Ireland

Responder Safety on Roads & ‘Eye-Popping’ Vehicle Markings

2013-09-05:  A few days ago, I was travelling on a motorway in Ireland … the scenery was luscious, and daylight and weather conditions were good … when I noticed that the visibility and marking of Emergency Response and Public Service Vehicles varied considerably.  The rear of one vehicle, in particular, had highly visible markings … but it was pulling a high trailer, without any markings … and, of course, the vehicle itself and its bright luminescent markings were almost obscured.

What would happen at night, in heavy rain … if any of these vehicles had to stop on a road without any public lighting … as they responded to a traffic accident … or because they were part of a Garda/police checkpoint ?   Serious danger for the responders and other road users is the obvious answer !

Then, more recently, while walking around Howth Harbour, in Dublin … I spotted this Irish Coast Guard Vehicle … which made me feel more optimistic …

Irish Coast Guard Vehicle, with High Visibility Markings, at Howth Harbour in Dublin.
Colour photograph showing an Irish Coast Guard Vehicle, with High Visibility Markings, at Howth Harbour in Dublin. Photograph taken by CJ Walsh. 2013-08-24. Click to enlarge.

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CVVFA-ERSI: ‘Vehicle Marking and Technology for Increased Highway Visibility – A Reference Guide for Decision-Makers’ (2013)

Click the Link Above to read and/or download PDF File (4.35 MB)

Produced by the U.S. Cumberland Valley Volunteer Firemen’s Association (CVVFA) Emergency Responder Safety Institute (ERSI) … with the support of the Federal Emergency Management Agency’s United States Fire Administration (USFA), and the National Institute of Justice (NIJ) – the research, development and evaluation agency of the U.S. Department of Justice.

Author: Ron Moore – Chief Instructor, CVVFA Emergency Responder Safety.

CVVFA ERSI WebSite: www.respondersafety.com

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Cover Page - U.S. Fire Administration Report FA-330: 'Traffic Incident Management Systems' (2012)U.S. Fire Administration Report FA-330 – March 2012

USFA: ‘Traffic Incident Management Systems’ (2012)

Click the Link Above to read and/or download PDF File (4.87 MB)

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Both of these documents must be carefully adapted by the reader to suit a European context … as the following List of Recommendations from USFA Report FA-330 will clearly indicate …

To help decrease vehicle-related injuries and fatalities of emergency responders if implemented at the appropriate levels:

1.   Develop a comprehensive database that tracks accidents involving emergency vehicles and any resulting injuries and/or deaths to both emergency responders and civilians.

2.   Limit speeds to a level that is safe for the vehicle being driven and the road conditions on which it is being operated.

3.   Adopt a zero-tolerance alcohol (and drugs) policy and enforce an 8-hour time difference between alcohol consumption and the commencement of work.

4.   Equip all emergency vehicles with appropriate traffic control and safety equipment.

5.   Ensure all traffic-channelizing devices meet applicable standards.

6.   Ensure flaggers, if used, are properly trained and meet Manual of Uniform Traffic Control Devices for Streets and Highways (MUTCD) qualifications.

7.   Require members to wear highly reflective American National Standards Institute (ANSI)/International Safety Equipment Association (ISEA) 107 Class II, Class III, or ANSI/ISEA 207 compliant public safety vests whenever they operate in a roadway.

8.   Mark the emergency vehicle perimeter with retro-reflective striping or markings.

9.   Extinguish forward facing emergency vehicle lighting when parked on the roadway, especially on divided roadways.

10.  Fire departments should consider the implementation of traffic safety response units.

11.  Position the initial-arriving emergency vehicle in a blocking position to oncoming traffic.

12.  Establish an adequately sized work zone.

13.  Develop a formalized Traffic Incident Management (TIM) information sharing method between public safety and transportation agencies.

14.  Manage major traffic incidents using the National Incident Management System (NIMS) Incident Command System (ICS).

15.  Consider the use of Unified Command (UC) to manage traffic incidents involving multiple jurisdictions or disciplines.

16.  Incorporate transportation departments into ICS when appropriate.

17.  Ensure adequate training on roadway hazards and safety procedures for responders.

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Belmayne Timber Frame Construction – Cometh An Inferno ?

2013-07-11 (2021-08-04):  Further to the Posts about the ongoing Fire Safety Fiasco at Priory Hall in Dublin, beginning on  2011-10-18 … and my recent reply to a question from Ms. Saffron Willetts, dated 2013-06-09 …

A house with a timber-framed party wall, whether the wall projects above the roof covering or not … in a terrace, or semi-detached … and constructed in 2004 (approaching the height of the Celtic Tiger frenzy in Ireland) ??   Not even torture in Guantánamo Bay (Cuba) by the Americans would persuade me to buy … or rent !

One last word of caution … carefully examine any ‘Opinion on Compliance’ covering this property.

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On Sunday evening last, 7 July 2013, I received an e-mail notification from Mr. Del Tillyer about a Belmayne ‘Fire Safety’ Press Conference to be held in his home … 19 Churchwell Place, Belmayne, Dublin 13 … on Tuesday, 9 July 2013, at 11.00 hrs.  I was very pleased to attend.

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Belmayne, Dublin 13 - Fire Hazard (1)
Colour photograph showing the attractive Belmayne Residential Development in Dublin, Ireland.  Taken by CJ Walsh.  2013-07-09.  Click to enlarge.

