Useful UK Update
On 17 December 2019, two and a half years after Grenfell Tower fire on 14 June 2017, I wrote a LinkedIn article "Textbook Technical Travesty" about an error in Fire Hazards of Exterior Wall Assemblies Containing Combustible Components.
https://www.dhirubhai.net/pulse/textbook-technical-travesty-ian-abley/
Exactly three and a half years after Grenfell Tower fire on 14 December 2020 Nathan White published an Errata and Addendum to his Fire Protection Research Foundation initiated Fire Hazards of Exterior Wall Assemblies Containing Combustible Components via the National Fire Protection Association. No comment was made to my knowledge on the Errata by Michael Delichatsios, Nathan White's co-author in 2014. At least Michael Delichatsios has never corresponded in the last year, while Nathan White has.
"The Errata primarily relate to an incorrect summary of Class 0 for England and Wales as defined by Approved Document Part B Volume 2 (2013)."
This is the double-definition of Class 0, approved by the Ministry since the 1984 Building Act, but authored in the Building Regulations before that back to the 1970s, which Fire Hazards of Exterior Wall Assemblies Containing Combustible Components failed to understand and communicate.
Had no Fire Engineer noticed that the double-definition of Class 0 meant 13b. made a mockery of 13a., so that "Class 0" specifications making no distinction were vulnerable?
No doubt some Fire Engineers had, somewhere. But to my knowledge the double-definition problem went unremarked upon in any wider construction Trade Press before Grenfell Tower fire. A deafening technical silence from Fire Engineering professionals.
Was the NFPA made aware of the error before 17 December 2019?
Did any Consultant seriously rely upon the erroneous UK related sections of Fire Hazards of Exterior Wall Assemblies Containing Combustible Components?
I have no idea...
But there is more of direct importance to the Grenfell Tower Inquiry, and the growing UK Cladding Scandal, described by Dominic Lawson in The Times as "becoming our worst corporate scandal". He doesn't fully appreciate that the scandal is about the interpenetration of corporations and the state as author of the Approved Document, practically defeating the intent of the law of Requirement B4-(1) in Schedule 1. of the 2010 Building Regulations.
https://www.thetimes.co.uk/article/grenfell-is-becoming-our-worst-corporate-scandal-bqk0grrx0
In understated terms the Errata puts it like this:
"It is noted that the 2013 Approved Document B Volume 2 reaction to fire provisions for external surfaces are less stringent than for insulation."
The authors had previously thought Cladding had to be Limited Combustibility, when at least Nathan White now recognises, as do the NFPA, that only Insulation had to be Limited Combustibility on buildings with a storey over 18m above ground, as Paragraph 12.7 in ADBv2 (2013) as written. Unless, that is, a BS 8414 System Test was undertaken to BR 135 Criteria and the Cladding System built exactly as tested, or the whole project was Fire Engineered to BS 7974. The only two Ministry approved alternatives to compliance with Paragraph 12.7 for Insulation Materials and Products.
Paragraph 12.7 is for Insulation. NOT Cladding. The Errata also weakly states that:
"Approved Document B Volume 2 (2013) does not appear to clarify if the combustible core of an Aluminium Composite Panel (ACP) should be regulated as an insulation material or as “composite product” which would only require the external surface to be exposed when tested in BS 476:Part 7 and BS 476:Part 6, without testing the exposed core material."
Of course ADBv2 never confused Cladding Products with Insulation Materials and Products as Paragraph 12.7. That would have been remarkable before Grenfell Tower fire. How is it that Nathan White's Errata, checked by fellow Fire Engineers, is unsure about that?
This relates to the Ministry lie in Footnote 4. of Advice Note 1. on 30 June 2017, which insisted that Cladding Product, and specifically Aluminium Composite Material (ACM), or the Core as "filler", was included in Paragraph 12.7.
It is upon this Ministry lie, issued for Sajid Javid and Alok Sharma by Nick Raynsford's friend Melanie Dawes, who now runs OFCOM, that the Advice Note Series was published.
