Construction

SDI Practice Announcement – New 32 Storey Hotel in China

2013-04-02:  Sustainable Design International Ltd. (SDI) is pleased to announce that its Managing Director, C.J. Walsh, has been invited to be ‘Project Design Architect’ / ‘Design Professional in Responsible Charge’ for a New 32 Storey Hotel in Yunnan Province, People’s Republic of China (PRC).

He will have responsibility for the Project’s Architectural Concept Design and General Schematic Design … including the overall architectural character and profile of primary exterior surfaces.

Project Approximate Value = € 65 Million (Euros) … excluding interior design, finishes and furnishing (which could end up doubling, or even tripling, the overall project value).

Sustainable Design International Ltd.  maintains a strict practice policy of Client Confidentiality.

[ If this Type of Professional Design Service Appeals to You, or Your Organization – Contact Us Immediately ! ]

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2012 ‘Understanding China’ Policy Briefing Friends of Europe & EuroChambres

An estimated One Billion People will be living in China’s cities by 2030.  This large-scale and very rapid urbanization demands that a sustainable transformation of their urban built, social, economic and institutional environments commences Today – not at some notional point in a far distant future.

Furthermore … replicating a European approach to sustainable design and construction in other regions of the world is doomed to failure.  Urban Transformation in China must be adapted to Local Geography, Climate, Climate Change, Social Needs, Cultures, Economy, and Local Severe Events (e.g. earthquakes, flooding).  With European support and collaboration … China must, and will, find its own way.

Greening China's Cities of Tomorrow (2012) - Report CoverGreening China’s Cities of Tomorrow (Spring 2012)

Click the Link Above to read and/or download a PDF File (4.42 Mb)

Report on a One-Day China Advisory Council Roundtable, co-organized by Friends of Europe and EuroChambres, which was held in Brussels on 8 March 2012.  This event was part of an ‘Understanding China’ Programme (mid-2009 to mid-2012), co-funded by the European Commission.

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2013 Asian Development Bank (ADB) Guidebook: ‘Increasing Climate Change Resilience of Urban Water Infrastructure’ 

This Guide describes a practical approach to bridge the gap between theoretical analyses of climate change impacts and the planning decisions that need to be made by city authorities and utility managers to increase climate change resilience of the water sector in the city of  Wuhan, Hubei Province, People’s Republic of China (PRC).  It focuses on answering the questions currently being asked by city planners and managers all over the world, as follows:

  • What changes might be caused by climate change ?
  • How will these changes affect services and utilities ?
  • What can we do now to prepare for them ?

The long lead time required to plan, finance, build, and commission city infrastructure facilities means that decision makers cannot wait for more detailed data on the effects of future climate change, especially those relating to local circumstances, but must make investment decisions based on what is known now and what can be readily predicted.  An important principle in this kind of ‘robust’ decision-making is provided by the  Intergovernmental Panel on Climate Change (IPCC)  tenet that adaptation investments, which move a city’s infrastructure toward sustainable development (such as providing safe drinking water and better sanitary conditions), are justifiable even without climate change.

This Guide is arranged in clear steps to provide direction and information for similar exercises in other areas.  Having grown out of a specific locality and its needs, the principles and solutions developed in this guide are founded on real world situations and problems …

ADB Guidebook: 'Increasing Climate Change Resilience of Urban Water Infrastructure' (2013) - Cover PageIncreasing Climate Change Resilience of Urban Water Infrastructure (ADB, 2013)

Click the Link Above to read and/or download a PDF File (2.31 Mb)

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***  THIS TALL BUILDING IN YUNNAN PROVINCE  &  SIMILAR COMPLEX ARCHITECTURAL PROJECTS  ***

Working within the professional constraints of ‘client confidentiality’ … it is possible to have a general discussion about current building design, construction and operation issues in an international sector which is operating, more and more, beyond national borders … without adequate, or very often any, national and local regulation.  By ‘regulation’, I mean a flexible system of building-related legislation which is operated in conjunction with mandatory and effective technical control.

In order to cope with today’s complex built environment and the enormous variation in the size and scale of construction projects … a ‘flexible’ mix of functional, performance and prescriptive legal requirements is the sharpest and most appropriate instrument.

And you can forget the hype about performance-based building codes coming out of the USA … hot air, and much ado about little !

Of course, the biggest issue of all is the competence of those individuals who work in Authorities Having Jurisdiction (AHJ’s), i.e. technical controllers.  Even in the most developed economies of the world … there are many occasions when the level of individual incompetence in an AHJ is astounding … and institutional arrangements within the AHJ itself are a mess, i.e. the AHJ is not fit for purpose.

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1.  Sustainable Design – Design Process Efficiency & Proper Preparation for Construction

A tremendous amount of waste is associated with and generated by the processes of conventional building design, construction and operation.  There is a more up-to-date and efficient way of doing things … an essential way for Sustainable Design … and it’s called Building Information Modelling (BIM) !

Furthermore … consider, for a moment, just the initial list of Specialist Consultants who will be engaged directly by the Chinese Client when the project’s conceptual design has reached a sufficiently developed stage.  How can all of these individuals and organizations – listed in the revised and agreed Project Design Agreement – obtain accurate and reliable ‘real time’ information about the rapidly evolving project from a central design library / information database … then feed their new work back into the centre without unnecessary delay ?   How, next, can everyone else who needs to know, be updated with the new design input … again, without delay ?   And perhaps, these consultants may also be based in different countries … working in very different time zones …