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Back in ‘ye good olde days’ of the Celtic Tiger … the price paid for this 2 Storey Timber-Framed Dwelling Unit was a staggering € 530,000 !   However, following occupation of their new home, it was noticed by the family that there were BIG problems concerning nuisance sound transmission from neighbouring units.  And that’s when their long shabby saga of ‘Fire Safety at Belmayne’ began … or, more correctly, it should be called the tortuous saga of a ‘Serious Lack of Fire Safety at Belmayne’ !!

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Belmayne, Dublin 13 - Fire Hazard (2)
Colour photograph showing 19 Churchwell Place, Belmayne, Dublin 13.  Taken by CJ Walsh.  2013-07-09.  Click to enlarge.

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In order to satisfy the Legal Requirements of Part D: ‘Materials and Workmanship’, Second Schedule to the Irish Building Regulations … this form of innovative construction was covered by an Irish Agrément Board Certificate …

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Front Page of IAB Certificate No.04/0198 (rev.2007) - Kingspan Century Medium Rise Timber Frame Construction System

Kingspan Century Medium Rise Timber Frame Construction System – IAB Certificate No.04/0198 (rev.2007)

Click the Link Above to read and/or download PDF File (1.43 MB)

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Unfortunately … any connection between IAB Certificate 04/0198 and the bitterly cold reality of how 19 Churchwell Place was actually constructed … is, at best, extremely tenuous … as the following photographs clearly show …

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Belmayne, Dublin 13 - Fire Hazard (3)
Photograph taken by CJ Walsh.  2013-07-09.  Click to enlarge.
Belmayne, Dublin 13 - Fire Hazard (4)
Photograph taken by CJ Walsh.  2013-07-09.  Click to enlarge.

[ It was difficult … but I resisted the temptation to add an elaborate caption to each image which would describe the original Shoddy, Careless, Incompetent Site Workmanship !   And please bear in mind that the opening-up shown was limited … more problems cannot be seen, or will only become apparent in the future, e.g. the inevitable settlement of low-density thermal insulation !! ]

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Belmayne, Dublin 13 - Fire Hazard (5)
Photograph taken by CJ Walsh.  2013-07-09.  Click to enlarge.
Belmayne, Dublin 13 - Fire Hazard (6)
Photograph taken by CJ Walsh.  2013-07-09.  Click to enlarge.

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[ This is the other unreported and completely hidden Irish National Debt … over 20 years of ‘Lite’ National Regulation of the Construction Sector and an Entirely Inadequate and Ineffective National System of Local Authority Building Control / Independent Site Technical Control have resulted in a New National Building Stock which will require an enormous amount of difficult and costly repairs during the next decades … which will have to be paid for by the citizen !   Those responsible … National Authorities Having Jurisdiction (AHJ’s), Professional Institutes and Societies, Property Developers, Construction Product Manufacturers, and Politicians … have all quietly slipped away from the crime scene !! ]

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Belmayne, Dublin 13 - Fire Hazard (7)
Photograph taken by CJ Walsh.  2013-07-09.  Click to enlarge.
Belmayne, Dublin 13 - Fire Hazard (8)
Photograph taken by CJ Walsh.  2013-07-09.  Click to enlarge.

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The Fire Consultant on this Repair Project was Mr. Noel C. Manning, R.I.P.

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Explanatory Note:

In the event of a fire incident at this dwelling unit … why are the construction failures shown in the photographs above so risky, so hazardous, so dangerous for its occupants (more precisely – their health, safety and welfare) ??

Even within the Construction Sector, it is not well understood that the Fire Safety Objectives of Building Regulations, generally and not just in Ireland, are limited in scope to the protection of people who use and/or occupy buildings from fire (i.e. heat, smoke and flame).  These Fire Safety Objectives only ‘extend’ to the protection of property (i.e. the building fabric) … insofar as the protection of that property is relevant to the protection, including the safe evacuation, of people in the building.

The biggest original construction failure shown above is that there is an extensive warren of continuous, hidden cavities within the walls, floors, service duct and ceilings of the house … which facilitates the unseen spread of fire, including toxic smoke, very rapidly throughout the building and to adjoining dwelling units.  This type of insidious fire spread cannot be detected by smoke alarms located in the area of a staircase.

The serious ‘cavity’ failure is compounded by another serious construction failure … the weak and inadequate protection from fire (i.e. heat, smoke and flame) to the staircase itself … which is the only means of evacuation from the house for the occupants.

The limited Fire Safety Objectives of Building Regulations must be clearly distinguished from Project-Specific Fire Engineering Design Objectives which have a much wider scope.  For an elaboration of this issue … go to:  https://www.cjwalsh.ie/2012/12/sustainable-fire-engineering-for-all-sdis-professional-service/

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Upcoming Building Research Workshop at Galway University

2013-06-08:  Looking forward to some serious, collaborative and multi-disciplinary discussions on the day … and a barrel of laughs in the process (!!) …

The Informatics Research Unit for Sustainable Engineering (IRUSE) in the Department of Civil Engineering … and The Ryan Institute for Environmental, Marine and Energy Research … both at the National University of Ireland Galway (NUIG) … have jointly organized a 1-Day National Research Networking Workshop which will take place on Monday, 24 June 2013.

