Ar C.J. Walsh – Registered Architect, Fire Engineer & Independent Technical Controller …… International Expert on Accessibility for All (including Fire Safety) + 'Real' Sustainability Implementation !
2020-09-22: Adopted at the International Fire Conference: SFE 2016 DUBLIN (www.sfe-fire.eu) …
Many years have passed since the 1972 UN Stockholm Declaration on the Human Environment and the 1992 Rio Declaration on Environment and Development. In 2016, Sustainable Development remains an intricate, open, dynamic and continually evolving concept. The guide and driver for frontline practitioners, policy and decision makers must be a personal Code of Ethics … an integrated and inter-related whole which cannot be reduced to fixed rules inviting game playing and ‘trade-offs’. After working with this Code, it may be necessary to expand on and discuss its principles and/or some of the issues raised … not to narrow its focus, but to broaden interpretation.
The realization of a Safe, Inclusive, Resilient & Sustainable Built Environment demands a concerted, collaborative, very creative and widely trans-disciplinary effort at national, local, regional and international levels across the whole planet – Our Common Home. The informed operation of appropriate legislation, administrative procedures, performance monitoring and targeting, and incentives/disincentives, at all of these levels, will facilitate initial progress towards this objective … but not the quantity, quality or speed of progress necessary. Our time is running out !
This Code of Ethics applies … for those who subscribe to its values … to policy and decision makers, and the many different individuals and organizations directly and indirectly involved in the design, engineering, construction, and operation (management and maintenance) of a Safe, Resilient & Sustainable Built Environment for ALL.
The Purpose of this Code of Ethics is to guide the work of competent individuals and organizations in a context where incomplete or inadequate legislation, administrative procedures and incentives/disincentives exist … but, more importantly, where they do not exist at all … and, amid much confusion and obfuscation of the terms, to ensure that implementation is authentically ‘sustainable’, and reliably ‘safe’ and ‘resilient’ for every person in the receiving community, society or culture … before it is too late !
Update 2020-09-01: Although the term ‘Vulnerable People’ remains unaltered, I considered it wise, and very necessary bearing in mind the obvious myopia in the mainstream health, safety and design worlds … clearly demonstrated by the 2017 Grenfell Tower Fire in England, and this current CoronaVirus / CoVID-19 Global Pandemic … to include references to specific social groups …
Vulnerable People: Those people – in a community, society or culture – who are most at risk of being physically, psychologically or sociologically wounded, hurt, damaged, injured, or killed … and include, for example, people with disabilities, young children, people with health conditions, frail older people, women in late pregnancy, refugees, migrants, prisoners, the poor, and homeless.
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2020-07-20: So many diverse design disciplines and interested groups are involved in the realization, operation and maintenance of a Safe, Inclusive, Resilient and Sustainable Human Environment (built, social, economic, virtual, and institutional) … that the use of simple, easily assimilated language and precise, harmonized technical terminology must be widely exercised. For the effective application of Building Information Modelling (BIM), this is particularly important.
And concerning Fire Engineering, it is not clear when the practice began, but defining a concept simply in terms of performance in a ‘standard test fire’ is entirely inadequate, and fails to explain the actual meaning of the concept.
This Terminology … a body of particular terms, each explaining and defining a single concept, covering inter-related building requirements, e.g. human health, accessibility and fire safety for all, firefighting, social rights, design, performance monitoring, and facility management … takes account of:
Sustainability Impact Assessment (SIA)
WHO International Classification of Functioning, Disability and Health (ICF)
Universal Declaration of Human Rights (UDHR)
U.N. Convention on the Rights of Persons with Disabilities (CRPD)
Environmental Impact.
Fire Engineering Terms … take account of the ‘realistic’ end condition, i.e. a real fire in a real building which is occupied or used by real people with varying behaviour and abilities in relation to self-protection, independent evacuation to an external place of safety remote from a fire building, and active participation in a building’s Fire Emergency Management Plan.
General Terms … are also included in order to facilitate a better understanding of:
the complexity of human behaviour and perception (visual, auditory, olfactory, gustatory, tactile and proprioceptive) ;
the wide range of health conditions ; and, more specifically
Within the professional discipline of Fire Engineering … either a building is Fire Safe, or it is not ; the design philosophy of the Fire Engineer is irrelevant. Similarly, building designers must now begin to think and act in the simple terms of a building being either Accessible, or not. Too many pointless discussions, and too much petty squabbling, about constrained and constraining accessibility philosophies have wasted valuable time, energy and resources.
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Colour photograph showing a typical, everyday scene in countries all over the world … a young person in a manual wheelchair, independently attempting to mount an external flight of steps in front of a building entrance. . Reality Check: A Universal, Dismally Inaccessible Built Environment ! . Click image to enlarge.
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Building Accessibility encompasses the complete cycle of Independent Use, in a dignified manner and on an equal basis with others … and includes the approach, entry and use of a building, its facilities and information systems … Egress during normal / ambient conditions and removal from the vicinity of the building … and most importantly, safe Evacuation during a fire emergency to a Place of Safety which is remote from the building and reached by way of an accessible route.
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Colour image illustrating the difference between Equality and Equity. Everybody is equal, and must be treated equally … but the measures necessary to achieve this in real life must, in many cases, be equitable. . Human Ability and Behaviour is a continuum … a gentle gradient on which every person functions and acts at different levels due to Environmental and Personal Factors. . Click image to enlarge.
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To be Accessible, a building must meet a long and complex list of inter-related Accessibility & Usability Design Criteria sufficiently well, i.e. the building must work properly for building occupants and users. The design target is Effective Accessibility … not half-baked accessibility, partial accessibility, the minimal accessibility required by building codes, or token accessibility.
On the other hand, and taking additional account of the current CoronaVirus / CoVID-19 Pandemic … the construction and operation target must be Successful Implementation, i.e. the finished building design, as constructed and operated, must provide a consistently high degree of safety, convenience and comfort for potential occupants and users during the lifetime of the building.
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Colour photograph showing the post-fire scene of a devastated Lift Lobby with an abandoned Manual Wheelchair. 25 people died and 123 were injured in a Jazan Hospital Fire, Saudi Arabia, which occurred on 24 December 2015. The fire broke out in the hospital’s Intensive Care Unit and Maternity Ward. Click photograph to enlarge.
