and 11 of the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD).

At the time of writing … the UN CRPD has been ratified by the European Union (EU) and 109 Other Countries.

An Important Note for Parties to the Convention which is entirely outside the scope of ISO 21542, and standardization generally … but very relevant to the implementation, for example, of Article 11 at national level in the ratifying Countries and EU Member States …

UN CRPD Article 12 – Equal Recognition Before The Law

1. States Parties reaffirm that persons with disabilities have the right to recognition everywhere as persons before the law.

2. States Parties shall recognize that persons with disabilities enjoy legal capacity on an equal basis with others in all aspects of life.

3. States Parties shall take appropriate measures to provide access by persons with disabilities to the support they may require in exercising their legal capacity.

4. States Parties shall ensure that all measures that relate to the exercise of legal capacity provide for appropriate and effective safeguards to prevent abuse in accordance with international human rights law. Such safeguards shall ensure that measures relating to the exercise of legal capacity respect the rights, will and preferences of the person, are free of conflict of interest and undue influence, are proportional and tailored to the person’s circumstances, apply for the shortest time possible and are subject to regular review by a competent, independent and impartial authority or judicial body. The safeguards shall be proportional to the degree to which such measures affect the person’s rights and interests.

5. Subject to the provisions of this article, States Parties shall take all appropriate and effective measures to ensure the equal right of persons with disabilities to own or inherit property, to control their own financial affairs and to have equal access to bank loans, mortgages and other forms of financial credit, and shall ensure that persons with disabilities are not arbitrarily deprived of their property.

ISO 21542 : 2011 is available from the International Standards Organization (ISO) at … www.iso.org/

The Official Abstract on the ISO WebSite states …

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.

END

OVE ARUP & Hong Kong’s New Fire Safety Code of Practice

Posted 2012-02-18 by CJ Walsh

2012-02-18: It will be of interest to people in this part of the world that Hong Kong has introduced a New Code of Practice on Fire Safety in Buildings, which will come into effect from 1 April 2012. The reason for this interest will be strange and unusual …

Hong Kong Buildings Department

2011 Hong Kong Code of Practice for Fire Safety in Buildings

Click the Link Above to read and/or download PDF File (3.96 Mb)

The following extract from the Foreward (paragraph #3) to this Code of Practice explains how it came to be developed … and then issued back in September 2011 …

This Code of Practice may be cited as the Code of Practice for Fire Safety in Buildings. It is prepared and issued by the Buildings Department on the basis of the consultancy study on fire engineering approach and fire safety in buildings. The consultancy study was conducted by Ove Arup & Partners Hong Kong Ltd., commissioned by the Buildings Department, and was supervised by a Steering Committee comprising representatives of professional institutions and other stakeholders of the building industry, as well as other Government Departments.

It so happens that, here, a few weeks ago … I was wondering how the United Nations Convention on the Rights of Persons with Disabilities (CRPD) was being implemented in a number of countries which had ratified it. China ratified the Convention on 1 August 2008. Once again, this is Article 11 …

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 users ! ]

So … what has been the response of Hong Kong to this issue … and to the voluntary obligation which China has accepted, under International Law, to comply with Article 11 of the UN CRPD ?

The issue has been completely ignored in the New Code of Practice !

END

2012 Review of Part B & TGD B – Irish Building Regulations

Posted 2012-02-18 by CJ Walsh

2012-03-02: Please bear with me while I update you at the start of this post … rather than at the end, which would be more usual here … and logical.

[ In Ireland … a related problem, which continues to fester and cause a great nuisance in an everyday work environment … concerns the lack of proper, i.e. formal, recognition of electronic communications, and information in an electronic format, by public and private organizations … in spite of the following very clear legal text …

2000 Electronic Commerce Act (No. 27 of 2000)

Section 9 – Electronic Form not to Affect Legal Validity or Enforceability

Information (including information incorporated by reference) shall not be denied legal effect, validity or enforceability solely on the grounds that it is wholly or partly in electronic form, whether as an electronic communication or otherwise. ]

Yesterday afternoon (1 March 2012), we received the following e-mail communication from the Department of Environment, Community & Local Government (DECLG) …

Folks,

Could you please send me your submissions in either Microsoft Word or Excel as it it easier to copy and paste into the format that is required , it is proving rather difficult to copy from a PDF document.