The NUIG ‘blurb’ for the day states … “Considering the importance of aggressive energy-efficiency measures in the Building Sector, together with the requirements for a safe, healthy, comfortable (and accessible) Built Environment … this NUIG Workshop will explore the topic of Integrated Modelling and Performance of the Built Environment.”

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I was very pleased to receive an invitation to make a Presentation at this prestigious event …

‘Sustainable Fire Engineering Design’  –  My Presentation Abstract

Fire Engineering … involves much more than mere compliance with building regulations and codes … whose fire safety objectives are limited, and whose performance requirements are sometimes inadequate and always minimal.  More problematically … a fundamental conflict is mushrooming between Safe Sustainable Climate Resilient Building Design and Conventional Fire Consultancy Practice.

However … Sustainable Fire Engineering Design Solutions are:

  • Reliability-based ;
  • Person-centred ;

and above all

  • Adapted to Local Context and Heritage (fr: le Patrimoine – see ICOMOS 2011) … geography, climate (incl. change, variability and severity swings), social need, culture, and economy, etc., etc.

This Presentation will discuss very rich collaborative research potential in the following areas …

  1. Creative Fire Engineering Concepts and Building Systems
  2. Fire-Induced Progressive Damage in Buildings
  3. Human Behaviour and Abilities in a Fire Situation
  4. Building Design for Firefighter Safety
  5. BMS – Fire Modelling – BIM

Research Output must be targeted at practical implementation in ‘real’ buildings … with actual user/construction performance carefully (i.e. reliably and precisely) monitored !

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If anybody out there is interested in attending this NUIG Research Workshop … please contact Ms. Magdalena Hajdukiewicz (IRUSE) at: hajdukiewicz1@nuigalway.ie

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POST-EVENT UPDATE:  2013-06-27 …

While it was difficult to keep the Workshop Programme, involving a series of short 10-minute presentation slots, on track … discussions during the day were engaging, energetic and extensive.

I happily look forward to a successful and collaborative outcome from the day … Multi-Disciplinary Teams producing Trans-Disciplinary Research Output … which is geared towards practical implementation in ‘real’ buildings, with actual construction and building user performance carefully (i.e. reliably and precisely) monitored !

Galway University (NUIG) Workshop Programme & Presentation Abstracts

Click the Link Above to read and/or download PDF File (193 Kb)

Galway University (NUIG) Built Environment Research Networking Workshop - 24 June 2013
Colour photograph showing the venue for the IRUSE & The Ryan Institute (Galway University – NUIG) Built Environment Research Networking Workshop, which was held in the New Engineering Building on 24 June 2013. Seen here is Dr. Harald Berresheim during his presentation on ‘The Self-Cleansing Capacity of Our Atmosphere – Limitations on Local to Global Scales’. Photograph taken by CJ Walsh. 2013-06-24. Click to enlarge.

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CJ Walsh Presentation: ‘Sustainable Fire Engineering Design’

Click the Link Above to read and/or download PDF File (1.78 MB)

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However … and especially since the Workshop had been organized by IRUSE (the ‘SE’ standing for ‘Sustainable Engineering’) … it was indeed very strange to have to clarify the following points, among others:

1.   The Minimum Life Cycle for a Sustainable Building is 100 Years … not 50 or 60 years !

2.   Future Research Collaboration should be targeted at the multi-aspect ‘Sustainability Agenda’.  The word ‘green’ (where only environmental aspects of sustainability are considered) should be actively discouraged, if not banned entirely !

3.   With regard to Good Indoor Air Quality (IAQ) … two high-level performance indicators which have been developed with the aim of protecting human health, and are both now referenced in International Standard ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’ … are …

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

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

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Galway University’s New Engineering Building

Concerning the substantive difference in meaning and scope between ‘sustainable’ and ‘green’ … there is, perhaps, no better way to illustrate this difference than to observe the atrocious ‘Accessibility-for-All’ Performance (Accessibility for People with Activity Limitations !) of the critically acclaimed (?!?) and award winning (?!?) New Engineering Building in Galway University … which flaunts its ‘über-green’ credentials …

Galway University's New Engineering Building - Inadequate Accessibility-for-All (1)

Galway University's New Engineering Building - Inadequate Accessibility-for-All (2)

Galway University's New Engineering Building - Inadequate Accessibility-for-All (3)

Galway University's New Engineering Building - Inadequate Accessibility-for-All (4)

Galway University's New Engineering Building - Inadequate Accessibility-for-All (5)

Can you believe what’s in those photographs ??   More importantly … can you believe what’s not in those photographs ????   In such a recently completed building … “incredible” is the only answer to both questions.

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Under International Law … lack of accessibility, or inadequate accessibility, to the social, built, virtual and economic environments … IS a denial and infringement of the basic human rights of people with activity limitations.  It also limits, needlessly and unnecessarily, the numbers of potential users of those environments … which makes no sense at all.

My strong recommendation to Galway University … is to immediately commission a Competent Accessibility Consultant to give the university campus a thorough going over !   You are failing the campus user population … the local community in Galway … and Irish society generally.

My even stronger recommendation to the Architects for the New Engineering BuildingRMJM Architects (Robert Matthew Johnson-Marshall) in Scotland, and Taylor Architects in Ireland … is to always commission a Competent Accessibility Consultant on all of your projects … small, medium and large … because you haven’t a bull’s notion about this important dimension of building performance !!