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People with Activity Limitations … those people, of all ages, who are unable to perform, independently and without assistance, basic human activities or tasks – because of a health condition or physical / mental / cognitive / psychological impairment of a permanent or temporary nature … are a significant vulnerable group in every community, in every society, and include people with disabilities, children under the age of 5 years, frail older people, women in the later stages of pregnancy, and people with health conditions, etc.
Fire Safety Codes and Standards for healthy, able-bodied, agile adults using buildings exist in almost every country ; these people can take for granted that buildings are fire safe for them !
However, guidelines concerning Fire Safety for People with Activity Limitations / Fire Safety for ALL (if those guidelines exist at all) are usually technically inadequate, entirely tokenistic and/or blatantly discriminatory ; these people must assume that there is a serious risk to their safety every time they enter a building. For them, this is a very significant barrier to their personal development, participation and social inclusion ; it is a clear and present violation of their human rights !
Forcefully mandated in the United Nations Convention on the Rights of Persons with Disabilities, adopted on 13 December 2006 … the UN CRPD’s Principal Aim is to ensure that the Human Environment (social, built, economic, virtual, and institutional) is sufficiently accessible to facilitate the safe exercise and enjoyment of those rights, protections and freedoms set down in the 1948 Universal Declaration of Human Rights (UDHR), and subsequent International Rights Instruments, by a vulnerable and major section of the population in all of our communities.
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Colour photograph showing the scene of a raging fire in London, on 14 June 2017. 72 people died and many more were injured in this 24 Storey, 120 Apartment Residential Building. Vulnerable People, including people with activity limitations, refugees, and immigrants with a poor grasp of the English language lived at various heights throughout the Tower. . A serious design flaw in this building (among many, many others), i.e. a lack of Effective Accessibility … only one narrow, atrociously detailed staircase serving the entire building, lifts/elevators which were useless in a fire emergency, and no areas of rescue assistance adjoining the staircase … had a profoundly negative impact on Firefighter Operations and Safety on the night of 14 June and the following day. . Click photograph to enlarge.
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It is time to Entirely Eradicate current obsolete, professionally negligent, incompetent and ridiculous approaches to Building Design which result in …
Fire Safety for SOME but not for ALL
Accessibility for SOME but not for ALL
Intricately inter-related … ‘Fire Safety for All’ is a vital component of ‘Accessibility for All’.
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Colour image / Presentation overhead showing how building designers face a critical choice in everyday practice … Legal or Ethical … Beyond Codes ?!?!? . Legal Compliance is Never Enough. . Click image to enlarge.
2020-04-28: A look back at a Benchmark Document, and an Introduction written nearly 16 years ago. So many years, so much valuable time has been wasted …
The words ‘green’, ‘environmental’, ‘ecological’ and ‘sustainable’ are becoming part of everyday language in the Developed World, but are frequently interchanged without understanding. To date, however, the concept of Sustainable Development has been hijacked by Environmentalists. For example, no connection at all may be seen between a ‘sustainable’ building and ensuring that it can be safely and conveniently entered and used by ordinary people.
In other parts of the World, the ambiguous WCED / Brundtland Definition of Sustainable Development is being systematically rejected ; the concept is viewed as an unaffordable luxury and/or as a means of continued domination and control by the ‘North’. Yet, sustainability must be a global compact.
In this intolerant and more fundamentalist 21st Century, the United Nations System, International Law, and Social Justice continue to come under sustained attack. And the Beslan School Tragedy* demonstrates that it is far more hazardous for disadvantaged, vulnerable and indigenous peoples in every society.
Some specific objectives for the 2004 Rio Declaration were as follows …
To present a 2nd Generation Definition of Sustainable Development which is more acceptable to the Developing World ;
To restore primacy to the Social Aspects of Sustainable Development … and particularly the ethical values of Social Justice, Solidarity and Inclusion-for-All ;
To embed the concept of the ‘Person’ in Sustainable Development … rather than the fleeting reference to ‘People’ which too often results in Disadvantaged, Vulnerable and Indigenous Groups being left behind ;
To signal one of the main challenges of Sustainable Development ahead – which will be to establish a framework of horizontal co-ordination at the many institutional levels … and between the many actors and end users … in the human environment.
Adopted in December 2004, at the Brazil Designing for the 21st Century III Conference, the Rio Declaration consists of a Preamble, 10 Principles and 5 Appendices ; its central concern involves People with Activity Limitations (2001 WHO ICF).
This Declaration extols implementation, and the targeting and monitoring of ‘real’ performance – as opposed to ‘imagined’ or ‘paper’ performance.
2020-03-24: Established relatively recently, in 2015 … the Lafcadio Hearn Japanese Gardens are located in Tramore, County Waterford, in the south-east of Ireland. Who Patrick Lafcadio Hearn (1850-1904) was, his Irish heritage, his historical links with Japan, and the layout of the Irish Gardens … can all be found at: http://lafcadiohearngardens.com/
Some special Sights & Sounds from a Visit to the Japanese Gardens on 13 March 2020 …
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Lefcadio Hearn. Photograph by CJ Walsh. 2020-03-13. Click to enlarge.
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The Greek Garden. Photograph by CJ Walsh. 2020-03-13. Click to enlarge.
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Arrival in Japan … looking towards the Tea House. Photograph by CJ Walsh. 2020-03-13. Click to enlarge.
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Path to the low crawl door entrance at the side of the Tea House. Photograph by CJ Walsh. 2020-03-13. Click to enlarge.
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View from the Azumaya (Summer Pavilion). Photograph by CJ Walsh. 2020-03-13. Click to enlarge.
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Zen Garden. Photograph by CJ Walsh. 2020-03-13. Click to enlarge.
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Garden of Peace and Harmony. Photograph by CJ Walsh. 2020-03-13. Click to enlarge.
2020-03-23: The Grenfell Fire Inquiry’s Phase 1 Recommendations (Part V in Volume 4 of the Phase 1 Report), were published on 30 October 2019. The initial issues covered in those Recommendations are fragmentary, lack depth and coherence … and in the case of Fire Alarms, with just one indirect reference to them in Paragraph #33.22 … they are in serious error …
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Colour image showing the Volume 4 Cover Page of the Grenfell Tower Inquiry Phase 1 Report. The Phase 1 Recommendations are contained in Chapter #33, on Pages 771-780. Click to enlarge.