Thank You

Claire Darragh, Architecture / Building Standards, DECLG.

I immediately replied …

Dear Claire,

Further to your informal e-mail message, which we received just a short while ago …

Please note that this is not an acknowledgement that the FireOx International Submission was received by the Department … and we certainly do not wish that you copy and paste anything relating to its contents anywhere else.

IF this is a Proper Public Consultation Process … you must adapt internal DECLG systems to suit the Submissions ! We will be communicating with the Minister’s Office concerning this issue.

Once again, I would ask you to properly acknowledge receipt of our Submission, dated 2012-02-14.

In connection with the original FireOx International Submission … I would also like to take this opportunity to advise you that:

Due to an error in ISO (International Standards Organization) … the publication of ISO 21542: ‘Building Construction – Accessibility and Usability of the Built Environment’, on 12 December 2011, was not notified to people directly involved in its development and drafting, or to the participating national standards organizations ;

and

In order to avoid the wide confusion which the term ‘Fire-Induced Progressive Collapse’ is continuing to cause at international level … the preferred term is now Fire-Induced Progressive Damage.

I have amended our Submission accordingly.

Kind regards.

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

2012-02-18: The following is the text of FireOx International’s Submission, dated 14 February 2012, to the Department of the Environment, Community & Local Government (DECLG) in Dublin … concerning the current review of the Irish Building Regulations Part B & TGD B … including, for good measure, some initial and very pertinent comments on the Irish Building Control Regulations.

None of these comments will come as any surprise to regular visitors here.

It should also be noted that the same comments are just as relevant in the case of the British (England & Wales) Building Regulations, Part B and Approved Document (AD) B !

Ms. Claire Darragh, Architecture & Building Standards Section, DECLG.

Dear Claire,

Thank you for this opportunity to advise the Department on some urgent and necessary improvements to Part B: ‘Fire Safety’ of the 2nd Schedule to the Building Regulations in Ireland … and its supporting Technical Guidance Document (TGD) B.

1. Some Initial Comments

The continuing debacle of the Priory Hall Apartment Complex, in Donaghmede Dublin 13, is just the tip of a very large iceberg in Ireland. Yet, when we now hear that there will be a ‘risk-based’ approach to Septic Tank Inspections, instead of an approach which involves inspecting all septic tanks … independently, competently and thoroughly … it is clear that the Minister, and senior officials in his Department, have failed to learn any lessons from ‘Priory Hall’.

What was happening on Irish construction sites during the Celtic Tiger boom years … has been happening for twenty years all over the country … more precisely, since the introduction of legal national building regulations in 1991, with NO effective building control … and, before that again, in those parts of the country 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 projects … and, depending on the type of project, occasional or frequent inspections above ground level.

Over the years, local authority officials who carried out building bye-law inspections accumulated a considerable wealth of knowledge and understanding about local construction conditions and practices. This valuable resource, widely used by the construction industry at the time, has now been diluted and discarded.

PLEASE LEARN THE LESSONS FROM ‘PRIORY HALL’ !!

In connection with ALL Applications for Fire Safety Certificates (Part B) and Disability Access Certificates (Part M) … competent and thorough inspections must, from now on, be carried out by local authority personnel to confirm proper implementation of Part B & M, respectively, of the 2nd Schedule to the Building Regulations.

Furthermore … while on site, local authority personnel must not be discouraged, or restricted, from dealing with any other Parts of the 2nd Schedule to the Building Regulations. Under the present dysfunctional system, important horizontal linkages between different Parts of the 2nd Schedule are being widely disregarded and ignored, e.g. between Parts B & D, between Parts B & M, and between Parts B & A … or between Parts M & D, etc., etc !

European Union (EU) Council Directive 89/106/EEC has been repealed … and, instead, we now have EU Regulation No 305/2011 of the European Parliament and of the Council, of 9 March 2011, laying down Harmonised Conditions for the Marketing of Construction Products.