An Advice Note Series consolidated as Building safety advice for building owners, including fire doors, which the disastrous RICS EWS1 form is predicated upon.
https://www.rics.org/globalassets/rics-website/ews1-external-wall-fire-review-final-2.pdf
The published Approved Document Part B Volume 2 Section 12 Paragraph 12.7 had never said anything like Footnote 4. It was Andrew Chapman who realised this first in July and August 2017, and who continued to explain Grenfell Tower: the genesis of a lie.
https://www.dhirubhai.net/pulse/grenfell-tower-genesis-lie-andrew-chapman/
The hesitant language of the Errata is at least a clarification that the Ministry has to substantiate the claim in Footnote 4. It can't. It lied. Nowhere is that reading of Paragraph 12.7 published with Ministry authority under Section 6 of the 1984 Building Act, which is the power vested in the Minister to approve documents for compliance with the 2010 Building Regulations.
https://www.legislation.gov.uk/ukpga/1984/55/section/6
Nowhere is the Footnote 4. reading anywhere published back to 2006 when Paragraph 12.7 was written. No Minister of any Parliamentary Party in a long succession over more than a decade ever acted to clarify Paragraph 12.7 in a Footnote 4. way. No Ministry Civil Servant ever came up with that reading until Melanie Dawes obliged, claiming approval from the pre-Inquiry Expert Panel, in the political panic following Grenfell Tower fire. If a Civil Servant ever thought that they wanted to change Paragraph 12.7 to address combustible Cladding, or tried to convince a Minister, there is no public record.
There is no record that the Building Regulations Advisory Committee ever suggested this revision of Paragraph 12.7. But then there have never been any minutes of BRAC meetings and the Construction Products Association had published no reinterpretation.
https://www.gov.uk/government/organisations/building-regulations-advisory-committee/about
Read the Errata here:
Read the Addendum too:
It is expected that Springer will also publish an Errata and perhaps an Addendum.
Ask the pre-Inquiry Expert Panel for their view on Paragraph 12.7 of ADBv2 (2006 to 2013) now that the 2014 reference Fire Hazards of Exterior Wall Assemblies Containing Combustible Components has been carefully corrected. Experts on 17 June 2017 were:
Alok Sharma MP (Chair) - Minister of State DCLG
Dr Debbie Smith OBE - Managing Director Building Research Establishment
Colin Todd - Independent Consultant
Professor Luke Bisby - Edinburgh University
Sir Ken Knight - Ex-Commissioner of London Fire Brigade
Martin Shipp - President of the Institute of Fire Engineers
Roy Wilsher - Chair of the National Fire Chiefs Council
Nick Coombe - London Fire Brigade
DCLG officials... Whoever they were!
At any moment the Ministry lie could be admitted, but the longer the Politicians, Civil Servants and Experts leave it, the worse the Cladding Scandal will become.
All that is required is the Truth. The whole Truth, and nothing but the Truth.
The public deserve no less, even if the demand for Full Disclosure of the Ministry role in the two versions of Class 0 that existed has not yet become the focus of Sir Martin Moore-Bick at the Grenfell Tower Inquiry. But he will get there...
Class 0 Quiz.
Which were true while Class 0 existed?
A. That Class 0 was EITHER "Limited Combustibility" as Table A7 of Approved Document Part B Volume 2 (2013) in Paragraph 13a., OR tested to BS 476: Part 6 and 7 Criteria in Paragraph 13b. of Appendix A.
B. That testing to BS 476: Part 6 and 7 Criteria in Paragraph 13b. allowed combustible materials onto the market.
C. That 13b. to BS 476: Part 6 and 7 was not an equivalent Reaction to Fire to 13a. as Limited Combustibility.
D. That Paragraph 13 in Appendix A of Approved Document Part B Volume 2 (2013) as the only definition of Class 0 made it appear that 13a. was equivalent to 13b.
E. That the Ministry published the Approved Document under statutory powers in Section 6 of the 1984 Building Act, and was responsible for the definition of Class 0.
F. That the Ministry published no correction to their Approved Document stating Class 0 was unequal to Limited Combustibility because undermined by Paragraph 13b. tests, even when warned by a Select Committee in 1999 and the Warrington Fire Research RADAR Reports of 2002.
All six...
Construction professionals may have known A. but have been ignorant of B., not expected C., did not question D., remained trusting of the Ministry in E., and were never corrected through F. Becoming a textbook, published by Springer, Fire Hazards of Exterior Wall Assemblies Containing Combustible Components had not understood this.
