Ar C.J. Walsh Technical Blog – Registered Architect, Fire Engineer & Independent Technical/Building Controller …… International Expert on Accessibility for All (including Fire Safety) + 'Real' Sustainability Implementation !
2014-04-20:Traditional/Conventional Fire Engineering Practice is slowly, but inevitably, being transformed … in order to meet the regional and local challenges of rapid urbanization and climate change, the pressing need for a far more efficient and resilient building stock, and a growing social awareness that ‘sustainability’ demands much greater human creativity …
Design Target: A Safe, Resilient and Sustainable Built Environment for All
Essential Construction & Occupancy Start-Up Processes: Careful Monitoring & Reporting – Independent Verification of Performance (MRV)
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Sustainable Fire Engineering Design Solutions:
Are Reliability-Based …
The design process is based on competence, practical experience, and an understanding of ‘real’ building performance and resilience during Extreme Man-Made Events, e.g. 2001 WTC 9-11 Attack & 2008 Mumbai Hive Attacks, and Hybrid Disasters, e.g. 2011 Fukushima Nuclear Incident … rather than theory alone.
Are Person-Centred …
‘Real’ people are placed at the centre of creative design endeavours and proper consideration is given to their responsible needs … their health, safety, welfare and security … in the Human Environment, which includes the social, built, economic and virtual environments.
Are Adapted to Local Context & Heritage* …
Geography, orientation, climate (including change, variability and severity swings), social need, culture, traditions, economy, building crafts and materials, etc., etc.
[* refer to the 2013 UNESCO Hangzhou Declaration]
In Sustainable Design … there are NO Universal Solutions !
Design Objectives:
To protect society, the best interests of the client/client organization and building user health and safety, and to maintain functionality under the dynamic, complex conditions of fire … Project-Specific Fire Engineering Design Objectives shall cover the following spectrum of issues …
Protection of the Health and Safety of All Building Users … including people with activity limitations (2001 WHO ICF), visitors to the building who will be unfamiliar with its layout, and contractors or product/service suppliers temporarily engaged in work or business transactions on site ;
Protection of Property from Loss or Damage … including the building, its contents, and adjoining or adjacent properties ;
Safety of Firefighters, Rescue Teams and Other Emergency Response Personnel ;
Ease and Reasonable Cost of ‘Effective’ Reconstruction, Refurbishment or Repair Works after a Fire ;
Sustainability of the Human Environment – including the fitness for intended use and life cycle costing of fire engineering related products, systems, etc … fixed, installed or otherwise incorporated in the building ;
Protection of the Natural Environment from Harm, i.e. adverse impacts.
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More Specifically … with Regard to Resilient Building Performance during a Fire Incident and the ‘Cooling Phase’ after Fire Extinguishment:
1. The Building shall be designed to comply with the Recommendations in the 2005 & 2008 NIST(USA) Final Reports on the World Trade Center(WTC) 1, 2 & 7 Building Collapses.
In one major respect, the 2005 NIST Report is flawed, i.e. its treatment of ‘disability and building users with activity limitations is entirely inadequate. The Building shall, therefore, be designed to comply with International Standard ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’, which was published in December 2011.
2. The Building shall remain Serviceable, not just Structurally Stable(!) … until all buildings users (including those users with activity limitations waiting in ‘areas of rescue assistance’) have been evacuated/rescued to an accessible ‘place of safety’ which is remote from the building, and have been identified … and all firefighters, rescue teams and other emergency response personnel have been removed/rescued from the building and its vicinity.
The Building shall be designed to resist Fire-Induced Progressive Damage and Disproportionate Damage. These requirements shall apply to all building types, of any height.
Under no reasonably foreseeable circumstances shall the Building be permitted to collapse !
3. The Building shall be designed to comfortably accommodate and resist a Maximum Credible Fire Scenario and a Maximum Credible User Scenario.
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Concerted International Research is Needed …
To creatively resolve the direct conflict which exists between Sustainable Building Design Strategies and Traditional/Conventional Fire Engineering.
An example … for cooling, heating and/or ventilation purposes in a sustainable building, it is necessary to take advantage of natural patterns of uninterrupted air movement in that building. On the other hand, fire consultants in private practice, and fire prevention officers in authorities having jurisdiction, 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. The result is that the sustainability performance of the building is seriously compromised.