Unlike the earlier EU Directive … this Regulation, applicable in all EU Member States, is binding in its entirety.

And although Annex I of EU Regulation 305/2011 will enter into force from 1 July 2013 … the Department should now prepare for, and slowly begin the process of, incorporating all of the Annex I Basic Requirements for Construction Works into the 2nd Schedule of the Irish Building Regulations.

SEE BELOW …

2. Firefighter Safety

Fully consistent with Basic Requirement for Construction Works 2(e), in Annex I of EU Regulation No. 305/2011 … Revise Part B Requirement 5 to read as follows …

B5 Firefighter Safety, and Access and Facilities for the Fire Service

A building shall be so designed and constructed that the safety of firefighters is adequately considered and, in the event of an outbreak of fire, that there is adequate provision for access for fire appliances and such other facilities as may be required to assist the fire service in the protection of life and property.

Two examples of issues which should be highlighted in a relevant revision/addition to TGD B’s Guidance Text:

The incorporation, in building designs, of alternative safe means of approach towards the scene of a fire by firefighters ;
The provision of wider staircases in buildings in order to facilitate the recovery of an injured/impaired firefighter during the course of firefighting operations.

3. Protection of Vulnerable Building Users from Fire

The European Union ratified the United Nations Convention on the Rights of Persons with Disabilities (CRPD) on 23 December 2010. Ireland has not yet ratified the Convention.

However … fully consistent with Ireland’s legal obligation, under Article 4.3 of the Treaty on European Union (TEU), to co-operate fully with EU Institutions in their implementation of this UN Convention … Revise Part B Requirement 1 to read as follows …

B1 Means of Evacuation in the Event of an Outbreak of Fire

A building shall be so designed and constructed that the protection of vulnerable building users is adequately considered and, in the event of an outbreak of fire, that there are adequate and accessible means of evacuation from the building to a place of safety remote from the building, capable of being safely and effectively used.

[ Use of the word ‘escape’, in the context of emergencies, should be strongly discouraged at all times. ]

Concerning TGD B’s Guidance Text … reference to ISO 21542: ‘Building Construction – Accessibility and Usability of the Built Environment’ will be more than sufficient.

Specifically relating to Adequate Protection of Vulnerable Building Users from Fire …

NOTE WELL THAT BS 9999 (AND BS 5588:PART EIGHT) IS (ARE) ENTIRELY UNFIT FOR PURPOSE !!

Please carefully examine the attached PDF File – My Note for the National Standards Authority of Ireland: ‘BS 9999:2008 & BS 8300:2009 – Impacts on Accessibility Design in Ireland & Implications for ISO Accessibility & Fire Safety Standards’ , dated June 2009.

4. TGD B’s Appendix A – Performance of Materials and Structures

2 Important Notes should be added to Paragraph A21 – Structural Fire Design …

In complying with Part B, reference should also be made to Part A of the 2nd Schedule of the Building Regulations, particularly Requirement A3 – Disproportionate Collapse ;

and

In order to show that a Fire Protection Material/Product/System for Structural Elements properly complies with Part D … it is also necessary, besides showing that it has been adequately fire tested, to show that the material/product/system is durable over a specified, reasonably long life cycle … and that it can adequately resist mechanical damage during construction of the building and, in the event of an outbreak of fire, during the course of that fire incident.

Specifically relating to Steel Structural Performance in Fire …

You should be aware that Table A1 and Table A2 are only appropriate for use by designers in the case of single, isolated steel structural elements.

In steel structural frame systems, no consideration is given in the Tables to adequate fire protection of connections … or limiting the thermal expansion (and other types of distortion) in fire of steel structural elements … in order to reduce the adverse effects of one steel element’s behaviour on the rest of the frame and/or adjoining non-loadbearing fire resisting elements of construction.

In the case of steel structural frame systems, therefore, the minimum fire protection to be afforded to ALL steel structural elements, including connections, should be 2 Hours. Connections should also be designed and constructed to be sufficiently robust during the course of a fire incident. This one small revision will contribute greatly towards preventing Fire-Induced Progressive Damage in buildings … a related, but different, structural concept to Disproportionate Damage …

Disproportionate Damage

The failure of a building’s structural system (i) remote from the scene of an isolated overloading action; and (ii) to an extent which is not in reasonable proportion to that action.