And remember folks … Accessibility has been clearly specified in the new International Standard ISO 21542 as including … ‘access to buildings, circulation within buildings and their use, egress from buildings in the normal course of events, and evacuation in the event of an emergency’.

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Urgent ! … Next Generation Architectural Design Concepts

2013-05-30:  Further to the recent post here, dated 2013-04-02 … and this Page on our Corporate WebSite …

Pausing … and stepping back … to consider conventional architectural practice, how architects are educated, and whether or not the professional institutes are helping, or handicapping, the forward progress of Architecture for a Better, More Sustainable World … I am deeply concerned about the future …

1.  Should it be ‘Multi-Disciplinary’ or ‘Trans-Disciplinary’ ?

The word ‘trans-disciplinary’ is confusing to a lot of people … surprisingly, to many at senior levels in construction-related industries, research sectors, and academia … not just in Ireland, but internationally.  The more senior the level, it seems the higher are the walls of that proverbial ‘box’.  But, let me reassure you, thinking outside the ‘box’ is not confined to people in their early 20’s !!

Looking over just the initial list of Consultant Specialists in a complex architectural project … it is the task of the Architect to transform a widely ‘multi-disciplinary’ input into a coherent ‘trans-disciplinary’ output.  These two concepts are very different.

Next Generation Architectural Processes and Procedures are urgently required …

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2.  EU Climate & Energy Policies – Key Driving Forces for Sustainability !

Recently, the European Commission issued this Green Paper … (which, by the way, has absolutely nothing to say about Climate Change Adaptation !) …

European Commission - COM(2013) 169 final Cover
Click to enlarge.

European Commission COM(2013) 169 final – Brussels, 2013-03-27

EU Green Paper – A 2030 Framework for Climate and Energy Policies

Click the Link Above to read and/or download PDF File (104 Kb)

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Concerning this Green Paper … Two Important Points …

(i)    Current European Union (EU) Climate and Energy Policies are not just a passing fad … they are here to stay.  With certainty, we also know that they will become more and more stringent … and that higher levels of performance will be mandated … not just on paper or a computer printout … but in reality, for example, in buildings which are constructed and actually occupied by ‘real’ building users.  Refer also to recent findings, in Europe, about the large and growing discrepancy between car fuel efficiencies claimed after testing in a laboratory, and when later monitored under ‘real’ driving conditions.

(ii)   It has now become obvious that the European Commission has lost the plot … big time !   Policies and Actions in closely related fields have been permitted to become fragmented, disjointed, and even counter-productive.  Written into the EU treaties is the term ‘sustainable development’ … an intricate, open, dynamic and continuously evolving concept.  However, senior levels (both political and bureaucratic) in the different Directorates-General of the European Commission have long ago forgotten, mislaid and/or lost the proper meaning of ‘sustainability’ … and the essential interdependency of its many aspects.

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… which brings me to the urgent necessity for Next Generation Architectural Design Concepts

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In Europe … the 1990’s and early 2000’s, taken together, was a period of construction experimentation and research.  We thought we could afford the resources and the lazy times … to try this, that and the other.  Little emphasis was placed on practical implementation in ‘real’ buildings.  However, the scale and immediacy of today’s Sustainable Development Challenges in the Built Environment have, within a few short years and much more quickly than expected, become unprecedented.

The Yanks (Gringos) are very strong on marketing … much stronger than Europe … so let’s examine a small model building … and see if its Architectural Design Concept is both coherent and comprehensive …

Mr. Amory Lovins, of the Rocky Mountain Institute in the USA ( www.rmi.org ) … has produced a very snazzy Visitor’s Guide to the sprawling complex that is ‘his home, bioshelter and office’ in Snowmass, Colorado … a Guide intended for wide public circulation.

Concerning this Building … Three Points of Interest(?) …

(i)    For a fleeting moment … let us imagine that a percentage – not even all – of the vast populations living in Africa, India and China wanted the same sort of lifestyle, including the house, that Amory Lovins possesses.  What would be the resource implications for this planet ??

RMI / Amory Lovins House, Colorado, USA - Exterior - Roof Photovoltaic (PV) Panels
Click to enlarge.

(ii)   In a first construction ‘try’ … separate solar and/or photovoltaic panels fixed in place on a roof … attached to the building, almost as an afterthought … were the norm.  Now, however, these building systems are no longer innovative … they must be properly shown to be ‘fit for their intended use’ (to comply with building regulations and codes) … and they should now be fully integrated into the architectural design concept for the building … which is not the case in the photograph above.  [ Car manufacturers face a similar design challenge today … how to successfully integrate new technologies, e.g. satellite navigation screens, smartphone docking stations, usb sockets, bluetooth, etc., etc., into the front dashboard.]

RMI / Amory Lovins House, Colorado, USA - Exterior - Tracking Photovoltaic (PV) Panel

Anyway … how reproducible is this model building in urban and suburban contexts … in the USA … or elsewhere in the world ??   How many people would have access to sufficient land outside a building to ‘plant’ one, or a series of photovoltaic panels ?   Tracking photovoltaic panels, as shown above ??   And as seen in Italy, with those ridiculous photovoltaic fields (in a post, dated 2011-11-07 ) … good agricultural lands should not be used for this purpose … not now, not ever, never !