[ Paragraph #33.22 ] There were no plans in place for evacuating Grenfell Tower should the need arise. I therefore recommend:
d. that all high-rise residential buildings (both those already in existence and those built in the future) be equipped with facilities for use by the fire and rescue services enabling them to send an evacuation signal to the whole or a selected part of the building by means of sounders or similar devices ;
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FUNDAMENTALS OF A SOLUTION
1. A Fire Alarm (more precisely from here on, a Fire Detection & Warning System) is a critical safety feature in all buildings … ALL BUILDINGS … from the smallest and most simple, to the biggest and most complex … no exceptions !!
In order to survive in a fire emergency, Vulnerable Building Users need more time to react, and evacuate, than other occupants/users. The valuable time provided by early, accurate and precise detection is the only way to effectively facilitate this. The ‘Required Time’ to prepare for evacuation depends on many factors, e.g. building complexity, familiarity of users with evacuation routes, range and severity of user activity limitations, etc.
It follows, therefore, that if building occupants/users have to wait 15, or 20, or 30 minutes before firefighters arrive at the fire scene (Full Response Time*) and ‘an evacuation signal to the whole or a selected part of the building’ is only then sent by those firefighters … all of that valuable evacuation time for vulnerable building users has been lost. This is ridiculous, and makes no sense whatsoever. This Recommendation must be rejected out of hand, and ignored !
[ *Full Response Time: The time interval from the receipt of an emergency communication at the primary public safety answering point (#PSAP) to when emergency response units are initiating action or intervening to control a fire incident. ]
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Colour photograph showing the Single, Narrow Staircase (1.040 metres in width between a handrail on one side of the staircase and a bare wall on the other side) in London’s Grenfell Residential Tower. This staircase, which was inadequately protected from fire, heat and smoke, was not wide enough to facilitate the ‘contraflow’ circulation of firefighters entering, while occupants evacuated at the same time. Without a Fire Alarm in the building, occupants could not have known that a serious Fire Emergency was in progress … especially Vulnerable Building Users accommodated high up in the Tower … and they remained in place (‘stayed put’). Once firefighters arrived at the scene, occupant evacuation using this staircase became impossible or extremely difficult. Click photograph to enlarge.
Important Note: In Chapter #34: ‘Looking Ahead to Phase 2’ of Moore-Bick’s Phase 1 Report, Volume 4 … Paragraph #34.14 states …
A question was raised about the width of the stairs, given that they provided the sole means of access to the upper floors of the tower for firefighters as well as the sole means of escape for the occupants. However, the stairs appear to have complied with requirements of the legislation in force at the time of their construction and the expert evidence supports the conclusion that they had sufficient capacity to enable all the occupants of the building to escape within a reasonable time. This aspect of the building will not, therefore, be the subject of further investigation in Phase 2.’
Astounding ! Absurd !! FUBAR !!!
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All Fire Emergency Warning Systems must be designed to accommodate People with Hearing Impairments. Audible and visual warning devices must be provided together, as a single combined unit. This is particularly important in noisy and isolated building spaces, e.g. bathrooms, small meeting rooms. Vibrating devices, such as pagers or mobile phones, can be integrated into a building’s fire emergency warning system in order to provide any individual with a tactile emergency alert.
Colour photograph showing a single combined visual-audible Fire Emergency Warning Device. Click to enlarge.
Important Note: Audible sounders, on their own, are never a sufficient Fire Emergency Warning !
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2. The Purpose of a Fire Emergency Warning System is to provoke calm, efficient and adaptable evacuation movement by ALL building users/occupants at the earliest possible stage in a fire incident, without causing user confusion, disorientation or panic. In all building types, therefore, a reliable, informative and accessible fire emergency warning system must be installed, and such a system must always have a fire protected electrical supply.
Colour image showing the movement of building occupants and users. The purpose of a Fire Emergency Warning System is to provoke calm, efficient and adaptable evacuation movement by ALL building occupants at the earliest possible stage in a fire incident, without causing user confusion, disorientation or panic. During a Fire Emergency, STANDARD MOVEMENT TIMES DO NOT EXIST. Click image to enlarge.
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3. To provoke a Calm Response from Building Users … the output from Fire Emergency Warning Devices, e.g. light, sound and messages, must be adapted to the local context of people and building surroundings.
Fire Emergency Audible Warnings … A sufficient number of low-output audible sounders, i.e. between 60-80 dB, must be specified for effectiveness. Small numbers of sounders with high output (in order to reduce costs) should never be specified, as this can lead to confusion, disorientation and panic attacks among some building users/occupants. The output of sounders must be adapted to suit interior surroundings, e.g. in small spaces with hard surfaces a lower sound output will be adequate.
Colour image. The output from Fire Emergency Audible Sounders must be between 60-80 dB. Click image to enlarge.
Important Note: When they are asleep, hearing-able children (around ten years of age and under) … and hearing-able older people (around 65 years of age and over) are more difficult to wake and rouse sufficiently for evacuation when alerted by an audible signal alone.
Fire Emergency Visual Warnings … Light strobes/beacons must be clearly visible. To reinforce #1 above … light strobes/beacons must be placed in wash rooms and in other locations within buildings where people may be alone ; they must also be placed in noisy environments.
A sufficient number of low-output strobes/beacons must be specified for effectiveness. Small numbers of strobes/beacons with high output (in order to reduce costs) should never be specified, as these produce a glare which may cause confusion, disorientation and panic attacks among some building users/occupants. The light output of strobes/beacons must be adapted to suit interior surroundings, e.g. in dark rooms.
For light strobes/beacons, a slow rate of flash is important, i.e. no faster than once every two or three seconds, in order to encourage a calm response from building users/occupants and to avoid photosensitivity seizures. Most importantly, the flash of one strobe/beacon must be synchronized with the flashes of all other light strobes/beacons in view.
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Colour video clip (.gif). The output from Fire Emergency Visual Strobes / Beacons must be no faster than one flash every two or three seconds. The flash rate shown above is too fast ! Click to run video clip.
Fire Emergency Voice Message Warnings … Are essential to improve Warning Credibility. In other words, building users are far less likely to sit around wondering, waiting to see whether this is a ‘real’ fire emergency, a false alarm, a practice evacuation, or an electrical error. Verbal or voice messages must be short and contain appropriate warning information which is easily assimilated. The speaker should be distinct and easy to understand. Live messaging during a fire emergency is preferred over pre-recorded, standard messages. In today’s multi-cultural social environment, messages must be transmitted in at least two to three different languages, as appropriate.
Fire Emergency Directional Warnings … Combination sounder, visible strobe/beacon, and voice messaging Fire Emergency Warning Devices are now a mainstream technology, are readily available, and are being specified in new and existing buildings.