  • Building Information Modelling (BIM) Consultant
  • Local Design Institute (LDI) … a local architectural practice which will produce the project’s working drawings, handle local spatial planning and building code approvals, carry out site inspections, and deal directly with construction organization(s), etc., etc.
  • Interior Design Consultant
  • Traffic / Parking Analysis Consultant
  • Curtain Wall Consultant (Curtain Wall, Skylights & Special Roof Structures)
  • Retail Market Analysis Consultant
  • Landscape Design Consultant
  • Quantity Surveying & Cost Estimating Consultant
  • Furniture Design Consultant
  • Geotechnical, Civil Engineering & Structural Engineering Consultant (including structural performance under fire and earthquake conditions, resistance to fire-induced progressive damage and disproportionate damage … and also including climate resilience)
  • Acoustic & Audio-Visual Design Consultant
  • Mechanical, Electrical & Plumbing (MEP) Engineering Consultant
  • Integrated Building Automation & Management / Telecom / Security / Networking Consultant
  • Fire & Life-Safety Engineering Consultant
  • Water Feature Consultant
  • Wind Tunnel Test Consultant
  • Kitchen Equipment and Layout Design Consultant
  • Art, Artefact and Accessories Consultant & Procurement Services for Art, Artefacts, and Accessories
  • Tenant Storefront Design Consultant
  • Helicopter Landing Pad Design Consultant
  • Universal Design / Accessibility for All Consultant [including access to the building, electronic, information and communication technologies (EICT’s), and services offered at the hotel … and including fire safety, protection and evacuation for all]

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2.  The ‘Design Professional in Responsible Charge’ !

The Project Design Agreement requests that the Client receive advice on who might be the different Specialist Consultants listed above.  In addition, it will be necessary to demarcate the boundaries within which each Consultant will operate … and, where appropriate, to prescribe a design performance target (see below) for each speciality … which must be ‘realized’ in the completed and occupied building !

Recalling the many previous posts, here on this Technical Blog, concerning NIST’s 2005 & 2008 Recommendations on the 9-11 World Trade Centre Building Collapses in New York City‘somebody’ must ensure that the many individuals and organizations listed above – members of the Larger (2nd Stage) Design Team – use consistent design data and assumptions … must co-ordinate design documents and specifications to identify overlaps and eliminate gaps … must serve as ultimate liaison between the Client, the Local Design Institute, AHJ officials, and the Construction Organization(s) … and must ensure that everybody is on the same communication wavelength, and working towards the same objective in a trans-disciplinary manner.

That ‘Somebody’ … the Design Professional in Responsible Charge … must be the Project Design Architect !

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3.  Some Sustainable Design Performance Targets

Actual construction and building user performance shall be carefully (i.e. reliably and precisely) monitored … and independently verified …

A.   Basic Functional Requirements … the Building shall comply with the Basic Requirements for Construction Works – elaborated in Annex I of European Union (EU) 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.

See my Post, dated 2011-09-13 … https://www.cjwalsh.ie/2011/09/new-eu-construction-product-regulation-3052011-halleluiah/

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B.   Good Indoor Air Quality (IAQ) … Two high-level performance indicators have been developed with the aim of protecting Human Health, and are both now referenced in International Standard ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’

      –   Radon Activity (incl. Rn-222, Rn-220, RnD) in a building should, on average, fall within the range of 10 Bq/m3 to 40 Bq/m3, but shall at no time exceed 60 Bq/m3 ;

      –   Carbon Dioxide (CO2) Concentrations in a building should not significantly exceed average external levels – typically within the range of 300 parts per million (ppm) to 500 ppm – and shall at no time exceed 800 ppm.

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C.   Energy Conservation & Efficiency + A ‘Positive Energy’ Return + Assured Building User Thermal Comfort

See my Post, dated 2013-09-10 … https://www.cjwalsh.ie/2013/09/passivhaus-standard-is-not-enough-in-new-building-projects/

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D.   Project-Specific Sustainable Fire Engineering Design Objectives

See my Post, dated 2014-04-20 … https://www.cjwalsh.ie/2014/04/sustainable-fire-engineering-design-targeting-mrv/

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‘Sustainability’ – New Part 11 in India’s National Building Code !

2013-03-17:  Happy Saint Patrick’s Day !!

Submissions on India’s Draft Amendment No.1 to the 2005 National Building Code (SP 7:2005) concerning the Proposed Incorporation of a New Part 11: ‘Approach to Sustainability’ had to arrive at the Bureau of Indian Standards (BIS), in Dilli … by e-mail … no later than Friday last, 15 March 2013 …

Indian National Building Code Proposed New Part 11: 'Approach to Sustainability' - Cover Memo
Click to enlarge.

Indian NBC, Proposed Part 11 on ‘Sustainability’ – December 2012 Consultation

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Extract From Foreword (Page 7):

‘ Developed nations’ approach to sustainability generally concentrates on energy conservation through high technology innovations, and use of products, materials and designs with lower embodied energy.  Their green ratings are based on intent, which implies expert inputs and simulation.  The Indian construction industry will do better using our traditional wisdom and practices, building in harmony with nature through regional common knowledge, consuming as little as necessary, applying low cost technology innovations, using recycled materials, and recognizing performance (not intent) through easily measurable parameters wherever feasible.’

How Right They Are About Prioritizing ‘Real’ Performance !!

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And Just Before That Extract Above:

‘ The authentic (my insert !) Indian way of life is aparigraha (minimum possessions), conservation (minimum consumption), and recycling (minimum waste).  These three attributes are the guiding principles for sustainable buildings as well.  With these attributes and its rich heritage, India can make a substantial contribution in this field and eventually lead the world on the path of sustainability.’

An Overly Ambitious Target ?   Perhaps Not.

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SDI Supporting India’s National Sustainable Buildings Strategy …

We very much welcome this opportunity to make a Submission on India’s Draft Amendment No.1 to the 2005 National Building Code (SP 7:2005) concerning the Proposed Inclusion of a New Part 11 ‘Approach to Sustainability’.

This IS an important development for India … and it DOES mark a substantial contribution to this field, at international level.  We wish that other countries would follow your example … particularly China, the other mushrooming economies in South-East Asia, and the Arab Gulf States.

You may not be aware that Sustainable Design International (SDI) has been specializing in the theory and implementation of a Sustainable Human Environment (social, built, virtual, and economic) since the mid-1990’s.

And, for example … in September 2007, we were invited to make a series of Keynote Presentations to 20 Senior National Decision-Makers, from both the public and private sectors, at a 2-Day Workshop which was organized for us in Lisboa, Portugal.  If invited, we would be delighted to repeat this valuable exercise in Dilli, Bengaluru, and other suitable venues in India.