I suggested to Nathan White it might have been more useful if the Errata he had circulated for checking among Fire Engineers had broken the issue down, as follows:
1. Approved Document B Volume 2 (2006 to 2013) Reaction to Fire provisions for External Surfaces of Walls as Diagram 40 were less stringent than for Insulation Materials and Products as Paragraph 12.7 requiring Limited Combustibility as Table A7.
2. Class 0 as the most onerous National Classification referred to in Diagram 40, had two measures in Paragraph 13a. and 13b.
3. While Class 0 to 13a. was also Limited Combustibility as Table A7, Class 0 to 13b. was a National Test to BS 476 Part 6 and 7 which allowed more combustible Materials and composite Products to pass. Class B-s3,d2 as the most onerous European Classification referred to in Diagram 40 was less stringent than Class A2-s3,d2 as the definition of Limited Combustibility to BS EN 13501-1.
4. Diagram 40 approved three reaction to fire Classifications; Class 0 to either 13a. or 13b. and Class B-s3,d2. Only Class 0 to 13a. was Limited Combustibility for Cladding Products because Paragraph 12.7 only applied to Insulation.
5. However a System could be voluntarily tested, instead of testing separate Materials or Products. Paragraph 12.5 also allowed the option of BS 8414 System Testing to BR 135 pass/fail Criteria, which allowed Paragraph 12.6 to 12.9, including Diagram 40 in Paragraph 12.6 and Paragraph 12.7 to be avoided. This BS 8414 option had advantages to manufacturers of combustible Insulation in particular, though could also benefit manufacturers of combustible Cladding.
If that was not clear enough, the way I had explained the problem in Approved Document Part B Volume 2 Section 12 to Judith Hackitt is recorded here:
https://www.dhirubhai.net/pulse/30-minutes-dame-judith-hackitt-approved-document-part-ian-abley/
The double-definition of Class 0 might be explained this way too, referring to the Approved Document as written, not as lied about by the Ministry:
If procurement was strictly to Paragraph 12.7 Insulation Material and Product for all buildings with a storey 18m above ground level was required to be Limited Combustibility unless the External Wall was a Cavity construction with an inner and outer Masonry leaf, both of more than 75mm, as Diagram 34 in Section 9.
Paragraph 12.7 strictly applied to Insulation Materials and Products to high-rise, but it was also required in Paragraph 12.9 that the Face into Cavities had to satisfy Diagram 40.
Diagram 40 in Paragraph 12.6. referred to the External Surfaces of Walls, showing the title of Diagram 40 to be a typing error.
Insulation Materials and Products procured strictly under Paragraph 12.7 for high-rise had to be Limited Combustibility. Under Paragraph 12.9 Insulation Materials and Products had to have a Face as Diagram 40, in which the most onerous Classification was Class 0 (National) OR Class B-s3,d2 (European). Diagram 40 Note 1 stated “… the National Classifications do not automatically equate with the equivalent European Classifications,” but the transposition was made as an Alternative. A similar transposition was made for Class C-s3,d2 (European). However Limited Combustibility was defined in Table A7 as Class A2-s3,d2 (European).
In the European Classification any Insulation Materials and Products under Paragraphs 12.7 had to be Class A2-s3,d2 to BS EN 13501-1, which was a lower Reaction to Fire than Class B-s3,d2 or Class C-s3,d2 required under Paragraph 12.9. The alternative being the National Classification. For Paragraph 12.7 Insulation Materials and Products Item 8 in Table A7 allowed four Tests to BS 476 Parts 4 or BS 476 Part 11, subject to density and composition.
No combustible Insulation Material or Product could pass these four Tests to BS 476 Parts 4 or BS 476 Part 11, even if they could achieve a Facing to satisfy Diagram 40.
It was additionally approved through Paragraph 12.5 for manufacturers of combustible Insulation Materials and Products to avoid Paragraph 12.6 to 12.9, including 12.7. Paragraph 12.5 allowed BS 8414 Testing to show the performance criteria in BR 135 Fire Performance of External Thermal Insulation for Walls of Multi-Storey Buildings. Though a BR 135 Classification Report was not explicitly required.