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Colour image showing a combination Fire Emergency Directional Audible Sounder, with Voice Messaging capability. Click image to enlarge.
Audible directional signalling must be installed when dealing with difficult building configurations, e.g. in large open office layouts/spaces with minimal signage … where building users/occupants are unfamiliar with their surroundings in modern shopping centres/malls and other complex building types … or visibility of high-level signage may be reduced because of smoke logging.
Directional sounders, which guide building users during a Fire Evacuation towards Exits, Areas of Rescue Assistance and Lift/Elevator Lobbies, must be positioned at carefully chosen, suitable locations. Once reached, a directional sounder must also have a voice messaging capability in order to inform people about the next phase of evacuation.
4. Fire Emergency Warning Systems must be Accessible (for People with Activity Limitations), i.e. capable of transmitting a warning in many formats in order to ensure that all users/occupants perceive and act upon the warning in a calm manner and, thereafter, that effective evacuation movement commences without delay. Warning Credibility improves in direct relation to the type and number of different warning formats.
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As well as indirectly referring to Fire Detection and Warning Systems, Paragraph #33.22 in Moore-Bick’s Phase 1 Recommendations has some other things to say about Evacuation. So this is an opportune moment to discuss some practical and human issues concerning Fire Emergency Evacuation … and, straight away, to deal with an unexpected consequence arising from the current CoronaVirus/CoVID-19 Emergency …
CoronaVIRUS / CoVID-19 PANDEMIC
There have been widely reported instances, in many countries, of panic buying in shops because of the 2020 CoronaVirus/CoVID-19 Emergency … but the photograph below illustrates an example of a panic reaction by building management. This appears to be a crime scene … the yellow and black tape is so dramatic. In a real Fire Emergency, many building users/occupants will be reluctant to use this final fire exit ; they will not have the time to read the small print on a notice ; they will attempt to re-trace their path of evacuation and find another exit.
Colour photographs showing how, as a panic reaction to the 2020 CoronaVirus/CoVID-19 Emergency, a Final Fire Exit has been blocked off from normal, everyday use. Click to enlarge.
This panic reaction by building management IS a serious impediment to Fire Evacuation !
Whatever the Motives of Building Management …
in countries which have Fire Codes / Regulations, this action is illegal ; and
in these days, when a wide range of ‘smart’ technologies is readily available … this action is inexcusable.
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SOME PRACTICAL FIRE EVACUATION ISSUES
A Skill is the ability of a person, resulting from competent training and regular practice, to carry out complex, well-organized patterns of behaviour efficiently and adaptively, in order to achieve some end or goal. All building occupants/users must be skilled for evacuation to an external ‘place of safety’, which is at a safe and remote distance from the fire building. Practice fire evacuations must be carried out sufficiently often to equip building users, particularly vulnerable users, with this skill, i.e. at least once every six months ; in complex building types, practices should be carried out more often. Prior notification to occupants/users, and regular scheduling of practice evacuations should be avoided.
Familiarity with Fire Evacuation Routes will be fostered and greatly improved by means of normal, everyday use by occupants/users. This is an important task for pro-active Building Management in existing buildings … and an important aspect of new building design for Architects and Fire Engineers.
While the transmission of fire emergency warnings in many formats will increase Warning Credibility, close observation of past tragic ‘real’ fire events, e.g. the WTC 9-11 Attacks in New York City, shows that initiation of evacuation and the actual process of evacuation itself can be problematic. An interesting, easily assimilated and user-targeted skills programme of training should incorporate practical solutions to deal with the following typical problems:
Fire Emergency Preparedness: Irregular attendance of building occupants/users at fire prevention and safety training sessions, and participation in practice fire evacuations. Users not being familiar with a building’s fire emergency management plan and not knowing who is in charge … not using a building’s fire evacuation route(s), particularly staircases, during practices … or having no information about where to assemble after evacuating … or, once at a place of safety, not having any head count or identification process ;
Delaying Activities Inside The Fire Building: Once building occupants/users decide to evacuate, but before moving to evacuate, they gather personal effects … seek out friends/co-workers … search for others … make phone calls/send tweets … finish tasks/turn off computers … wait around for instructions … change shoes … and try to obtain permission to leave ;
Delaying Activities Outside The Fire Building: Once outside the building’s final fire exit, but before moving directly to a place of safety, building occupants/users stop to see what is happening … look for friends/co-workers … look for a phone … do not know where to go … or, within the ‘danger zone’ of the fire building, stop to receive medical attention.
It may seem obvious that Fire Evacuation Routes must also be Accessible (for People with Activity Limitations), which also makes routes much safer for every other building user … and sufficiently wide to accommodate Contraflow (emergency access by firefighters or rescue teams into a building and towards a real fire, while building users are still moving away from the fire and evacuating the building) … a harsh lesson learned from the 2001 WTC 9-11 Attacks and the 2017 Grenfell Tower Fire. Since they are new, strange and unusual for many building designers, and most fire engineers … these aspects of building performance are overlooked in nearly every building.
Practice Evacuations should include exercise of the buddy system ; fire safety fittings, e.g. portable fire extinguishers ; and fire evacuation devices intended for use by people with activity limitations which will require more intensive training.
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Colour image showing a range of personal Facilitation / Mobility Aids. People with Activity Limitations must be allowed, and positively encouraged, to keep these Aids during practice and real fire evacuations. Prior meaningful consultation (see below) is essential. Click to enlarge.
Important Note: During fire emergencies, People with Activity Limitations must be permitted to keep possession of their own personal Facilitation / Mobility Aids.
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SOME HUMAN FIRE EVACUATION ISSUES
The actual people who use and occupy buildings are individuals. They are different from each other, and they each have a different range of abilities (in relation to self-protection, independent evacuation to an external place of safety remote from a fire building, and active participation in a building’s fire emergency management plan), behaviour and manner of perceiving their surroundings. Two apparently similar people will also show variations in how they react to and behave in any specific situation, particularly a fire emergency.
Ability / Disability is a Continuum – a gentle gradient on which every person functions and acts at different levels due to personal and environmental, i.e. external, factors.
In situations of severe stress, e.g. during a fire emergency in a building, where there is a lack of preparedness for such an event, a lack of familiarity with evacuation routes, lack of reliable evacuation information, lack of competent leadership and clear direction, and the presence of smoke, user/occupant confusion, disorientation and panic will occur. Standard evacuation movement times will also be non-existent. In addition, people with activity limitations must then deal with many physical barriers which routinely impede their evacuation from buildings, e.g. fire resisting doorsets which are difficult to open, steps along evacuation routes and at final fire exits.
