SUBMISSION TO THE MINISTER ON BUILDING REGULATIONS (to extend controls on PVC window design in terms of fire egress) Friends of the Irish Environment
Noel Dempsy TD.
Minister for the Environment
Customs House Dublin 1
17 May 1998
Re: PVC Window Fire Hazards
We write to you because we have been informed that the amendments to the Building Regulations Technical Guidelines due to come into force on July 1 1998 relating to PVC windows apply only to those on the first floor of new buildings.
We are concerned about the design of replacement PVC windows in public buildings in emergency situations where other methods of exit are impeded. Friends of the Irish Environment [FIE] believes the Technical Guidelines should be extended to control the use of these windows in bungalows particularly those used as guest houses and to refurbished older buildings like many of our finest hotels where PVC pushout windows have replaced the original elegant wooden sash windows.
In reviewing this situation we note that the content of PVC with its established toxic fire hazard in modern buildings now ranges from windows and doors to soffits fascias skirting boards pipework and internal cabling and ducting. We have accordingly written to 27 Fire Officers of local authorities asking them a series of relevant questions. We attach this letter.
Our concern is that PVC windows and doors - which are incongruous architecturally and have disfigured many of the nations finest heritage buildings as well as damaging streetscapes - are also a major fire hazard that has not been properly recognised by our authorities. We would be grateful for the opportunity to met with you and discuss ways in which the alternatives to the use of PVC might be encouraged with incentives and discouraged through changes in the forthcoming Technical Guidelines.
(For Friends of the Irish Environment)
Friends of the Irish Environment
C/o peter sweetman bunahowen cashel in connemarra county galway
TO: T. Gleeson Chief Fire Officer
Waterford County Borough Council
16 May 1998
Friends of the Irish Environment (FIE) are writing to all County and Urban Council Fire Officers questioning the fire aspects of the prevailing design and content of PVC windows in public buildings in emergency situations.
We are asking for details of any experiences relating either to the design of these windows in fire situations or the toxic fire hazard they represent. This request for information is being made under the newly implemented Statutory Instrument 125 of 1998 extending the regulations relating to Freedom of Access to Information on the Environment.
PVC as a fire hazard through toxic fumes
FIE is concerned with the increasing amount of PVC in modern buildings. These range from windows and doors to soffits fascias skirting boards pipework and internal cabling and ducting. In particular we are concerned that toxic fumes can be created before flames have appeared.
At the Beverly Hills Supper Club fire in the United States 161 people died from inhaling PVC fumes from decomposing wiring before flames became visible. In the 1996 Dusseldorf Airport fire PVC cables were ignited by a welder's torch leading to the death of 16 people.
Do you have any experience of situations in which PVC materials have been responsible for toxic fumes posing a danger in themselves?
What equipment do you have to deal with the hydrogen chloride and related toxic fumes emitted from a typical fire in a building with a significant number of PVC components and what protocols are in place for their use?
Do you know of or have access to any fire toxicity tests on PVC materials?
Do you have any procedures in place to deal with the ash created by the combustion of PVC materials which contain carcinogenic dioxins which are in themselves toxic?
PVC Window Design
As to the prevalent push out design of modern PVC windows FIE notes with some concern that the revised Building Regulations with their Technical Guidance Documents which will come into force on July 1 1998 apply only to PVC windows on the first floor of new buildings.
We question the omission from these Guidance Documents the use of PVC replacement windows particularly in hotels and places where the public congregates as well as in modern bungalows. Unlike traditional sash windows the design of these windows do not permit easy escape. where other methods of exit are impeded.
5) Do you have any experience of the design of these windows creating safety hazards?
We would be most grateful for any information you could provide.