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IF India is to lead the world on this particular track, i.e. Sustainable Buildings, a coherent philosophy must be outlined in the Proposed New Part 11 of the National Building Code, and a clear direction must also be given there to decision-makers, e.g. clients/client organizations, and designers.

Certain essential content must be included in Part 11.  With regard to an improved layout of Part 11, please review the attached  SDI Document: ‘SEED Building Life Cycle’ (PDF File, 55 Kb) .

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Because you have prioritized ‘real’ building performance over pre-construction design ‘intent’, it is appropriate to begin our comments here …

1.   Sustainability Performance Indicators

In order to prioritize ‘real’ performance, the monitoring of actual sustainability performance in completed and occupied buildings must be comprehensive, accurate and reliable.  Indicators of sustainability performance must, therefore, be included in all sections of the Proposed New Part 11.

Sustainability Performance Indicators provide important signposts for decision-making and design in many ways.  They can translate physical and social science knowledge into manageable units of information which facilitate the decision-making and design processes.  They can help to measure and calibrate progress towards sustainable development goals, and sectoral sustainability targets.  They can provide an early warning to prevent economic, social and environmental damage and harm.  They are also important tools to communicate ideas, thoughts and values because, as statisticians say: “We measure what we value, and value what we measure”.

Performance Indicators may be both quantitative and qualitative … but must cover all stages of the building process, i.e. project feasibility and performance specification, spatial planning, design, construction, management, operation, maintenance and servicing, de-construction, disposal, final site clean-up and sustainable repair.

While many, though not all, types of building performance can be successfully monitored using lightweight portable equipment … a certain number of monitoring devices must also be permanently installed in the building during construction.  A facility to reliably feed the output from these devices back to data collection points, on site and remote, must also be incorporated in the Building’s Intelligent Management System.

Management and collation of sustainability performance data must be reliable.  Uncertainty is always present.  Therefore, Statements of Uncertainty should always be attached to ‘reliable’ data.

Safety Factors should always be included when targeting critical ‘health and safety’ related types of performance.

Sustainability Performance Indicators must be directly comparable across different Global Regions … within Asia, across different countries … and within India, across different States.  A Balanced, Harmonized Core Set of Indian Performance Indicators should be quickly developed.  A Balanced ‘Local’ Set of Performance Indicators will always be necessary.

People tasked with monitoring sustainable building performance must be competent … and independent, i.e. be unconnected to client, design and construction organizations.

Specifically in relation to Energy Performance, the targets to be achieved in new buildings must be far more ambitious.  Please review the attached  SDI Document: ‘SEED Positive Energy Buildings’ (PDF File, 29 Kb) .

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2.   Properly Defining ‘Sustainable Development’

As currently drafted … Definition 2.26 Sustainable Development, on Page 13 of the Proposed New Part 11, is not only ambiguous, it is inadequate for India’s needs … and it is barely the first half of the full, correct definition …

Sustainable Development  is development that meets the needs of the present without compromising the ability of future generations to meet their own needs.  It contains within it two key concepts:

  • the concept of ‘needs’, in particular the essential needs of the world’s poor, to which overriding priority should be given ;  and
  • the idea of limitations imposed by the state of technology and social organization on the environment’s ability to meet present and future needs.

[ Please refer to the 1987 Report of the World Commission on Environment & Development (WCED): ‘Our Common Future’ – Chapter 2, Paragraph 1.]

This original definition in the 1987 WCED Report IS appropriate for India … and it must become the core definition at the heart of India’s National Sustainable Buildings Strategy !

A careful reading of the full definition makes it clear that there are Many Aspects to this intricate, open, dynamic and still evolving concept … the most important of which are:  Social, Economic, Environmental, Institutional, Political, and Legal.

It is a Fundamental Principle of Sustainability, and one of its Primary Values … that Implementation must be Synchronous, Balanced and Equitable across All Aspects of Sustainability.

The ‘Green Agenda’ merely considers Environmental Aspects of Sustainability … in isolation from all of the other Aspects !   This is a fatal flaw which must be avoided in the Proposed New Part 11 !!

[ I made many references to this issue during the FSAI Conferences in India ! ]

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3.   Sustainability Impact Assessment (SIA) for India !

Rather than Environmental Impact Assessment … surely the Proposed New Part 11: ‘Approach to Sustainability’ must now use, explain and discuss Sustainability Impact Assessment instead !?!

Sustainability Impact Assessment (SIA)

A continual evaluation and optimization assessment – informing initial decision-making, or design, and shaping activity/product/service realization, useful life and termination, or final disposal – of the interrelated positive and negative social, economic, environmental, institutional, political and legal impacts on the synchronous, balanced and equitable implementation of Sustainable Human & Social Development.

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4.   A Robust Legal Foundation for ‘Sustainable Human & Social Development’

Paragraph 4 (Chapter 2, 1987 WCED Report) states …

‘ The satisfaction of human needs and aspirations is the major objective of development.  The essential needs of vast numbers of people in developing countries – for food, clothing, shelter, jobs – are not being met, and beyond their basic needs these people have legitimate aspirations for an improved quality of life.  A world in which poverty and inequity are endemic will always be prone to ecological and other crises.  Sustainable development requires meeting the basic needs of all and extending to all the opportunity to satisfy their aspirations for a better life.’

Trying to list the essential needs of people / the basic needs of all is a very difficult task … but it is work which has been on-going, at international level, since just after the Second World War.

The essential needs of people / the basic needs of all … are specified as being Human Rights and Fundamental Freedoms, and are already fully described within the extensive framework of International Legal Rights Instruments.

Which is why, many years ago, SDI developed this definition for Sustainable Human & Social Development … in order:

  • to give this concept a robust legal foundation ;   and
  • (because of widespread confusion in media, political and academic circles) … to clearly establish that we are talking about sustainable human and social development, and not sustainable economic development, or any other type of development !

Sustainable Human & Social Development

Development which meets the responsible needs, i.e. the Human & Social Rights*, of this generation – without stealing the life and living resources from future generations … especially our children, and their children … and the next five generations of children.