If, however, adequate independent technical control is absent on the site of a sustainable building … it is the fire safety and protection which will be seriously compromised !
To effectively deal with the fire safety problems (fatal, in the case of firefighters) which result from the installation of Innovative Building/Energy/EICT Systems and Products in Sustainable Buildings.
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These are appropriate tasks for a new CIB W14 Research Working Group VI: ‘Sustainable Fire Engineering Design & Construction’ !
2013-09-10: Recently, much ado has been made in the technical press about a New Multi-Storey Office Block in Vienna which has achieved the German ‘Passivhaus’ (Passive House) Standard …
Is There A Problem ?? Yes !!
1. It takes approximately 3 Years of Building Occupation, by ‘real’ people, before the actual performance of a building can be properly monitored and reliably shown. The building is still ‘drying out’ for the first year. It takes at least one to two years of running the complex technologies and systems in today’s buildings … training people how to operate them efficiently and effectively … and fine-tuning and de-bugging as you go along … before everything begins to work together, as originally intended during the building design stage. Then, if all goes well … in the third year of occupation, the careful (i.e. accurate and reliable) monitoring of ‘real’ building performance, by means of portable measuring devices and devices installed within the construction, can commence.
So … what exactly has achieved the German ‘Passivhaus’ (Passive House) Standard … the design intent for the building, or the building’s ‘real’ performance ???
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2. Much more fundamentally … achieving this Standard is a good starting point … but in a new building project … It Is Not Enough !
A. Energy Conservation and Efficiency Burden Sharing by Different Building Types
Separate strategies are required to greatly improve the energy performance of:
existing buildings … onto which many energy efficiency measures can be successfully grafted, but it will be difficult work and will certainly not be cheap ;
buildings of historical, architectural or cultural importance … the integrity of which must be protected ; and
new buildings and facilities … which must therefore carry the major burden.
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B. Paradigm for New Buildings – A ‘Positive Energy’ Return + Assured Building User Comfort
Primary Energy Consumption should be less than or equal to 15 kWh/m2/yr.
And …
Renewable Energy and Heating Systems should contribute a reliable quantity of energy, per year, which covers the following:
i) the Building’s/Facility’s Primary Energy Consumption ;
ii) an Energy Efficiency Degradation Factor which takes account of the degradation in energy efficiency …
(a) normally expected during the life cycle of renewable energy and heating systems installed in the building. The rate of degradation will depend on the quality of maintenance and servicing ; and
(b) caused by wasteful patterns of building management and/or use ;
iii) the energy consumed by Private Transport associated with the building or facility ;
iv) an Energy Return to an Intelligent District, Local or Regional Grid exceeding, by a multiple of 3 (three), the total energy consumed by the Building/Facility (including its Energy Efficiency Degradation Factor) and any associated Private Transport.
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Notes:
Primary Energy includes the energy required to generate, transmit and distribute electricity, as well as energy directly consumed on site.
User Thermal Comfort = Air Temperature + Mean Radiant Temperature + Air Humidity + Air Velocity, i.e. draughts (ISO 7730).
2013-07-19: Once upon a time, back in 1979, when I was flying to Sydney, Australia … one of the scheduled stops on the route was Bahrain and the New International Airport Terminal there. In spite of the flashy and expensive building, I noticed how obsolete looking (and functioning) were the fittings in the toilet area. Could it possibly be, I wondered, that the Arab Gulf Region was being supplied with shoddy, second rate construction products from you-know-where ??
Fast forward to a few years ago … in Riyadh, Saudi Arabia … and I encountered one building – the same building – where one half had a 110 Volt electrical supply, and the other half had a 220 Volt supply. Amazing !?! Two different consultants, or contractors, or whatever … one from North America, and the other from Europe … with the Saudis in the middle, having to tolerate this nonsense !!
Photograph taken by Brian Candy. 2012-05-28. Click to enlarge.
DOHA City Fire – Monday, 28 May 2012 …
I distinctly remember that some Irish people who had actually witnessed the Fatal Fire Incident at the ‘Villaggio’ Shopping Mall (www.villaggioqatar.com), in Doha (capital city of Qatar) … were afterwards talking to Mr. Joe Duffy, on the lunchtime ‘Liveline’ Programme (Ireland’s RTE Radio 1 Station).