RMI / Amory Lovins House, Colorado, USA - Interior - Building Services
Photograph taken by Judy Hill Lovins. Click to enlarge.

(iii)  Sustainable Buildings are ‘high-tech’ … and a very large amount and variety of electronic and mechanical equipment is necessary in order to reliably monitor and tightly control their performance … in other words, to operate a building in accordance with its design specification.  Again … these services should be fully integrated into the architectural design concept for what is, no longer, just a simple dwelling.  Do similar houses without basements, for example, now need a central well-ventilated service room, complete with compact workstation ?

RMI / Amory Lovins House, Colorado, USA - Interior - Battery Array
Photograph taken by Judy Hill Lovins. Click to enlarge.

In my opinion … the Architectural Design Concept for this building is not coherent.  The overall architectural impression is one of a large sprawling house, on a very large plot of land … with many different ‘environmental/energy’-related appendages, or add-ons.  Can you see any coherence ?

It is the task of the Architect to consider all facets of building performance at the earliest stages of design … whether a small building, or a very large complex building … and to integrate those many diverse, but interdependent, facets into a coherent architectural statement … having a conceptual single crystalline shape … while also bearing in mind ‘person-centredness’‘flexibility’, ‘adaptability’, ‘accessibility for all’, and a ‘long and useful life cycle’.

[ An aside … closer to home … we are now witnessing the rise of the ‘Passive House Designer’.  This person, who is able to use a specific computer software package … no less, and no more … need not necessarily be an architect, or have any architectural education/training.  Is it possible to refer to the realized output from this software as ‘architecture’ … or are they merely drab, boring boxes ?? ]

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3.  Sustainable Buildings, Fire Safety & Fire Engineering ?

In the elaborate Amory Lovins Visitor’s Guide above … there is only one mention of fire hazard in the building … and that is in relation to a Passive Clothes Dryer (Page 40).  End of story with regard to the Fire Safety Issues for its Users … and the Fire Engineering Implications arising from a chosen architectural design and chosen construction materials and methods.

When I was referring to a centrally located service room in # 2(iii) above … that room should also be structurally hardened, and fire and smoke ‘separated’ from other spaces in the house.  Or … if the service equipment is located in a roof space, there are implications for roof structural reliability in a fire situation, and the fire resistance of the ceiling construction beneath.  Or … if the equipment is located in a basement, a simple intermediate timber floor construction overhead is inadequate.

Furthermore … an intelligent fire detection and warning system … and a suitable domestic fire suppression system … are no longer luxuries or optional extras, but essential requirements !   Who would want to lose such a valuable investment ??

And insofar as fire safety issues are not being considered … it seems, at all … in the case of most ‘high-tech’, sustainable buildings … and certainly not in the case of the Lovins House … the Architectural Design Concepts for these buildings ‘suffer’ from a gaping hole … an enormous void … they are incomplete and, therefore, entirely inadequate.

Fire Engineering involves much, much more than mere compliance with building regulations and codes … whose fire safety objectives are limited, and whose performance requirements are sometimes inadequate and always minimal.

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

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

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

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

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Sustainable Fire Engineering Design, on the other hand, is the creative response to Sustainable Design … and the powerful drivers of Climate Change Adaptation, and Energy Conservation/Efficiency in Buildings.

Sustainable Fire Engineering Design Solutions are …

  • Adapted to Local Conditions … Geography, Climate (change, variability and severity swings), Social Need, Culture, and Economy, etc., etc ;
  • ‘Reliability-Based’ … the design process is based on competence, practical experience, and an examination of ‘real’ extreme events, e.g. 2001 WTC 9-11 & 2008 Mumbai Attacks, and 2011 Fukushima Nuclear Incident … rather than on theory alone ;
  • ‘Person-Centred’ … ‘real’ people are placed at the centre of creative endeavours and proper consideration is given to their responsible needs … and their health, safety and welfare … and security … in the Human Environment.

Sustainability continues to fundamentally transform our Fire Engineering, Architectural and Consultancy Practice at Sustainable Design International Ltd (SDI) !

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RF-Based Firefighter Communication Performance in Buildings

2013-05-22:  Whatever Service Providers claim … every day, we experience mobile/cell phone reception variability, drop-off and failure in buildings … whether we are fully conscious of it or not.  It’s inconvenient, but all we have to do is change location, even slightly … and ‘re-dial’.  However, if we are travelling on a train or bus, and it enters a tunnel … the problem can be annoying, as the situation is beyond our control !

On the other hand, however … not too far from where I live, there is an art house cinema with underground screens on different levels.  In this particular case, mobile/cell phone reception failure can be a positive joy – it will not be necessary to listen to someone else’s loud conversations during the film !

BUT … emergency first responders use radio frequency-based communication systems during the normal course of their work … and in the current built environment, these systems can also be unreliable.  Improved climate resilience in our future building stock will make matters worse.  So, it makes a lot of sense to take this issue seriously now !

Fire Departments equip their firefighters with a Radio Frequency-Based Personal Alert Safety System (PASS) … also known as an Automatic Distress Signal Unit (ADSU) … which sends out a signal to a fire incident base / control centre / command post when the firefighter is motionless or in distress, with a clear indication of his/her location … or, if necessary, a general warning can be sent from the fire incident base / control centre / command post to all firefighters to evacuate a building immediately … for example, if extensive structural collapse is imminent.