Paragraph 12.5 BS 8414 System Testing to BR 135 pass/fail Criteria allowed Paragraph 12.6 to 12.9, including Paragraph 12.7 to be avoided. That was advantageous to manufacturers of combustible Insulation Materials and Products, but could also assist manufacturers of Cladding Products. Without the BS 8414 option Cladding Products needed to satisfy Diagram 40. Paragraph 12.7 did not apply to Cladding, because it was only concerned with Insulation Materials and Products, as Item 8 of Table A7 made clear. A strict reference to Insulation NOT Cladding, as stated in the Paragraph 12.7 title.
Like the Face of Insulation in cavity construction, Cladding was classified in Diagram 40 in Paragraph 12.6. This classification had a National and European option. Class B-s3,d2 as the most onerous European Classification referred to in Diagram 40 was less stringent than Class A2-s3,d2 as the BS EN 13501-1 definition of Limited Combustibility in Table A7. However Class 0 as the most onerous National Classification had two measures in Paragraph 13a. and 13b. While Class 0 to 13a. was also Limited Combustibility as Table A7, Class 0 to 13b. was a National Test to BS 476 Part 6 and 7 which allowed more combustible Materials and composite Products to pass.
For Cladding Products only Class 0 to 13a. was Limited Combustibility.
There was a fatal double-definition of Class 0 that approved combustible Cladding.
Any manufacturer of Limited Combustibility Cladding Product could pass Paragraph 13a., but might choose BS 8414 Testing with a particular Insulation in a System to show the performance criteria in BR 135.
Any manufacturer of combustible Cladding might still choose System Testing, and some Class B Cladding Products have been able to pass the BS 8414 Test to BR 135 Criteria using Non-Combustible Insulation.
Any manufacturer of combustible Cladding not choosing System Testing, but preferring to test Materials and Products separately, might be able to achieve Class B-s3,d2 (European) or Class 0 (National) to Paragraph 13b. But Class B is not Class A2 Limited Combustibility.
Some Cladding able to achieve Class 0 to 13b. could be Class C or D to BS EN 13501-1. As Diagram 40 Note 1 correctly stated “… the National Classifications do not automatically equate with the equivalent European Classifications.”
It was approved in Paragraph 12.5 that by BS 8414 System Testing to Criteria in BR 135 subsequent Paragraphs 12.6 to 12.9 could be avoided for both Cladding and Insulation Materials and Products for the high-rise market.
It was approved in Paragraph 13b. that by testing to BS 476 Part 6 (Index (I) <12 and Sub-Index ,6) and BS 476 Part 7 (Class 1) Cladding was considered Class 0 to satisfy Diagram 40, which was not Limited Combustibility as Paragraph 13a.
Then Grenfell Tower fire killed 72 and the Ministry went into political panic instead of admitting the double-definition of Class 0.
In condensed form, in Footnote 4. of Advice Note 1 on 30 June 2017, the Ministry conflated Cladding with Insulation Paragraph 12.7. This was not how Paragraph 12.7 was written in the Approved Document Part B Volume 2 from 2006 to 2013 revisions, up to Grenfell Tower fire on 14 June 2017.
The purpose of Footnote 4. of Advice Note 1 on 30 June 2017 was to create doubt.
A doubt that even with the Errata the authors of Fire Hazards of Exterior Wall Assemblies Containing Combustible Components and their publishers are unwilling to recognise in clear terms. This is nerdy, but not difficult.
There was a double-definition of Class 0, and Paragraph 12.7 was never published in a way to include Cladding, let alone Aluminium Composite Materials (ACM).
That is why the country is finding combustible Class 0 Cladding in abundance.
Combustible Class 0 Cladding was approved, and the approval was lied about.
A weak Errata at the end of 2020 correcting Fire Hazards of Exterior Wall Assemblies Containing Combustible Components of 2014 is better than no correction at all.
Admission of the Ministry lie from June 2017 is the task ahead in 2021.
Social strategist, technical writer and facilitator at Just Practising Limited
5 个月Three years on will Sir Martin Moore-Bick publish the truth in his Phase 2 #GrenfellInquiry report I wonder?