19 People were killed on that Monday morning in Doha … 13 Children, 4 Teachers, and 2 Firefighters. Many more were injured from inhaling toxic smoke.
According to various news reports … an electrical fire, caused by a light fitting (which was not ‘fit for its intended use’) in a Nike Shop, engulfed a section of the shopping centre … spreading to the Gympanzee Drop-and-Shop Childcare Centre on the first floor.
The staircase leading to the Childcare Centre collapsed … trapping victims inside. One of their fire exits led directly to the seat of the fire, while the other fire exit was locked from the outside.
In addition, the ‘Villaggio’ – a luxury mock-Italian shopping centre (one of the most popular in the country !) where customers could ride around Venetian-style Canals, in Venetian-style Gondolas – was later found to be in breach of legislation because Essential Fire Safety Measures were either inadequate or missing, at the time of the fire: the fire sprinkler system was not working properly; inflammable paint and decorative mouldings were used in the construction; the building did not have effective fire evacuation procedures in place; the building was not equipped with proper fire-fighting equipment; and the fire alarm wasn’t loud enough.
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A Qatari Court – Thursday, 20 June 2013 …
The recent outcome from this Qatari Court Case has been nagging at me ever since I saw the news on Al Jazeera (English) … www.aljazeera.com
Only Some of the People having Control / Responsibility were convicted for the Negligence which resulted in the 19 Deaths, and many injuries, at the 2012 ‘Villaggio’ Fatal Fire Incident.
Four people received six-year jail terms, while the fifth received a five-year term. All five are currently out on appeal, and will remain out of custody until the appeals process is completed.
Those convicted include Two Co-Owners of the Childcare Centre, and Members of the Mall’s Management Team. Sheikh Ali Bin Jassim Al Thani, one of the co-owners, is also currently Qatar’s Ambassador to Belgium … while Iman Al-Kuwari, the other co-owner, is the daughter of Qatar’s Culture Minister.
Two other defendants, including the Mall’s Assistant Manager and Head of Security, were cleared of all charges.
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Other People having Control / Responsibility were also Careless, Incompetent, and Negligent …
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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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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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 …
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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Photograph taken by CJ Walsh. 2013-07-09. Click to enlarge.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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Photograph taken by CJ Walsh. 2013-07-09. Click to enlarge.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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Photograph taken by CJ Walsh. 2013-07-09. Click to enlarge.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.
2013-06-09:Further to yesterday’s post … and my use of the phrase ‘Adapted to Local Context and Heritage (fr: le Patrimoine)’ … in relation to Sustainable Fire Engineering Design Solutions … or, indeed, Sustainable Design Solutions generally …
The International Council on Monuments and Sites (ICOMOS) … has just published the hard-copy version of … ‘Le Patrimoine, Moteur de Développement : Enjeux et Projets‘ … the proceedings from the 2011 ICOMOS International Scientific Symposium, which was held in conjunction with the 17th ICOMOS General Assembly in early December 2011 … and organized by ICOMOS-France (www.icomosfrance.fr).
This bilingual (French and English) document provides a summary of the 4 Main Issues discussed during the Paris Symposium.
Manifested here … is a profound re-imagining of the concept of ‘heritage’, and its symbiotic relationship with ‘local context’ … which also now facilitates a synergetic fusion of ‘heritage’ with mainstream sustainable development theory and implementation. I have highlighted key passages …
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HERITAGE – DRIVER OF DEVELOPMENT
The Theme of the International Scientific Symposium, which forms part of the ICOMOS General Assembly, is the role of heritage in the creation of tomorrow’s society.
The effects of globalization, which are manifested in growing trends towards standardization and westernization, bring various forms of instability to human societies. Until now, heritage has been confined to the role of passive conservation of the past, and so has often been seen as a burden hindering development. In the future, it should be called upon instead to play a major role, re-establishing cultural identity and diversity as key reference points for development; these factors are currently endangered, yet vital. There is therefore a need to reassess the role of heritage in a constructive way.
The concept of heritage, which ranges from designated historic monuments to a jumble of memories, first needs a clear definition which identifies its inherent nature and sets out its boundaries and limits, now and in the future.
As it would be impossible to cover all these issues at the Symposium, it is proposed to focus on the following four issues, chosen for their fundamental importance or contemporary relevance …
Photograph taken by CJ Walsh. 2009-08-14. Click to enlarge.