*As defined in the 1948 Universal Declaration of Human Rights.

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5.   Climate Change Adaptation & Resilient Buildings in India ?

Atmospheric Ozone Depletion and Climate Change are mentioned, here and there, in the Proposed New Part 11.  The important implications of these phenomena for Sustainable Building Design in India are not explained … at all.  Why not ?

To properly respond to these phenomena, both must be integrated into India’s National Sustainability Strategies & Policies.

At the very least … we strongly recommend that Design Guidance on Climate Resilient Buildings be immediately drafted.  This guidance must be appropriate for implementation in each of the different climatic regions of India.

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6.   A Sustainable Indian Built Environment which is Accessible for All !

Barrier Free is mentioned, here and there, in the Proposed New Part 11.  This is to be warmly welcomed and congratulated.  Under Social Aspects of Sustainable Human & Social Development … this is an essential attribute of a Sustainable Built Environment !   However, no guidance on this subject is given to decision-makers or designers.  Why not ?

However, you should be aware that India ratified the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) on 1 October 2007.  For your convenience, I have attached copies of the Convention in English, Hindi and Tamil.

You should also be aware that, in December 2011, the International Standards Organization (ISO) published ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’.  In its Introduction, ISO 21542 is directly linked to the U.N. Convention … almost like an umbilical cord.  The scope of this Standard currently covers public buildings.  As the Accessibility Agenda in the U.N. Convention is very broad … much standardization work remains to be finished at international level.

The correct term … Accessibility for All … has been defined in ISO 21542 as including … ‘access to buildings, circulation within buildings and their use, egress from buildings in the normal course of events, and evacuation in the event of an emergency’.

A note at the beginning of the standard also clarifies that Accessibility is an independent activity, i.e. assistance from another person should not be necessary … and that there should be an assurance of individual health, safety and welfare during the course of those (accessibility-related) activities.

In order to fulfil India’s legal obligations as a State Party to the U.N. Convention on the Rights of Persons with Disabilities … adequate Design Guidance on Accessibility must be included in the Proposed New Part 11, supported by ISO 21542.

In addition, the Bureau of Indian Standards (BIS) should immediately adopt ISO 21542 as the Indian National Standard on Accessibility for All … IS / ISO 21542.

[ I made many references to this issue during the FSAI Conferences in India ! ]

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7.   Fire Safety & Protection for All in Sustainable Indian Buildings ?

Yes … there is 1 mention of ‘fire safety’ and 40 other references to ‘fire’ in the Proposed New Part 11 … but no design guidance.  Why not ?

You should be aware that there is a fundamental conflict between Sustainable Building Design Strategies and the current state-of-the-art in Fire Engineering Design.  As a good example … for cooling, heating and/or ventilation purposes in a sustainable building, it is necessary to take advantage of natural patterns of air movement in that building.  On the other hand, fire engineers in private practice, and fire prevention officers in Authorities Having Jurisdiction (AHJ’s), will demand that building spaces be strictly compartmented in order to limit the spread of fire and smoke … thereby dramatically interfering with those natural patterns of air movement.

In everyday practice, there is a vast chasm in understanding and communication between these two very different design disciplines.  As a result, serious compromises are being enforced on Sustainability Building Performance.  If, on the other hand, adequate independent technical control is absent on the site of a Sustainable Building … it is the fire safety and protection which is being seriously compromised.

A range of critical fire safety issues (fatal, in the case of firefighters) are also arising with the Innovative Building Products and Systems being installed in Sustainable Buildings.

Because the emphasis is on pre-construction design ‘intent’ rather than the ‘real’ performance of the completed and occupied building … all of these problems are being conveniently ignored, and they remain hidden from everybody’s view.

This must be addressed in the Proposed New Part 11.

[ I made many references to this issue during the FSAI Conferences in India ! ]

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C. J. Walsh – Consultant Architect, Fire Engineer & Technical Controller – Managing Director, Sustainable Design International Ltd. – Ireland, Italy & Turkey.

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Ireland’s Draft National Radon Control Strategy – A Fraud !!

2013-02-28:  Submissions on Ireland’s Draft National Radon Control Strategy must arrive at the Department of the Environment, Community & Local Government, our national authority having jurisdiction … by e-mail or hand delivery to either the Custom House in Dublin or the DECLG Offices in Wexford … no later than 17:30 hrs tomorrow, Friday 1 March 2013

DECLG - Draft National Radon Control Strategy Title Page (January 2013)

Ireland’s Draft National Radon Control Strategy – January 2013 Consultation

Click the Link above to read/download PDF File (425 Kb)

The Aim of this Draft Strategy, as stated on the DECLG WebSite, is to ensure that exposure to Radon Gas, which presents a significant public health problem, is addressed in an effective and co-ordinated way across all relevant public authorities through appropriate interventions.  The Draft Strategy was developed by an Inter-Agency Group comprising representatives from relevant public authorities.

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After all of the progress made on radon protection in buildings at the end of the 1990’s and beginning of the 2000’s, it is extremely disappointing to read this miserable excuse for a strategy document.  If the general public in Ireland is under any impression that the ‘powers-that-be’ are deeply concerned about protecting our health … they are making a fatal mistake !

The complete absence of any reference to a Recommended Health-Related Radon Target Level – Safety-Related National Reference Levels which are not clearly explained will result in some injury and harm – Lack of Meaningful Consultation with, and Informed Consent of, the National Population – Horrendously Inadequate Technical Control Procedures on Irish Building Sites – RPII Recommended Indoor Radon Activity Measuring Devices having Very High Measurement Uncertainty (±30% under typical conditions of use) – A Purposeful Lack of Detailed Guidance on Exactly When and How to Measure Indoor Radon – Inadequate RPII Radon Measurement Test Reporting … are just some of the tell-tale signs for a seasoned observer.

In this regard, therefore … and let me be very clear and simple in my use of language … this Draft National Radon Control Strategy is a blatant fraud !!

Fraud:  Deliberate deception, trickery, or cheating intended to gain an advantage – An act or instance of such deception (from Latin Fraus (f): deceit, deception).