Technical Designer
3 年Brilliant article about the interpenetration of state and corporations in the Cladding Scandal from Anna Sergi, Senior Lecturer in Criminology at the Department of Sociology, University of Essex. https://www.dhirubhai.net/pulse/after-grenfell-cladding-scandal-state-corporate-crime-anna-sergi/
Technical Designer
3 年Robert Booth has finally got round to talking about the Ministers... https://www.theguardian.com/uk-news/2020/dec/29/grenfell-tower-inquiry-government-ministers-called-to-give-evidence But he doesn't spell out why this matters. Either he doesn't understand, or is deliberately not explaining. Booth does not want to talk about how the double-definition of Class 0 approved by Ministers back to Yvette Cooper and Nick Raynsford led to Grenfell Tower fire. Booth does not want to talk about the Ministry lie to cover that up in June 2017, which involves Melanie Dawes (now running OFCOM). Booth just wants to make this seem like a Conservative Ministry failure. The Ministry lie is certainly a Conservative Ministry action, but the inaction from Labour Shadow Ministers is notable. They are covering for the Conservative Ministers who lied. They hope that in return the Conservative Ministers will not point out the succession of Labour Ministers who were warned about the double-definition of Class 0. That connivance of Opposition with Government will not work, except among those who read no more than Robert Booth at the Guardian and can't think for themselves.
Technical Designer
3 年Rockwool's Darryl Matthews has taken out an advertorial in the Spectator, asking the government to "... not bow to pressure to revert to any version of the old system that allowed combustible materials on these buildings." https://www.spectator.co.uk/article/learning-the-lessons-of-grenfell-for-good This sort of advertorial battle between Rockwool, the leading manufacturer of Stone Wool, and the manufacturers of combustible Insulation, has happened before, and it will not be the last. https://www.dhirubhai.net/pulse/fibre-foam-insulation-companies-quibble-new-statesman-ian-abley/ But Darryl Matthews does not say what the "Old System" was, because to do so requires criticism of the Government Ministry publishing Approved Documents under the 1984 Building Act. From 2006 combustible Insulation on the External Wall of buildings with a storey over 18m above ground was explicitly NOT approved in Paragraph 12.7 UNLESS: a. A system of Cladding AND Insulation was BS 8414 Tested to BR 135 Criteria, though Paragraph 12.5 did not insist upon a BR 135 Assessment Report; OR b. The whole building was Fire Engineered to BS 7974 which was more than a mere "Fire Strategy". However combustible Class 0 Cladding was Ministry approved from 1984.
Technical Designer
3 年Melanie Dawes was the Permanent Secretary to the Ministry of Housing, Communities & Local Government, and the Civil Service Gender Champion on 8 March 2018 - International Women's Day. "The theme of this year's?International Women's Day in the Civil Service is 'Wonder Women'. This doesn’t mean comic-book superheroines in red boots – it's about celebrating the women working in the public sector across the UK who do amazing things, at work or at home." https://civilservice.blog.gov.uk/2018/03/08/international-womens-day-celebrating-the-public-servants-who-inspire-us/ Then, in 2019, Melanie Dawes become Diversity and Inclusion Champion for the Civil Service. "When I joined the Civil Service in 1989, women in senior positions were very rare. This was obvious in every meeting, and for many years I felt that I was noticed as a woman first, and for my skills and expertise second." https://civilservice.blog.gov.uk/2019/07/10/my-priorities-as-civil-service-diversity-and-inclusion-champion/ Is Melanie Dawes going to be remembered for the skill of publishing the Ministry Lie of Footnote 4. in Advice Note 1. on 30 June 2017, and her expertise in sustaining it while promoted in the Civil Service? Or is Melanie Dawes, perhaps before International Women's Day 2021, going to publicly admit the Footnote 4. falsehood concocted under political direction from Ministers to draw attention from Diagram 40 and Class 0 (13b.) after Grenfell Tower fire? Come on Melanie (now OFCOM)... Tell the Truth! It is a poor standard if all equality means is being able to lie as well as any Male Permanent Secretary to the MHCLG. It makes a mockery of the Seven Principles of Public Life when the Ministry lies. It diminishes the media if the head of OFCOM keeps to the Ministry Lie.