1. Regional Development
As more and more people abandon small towns and the countryside, migrating to large conurbations, urban development has become anarchic, ad-hoc and difficult to control. This has already had serious, even catastrophic, results … in particular:
– The disruption of spatial scale and the loss of landmarks ;
– The breakdown of social relationships, loss of communal solidarity, concerns over security, extremist and violent demonstrations ;
– An imbalance between the city – where most concerns now focus and where most development projects take place – and the countryside, where the issue is no longer merely rural decline, but rather the complete socio-economic and cultural collapse of forgotten populations ;
– The squandering and trivialization of space, which is a non-renewable resource, and in particular the loss of landscapes and farmland, resulting from both extensive urban encroachment and land being left to lie fallow.
It is vital to return to a more balanced form of development. This will be achieved by replacing the principle of urban expansion with that of regional development, which takes into account both the countryside and secondary urban centres (small and medium-sized towns), as part of a balanced network. In this context, lessons from our heritage will again be valued as an inspiration for new developments: time-honoured frameworks, traditional plot sizes, methods of organization (urban historic core zones), communication (by land – rail – water), and energy generation (small-scale solar and hydroelectric power stations), etc.
Photograph taken by CJ Walsh. 2009-08-14. Click to enlarge.
2. Sustainable (Human & Social) Development – Return to the Art of Building !
The second half of the 20th Century was marked by the frantic exploitation of fossil fuels and is credited with the international spread of Western lifestyles and buildings, said to represent ‘progress’ but nevertheless creating a decisive break with traditional models. The goals we have today for energy saving and recycling require a fundamental change in the character of both new and old buildings, in line with the following three points:
– Expertise in Re-Use.Until the 1950’s, heritage buildings – especially vernacular ones – provided countless examples of successful adaptation to the physical environment (location, orientation, protection from sun, wind, and climate); use of local materials (earth – wood – stone, etc.); traditional techniques providing / guaranteeing the greatest opportunities to acquire and perfect artisanal skills; and an optimum capacity for recycling. The resulting buildings address today’s requirements for sustainable development particularly well. Where historic buildings are capable of residential re-use according to modern sustainability criteria, we must be able to measure and maximise their current performance before adapting them according to new artificial design standards.
– Expertise in Building.In terms of new construction, recent examples have shown the ability of traditional practices to create architecture that is indisputably creative and modern/contemporary, and offer an alternative to artificial solutions proposed in response to new standards.
– Adapting to Sustainable Living.Rather than putting the entire onus on the built heritage, we must question our expectations about comfort and utilization. We need to abandon attempts to use sites for activities for which they are fundamentally not suited; modify usage according to the seasons (closing down places that are difficult to heat in winter); and, finally, reconsider our demands in terms of comfort, which have grown excessively and unreasonably over the last decades. The progress that would be made in the fields of environmental and public health is well known.
Photograph taken by CJ Walsh. 2009-08-14. Click to enlarge.
3. Development and Tourism
Heritage is a major part of the tourist industry, but at the same time, because of the mass consumption to which it is increasingly subject, it runs the risk of becoming meaningless, by fluctuating between preservation of museum pieces and theme-park caricatures. Cut off from its context, the real significance of heritage is drowned out by a feeble reflection, and its very nature is altered by excessive numbers of visitors and the facilities installed for them.
Several courses of action are available, among others:
– Rendering identification with cultural heritage tangible … by revealing and interpreting heritage in all the richness of its context and distinctiveness, and by encouraging public awareness of history through education and the wider media.
– Controlling public access … so as both to limit physical erosion and to ensure the comfort of visitors and provide the best conditions for them to understand and appreciate the value of heritage. Some preliminary reports on trials successfully undertaken at a number of buildings and Grands Sites [designated French cultural landscapes] may help in developing guidelines.
Photograph taken by CJ Walsh. 2009-08-14. Click to enlarge.
4. Economics of Development
“The Amphitheatre at Nîmes and the Pont du Gard have brought more to France than they ever cost the Romans.” This quotation from Abbé Grégoire in the second year of the French Republic remains valid today. Investment in our heritage produces particularly attractive returns. The cultural sector fully understands this, but adopts methods that tend to be rather commercial.