Recently, the National Institute of Science & Technology (USA) issued Technical Note 1792.  I have just a few short comments to make before jumping into the document …

1.   The Empire State Building and a Subway Station in New York City are both iconic building types … and unusual, in the context of the USA generally … but not so in Europe, with our long tradition for ‘hard/heavy’ construction.  Challenging environments for radio frequency-based communication systems are encountered in our basement / underground building types, and low-rise complex building types … never mind high-rise and tall buildings.

2.   Outside buildings, adequate external access routes for Firefighting Vehicles are mandated in building codes and standards … and Firefighter Lifts are provided inside buildings, etc., etc., etc.  Facilitating reliable radio frequency-based emergency communications should become a normal part of thinking about … and designing for … Safe Firefighter Access.  And … before new buildings are occupied, it should become routine to carry out an emergency communications check, as part of a wider collaborative effort between Building Management Teams and Local Fire Services.

3.   This NIST Technical Note is further evidence … as if any more evidence were needed … that it is a continuing and difficult process to fully implement the 2005 & 2008 NIST WTC 9-11 Recommendations.  To date, the easier low hanging fruit (system and procedural inadequacies !) have been tackled, which may be presented and/or described as substantive changes in building codes and standards … mere window dressing … tokenism, at its worst !   However, as discussed here before many times, some European countries continue to completely ignore these important NIST Recommendations.

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NIST Technical Note 1792 (March 2013) - Title Page
Click to enlarge.

March 2013 – NIST Technical Note 1792: ‘Performance Analysis of RF-Based Electronic Safety Equipment in a Subway Station and the Empire State Building’.

To Read/Download NIST TN 1792 (PDF File, 9.02 MB), go to … http://dx.doi.org/10.6028/NIST.TN.1792

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NIST TN 1792 – Summary & Conclusion (Page 59)

Radio Frequency (RF) PASS Tests were performed in a New York Subway Station and the Empire State Building because these types of structures provide challenging RF propagation-channel environments.  In the Subway, the RF PASS systems were limited in their ability to communicate beyond the initial entrance level.  Without the use of repeaters, most of the systems could communicate only a short distance beyond the bottom of the stairwell that connected the token booth corridor to the street.  Two systems used repeaters to extend the coverage area.  When a repeater was located at the base of the stairwell leading up to the street, those two systems were able to communicate the RF PASS alarms between the street level and the first passenger platform.  However, with only a single repeater, neither of the two repeater systems was able to communicate between the external receive site and the second passenger level.  This suggests that for structures with sizable subterranean sections, a repeater system will likely be required to reach an external incident command post.  If the structure has multiple subterranean levels of increasing depth, a multiple-hop relay system will likely be necessary to ensure the reliability of the communication channel.

NIST TN 1792 - Figure 16: 'Subway + System 4 Performance'
NIST TN 1792 – Figure 16: ‘Subway + System 4 Performance’. Click to enlarge.

In the path-loss measurements and analysis performed at five frequencies, ranging from 430 MHz to 2405 MHz, there are several important insights.  Based on the upper adjacent values in the box-plot statistical representation of the path-loss data from the Empire State Building (see Figure 36), path-loss values of 140 dB to 175 dB are possible for high-rises.  For the Subway, the path-loss values exceed 210 dB to 240 dB at the lower two passenger platforms (see Figure 35).  The frequency dependence is more pronounced for the Empire State Building results, but less apparent in the Subway data.  Thus, while a system may function well at the lower end of the frequency spectrum in the above ground portions of a large building, the subway results demonstrate that subterranean structures can cause path-loss values greater than 200 dB across the 430 to 2400 MHz range.

NIST TN 1792 - Figure 21: 'Tall Building + System 4 Performance'
NIST TN 1792 – Figure 21: ‘Tall Building + System 4 Performance’. Click to enlarge.

The testing completed here focused on RF PASS system performance and RF propagation-channel measurements in a high-rise and subway station.  While a primary goal of the effort was to look at the correlation between the system performance and path-loss behaviour, a secondary goal was to gather path-loss data in two high-attenuation settings.  Thus, parameter values for log-normal distributions that will allow simulation of the measured path-loss conditions are included in this report.  The authors hope that the data presented here, along with future sets of data, can be used to develop a complete suite of test methods, not only for RF-based PASS systems, but also for other RF-based electronic safety equipment.  The path-loss values obtained here are general and could be used to develop standards for other equipment as the need arises for standards for these systems.

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In Ireland … 10 UHF Channels have been allocated to the Fire Services for use with hand portable radios …

Ireland: The Fire Services Council's Firefighter Handbook (2001) - Table 2.4.2
Ireland: The Fire Services Council’s Firefighter Handbook (2001) – Table 2.4.2. Click to enlarge.

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SDI Practice Announcement – New 32 Storey Hotel in China

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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2.  The ‘Design Professional in Responsible Charge’ !

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

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

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

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3.  Some Sustainable Design Performance Targets

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

A.   Basic Functional Requirements … the Building shall comply with the Basic Requirements for Construction Works – elaborated in Annex I of European Union (EU) Regulation No.305/2011 of the European Parliament and of the Council, of 9 March 2011, laying down Harmonized Conditions for the Marketing of Construction Products and Repealing Council Directive 89/106/EEC.