In the case of people with a mental or cognitive impairment, there is a particular need to encourage, foster and regularly practice the adaptive thinking which will be necessary during evacuation a real fire incident.
People with respiratory health conditions will not be able to enter or pass through smoke. People with visual impairments will require continuous, linked tactile and/or voice information during the whole process of fire evacuation. People with psychological impairments, i.e. vertigo and agoraphobia, will be unable to use fire evacuation staircases with glass walls in high-rise buildings. Because of the stigma still associated with disability in many countries, some users/occupants who will need assistance during a fire emergency will be reluctant to self-identify beforehand. Other people may not even be able to recognize that they have an activity limitation or a health condition.
Meaningful Consultation with a person known to occupy or use a building, for the purposes of receiving his/her active co-operation and informed consent (involving a personal representative, if necessary), is an essential component of adequate pre-planning and preparation for a fire emergency.
Building Designers, Fire Engineers and Firefighters should be aware of the following human conditions:
Agoraphobia: A fear of open spaces.
Commentary: Agoraphobia is one of the most commonly cited phobic disorders of people seeking psychiatric or psychological treatment. It has a variety of manifestations, e.g. a deep fear of leaving a building, or of being caught alone in some public place. When placed in threatening situations, agoraphobics may experience a panic attack.
Anosognosia: A neurological disorder marked by the inability of a person to recognize that he/she has an activity limitation or a health condition.
Dementia: Any degenerative loss of intellectual capacity, to the extent that normal and occupational activities can no longer be carried out.
Panic: A sudden overwhelming feeling of anxiety, which may be of momentary or prolonged duration.
Panic Attack: A momentary period of intense fear or discomfort, accompanied by various symptoms which may include shortness of breath, dizziness, palpitations, trembling, sweating, nausea, and often a fear by a person that he/she is going mad.
2019-11-11:Kensington and Chelsea’s wilful disdain for the Health, Safety and Welfare of ALL the residents within its functional area … and knowing neglect of its legal and ethical Duty of Care towards ALL … resulted in a significant number of people with activity limitations living high up in Grenfell Tower prior to June 2017 … in spite of the now incontrovertible fact that, in the event of a fire emergency, many would be left behind … to die.
‘All human beings are born free and equal in dignity and rights.’
Article 1, 1948 Universal Declaration of Human Rights
Colour photograph showing a Firefighter watching the horrific fatal fire scene at Grenfell Tower in London, on 14 June 2017, from a nearby balcony. Click to enlarge.
London Fire Brigade was an easy target for the Grenfell Fire Inquiry’s Phase 1 Report, made all the more so following some careless, insensitive and ignorant public comments by its Commissioner, Dany Cotton. However, we must clearly distinguish between the behaviour of LFB’s Frontline Firefighters, who were brave and dedicated despite inadequate training, and lack of proper equipment, back-up resources and personnel strength … and LFB’s Senior Commanders … which is another matter.
Colour photograph showing the London Fire Brigade (LFB) Commissioner, Dany Cotton. In order to ensure that transformation of the LFB actually takes place in the short term, and is fully effective, Dany Cotton and all of her Senior Commanders must resign now, or be fired ! Click to enlarge.
In England … there is widespread indifference, and some rabid resistance, to answering the desperate needs, and mitigating the agonizing plight, of Vulnerable Building Users during fire emergencies … which includes people with activity limitations, children under 5 years of age, frail older people (not All older people !), women in late stage pregnancy, people with disabilities, refugees, migrants, the poor, and people who do not understand the local culture or cannot speak the local language. British National Standard B.S.9999 (not solely those sections previously contained in B.S.5588:Part 8) and England’s National Building Regulations – Approved Document B: ‘Fire Safety’ – offer only token, i.e. inadequate, protection for vulnerable people in fire emergencies. When a senior representative of BSI, the British Standards Institution, was directly approached by me, and requested to open up B.S.9999 for meaningful updating … the answer was a firm “NO” ! The same attitude is deep-seated among fire research organizations in the country, and among people who develop computer fire evacuation models.
Presentation Overhead, in colour, showing the ‘Fire Safety for All’ Matrix, which outlines the scope of its application in the Human Environment and the different social groups to be targeted. Balanced consideration must be given to people who use wheelchairs (physical function impairment) … and to people with visual, hearing, psychological, and mental/cognitive impairments … and to other vulnerable building users, e.g. people with health conditions. Click to enlarge. Matrix developed by CJ Walsh.Presentation Overhead showing the definition of ‘people with activity limitations’, with its equivalent French translation … also showing from where this term is derived … and who this term includes. During a fire emergency, confused and/or confusing disability-related language costs lives ! Click to enlarge.
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Grenfell Fire Inquiry’s Phase 1 Recommendations – Chapter #33
After hearing the first media reports about the tough Recommendations aimed at London Fire Brigade, I had naturally expected that the other Phase 1 Recommendations would be equally as tough. But NO … they are far from comprehensive … they are fragmentary, lack depth and any sort of coherence. Specifically with regard to Vulnerable Building Users, the Recommendations are pathetically and disgracefully inadequate !
And in case there is any doubt, the status quo in England – and to be fair, in many other countries as well – is entirely unacceptable !!
Few people realize that the fire safety objectives in current fire regulations/codes are limited and constrained. To implement changes to the flawed regulations in England, it will take many years … and, based on recent past history, implementation will be incomplete and unsatisfactory. Residents in high-rise buildings, whether public or private, must no longer wait in vain for this to happen. Instead, the time has arrived to become proactive, and to immediately initiate their own comprehensive programmes of Self-Protection In Case Of Fire … which go far and beyond the pathetic Recommendations in Moore-Bick’s Phase 1 Report.
Fires Similar To Grenfell Tower Are Frequent
[ Paragraph #33.5 ] … although not unprecedented, fires of the kind that occurred at Grenfell Tower are rare.
[ Response ] Not true … misleading, and a complete fallacy !
Just since 2010, fires similar to Grenfell Tower have occurred in South Korea, many in the United Arab Emirates, France, Chechnya, Australia, Azerbaijan, Russia, and most recently in Turkey. Each one of these fires has been recorded and illustrated on our Twitter Account: @sfe2016dublin. Seeing, and understanding, this striking pattern of unusual fire behaviour … a competent person would react and plan accordingly.