Furthermore … the Inter-Agency Group which produced this Draft National Radon Control Strategy for the DECLG Minister, Mr. Phil Hogan T.D., and Senior Civil Servants within the Department … whoever the Group’s participants are, wherever they are … should be thoroughly ashamed of themselves for being associated with this negligent act !

Negligent:  Lacking attention, care or concern.

Negligence:  A wrong whereby a person(s) is in breach of a legal duty of care, resulting in harm or injury to another person(s) … in this case, the Irish Public.

To see a complete overview on this Serious Building-Related Human Health Issue, and for information about a Far Better and More Coherent Approach to Radon Protection in Buildings which takes proper account of European Union (E.U.) legislation, e.g. the Precautionary Principle … please refer to SDI’s Corporate WebSite

NORM, Radon Gas, Radon Activity & Protection from Radon in Buildings

(It is not my intention to reproduce, here, all of the content on this WebPage as part of the Submission.)

I am also the Technical Consultant who drafted these 2 Benchmark Irish Agrément Board (IAB) Certificates for Radon Protection Measures in Buildings …

Monarflex Radon Resisting Membranes – IAB Certificate No. 98/0075

and

Radon Control Systems: Easi-Sump & Easi-Sump Cap-Link – IAB Certificate No. 01/0130

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SDI’s Comments on Ireland’s Draft National Radon Control Strategy (NRCS)

1.   Protecting Human Health versus Reducing Risk to Safety

The following two short extracts from 1. Introduction and Background in the Draft NRCS reveal the true intent of the Inter-Agency Group …

‘ Radon gas is the greatest source of exposure to ionising radiation for the general public and is the second greatest cause of lung cancer in Ireland.  Recognising the serious health risk presented by radon, the Minister for the Environment, Community and Local Government in November 2011 established an inter-agency group to develop a National Radon Control Strategy (NRCS).’

and …

‘ During 2012 the inter-agency group developed a draft NRCS based on wide stakeholder consultation and a health economics evaluation of different radon intervention strategies.  The stakeholder consultation involved a range of individuals and bodies involved in: health care, construction, radon services, Government and academia.  The health economics evaluation was undertaken by the Radiological Protection Institute of Ireland (RPII) and Health Service Executive (HSE) with the assistance of the Health Economics Unit at the University of Oxford.  This draft strategy sets out a range of measures to reduce the risk from radon to people living in Ireland.’

Radon is a serious human health issue, and it is explained in a later section of the document 1.2 The Radon Problem in Ireland that ‘indoor radon is linked to between 150 to 200 lung cancer deaths each year in Ireland, which equates to approximately 13% of all lung cancer deaths.’

However … after the references above to ‘health economics evaluation’ (!) … to the ‘prevailing  economic situation’ (!!) in section 1.1 Public Consultation … and to ‘health economics tools’ (!!!) in section 2. Draft National Radon Control Strategy … etc … you should then sensitize yourself to the subtle change in language very early in the document … from a consideration of health protection, to reducing the risk from radon (or similar variations on that theme).

The concept of Protecting Human Health is altogether different from the concept of Assessing and Mitigating / Reducing Risk to Safety !   Please refer to SDI’s Corporate WebSite.

As far back as the end of the 1990’s … the Irish Agrément Board, which at the time included a representative from the Department of the Environment, accepted the following …

Radon Activity in Buildings – Recommended Target Health Level

Radon Activity (incl. Rn-222, Rn-220, RnD) should, on average, fall within the range of 10-40 Bq/m3, but should at no time exceed 60 Bq/m3.

This Recommended Target Health Level for Radon now also appears in International Standard ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’, which was published in December 2011.  Please refer to Annex B.8 – Indoor Air Quality (IAQ) in the ISO Standard.

The Draft NRCS must refer to such a Recommended Target Health Level … and it must be stated that it is National Policy to progressively reach that target by 2025 (bearing in mind the ‘prevailing economic situation’ in the country !).

Note:  In contrast to the above … 200 Bq/m3 for Residential Buildings, and 400 Bq/m3 for Workplaces … are NOT Health-Related Target Levels … they are Safety-Related National Radon Reference Levels which result in some measure of harm and injury to people … particularly children under the age of 10 years, and people with activity limitations who constantly remain indoors for prolonged periods of time.

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2.   National Policy Priority:  ‘Real’ Protection from Radon in ‘Real’ Irish Buildings

Yes … in Ireland, we have enormous problems with regard to a lack of awareness among the general population about the serious health hazard posed by indoor radon … and the absence of proper education and training for everyone directly involved in the design, construction, management, operation, servicing or maintenance of our building stock (both new and existing).

BUT … if we are committed to providing ‘real’ radon protection in ‘real’ Irish buildings, then a practical construction-oriented approach is demanded.

This is a Key Paragraph in 2.1 Radon Prevention in New Buildings

‘ The stakeholder engagement also points to some practical difficulties associated with the implementation of the current technical guidance on radon prevention.  These difficulties relate to the correct installation of radon barriers under site conditions, protection of the integrity of radon barriers once installed and identification of radon preventive measures on site.  The stakeholder engagement also indicated the system of building control in place prior to 2012 did not provide adequate assurance that radon preventive measures had been correctly installed ‘

… which we later discover is a masterstroke of understatement and evasion, because none of these important issues are tackled head on in the document.

On the critical issue of Building Control … there is no mention of mandatory inspections of construction projects by competent Local Authority personnel.  Because … it remains the unwritten policy of Ministers and Senior Civil Servants in Ireland’s Department of the Environment, Community & Local Government (DECLG) that Local Authority Building Control Sections will be entirely ineffective.

On the other hand … will Competent Private Independent Technical Controllers be facilitated in carrying out sufficient inspections of all radon protection related works before ‘signing off’ on proper completion ???

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3.   Regulatory Status of RPII’s Radon Prediction Maps

This is NOT a problem unique to Ireland.

The presence of the RPII Radon Prediction Maps in Technical Guidance Document C (Building Regulations), and the status they are given there … are both entirely inappropriate.