Fire-Induced Progressive Damage

The sequential growth and intensification of structural distortion and displacement, beyond fire engineering design parameters, and the eventual failure of elements of construction in a building – during a fire and the ‘cooling phase’ afterwards – which, if unchecked, will result in disproportionate damage, and may lead to total building collapse.

With regard to the above … please carefully examine these 2 Series of Posts on FireOx International’s Technical Blog ( www.cjwalsh.ie ), beginning on the dates indicated …

2011-10-25: NIST’s (2005) Recommendations on the 9-11 WTC Building Collapses … GROUP 1. Increased Structural Integrity – Recommendations 1, 2 & 3 (out of 30) ;

and

2012-01-18: Progressive Collapse of WTC 7 – 2008 NIST Recommendations – Part 1 of 2 … GROUP 1. Increased Structural Integrity – Recommendation A … and GROUP 2. Enhanced Fire Endurance of Structures – Recommendations B, C, D & E (out of 13).

5. TGD B’s Appendix F – Reference Standards

Add this Important New Standard …

ISO 21542 : 2011 Building Construction – Accessibility and Usability of the Built Environment

6. TGD B’s Appendix G – Reference Publications

Add these Two Important Publications …

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

and

NIST (National Institute of Standards and Technology). August 2008. Federal Building and Fire Safety Investigation of the World Trade Center Disaster: Final Report on the Collapse of World Trade Center Building 7. NIST NCSTAR 1A. Gaithersburg, MD, USA.

Should you wish to receive further information on any of my comments … please consult FireOx International’s Technical Blog at www.cjwalsh.ie … or contact me directly.

Please acknowledge receipt of this e-mail communication.

Kind regards.

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

END

NIST WTC Recommendations 25-28 > Improved Practices

Posted 2011-12-7 by CJ Walsh

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

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

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

2011-12-07: SOME PRELIMINARY COMMENTS …

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

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

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

Fire Compartmentation

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

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

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

Here are two reasons why not …

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

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

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

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

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

2005 NIST WTC RECOMMENDATIONS

GROUP 7. Improved Procedures and Practices

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

NIST WTC Recommendation 25.

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

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

NIST WTC Recommendation 26.

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

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

NIST WTC Recommendation 27.

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

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

NIST WTC Recommendation 28.

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

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

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

END

NIST WTC Recommendations 21-24 > Improved Firefighting

Posted 2011-12-4 by CJ Walsh

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

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

2011-12-04: SOME PRELIMINARY COMMENTS …

1. Such is the pervasively high level of both direct and indirect fire losses, not all of which have yet been identified … that a force of committed firefighters, having sufficient numbers and properly trained and equipped, is a valuable social asset in any community … and one not to be weakened or diluted easily.

2. Lack of discipline among firefighters was an issue during the day of 9-11 (11th September 2011) in New York …

In real life or death situations, however, discipline is essential … but competent and efficient command, control and co-ordination … facilitated by reliable systems of communication (human and electronic) … are critical.

And accurate, real time information about what is happening at a building fire incident of whatever scale … i.e. situation awareness … is a tool which propels forward and encourages the effective functioning of both the firefighter and the user/occupant evacuating the building.

3. A serious gap, internationally … a deep cavern … in the awareness, training and education of firefighters at all levels … is the issue of ‘disability’ and the varying range of abilities in a typical building user/occupant profile.

It is not fully appreciated by firefighters that certain people may die if placed in a standard fireman’s lift position … or, if shouted and screamed at, many people may have no understanding whatever of the firefighter’s intended meaning … or that, in order for everyone to reach a place of safety, it is necessary for firefighters to ensure that safe, accessible routes from the building (i.e. clear of all obstacles, e.g. fire hose lines) are prepared for, thoroughly, in advance of any fire incident … and actually provided should one occur.

Panic attacks during an emergency do exist ! Standard movement times for people evacuating do not exist !! And … firefighters may themselves become impaired during a building fire incident !!!