Effective Fire Compartmentation Is A Delusion … A Fantasy !
[ Paragraph #33.5 ] Effective compartmentation is likely to remain at the heart of fire safety strategy and will probably continue to provide a safe basis for responding to the vast majority of fires in high-rise buildings.
[ Response ] Not true … demonstrates a fundamental flaw in European fire safety strategizing !
In an environment of lax or non-existent compliance monitoring … the quality of architectural/fire engineering design and the reliability of related-construction will both, inevitably, be poor and unacceptable. Fire loads in today’s residential buildings are also far higher than a generation ago, for example, because of more electrical/electronic equipment and synthetic furnishings. And whatever about first-built, i.e. whether it’s good, bad or ugly, later alterations and other construction work will typically compromise the original performance of fire resisting doorsets and service penetration fire sealing. Modern ‘green’ building materials and construction methods are further aggravating these problems. A competent person would be aware of fire research at the UL Laboratories, in the U.S.A., which confirmed the above developments.
‘ Rigorous enforcement of building codes and standards by state and local agencies, well trained and managed, is critical in order for standards and codes to ensure the expected level of safety. Unless they are complied with, the best codes and standards cannot protect occupants, emergency responders, or buildings.’
U.S. National Institute of Standards and Technology. Final Report on the Collapse of the World Trade Center Towers. NIST NCSTAR 1. 2005.
‘Stay Put’ Policies Are Criminal
[ Paragraph #33.5 ] However, in the case of some high-rise buildings it will be necessary for building owners and fire and rescue services to provide a greater range of responses, including full or partial evacuation. Appropriate steps must therefore be taken to enable alternative evacuation strategies to be implemented effectively.
[ Paragraph #33.15 ]e. that policies be developed for managing a transition from ‘stay put’ to ‘get out’ ;
[ Response ] Too little … and far too late !
[ Solution ] Two fatal fires separated in time and space … the 2009 Lakanal House Fire, in London, and the 2017 Marco Polo High-Rise Apartment Building Fire, in Honolulu, continue to clearly demonstrate that effective fire compartmentation is a delusion. Even if carried out by a competent person … it is not possible to establish with reasonable certainty, by means of a visual/surface building inspection alone, whether or not fire compartmentation is effective in an existing building. The London and Honolulu buildings were not fitted with any active fire suppression system, e.g. fire sprinklers or a water mist system.
Buildings must remain structurally ‘serviceable’, not merely structurally ‘stable’, for a Required Period of Time. See the Presentation Overhead below.
Presentation Overhead, in colour, explaining the concept of ‘Structural Reliability’ in fire conditions … and defining ‘Required Period of Time’, during which a building must remain serviceable. Click to enlarge.
Authorities Having Jurisdiction (AHJ’s), firefighters, client organizations, design teams, and building owners/managers must not, therefore, direct, or even suggest, that any of its building users wait (‘stay put’) in that building during a fire emergency. A competent person always connects building fire performance with its structural performance, and vice versa … and always learns from the evidence of ‘real’ fatal fires.
All Lifts/Elevators Must Be Used For Fire Evacuation
[ Paragraph #33.13 ] When the firefighters attended the fire at Grenfell Tower they were unable to operate the mechanism that should have allowed them to take control of the lifts. Why that was so is not yet known, but it meant that they were unable to make use of the lifts in carrying out firefighting and search and rescue operations. It also meant that the occupants of the tower were able to make use of the lifts in trying to escape, in some cases with fatal consequences.
[ Response ] There is a ridiculous assumption in Moore-Bick’s Phase 1 Report that it is only firefighters who use lifts/elevators during a fire emergency, and that it is dangerous for anybody else to use them.
[ Solution ] In order to adequately protect Vulnerable Building Users … ALL lifts/elevators in a building must be capable of being used for fire evacuation during a fire emergency.
Until such time as firefighters arrive at a building fire scene in sufficient strength and are properly prepared to carry out effective firefighting and rescue operations … Firefighter Lifts/Elevators must be used for the fire evacuation of building occupants/users. Prior liaison and pre-planning with local fire services is always necessary with regard to the use of firefighting lifts/elevators for the evacuation of occupants/users.
Colour photograph showing a typical sign outside most lifts/elevators around the world … ‘In The Event of Fire, Do Not Use Lift’. This is a pre-historic dinosaur of a policy which places Vulnerable Buildings Users in immediate and very serious danger during a fire emergency. Click to enlarge.
A fundamental principle of fire safety design is that there must be alternative, safe and accessible evacuation routes away from the scene of a fire, which can occur in any part of a building during its life cycle ; these evacuation routes must be capable of being used by all building users, including people with activity limitations.
This is why there must always be at least 2 Fire Evacuation Staircases in High-Rise Residential Buildings !
The location of lifts/elevators and lobbies, within peripheral building cores, must always be considered in relation to the position of adjacent fire protected evacuation staircases, which must be easily found by building occupants/users, and the areas of rescue assistance adjoining those staircases.
To be used for fire evacuation, a lift/elevator must be ‘fit for its intended use’, must operate reliably during a fire emergency, and must comprise a complete building assembly which meets specific performance criteria.
A Lift/Elevator Fire Evacuation Assembly is an essential aggregation of building components arranged together – comprising a lift/elevator, its operating machinery, a hard-construction vertical shaft enclosure, and on every floor served by the lift/elevator a sufficiently large, constantly monitored lobby for people to wait in safety and with confidence, all robustly and reliably protected from heat, smoke, flame and structural collapse during and after a fire – for the purpose of facilitating the safe evacuation of building occupants/users throughout the duration of a fire emergency.
If a building is located in a Seismic Zone, Lift/Elevator Fire Evacuation Assemblies which can safely operate during an earthquake must always be specified and installed.
Gravity Evacuation Chair Devices, which are not electrically-powered and operate by gravity, facilitate downward movement, only, on straight flights of stairs. Having descended a staircase, with the user having left his/her wheelchair behind, these devices are not fully stable when travelling the long horizontal distances necessary to reach an external ‘place of safety’ remote from a building, perhaps over rough terrain.
Colour photograph showing a Gravity Evacuation Chair and how it is used during a fire emergency. Click to enlarge.
If lifts/elevators in existing buildings undergo a major overhaul, or if they are replaced, they should then be made capable of use for fire evacuation.
