International Legal Instrument

Sick Building Syndrome, ISO 21542:2021 & Indoor Air Quality (IAQ)

2012-05-31 (2021-08-02):  The Revised International Standard  ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’  was published on 1 June 2021.  Many years before, however, a decision was taken to link this Standard directly to the United Nations  Convention on the Rights of Persons with Disabilities  (#CRPD) … specifically now referencing Preamble Paragraph (g) and Articles 9, 10, 11, 12 and 19 in its Introduction.  Reading the document, this linkage looks and feels very naturally like an unbreakable umbilical cord !

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Black and White image showing the Title Page of International Standard ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’, which was published on 1 June 2021.  Click to enlarge.

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ISO 21542 has significantly widened the meaning of the concept #Accessibility4ALL … a normal evolutionary process … in particular, the #FireSafety4ALL Texts.  I wonder, though, how many people would ever have considered  Good Indoor Air Quality  to be on the ‘Accessibility’ Menu ??

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Colour image showing a young child wearing a face mask (#Pandemic #CoronaVirus #CoVID19) … with an accompanying text: ‘Poor Indoor Air Quality Is A Serious Threat’.  Click to enlarge.

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Much lower rates of direct fresh air ventilation … and a dramatic reduction in accidental or unintended air seepage from, or into, buildings (depending on local climate conditions) … all driven by an urgent need to conserve energy and to impose greater energy efficiencies on the energy which is actually consumed … are, once again, one of the main causes of serious health problems for ALL #BuildingUsers …

Building Related Ill-Health:  Any adverse impact on the health of building users – while living, working, generally occupying or visiting a specific building – caused by the planning, design, construction, management, operation or maintenance of that building.

I say “once again” because, in Europe, we have been here before … after the two big oil crises of the 1970’s.

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Anyway … I thought that it would be useful to present a relevant extract from ISO 21542

B.8 – INDOOR AIR QUALITY (#IAQ)

Poor indoor air quality, an important factor in relation to Building Related Ill-Health (also known as ‘sick building syndrome’), can cause serious health impairments and severely restrict a person’s participation in everyday activities, e.g. work.

Symptoms and signs may include:

  • irritation of eyes, nose and throat ;
  • respiratory infections and cough ;
  • voice hoarseness and wheezing ;
  • asthma ;
  • dry mucous membrane and skin ;
  • erythema (reddening or inflammation of the skin) ;
  • lethargy ;
  • mental fatigue and poor concentration ;
  • headache ;
  • stress ;
  • hypersensitivity reactions, i.e. allergies ;
  • nausea and dizziness ;
  • cancers.

These symptoms and signs are present in the population at large, but are distinguished by being more prevalent in some building users, as a group, when compared with others.  The symptoms and signs may disappear, or may be reduced in intensity, when an affected person leaves the building.  It is not necessary that everyone in a building should be affected before building related ill-health is suspected.

ISO 16814: ‘Building Environment Design – Indoor Air Quality – Methods of Expressing the Quality of Indoor Air for Human Occupancy’ covers methods of expressing indoor air quality (IAQ) and incorporating the goal of achieving good IAQ into the building design process.  It also covers ventilation effectiveness, harmful emissions from building materials, air cleaning devices, and heating, ventilation and air conditioning equipment.

The indoor pollutants considered in ISO 16814 include human bio-effluents, which have often been the principal consideration in air quality and ventilation design, but also the groups and sources of pollutants which can reasonably be anticipated to occur in the building during its long Life Cycle.

These pollutants, depending on the sources present, may include:

  • volatile organic compounds (#VOC’s) and other organics, such as formaldehyde ;
  • environmental tobacco smoke (#ETS) ;
  • natural radon, consisting of a number of different isotopes, is an invisible radioactive gas, and is found in the soils under buildings, water supplies to buildings and in the air ;
  • other inorganic gases, such as carbon monoxide (#CO), the oxides of nitrogen (NOx), and low-level ozone (smog) which is formed when NOx and VOC’s react in the presence of sunlight ;
  • viable particles, including viruses, bacteria and fungal spores ;
  • non-viable biological pollutants, such as particles of mites or fungi and their metabolic products ;
  • non-viable particles, such as dusts and fibres.

The following Two Performance Indicators of Good Indoor Air Quality, developed with the aim of protecting human health, are recommended:

  1. Radon Activity (including Rn-222, Rn-220, RnD)  in a building should, on average, fall within the range of 10-40 Bq/m3, but should at no time exceed 60 Bq/m3.
  2. Carbon Dioxide (CO2)  concentrations in a building should not significantly exceed average external levels – typically within the range of 300-500 parts per million (#PPM) – and should at no time exceed 800 ppm.

[ While the current CoVID-19 Pandemic lasts … these are Essential ‘Health’ Performance Indicators, as opposed to ‘Safety’ Indicators … and they should be stringently operated and constantly monitored in all building types. ]

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

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

Hong Kong Buildings Department

2011 Hong Kong Code of Practice for Fire Safety in Buildings

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

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

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

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

UN CRPD  Article 11 – Situations of Risk & Humanitarian Emergencies

States Parties shall take, in accordance with their obligations under international law, including international humanitarian law and international human rights law, all necessary measures to ensure the protection and safety of persons with disabilities in situations of risk, including situations of armed conflict, humanitarian emergencies and the occurrence of natural disasters.

[ Note:  An outbreak of fire in a building is a situation of serious risk for all vulnerable building users ! ]

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

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

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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 ; 

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  • 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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Sustainable Fire Engineering – IABSE Lecture 1 December 2011

2011-11-14 …

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

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

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

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IABSE Irish National Group Sponsored Lecture

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

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

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

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

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

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

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

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

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Complaints to the UN Disability Rights Convention Committee

2011-11-14:  At the time of writing, this was the up-to-date position regarding the United Nations Convention on the Rights of Persons with Disabilities (CRPD)

Convention153 Signatories … 106 Ratifications

Optional Protocol90 Signatories … 63 Ratifications

For reasons which can sometimes be complex … individuals and disability-related organizations are reluctant to make valid complaints … at local, regional or national levels in their countries.

This must stop !   If nobody complains … nothing will change !!

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The following documents should now be used as a Proper Model for Making a Complaint … at any level.  And should all domestic remedies be exhausted at national level in a State Party … you will have saved yourself a lot of time and energy, should you decide to take matters further … because the complaint will already be in the correct CRPD format …

Committee on the Rights of Persons with Disabilities – 15 June 2011

UN CRPD/C/5/2 – Fact Sheet on the Procedure for Submitting Communications to the Committee on the Rights of Persons with Disabilities under the Optional Protocol to the Convention  (PDF File, 41 kb)

UN CRPD/C/5/3 – Guidelines for Submission of Communications to the Committee on the Rights of Persons with Disabilities under the Optional Protocol to the Convention  (PDF File, 47.5 kb)

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