While these Maps are a useful design aid, in the case of small construction projects, they offer NO assurance of certainty to either building designers or users.  They are NOT reliable !   And the average values shown in any particular ‘box’ may actually conceal a considerable degree of variability in the radon concentrations found in completed buildings.

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4.   SDI’s Acceptance of RPII Services

Please refer to SDI’s Corporate WebSite.

Unfortunately, until the Radiological Protection Institute of Ireland (RPII) includes proper statements of Measurement Uncertainty in its Test Reports (this is a requirement of European Standard EN ISO/IEC 17025)  … our Organization:

  • cannot recommend any RPII Radon Testing Services to 3rd Parties ;

and

  • will not accept any RPII Test Reports as proper evidence of Radon Test results.

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C. J. Walsh – Consultant Architect, Fire Engineer & Technical Controller – Managing Director, Sustainable Design International Ltd. – Ireland, Italy & Turkey.

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‘Sustainable Fire Engineering for All’ – SDI’s Professional Service

2012-12-14 & 2012-12-30:  Further to this distressing incident … which exposed a profound lack of awareness, care and competence within the general fire safety industrial sector …

Recent Fatal Fire at a Disabled Workshop in SW Germany

… this is how we would like to help you … whether you are an individual, or an organization … whether you are located in Ireland, Italy or Turkey … some other part of Europe, the Arab Gulf Region, India, Japan, China … or wherever !

And … we can, if requested or necessary, work in collaboration with local partners in those different geographical regions.

– FireOx International is the Fire Engineering Division of Sustainable Design International Ltd. (SDI) –

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Colour photograph showing the 2 World Trade Center Towers, in New York City, immediately after the second plane impact. The mechanical damage arising from such a plane impact had been considered in the Initial Building Design Process; incredibly, any type of Fire Incident had not ! In the case of both towers and within a short period of time, Fire-Induced Progressive Damage resulted in Disproportionate Damage, and eventual Total Building Collapse. The horror and carnage at the World Trade Center Complex, and the extensive collateral damage to everywhere south of Canal Street, caused enormous long-term damage to the economy of Manhattan ... and had a very significant adverse impact on Global Financial Markets. Click to enlarge.
Colour photograph showing the 2 World Trade Center Towers, in New York City, immediately after the second plane impact. The mechanical damage arising from such a plane impact had been considered in the Initial Building Design Process; incredibly, any type of Fire Incident had not ! In the case of both towers and within a short period of time, Fire-Induced Progressive Damage resulted in Disproportionate Damage, and eventual Total Building Collapse. The horror and carnage at the World Trade Center Complex also caused enormous long-term damage to the economy of Manhattan … and had a very significant adverse impact on Global Financial Markets. Click to enlarge.

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Introduction

Fundamentally, the 9-11 World Trade Center Incident in New York (2001) was an Extreme ‘Real’ Fire Event.  It presented the International Fire Engineering Community with a catastrophic failure in conventional practices and procedures related to:

  • Fire Engineering, Structural Engineering, and Architectural Design ;
  • Human Building Management Systems ;
  • Emergency Response by Firefighters, Rescue Teams, and Medical Personnel ;
  • National and Local Organizations Having Authority or Jurisdiction (AHJ’s) ;

… and with the serious problem of entirely inadequate Fire Safety Objectives in the building legislation, model codes and design standards of the most economically advanced countries in the world.

Those people who understand the building design process, and have experience as construction practitioners, have long realised that the lessons from 9-11 must be applied across the full spectrum of building types … not just to tall buildings.  Right up to the present day, unfortunately, many people in the International Fire Engineering Community are either unwilling, or unable, to do this.

Furthermore … Fire Engineering, Architectural Design and Structural Engineering must, of urgent necessity, be seamlessly conjoined … with the aim of removing misunderstandings and the wide gaps in client service delivery between the different disciplines.

In 2002, a series of Long-Term 9-11 Survivor Health Studies commenced in the USA … and in 2005 and 2008, the U.S. National Institute of Standards and Technology (NIST) issued a series of Post 9-11 Critical Recommendations concerning the design, construction, management and operation of buildings.

At FireOx International … we have fully integrated this essential design guidance into our frontline fire engineering and architectural practice … we have developed unique and practical solutions for worldwide application, some of which appear in International Standard ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’, published in December 2011.

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Colour photograph showing an armed assailant during the November 2008 'Hive-Attack' on Mumbai ... an extraordinarily violent, co-ordinated assault on the largest (and wealthiest) city in India, which involved the strategic targeting of built environment Places of Public Resort, Iconic Buildings, High-Rise Buildings, Buildings having a Critical Function, Transport Infrastructure and Service Utilities ... with the aim of causing widespread terror among the general population, including tourists, and disruption to the city’s important economic environment. Click to enlarge.
Colour photograph showing an armed assailant during the November 2008 ‘Hive-Attack’ on Mumbai … an extraordinarily violent, co-ordinated assault on the largest (and wealthiest) city in India, which involved the strategic targeting of built environment Places of Public Resort, Iconic Buildings, High-Rise Buildings, Buildings having a Critical Function, Transport Infrastructure and Service Utilities … with the aim of causing widespread terror among the general population, including tourists, and disruption to the city’s important economic environment. Click to enlarge.

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FireOx International’s Commitment to You

As a necessary response to the New 21st Century Paradigm of Real Extreme Event in a Built Environment which is becoming more and more complex … is subject to climate change and severe weather events … and is vulnerable to malign and malevolent disruption –

WE are committed to … the implementation of a Sustainable Human Environment which is Fire Safe and Secure for All, meaning that an ‘appropriate project-specific fire safety level’ is our fire engineering objective, with ‘human health protection’ targeted as a priority … through the use of innovative, reliability-based and person-centred sustainable design practices and procedures.

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What is an ‘Appropriate Fire Safety Level’ in Your Building or Facility ?

It is rarely, if ever, explained to clients/client organizations that the Minimal Fire Safety Objectives in building legislation are focused solely on protecting the ‘interests’ of society, not those of the individual …  are, quite often, inadequate and/or flawed … and are, always, revised only after the latest tragedy !