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

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

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

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

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

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

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D.   Project-Specific Sustainable Fire Engineering Design Objectives

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

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Mainstream Good Design & Accessibility for All Signage ?

2013-03-06:   Further to an earlier Post, dated 30 November 2012 … on Sustainable Accessibility for All

Accessibility IS a Fundamental Human Right !

‘ For many Weak and Vulnerable People, today’s Complex Human Environment is inaccessible and unsafe … a hostile ‘reality’ which prevents independent functioning and participation in a local community;  it is a blatant denial of their human rights.’

Relevant Human Environment (social – built – virtual – institutional) Factors … factors which are external, or extrinsic, to the context of a person’s life and living situation … include policies and standards, negative attitudes and stigma, lack of services, problems with service delivery, inadequate funding, lack of accessibility in the built environment and to electronic, information and communication technologies, lack of consultation and involvement, and an absence of reliable data and evidence.

Accessibility for All …

Take a really close look at the photograph below … and see a staircase which, in spite of all the legislation in the EU Member States, contravenes almost every accessibility-related design guideline.  It is far from being an unusual scene in our European Built Environment …

Staircase Egress - Unsafe, Difficult Accessibility !!
Photograph taken by CJ Walsh. 2009-10-31. Click to enlarge.

Now, imagine the consequences of one, tiny slip …

Which is why our concern must be with Accessibility for All … which includes consciously thinking about children under the age of 5 years, women in the later stages of pregnancy, and frail older people (not all older people !) … and how they use and interact with their surroundings.

In addition, however … our attention must also turn to the large numbers of people, in all of our societies, with health conditions which result in serious impairments, activity limitations and participation restrictions.  As a prime example, consider the Big-4 Non-Communicable Diseases (NCD’s): Cardiovascular Diseases (e.g. heart attacks and stroke), Cancers, Diabetes, and Chronic Lung Diseases.

These 4 NCD’s – targeted in a World Health Organization (WHO) Global NCD Campaign – share health risk factors (tobacco use, unhealthy diet, lack of physical activity, harmful alcohol use) … cause more than 36 million deaths annually (almost 80 % of deaths, from such diseases, occur in low and middle-income countries) … and result in a high proportion of disability (66.5 % of all years lived with disability in low and middle income countries).

NCD’s can limit one or more of a person’s major life and living activities … such as walking, eating, communicating, and caring-for-oneself.  Examples of common NCD-related impairments include paralysis due to stroke, and amputation as a result of diabetic neuropathy.

When Easily Assimilated Signage IS Essential in Buildings …

Good Architectural Design IS ‘intuitive and obvious’ for building users … design characteristics which are critical in the case of Fire Engineering Design.  However, what is intuitive and obvious in Ireland may not be so intuitive and obvious in Turkey … and what is intuitive and obvious in Europe will certainly not be intuitive and obvious in Africa, India, or China.

Architectural & Fire Engineering Design must, therefore, be adapted to Local conditions … culture, social need, etc., etc.

When a building is NOT ‘intuitive and obvious’ for the broad range of potential building users … easily assimilated signage IS essential …

International Standard ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’ was published in December 2011, as a full standard.  In its Introduction, ISO 21542 is linked to the U.N. Convention on the Rights of Persons with Disabilities (CRPD) … almost like an umbilical cord.

The scope of ISO 21542 covers public buildings.  The Accessibility Agenda in the U.N. Convention is very broad … so much standardization work remains to be completed at international level.

Concerning Accessibility Symbols and Signs … reference should be made to ISO 21542: Clause 41 – Graphical Symbols … and on Pages 106, 107, 108, and 109 … the following will be found:

  • Figure 66 – Accessible Facility or Entrance ;
  • Figure 67 – Sloped or Ramped Access ;
  • Figure 68 – Accessible Toilets (male & female) ;
  • Figure 69 – Accessible Toilets (female) ;
  • Figure 70 – Accessible Toilets (male) ;
  • Figure 71 – Accessible Lift / Elevator ;
  • Figure 72 – Accessible Emergency Exit Route.

I use the word ‘accessibility’, and not ‘access’ … because Accessibility has been defined in ISO 21542 as including … ‘access to buildings, circulation within buildings and their use, egress from buildings in the normal course of events, and evacuation in the event of an emergency’.

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

During the very long gestation of ISO 21542, an overwhelming consensus emerged in favour of using the term Accessibility for All … thereby sidestepping the thorny issue of different design philosophies which are described as being accessibility-related but, in practice, are limited and/or no longer fit-for-purpose.

'Accessibility for All' Symbol ?The Accessibility Symbol used throughout ISO 21542 is shown above.  I know that a small group of people from different countries worked very hard on this particular part of the standard.  My only contribution was in relation to the inclusion of Figure 72, concerning Fire Evacuation.

This ‘accessibility’ symbol is an attractive, modern and, of course, abstract representation of a concept … a person with an activity limitation using a wheelchair.  The symbol succeeds very well in communicating that concept.

However … as an Accessibility for All Symbol … encompassing people with other than functional impairments, e.g. hearing and visual impairments … and children under the age of 5 years, women in the later stages of pregnancy, frail older people … and people with the four main types of non-communicable disease discussed above … is this symbol, also, limited and no longer fit-for-purpose ??