Lifts/elevators used for fire evacuation must always have a fire protected electrical supply which is separate from the main building electrical supply, in order to ensure that they can continue to operate without interruption during a fire emergency.
In addition to conventional passive fire protection measures, Lift/Elevator Lobbies must also be protected by an active fire suppression system. Water mist is the preferred fire suppression medium, because it is user-friendly, will not greatly interfere with user visibility, uses far less water compared to water sprinklers, and is also climate-friendly. Furthermore, because people with activity limitations will be waiting for evacuation in lift/elevator lobbies, building designers and managers must ensure that these lobbies are properly fitted out with appropriate fire safety equipment, facilitation aids, smoke hoods, signage and communications, etc., etc.
Proper Use of Personal Emergency Evacuation Plans (PEEP’s)
[ Paragraph #33.22 ]f. that the owner and manager of every high-rise residential building be required by law to include up-to-date information about persons with reduced mobility and their associated PEEP’s in the premises information box ;
[ Response ] There is No Recommendation or explanation in Moore-Bick’s Inquiry Phase 1 Report concerning the ‘what’, ‘why’ or ‘how’ of PEEP’s.
[ Solution ] A Personal Emergency Evacuation Plan is a person-specific and location-specific document, and is an integral part of the overall Fire Emergency Management Plan for a building. It is intended for regular occupants/users who may be vulnerable in an emergency situation, i.e. those with limited abilities in relation to self-protection, independent evacuation to an external place of safety remote from the building, and active participation in the building’s fire emergency procedures.
In new buildings, which are effectively accessible (including fire safe) for all, Personal Emergency Evacuation Plans are not necessary.
In existing buildings, Personal Emergency Evacuation Plans must not be used to limit or restrict access by an individual to any part of a building and its facilities. To ensure this, sufficient accessibility works must be carried out and appropriate management procedures put in place.
In buildings of historical, architectural and cultural importance, where the historical, architectural or cultural integrity of the building must be protected, Personal Emergency Evacuation Plans may limit or restrict access to parts of a building and some of its facilities. Refer to the ICOMOS 1964 International Charter for the Conservation and Restoration of Monuments and Sites.
There are No Recommendations in Moore-Bick’s Inquiry Phase 1 Report concerning these critical issues.
[ Solution ] There are many fire safety problems associated with high-rise and tall buildings. Evacuation by staircases alone can take many hours ; the physical exertion involved in descending even 10 floors/storeys by staircase is too much for many able-bodied people and is impossible for most vulnerable building occupants/users, particularly people with activity limitations. Passive fire protection of staircases, alone and/or supplemented by pressurization to prevent smoke ingress, is far too unreliable. And heavily equipped firefighters cannot be expected to ascend more than 10 floors/storeys by staircase before carrying out arduous firefighting and search/rescue operations. Furthermore, uninterrupted lift/elevator shafts, extending throughout the full height of a tall building, pose a significant risk of uncontrolled fire spread.
Colour photograph showing the very narrow, single staircase in the Grenfell Tower, London. How anybody – ANYBODY – could ever imagine that this staircase would be adequate to serve the fire evacuation needs of a diverse occupant population in a high-rise residential building is beyond belief ! A Syndrome is a cluster of symptoms which occur together and can be taken as indicative of a particular design abnormality. Click to enlarge.Presentation Overhead, in colour, illustrating a sufficiently wide fire evacuation staircase … minimum width 1.5m between handrails … which will accommodate Contraflow and the Assisted Evacuation of people in wheelchairs … with a sufficiently large, directly adjoining Area of Rescue Assistance … which will accommodate people unable to independently evacuate during a fire emergency. The space provided in an Area of Rescue Assistance, on each floor/storey, is calculated in relation to the design occupant/user population of a building. Even if a building is fully sprinklered, an Area of Rescue Assistance must adjoin every fire evacuation staircase. Click to enlarge. Staircase design by CJ Walsh.
A Floor of Temporary Refuge is an open, structurally robust floor/storey in a tall building – having an exceptionally low level of fire hazard and risk, ‘intelligently’ fitted with a suitable user-friendly and climate-friendly fire suppression system, e.g. water mist, and serviced by sufficient accessible, fire protected lifts/elevators capable of being used for evacuation during a fire emergency ; it is designed and constructed to halt the spread of heat, smoke and flame beyond that floor/storey, and is intended as a place of temporary respite, rest and relative safety for building users before continuing with evacuation, and as a forward command and control base for firefighters.
In a high-rise, tall, super-tall or mega-tall building, every 20th floor must be a Floor of Temporary Refuge, even if the building is co-joined with another building, or there are sky bridges linking the building with one or more other buildings.
Special provision must be made, on these floors, for accommodating large numbers of building occupants/users with activity limitations … and because people will be waiting on Floors of Temporary Refuge, perhaps for extended periods of time, building designers and managers must ensure that these floors/storeys are properly fitted out with appropriate fire safety equipment, facilitation aids, smoke hoods, signage and communications, etc., etc.
Presentation Overhead, in colour, illustrating and explaining the design concept of Floors of Temporary Refuge. Click to enlarge.
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Conclusion: Fire Engineering Capacity in England is Lacking
In England … the very important 2005 and 2008 U.S. NIST Recommendations following the 9-11 (2001) Attacks on the World Trade Center, in New York City, were completely ignored. Following the 2009 Lakanal House Fire, in London, the 2013 Coroner’s Recommendations were only partially implemented.
With regard to Vulnerable Building Users … there is NO capacity within the English Fire Establishment, including the National Fire Chiefs Council (NFCC), English Authorities Having Jurisdiction (AHJ’s), and its Building Design and Fire Engineering Communities … to properly respond to … never mind understand … the Fire Safety, Protection and Evacuation for ALL in Buildings.
2017-10-10: After the Grenfell Tower Fire Tragedy in London, on 14 June 2017, the integrity of the English Regulatory and Technical/Building Control Systems is now so compromised that a complete Systems Transformation is immediately required ! Closer to home, here in Ireland … what nobody is daring to say, even our tame media, is that Our Regulatory System is based very closely on the English System. And Our Technical/Building Control System is purposefully under-resourced … so it is weak and ineffective.
Let there be no confusion … Priory Hall and Longboat Quay, both in Dublin, are just the tip of an enormous iceberg …
Colour photograph showing the Grenfell Tower Fire, in London … early in the morning, after dawn, on Wednesday, 14 June 2017. Harsh, tragic Reality ! Click to enlarge.
So where do we start again ?