4. As for building designers … where do I even start ?? Much could, and should, be done in the design and initial construction of a building to assure firefighter safety. But … where does any requirement to consider this issue appear in national building codes/regulations ??

I have already discussed this matter in relation to European Union (EU) Regulation 305/2011 on Construction Products, where such a requirement is contained in Basic Requirement for Construction Works 2: ‘Safety in Case of Fire’ (Annex I).

2005 NIST WTC RECOMMENDATIONS

GROUP 6. Improved Emergency Response

Technologies and procedures for emergency response should be improved to enable better access to buildings, response operations, emergency communications, and command and control in large-scale emergencies.

NIST WTC Recommendation 21.

NIST recommends the installation of fire-protected and structurally hardened elevators to improve emergency response activities in tall buildings by providing timely emergency access to responders and allowing evacuation of mobility-impaired building occupants. Such elevators should be installed for exclusive use by emergency responders during emergencies.* In tall buildings, consideration also should be given to installing such elevators for use by all occupants. NIST has found that the physiological impacts on emergency responders of climbing numerous (e.g. 20 or more) storeys makes it difficult to conduct effective and timely firefighting and rescue operations in building emergencies without functioning elevators. The use of elevators for these purposes will require additional operating procedures and protocols, as well as a requirement for release of elevator door restrictors by emergency response personnel.

[ * F-44 The access time for emergency responders, in tall building emergencies where elevators are not functioning and only stairways can be used, averages between 1 minute and 2 minutes per floor, which, for example, corresponds to between 1½ and 2 hours (depending on the amount of gear and equipment carried) to reach the 60th floor of a tall building. Further, the physiological impact on the emergency responders of climbing more than 10 to 12 floors in a tall building makes it difficult for them to immediately begin aggressive firefighting and rescue operations.]

Affected Standards: ASME A 17, ANSI 117.1, NFPA 70, NFPA 101, NFPA 1221, NFPA 1500, NFPA 1561, NFPA 1620, and NFPA 1710. 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 22.

NIST recommends the installation, inspection, and testing of emergency communications systems, radio communications, and associated operating protocols to ensure that the systems and protocols: (1) are effective for large-scale emergencies in buildings with challenging radio frequency propagation environments; and (2) can be used to identify, locate, and track emergency responders within indoor building environments and in the field. The federal government should co-ordinate its efforts that address this need within the framework provided by the SAFECOM programme of the Department of Homeland Security.

a. Rigorous procedures, including pre-emergency inspection and testing, should be developed and implemented for ensuring the operation of emergency communications systems and radio communications in tall buildings and other large structures (including tunnels and subways), or at locations where communications are difficult.

b. Performance requirements should be developed for emergency communications systems and radio communications that are used within buildings or in built-up urban environments, including standards for design, testing, certification, maintenance, and inspection of such systems.

c. An interoperable architecture for emergency communication networks – and associated operating protocols – should be developed for unit operations within and across agencies in large-scale emergencies. The overall network architecture should cover local networking at incident sites, dispatching, and area-wide networks, considering: (a) the scale of needed communications in terms of the number of emergency responders using the system in a large-scale emergency and the organizational hierarchy; and (b) challenges associated with radio frequency propagation, especially in buildings; (c) interoperability with existing legacy emergency communications systems (i.e. between conventional two-way systems and newer wireless network systems); and (d) the need to identify, locate, and track emergency responders at an incident site.

Affected Standards: FCC, SAFECOM, NFPA Standards on Electronic Safety Equipment, NFPA 70, NFPA 297, and NFPA 1221. 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.

NIST WTC Recommendation 23.

NIST recommends the establishment and implementation of detailed procedures and methods for gathering, processing, and delivering critical information through integration of relevant voice, video, graphical, and written data to enhance the situational awareness of all emergency responders. An information intelligence sector* should be established to co-ordinate the effort for each incident.

[ * F-45 A group of individuals that is knowledgeable, experienced, and specifically trained in gathering, processing, and delivering information critical for emergency response operations, and is ready for activation in large and/or dangerous events.]