This investment must be better directed, by identifying targets and striving more for qualitative results rather than short-term profits.
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 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 …
Creative Fire Engineering Concepts and Building Systems
Fire-Induced Progressive Damage in Buildings
Human Behaviour and Abilities in a Fire Situation
Building Design for Firefighter Safety
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 !
Click the Link Above to read and/or download PDF File (193 Kb)
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.
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.
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 …
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 Building … RMJM 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’.
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 !) …
Click to enlarge.
European Commission COM(2013) 169 final – Brussels, 2013-03-27
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 ??
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.]
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 !
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 ?
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) !
Submissions on India’s Draft Amendment No.1 to the 2005 National Building Code (SP 7:2005) concerning the Proposed Incorporation of a New Part 11: ‘Approach to Sustainability’ had to arrive at the Bureau of Indian Standards (BIS), in Dilli … by e-mail … no later than Friday last, 15 March 2013 …
Click to enlarge.
Indian NBC, Proposed Part 11 on ‘Sustainability’ – December 2012 Consultation
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Extract From Foreword (Page 7):
‘ Developed nations’ approach to sustainability generally concentrates on energy conservation through high technology innovations, and use of products, materials and designs with lower embodied energy. Their green ratings are based on intent, which implies expert inputs and simulation. The Indian construction industry will do better using our traditional wisdom and practices, building in harmony with nature through regional common knowledge, consuming as little as necessary, applying low cost technology innovations, using recycled materials, and recognizing performance (not intent) through easily measurable parameters wherever feasible.’
How Right They Are About Prioritizing ‘Real’ Performance !!
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And Just Before That Extract Above:
‘ The authentic (my insert !) Indian way of life is aparigraha (minimum possessions), conservation (minimum consumption), and recycling (minimum waste). These three attributes are the guiding principles for sustainable buildings as well. With these attributes and its rich heritage, India can make a substantial contribution in this field and eventually lead the world on the path of sustainability.’
An Overly Ambitious Target ? Perhaps Not.
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SDI Supporting India’s National Sustainable Buildings Strategy …
We very much welcome this opportunity to make a Submission on India’s Draft Amendment No.1 to the 2005 National Building Code (SP 7:2005) concerning the Proposed Inclusion of a New Part 11 ‘Approach to Sustainability’.
This IS an important development for India … and it DOES mark a substantial contribution to this field, at international level. We wish that other countries would follow your example … particularly China, the other mushrooming economies in South-East Asia, and the Arab Gulf States.
You may not be aware that Sustainable Design International (SDI) has been specializing in the theory and implementation of a Sustainable Human Environment (social, built, virtual, and economic) since the mid-1990’s.
And, for example … in September 2007, we were invited to make a series of Keynote Presentations to 20 Senior National Decision-Makers, from both the public and private sectors, at a 2-Day Workshop which was organized for us in Lisboa, Portugal. If invited, we would be delighted to repeat this valuable exercise in Dilli, Bengaluru, and other suitable venues in India.
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IF India is to lead the world on this particular track, i.e. Sustainable Buildings, a coherent philosophy must be outlined in the Proposed New Part 11 of the National Building Code, and a clear direction must also be given there to decision-makers, e.g. clients/client organizations, and designers.
Certain essential content must be included in Part 11. With regard to an improved layout of Part 11, please review the attached SDI Document: ‘SEED Building Life Cycle’ (PDF File, 55 Kb) .
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Because you have prioritized ‘real’ building performance over pre-construction design ‘intent’, it is appropriate to begin our comments here …
1. Sustainability Performance Indicators
In order to prioritize ‘real’ performance, the monitoring of actual sustainability performance in completed and occupied buildings must be comprehensive, accurate and reliable. Indicators of sustainability performance must, therefore, be included in all sections of the Proposed New Part 11.
Sustainability Performance Indicators provide important signposts for decision-making and design in many ways. They can translate physical and social science knowledge into manageable units of information which facilitate the decision-making and design processes. They can help to measure and calibrate progress towards sustainable development goals, and sectoral sustainability targets. They can provide an early warning to prevent economic, social and environmental damage and harm. They are also important tools to communicate ideas, thoughts and values because, as statisticians say: “We measure what we value, and value what we measure”.