To properly protect Your Interests as a client/client organization … we strongly advise that the Appropriate Level of Fire Safety in Your Building or Facility should exceed the minimal level of safety required by building legislation.  We would also caution that, in many jurisdictions (e.g. India), compliance with national building legislation is voluntary.

Which raises the issues of whether or not you will actually get what you pay for, and whether or not the Fire Protection Measures in Your Building or Facility are reliable (in other words, will they perform as intended at the time of a ‘real’ fire, which may occur at any time in a building’s long life cycle) !?!   Competent Technical Control of Design and Construction, independent of the design and construction organization(s), is essential.

You should carefully consider the following spectrum of issues which may be directly relevant to Your Project.  Following a process of consultation with you, we then develop Project-Specific Fire Engineering Design Objectives … bearing in mind that you must also comply with safety at work, anti-discrimination, and environmental legislation, etc … maintain business continuity, etc … be energy efficient, etc … and be socially responsible, etc …

–     Protection of the Health of All Building Users … including People with Activity Limitations (2001 WHO ICF), Visitors to the building or facility who may be unfamiliar with its layout, and Contractors or Product/Service Suppliers temporarily engaged in work or business transactions on site ;

–     Protection of Property from Loss or Damage … including the Building or Facility, its Contents, and Adjoining or Adjacent Properties ;

–     Safety of Firefighters, Rescue Teams and Other Emergency Response Personnel ;

–     Ease and Reasonable Cost of ‘Effective’ Reconstruction, Refurbishment or Repair Works after a Fire ;

–     Sustainability of the Human Environment (social – built – virtual – economic) … including Fitness for Intended Use and Life Cycle Costing of fire engineering related products and systems, etc … fixed, installed or otherwise incorporated in the building or facility ;

–     Protection of the Natural Environment from Harm, i.e. Adverse or Damaging Impacts.

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FireOx International – Our Fire Engineering Services

  • WE  will advise you on Fire Safety Policy, Fire Safety Strategy Development, Fire Safety Implementation … and, whether you are within or from outside the European Union, on CE Marking of Fire Protection Related Construction Products

  • WE  understand the process of Design, particularly the new language of Sustainable Design … and we will produce Creative Fire Engineering Solutions for Your Project

  • WE  are thoroughly familiar with the intricacies of Building Sites … and we will verify and/or validate Design Compliance during construction, and at project completion … and, if requested or necessary, as a completely Independent Technical Controller ; 

  • WE  communicate easily and effectively with other Professional Design Disciplines, including architects and structural engineers … and we will act as fully participating members of Your Project Design & Construction Team … and, if requested or necessary, as the Design Professional in Responsible Charge **

  • WE  practice in accordance with a comprehensive Professional Code of Ethics

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Sustainable Fire Engineering Solutions ?

  1. Are adapted to Local Geography, Climate/Climate Change, Social Need, Culture, Economy … and Severe Events (e.g. earthquakes, flooding) ;
  2. Are ‘Reliability-Based’, i.e. that design process based on practical experience, competence and an examination of real extreme events, e.g. 2001 WTC 9-11 & 2008 Mumbai Attacks, and 2011 Fukushima Nuclear Incident … rather than theory alone ;
  3. Are ‘Person-Centred’, i.e. that design process which places ‘real’ people at the centre of creative endeavours and gives due consideration to their responsible needs, and their health, safety, welfare and security in the Human Environment.

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FireOx International’s Contact Information

E-Mail:  cjwalsh@sustainable-design.ie

International Phone:  +353 1 8386078   /   National Phone:  (01) 8386078

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Important Note:  This Post should be read in conjunction with an earlier Post …

Sustainable Design International Ltd. – Our Practice Philosophy

It is there, not here, that we define Sustainable Human & Social Development … and describe how our Practice is responding to this open, intricate, dynamic, and still evolving concept.  The resulting transformation in how frontline services are provided to our Clients/Client Organizations ensures a much more comfortable ‘fit’ to their needs … and a greater level of protection, safety and security for society !

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[ ** 2005 NIST(USA) Final Report on 9-11 World Trade Center 1 & 2 Tower Collapses

– Footnote 49 –

… the Design Professional in Responsible Chargeusually the lead architect – ensures that the (Design) Team Members use consistent design data and assumptions, co-ordinates overlapping specifications, and serves as the liaison with enforcement and review officials, and with the client or client organization. ]

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

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.
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.

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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.

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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 !!

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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.

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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.

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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.

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

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. ]

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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.

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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.

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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.

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I have amended our Submission accordingly.

Kind regards.

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

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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 !

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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 …

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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.

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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.

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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.

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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.

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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.

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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).

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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

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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.

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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.

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Kind regards.

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

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NIST WTC Recommendations 29-30 > Improved Fire Education

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 EnduranceGROUP 2.  Enhanced Fire Endurance of Structures – Recommendations 4, 5, 6 & 7

2011-11-24:  NIST WTC Recommendations 8-11 > New Design of StructuresGROUP 3.  New Methods for Fire Resisting Design of Structures – Recommendations 8, 9, 10 & 11

2011-11-25:  NIST WTC Recommendations 12-15 > Improved Active ProtectionGROUP 4.  Improved Active Fire Protection – Recommendations 12, 13, 14 & 15

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

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

2011-12-07:  NIST WTC Recommendations 25-28 > Improved PracticesGROUP 7.  Improved Procedures and Practices – Recommendations 25, 26, 27 & 28

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2011-12-08:  SOME PRELIMINARY COMMENTS …

  1.     At last, we arrive at the Group 8 Recommendations !   At this stage … my impression is that the NIST Team began to run out of steam, because these two short Recommendations barely scratch the surface with regard to the significant education and training needs of the many different design, construction, management, operation, maintenance and emergency response disciplines engaged with, and confronted by, the Built Environment … every day of every week.