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Proposed New Sign for 'Area of Rescue Assistance'

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Shown next, above, is the proposal for a new Area of Rescue Assistance Sign … which is contained in ISO 7010:2011 / FDAM 115 (2013).  While it is nice to finally see this Safety Sign appear in the mainstream of safety signage … the title being proposed for the sign and the explanatory texts which accompany it are very problematic …

  • The technical term being proposed – Evacuation Temporary Refuge – is too long and too difficult to understand ;
  • The explanatory texts which accompany this Sign are very confusing and misleading.

This problem has arisen because the people who drafted ISO 7010:2011 / FDAM 115 (2013) hadn’t a bull’s notion that ISO 21542 even existed !

In ISO 21542, we use the term Area of Rescue Assistance … which is easy for everybody to understand, including building users, building managers and firefighters, etc., etc.

We also explained, in ISO 21542, that a Place of Safety is a remote distance from the building … not anywhere inside the building !

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Mainstreaming Disability …

U.N. CRPD – Preamble

(g)  Emphasizing the importance of mainstreaming disability issues as an integral part of relevant strategies of sustainable development,

As ‘disability’ moves closer towards … and is integrated and fully included in the ‘mainstream’ of sustainable community life and living … it is absolutely imperative that individuals and organizations who make up the Disability Sector become much more cohesive (far less fractious within) … that they begin to fully understand the practices and procedures of the mainstream … and actively and robustly engage with that mainstream.

It is ridiculous, for example, that a large amount of the Sector’s energy is still being diverted into meaningless meditations and endless tracts on whether it is ‘universal design’, or ‘design-for-all’, or ‘inclusive design’, or ‘facilitation design’, etc … when an entirely new design paradigm is being demanded by a world (our small planet when seen from the moon !), which is experiencing enormous levels of human poverty, natural resource shortages, human rights violations, and severe weather events.  The overriding priority must be ‘real’ implementation … Effective Accessibility for All !

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'Earthrise' from Apollo 14
Colour photograph – ‘Earthrise’ – taken from the Apollo 14 Spacecraft … showing a bright colourful Earth, in a dense black ‘sky’, rising above the pale surface of the Moon. Click to enlarge.

NASA’s Gateway to Astronaut Photography of Earth

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And … Effective Accessibility for All is but one component of …

‘Social Wellbeing for All in a Sustainable Built Environment’

Refer also to …

2004 Rio de Janeiro Declaration on Sustainable Social Development, Disability & Ageing

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Update:  2013-05-31 …

While the wider international design community is working hard on developing an array of Accessibility Symbols to facilitate different health condition and impairment categories, and to suit different environmental situations, e.g. a fire emergency in a building … I recently encountered another interesting contribution …

Alternative Accessibility Symbol (USA-2011) - Functional Impairment
Click to enlarge. For more information: www.accessibleicon.org

Any comments ??

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

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

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

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

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

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

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

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

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

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

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

Negligent:  Lacking attention, care or concern.

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

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

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

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

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

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

and

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

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

1.   Protecting Human Health versus Reducing Risk to Safety

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

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

and …

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

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

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

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

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

Radon Activity in Buildings – Recommended Target Health Level

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

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

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

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

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

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

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

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

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

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

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

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

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3.   Regulatory Status of RPII’s Radon Prediction Maps

This is NOT a problem unique to Ireland.

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

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

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4.   SDI’s Acceptance of RPII Services

Please refer to SDI’s Corporate WebSite.

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

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

and

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

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

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‘Building External Lighting Design’ – An SDI Professional Service

2013-01-30:  The Energy Efficiency of Electrical Light Fittings continues to improve dramatically … and it’s about time too.  So much energy was needlessly wasted before !

Prior to the commencement of the External Lighting Design Project below … this prominent religious building in Dublin City was ‘pitch’ dark at night, almost a black hole in the local urban landscape, a depressing non-entity … people waiting at bus stops on each of the roads beside the building were nervous … muggings occasionally took place … litter was always being thrown into the grounds surrounding the building … evidence screaming out loud that nobody cared !

External Lighting Design Project - Prominent Religious Building, Dublin City, Ireland
Colour photograph showing the finished External Lighting Project for a prominent religious building in Dublin City, Ireland. Project Design and Supervision of Installation by CJ Walsh. Electrician: W. Fleming, Electrical Services. Click to enlarge.

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After Project Completion … the ‘presence’ of this building within the local community was enhanced to an extraordinary extent … it was at once seen to be at its centre … security issues at night were immediately resolved … the building looked as if people cared about it … and a special bonus … architectural features which usually went unnoticed by the public during the day were beautifully highlighted at night.

The Client Organization … in this case, a religious order … was so pleased with the finished work that they commissioned a professional photographer … and then used the image above on the Parish Christmas Cards to be distributed to parishioners.

The Moral of The Story for Clients/Client Organizations is … give serious consideration to how your building (whether it is a church, mosque, or synagogue) looks during daylight … and most importantly, during the long hours of darkness !

External Building Lighting is much more than mere decoration … it is an essential component in the sustainable design of any important / iconic building type !!

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SDI Contact Information

E-Mail:  cjwalsh@sustainable-design.ie

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

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