Performance Indicators may be both quantitative and qualitative … but must cover all stages of the building process, i.e. project feasibility and performance specification, spatial planning, design, construction, management, operation, maintenance and servicing, de-construction, disposal, final site clean-up and sustainable repair.
While many, though not all, types of building performance can be successfully monitored using lightweight portable equipment … a certain number of monitoring devices must also be permanently installed in the building during construction. A facility to reliably feed the output from these devices back to data collection points, on site and remote, must also be incorporated in the Building’s Intelligent Management System.
Management and collation of sustainability performance data must be reliable. Uncertainty is always present. Therefore, Statements of Uncertainty should always be attached to ‘reliable’ data.
Safety Factors should always be included when targeting critical ‘health and safety’ related types of performance.
Sustainability Performance Indicators must be directly comparable across different Global Regions … within Asia, across different countries … and within India, across different States. A Balanced, Harmonized Core Set of Indian Performance Indicators should be quickly developed. A Balanced ‘Local’ Set of Performance Indicators will always be necessary.
People tasked with monitoring sustainable building performance must be competent … and independent, i.e. be unconnected to client, design and construction organizations.
Specifically in relation to Energy Performance, the targets to be achieved in new buildings must be far more ambitious. Please review the attached SDI Document: ‘SEED Positive Energy Buildings’ (PDF File, 29 Kb) .
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2. Properly Defining ‘Sustainable Development’
As currently drafted … Definition 2.26 Sustainable Development, on Page 13 of the Proposed New Part 11, is not only ambiguous, it is inadequate for India’s needs … and it is barely the first half of the full, correct definition …
Sustainable Development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs. It contains within it two key concepts:
the concept of ‘needs’, in particular the essential needs of the world’s poor, to which overriding priority should be given ; and
the idea of limitations imposed by the state of technology and social organization on the environment’s ability to meet present and future needs.
[ Please refer to the 1987 Report of the World Commission on Environment & Development (WCED): ‘Our Common Future’ – Chapter 2, Paragraph 1.]
This original definition in the 1987 WCED Report IS appropriate for India … and it must become the core definition at the heart of India’s National Sustainable Buildings Strategy !
A careful reading of the full definition makes it clear that there are Many Aspects to this intricate, open, dynamic and still evolving concept … the most important of which are: Social, Economic, Environmental, Institutional, Political, and Legal.
It is a Fundamental Principle of Sustainability, and one of its Primary Values … that Implementation must be Synchronous, Balanced and Equitable across All Aspects of Sustainability.
The ‘Green Agenda’ merely considers Environmental Aspects of Sustainability … in isolation from all of the other Aspects ! This is a fatal flaw which must be avoided in the Proposed New Part 11 !!
[ I made many references to this issue during the FSAI Conferences in India ! ]
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3. Sustainability Impact Assessment (SIA) for India !
Rather than Environmental Impact Assessment … surely the Proposed New Part 11: ‘Approach to Sustainability’ must now use, explain and discuss Sustainability Impact Assessment instead !?!
Sustainability Impact Assessment (SIA)
A continual evaluation and optimization assessment – informing initial decision-making, or design, and shaping activity/product/service realization, useful life and termination, or final disposal – of the interrelated positive and negative social, economic, environmental, institutional, political and legal impacts on the synchronous, balanced and equitable implementation of Sustainable Human & Social Development.
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4. A Robust Legal Foundation for ‘Sustainable Human & Social Development’
Paragraph 4 (Chapter 2, 1987 WCED Report) states …
‘ The satisfaction of human needs and aspirations is the major objective of development. The essential needs of vast numbers of people in developing countries – for food, clothing, shelter, jobs – are not being met, and beyond their basic needs these people have legitimate aspirations for an improved quality of life. A world in which poverty and inequity are endemic will always be prone to ecological and other crises. Sustainable development requires meeting the basic needs of all and extending to all the opportunity to satisfy their aspirations for a better life.’
Trying to list the essential needs of people / the basic needs of all is a very difficult task … but it is work which has been on-going, at international level, since just after the Second World War.
The essential needs of people / the basic needs of all … are specified as being Human Rights and Fundamental Freedoms, and are already fully described within the extensive framework of International Legal Rights Instruments.
Which is why, many years ago, SDI developed this definition for Sustainable Human & Social Development … in order:
to give this concept a robust legal foundation ; and
(because of widespread confusion in media, political and academic circles) … to clearly establish that we are talking about sustainable human and social development, and not sustainable economic development, or any other type of development !