Reality – Reliability – Redundancy – Resilience !
With regard to Reliable Fire Engineering Related Design, Supply and Construction … this is how we must proceed …
Design of the works is exercised by an independent, appropriately qualified and experienced architect/engineer/fire engineer, with design competence relating to the fire protection of buildings ;
Supply of fire safety related construction products/systems to the works is undertaken by reputable organizations with construction competence, particularly in relation to the fire protection of buildings ;
Installation/fitting of fire safety related construction products/systems is exercised by appropriately qualified and experienced personnel, with construction competence relating to the fire protection of buildings ;
Supervision of the works is exercised by appropriately qualified and experienced personnel from the principal construction organization ;
Regular inspections, by appropriately qualified and experienced personnel familiar with the design, and independent of both the design and construction organizations, are carried out to verify that the works are being executed in accordance with the design.
2016-09-14: Only now are we really catching up with the extremely serious matter of Fire Safety in Sustainable Buildings … serious for building occupants … and firefighters !
‘ In order to achieve sustainable development, environmental protection and energy efficiency/conservation shall constitute integral parts of the development process, and shall not be considered in isolation.’
2016 Dublin Code of Ethics: Design, Engineering, Construction & Operation of a Safe, Resilient & Sustainable Built Environment for All ( www.sfe-fire.eu )
The Performance Target for New Construction must be Positive Energy Buildings.
So … we will see more and more Solar Photovoltaic Panels installed on more and more buildings … in every country. Certainly not less ! And, let’s face it, many will not be properly approved, i.e. shown to be ‘fit for their intended use’ …
Colour photograph showing a house fire caused by Solar Photovoltaic Roof Panels.
At the beginning of this decade, a Fire Research Project was carried out by the Underwriters Laboratories Firefighter Research Institute in the USA … and it addressed the issue of firefighter vulnerability to electrical hazards, and serious injury, when fighting a fire involving Solar Photovoltaic (PV) Modules and Support Systems installed on buildings.
Colour photograph showing two firefighters on a roof, one with cutting equipment. Solar Photovoltaic Roof Panels restrict firefighter access to building interior roof spaces.
The Total Global Solar Energy Capacity averaged 40 % annual growth from 2000 to 2010 (source: International Energy Agency). In the USA, Grid-Connected Solar Photovoltaic Capacity grew 50 % per year for much of that time (source: US Federal Energy Regulatory Commission). These trends increase the potential of a Fire Service Response to a building having a Photovoltaic Installation, irrespective of the PV being involved with the initiation of the fire event. As a result, conventional firefighter tactics for suppression, ventilation and overhaul have been complicated, leaving firefighters vulnerable to potentially unrecognized exposure. Though the electrical and fire hazards associated with electrical generation and distribution systems are well known, PV Systems present unique safety concerns. A limited body of knowledge and insufficient data exist to understand these risks … to the extent that Fire Services have been unable to develop safety solutions and respond in a safe manner.
This Fire Research Project developed the empirical data needed to quantify the hazards associated with PV Installations … and provided the foundation to modify current or develop new firefighting practices to reduce firefighter deaths and injury.
Colour photograph showing a large array of Solar Photovoltaic Panels on a roof. Extra loading on roof structures must be considered, as well as possible interference with roof fire evacuation routes for able-bodied occupants.
The Tactical Considerations addressed during the Project include:
Shock hazard due to the presence of water and PV power during fire suppression activities ;
Shock hazard due to the direct contact with energized components during firefighting operations ;
Emergency disconnect and disruption techniques ;
Severing of conductors ;
Assessment of PV power during low ambient light, artificial light and light from a fire ;
Assessment of potential shock hazard from damaged PV Modules and Systems.
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Office of California’s State Fire Marshal – November 2010
UL Report (2011): The Following Summarizes the Findings of This Fire Research Project:
The electric shock hazard due to the application of water is dependent on voltage, water conductivity, distance and spray pattern. A slight adjustment from a solid fire hose stream towards a fog pattern (10 degree cone angle) reduced measured current below perception level. Salt water should not be used on live electrical equipment. A distance of 6 m has been determined to reduce potential shock hazard from a 1000 VDC source to a level below 2 mA, considered as safe. It should be noted that pooled water or foam may become energized due to damage in the PV System.
Outdoor weather exposure-rated electrical enclosures are not resistant to water penetration by fire hose streams. A typical enclosure will collect water and present an electrical hazard.
Firefighters’ gloves and boots afford limited protection against electrical shock provided the insulating surface is intact and dry. They should not be considered equivalent to Electrical Personal Protective Equipment (PPE).
Turning off an array is not as simple as opening a disconnect switch. Depending on the individual system, there may be multiple circuits wired together to a common point such as a combiner box. All circuits supplying power to this point must be interrupted to partially de-energize the system. As long as the array is illuminated, parts of the system will remain energized. Unlike a typical electrical or gas utility … on a PV Array, there is no single point of disconnect.
Tarps offer varying degrees of effectiveness to interrupt the generation of power from a PV Array, independent of cost. Heavy, densely woven fabric and dark plastic films reduce the power from PV to nearly zero. As a general guide, if light can be seen through a tarp, it should not be used. Caution should be exercised during the deployment of tarps on damaged equipment, as a wet tarp may become energized and conduct hazardous current if it contacts live equipment. Also, firefighting foam should not be relied upon to block light.
When illuminated by artificial light sources, such as Fire Department light trucks or an exposure fire, PV Systems are capable of producing electrical power sufficient to cause a lock-on hazard.
Severely damaged PV Arrays are capable of producing hazardous conditions ranging from perception to electrocution. Damage to the array may result in the creation of new and unexpected circuit paths. These paths may include both array components (module frame, mounting racks, conduits, etc) and building components (metal roofs, flashings and gutters). Care must be exercised during all operations, both interior and exterior. Contacting a local professional PV Installation Company should be considered to mitigate potential hazards.
Damage to modules from tools may result in both electrical and fire hazards. The hazard may occur at the point of damage or at other locations depending on the electrical path. Metal roofs present unique challenges in that the surface is conductive unlike other types such as shingle, ballasted or single ply.
Severing of conductors in both metal and plastic conduit results in electrical and fire hazards. Care must be exercised during ventilation and overhaul.
Responding personnel must stay away from the roofline in the event of modules or sections of an array sliding off the roof.
Fires under an array but above the roof may breach roofing materials and decking … allowing fire to propagate into the attic space of the building.
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