Affected Standards: National Incident Management System (NIMS), NRP, SAFECOM, FCC, NFPA Standards on Electronic Safety Equipment, NFPA 1221, NFPA 1500, NFPA 1561, NFPA 1620, and NFPA 1710. 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.

NIST WTC Recommendation 24.

NIST recommends the establishment and implementation of codes and protocols for ensuring effective and uninterrupted operation of the command and control system for large-scale building emergencies.

a. State, local, and federal jurisdictions should implement the National Incident Management System (NIMS). The jurisdictions should work with the Department of Homeland Security to review, test, evaluate, and implement an effective unified command and control system. NIMS addresses interagency co-ordination and establishes a response matrix – assigning lead agency responsibilities for different types of emergencies, and functions. At a minimum, each supporting agency should assign an individual to provide co-ordination with the lead agency at each incident command post.

b. State, local, and federal emergency operations centres (EOC’s) should be located, designed, built, and operated with security and operational integrity as a key consideration.

c. Command posts should be established outside the potential collapse footprint of any building which shows evidence of large multi-floor fires or has serious structural damage. A continuous assessment of building stability and safety should be made in such emergencies to guide ongoing operations and enhance emergency responder safety. The information necessary to make these assessments should be made available to those assigned responsibility (see related Recommendations 15 and 23).

d. An effective command system should be established and operating before a large number of emergency responders and apparatus are dispatched and deployed. Through training and drills, emergency responders and ambulances should be required to await dispatch requests from the incident command system and not to self-dispatch in large-scale emergencies.

e. Actions should be taken via training and drills to ensure a co-ordinated and effective emergency response at all levels of the incident command chain by requiring all emergency responders that are given an assignment to immediately adopt and execute the assignment objectives.

f. Command post information and incident operations data should be managed and broadcast to command and control centres at remote locations so that information is secure and accessible by all personnel needing the information. Methods should be developed and implemented so that any information that is available at an interior information centre is transmitted to an emergency responder vehicle or command post outside the building.

END

NIST WTC Recommendations 12-15 > Improved Active Protection

Posted 2011-11-25 by CJ Walsh

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: SOME PRELIMINARY COMMENTS …

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

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

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

Quality of Fire Engineering Design & Related Construction

Category A

(a) Design of the works is exercised by an independent, appropriately qualified and experienced architect/engineer/fire engineer, with design competence relating to fire safety and protection in buildings … and, most importantly, that he/she interacts directly with the Project Design Professional in Responsible Charge ;

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

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

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

Category B

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

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

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

Category C

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

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

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

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

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

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

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

2005 NIST WTC RECOMMENDATIONS

GROUP 4. Improved Active Fire Protection

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

NIST WTC Recommendation 12.

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

NIST WTC Recommendation 13.

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

NIST WTC Recommendation 14.

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

NIST WTC Recommendation 15.

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

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

END

NIST WTC Recommendations 8-11 > New Design of Structures

Posted 2011-11-24 by CJ Walsh

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: SOME PRELIMINARY COMMENTS …

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

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

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

i) Increased structural integrity ;

ii) Enhanced fire endurance of structures ;

iii) New methods for fire resisting design of structures ;

iv) Enhanced active fire protection ;

v) Improved building evacuation ;

vi) Improved emergency response ;

vii) Improved procedures and practices ; and

viii) Education and training.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Vested interests … vested interests … vested interests !!!

2005 NIST WTC RECOMMENDATIONS

GROUP 3. New Methods for Fire Resisting Design of Structures

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

NIST WTC Recommendation 8.

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

NIST WTC Recommendation 9.

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

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

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

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

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

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

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

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

NIST WTC Recommendation 10.

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

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

NIST WTC Recommendation 11.

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

END

Sustainable Fire Engineering – IABSE Lecture 1 December 2011

Posted 2011-11-14 by CJ Walsh

2011-11-14 …

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

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

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

IABSE Irish National Group Sponsored Lecture

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

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

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

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

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

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

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

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

END

Ar C.J. Walsh Technical Blog – Registered Architect, Fire Engineer & Independent Technical/Building Controller …… International Expert on Accessibility for All (including Fire Safety) + 'Real' Sustainability Implementation !

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