Sustainable Human & Social Development
Development which meets the responsible needs, i.e. the Human & Social Rights*, of this generation – without stealing the life and living resources from future generations … especially our children, and their children … and the next five generations of children.
*As defined in the 1948 Universal Declaration of Human Rights.
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5. Climate Change Adaptation & Resilient Buildings in India ?
Atmospheric Ozone Depletion and Climate Change are mentioned, here and there, in the Proposed New Part 11. The important implications of these phenomena for Sustainable Building Design in India are not explained … at all. Why not ?
To properly respond to these phenomena, both must be integrated into India’s National Sustainability Strategies & Policies.
At the very least … we strongly recommend that Design Guidance on Climate Resilient Buildings be immediately drafted. This guidance must be appropriate for implementation in each of the different climatic regions of India.
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6. A Sustainable Indian Built Environment which is Accessible for All !
Barrier Free is mentioned, here and there, in the Proposed New Part 11. This is to be warmly welcomed and congratulated. Under Social Aspects of Sustainable Human & Social Development … this is an essential attribute of a Sustainable Built Environment ! However, no guidance on this subject is given to decision-makers or designers. Why not ?
However, you should be aware that India ratified the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) on 1 October 2007. For your convenience, I have attached copies of the Convention in English, Hindi and Tamil.
You should also be aware that, in December 2011, the International Standards Organization (ISO) published ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’. In its Introduction, ISO 21542 is directly linked to the U.N. Convention … almost like an umbilical cord. The scope of this Standard currently covers public buildings. As the Accessibility Agenda in the U.N. Convention is very broad … much standardization work remains to be finished at international level.
The correct term … Accessibility for All … has been defined in ISO 21542 as including … ‘access to buildings, circulation within buildings and their use, egress from buildings in the normal course of events, and evacuation in the event of an emergency’.
A note at the beginning of the standard also clarifies that Accessibility is an independent activity, i.e. assistance from another person should not be necessary … and that there should be an assurance of individual health, safety and welfare during the course of those (accessibility-related) activities.
In order to fulfil India’s legal obligations as a State Party to the U.N. Convention on the Rights of Persons with Disabilities … adequate Design Guidance on Accessibility must be included in the Proposed New Part 11, supported by ISO 21542.
In addition, the Bureau of Indian Standards (BIS) should immediately adopt ISO 21542 as the Indian National Standard on Accessibility for All … IS / ISO 21542.
[ I made many references to this issue during the FSAI Conferences in India ! ]
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7. Fire Safety & Protection for All in Sustainable Indian Buildings ?
Yes … there is 1 mention of ‘fire safety’ and 40 other references to ‘fire’ in the Proposed New Part 11 … but no design guidance. Why not ?
You should be aware that there is a fundamental conflict between Sustainable Building Design Strategies and the current state-of-the-art in Fire Engineering Design. As a good example … for cooling, heating and/or ventilation purposes in a sustainable building, it is necessary to take advantage of natural patterns of air movement in that building. On the other hand, fire engineers in private practice, and fire prevention officers in Authorities Having Jurisdiction (AHJ’s), will demand that building spaces be strictly compartmented in order to limit the spread of fire and smoke … thereby dramatically interfering with those natural patterns of air movement.
In everyday practice, there is a vast chasm in understanding and communication between these two very different design disciplines. As a result, serious compromises are being enforced on Sustainability Building Performance. If, on the other hand, adequate independent technical control is absent on the site of a Sustainable Building … it is the fire safety and protection which is being seriously compromised.
A range of critical fire safety issues (fatal, in the case of firefighters) are also arising with the Innovative Building Products and Systems being installed in Sustainable Buildings.
Because the emphasis is on pre-construction design ‘intent’ rather than the ‘real’ performance of the completed and occupied building … all of these problems are being conveniently ignored, and they remain hidden from everybody’s view.
This must be addressed in the Proposed New Part 11.
[ I made many references to this issue during the FSAI Conferences in India ! ]
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C. J. Walsh – Consultant Architect, Fire Engineer & Technical Controller – Managing Director, Sustainable Design International Ltd. – Ireland, Italy & Turkey.
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 …
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 …
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.