After a careful reading of all 30 NIST WTC Recommendations, I hope that you have satisfied yourself/yourselves that these Recommendations must be applied to ALL Buildings … not just Tall Buildings.  At various times … Iconic Buildings, and Buildings having a Critical Function or an Innovative Design have been specifically mentioned.  And look back to Recommendation 22a … tunnels and subways also made an appearance !   The proper focus for the International Fire Science and Engineering Community must be on the Built Environment as a whole.

At All Levels in a Typical Construction Project … there are also pressing education and training needs.  It is of little use if the Project Design Documentation is 100% … and the people actually installing the passive fire protection measures or the active fire protection systems on site don’t know which end is ‘up’ !   The Project Design Documentation, in whatever format, is merely a means to an end … a fully realized and occupied Building, which is fire-safe.

Preferably … we should be discussing the mandatory Re-education and Re-training of Practitioners in the different Disciplines … [CPD (Continuing Professional/Personal Development) is not at all sufficient !] … accompanied by a very necessary Re-engineering of the Stakeholder Professional and Educational Institutions … and other related Organizations, particularly National Authorities Having Jurisdiction (AHJ’s).

Our Best Hope for Transformation … lies with the current crop of third-level undergraduate students in the different disciplines.  And, as we are discovering with the introduction of the Structural EuroCodes in the European Union, it will take perhaps 5-8 years of continuous student output to transform pre-9/11 conventional fire engineering … into a post-9/11 and post-Mumbai fire engineering which is properly ‘reliability-based’ and ‘person-centred’, i.e. Sustainable Fire Engineering !

As for the Future, and Some Conclusions to this Series … coming shortly to a computer monitor screen near you !

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2005 NIST WTC RECOMMENDATIONS

GROUP 8.  Education and Training

The professional skills of building and fire safety professionals should be upgraded through a national education and training effort for fire protection engineers, structural engineers, and architects.  The skills of building regulatory and fire service personnel should also be upgraded to provide sufficient understanding and the necessary skills to conduct the review, inspection, and approval tasks for which they are responsible.

NIST WTC Recommendation 29.

NIST recommends that continuing education curricula be developed, and programmes be implemented for:  (1) training fire protection engineers and architects in structural engineering principles and design;  and (2) training structural engineers, architects, fire protection engineers, and code enforcement officials in modern fire protection principles and technologies, including the fire resisting design of structures;  and (3) training building regulatory and fire service personnel to upgrade their understanding and skills to conduct the review, inspection, and approval tasks for which they are responsible.  The outcome would further the integration of the disciplines in effective fire-safe design of buildings.  Affected Organizations:  AIA, SFPE, ASCE, ASME, AISC, ACI, and state licensing boards.  Model Building Codes:  Detailed criteria and requirements should be incorporated into the model building codes under the topic ‘Design Professional in Responsible Charge’.

NIST WTC Recommendation 30.

NIST recommends that academic, professional short-course, and web-based training materials in the use of computational fire dynamics and thermo-structural analysis tools be developed and delivered to strengthen the base of available technical capabilities and human resources.  Affected Organizations:  AIA, SFPE, ASCE, ASME, AISC, ACI, ICC, and NFPA.

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Concrete Testing Fraud in New York – 1 World Trade Center

2009-09-09

Background & Verification

Early 2008 … a New York Inquiry into the Concrete Testing Industry begins.  At issue is the Structural Reliability of Current Major Public Works Projects in the City, including many Tall Buildings.

Current Internet Search: ‘New York Concrete Testing Inquiry’ … to discover the full measure of fraud and corruption.

I wonder how the U.S. Model Building & Fire Code Organizations … including the U.S. International Code Council … are responding to this growing scandal in New York.   Are they responding at all ?   AND … do they discuss this sort of issue openly, as they heavily ‘promote’ the adoption of U.S. Codes in Developing Countries around the world ?

What is the position of the Council on Tall Buildings & Urban Habitat (CTBUH) ???

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2009-09-08 … by Niki May Young, News Editor, World Architecture News(.com) …

Robert LiMandri, New York’s Buildings Commissioner, has announced that concrete tests are to be carried out on 82 New York buildings following safety concerns arising from the indictment of Testwell Laboratories in January and a further firm in July.  Testwell were accused of falsifying concrete mix design reports for the high profile Freedom Tower Project (now 1 World Trade Center), Yankees Stadium, Jet Blue Terminal and a number of other projects and had their license suspended.  Stallone Testing Laboratories were also indicted for falsifying concrete mix design reports in July.

The indictment of Testwell led to a lack of confidence in the safety of over 100 buildings in New York.  Following investigations, 82 buildings are to be re-examined.  The investigations come as part of an announcement by LiMandri of a new comprehensive program to increase the oversight and evaluation of concrete testing at construction projects throughout the City, including projects funded by the City and private developers.  The program includes plans to build a city-owned and operated concrete-testing laboratory and the creation of a new Concrete Unit at the Department Of Buildings (DOB).

The new City laboratory, which will be operated by the Department of Design & Construction (DDC) and is expected to open as early as January, will offer testing services to all City agencies responsible for construction projects.  New York City has 35 private concrete-testing firms currently licensed to do business in the City and the new facility will also make it possible to audit these firms.

“Concrete testing is a critical component of concrete operations, and the results should affirm the strength and quality of materials used for a building under construction,” said LiMandri.  “However, the integrity of concrete-testing practices has come into serious question, and this new laboratory, as well as a new Concrete Unit and re-testing protocol, are three significant measures to ensure concrete testing procedures are lawful and the concrete used meets a project’s specific design requirements.”

DOB denied Testwell’s application to renew its concrete-testing license but a State Supreme Court Judge rejected DOB’s denial of the license renewal.  DOB is now appealing that decision.  Last Friday, DOB revoked Stallone’s concrete-testing license, prohibiting them from testing concrete in the City.  The Department Of Buildings is currently working with property owners named in the Stallone indictment to determine whether a project’s final test results meet the structural design requirements.  If they do not, the affected property owners will also be required to follow the re-testing protocol.

“New Yorkers must be confident the City’s buildings have been built to exacting standards and that the concrete, not usually visible, was mixed to proper construction specifications,” added Design and Construction Commissioner Burney.

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