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Building’s breach of ventilation regulations

Dear Sir,

At Emerson House in Eccles, Manchester, two organisations are occupying an 11-storey office building that has had its original perimeter individual induction unit-type fresh air ventilation system totally removed.

Replacement ‘re-circulation only’ units give no fresh air. The adjoining office block is similar and also owned/refurbished by the same company.

Complaints to the Health and Safety Executive dating back to 2008 unsurprisingly resulted in a six-month investigation in 2011/12 when they were shown photographs (supplied to H&V News) of the clear total lack of a ventilation system.

The supposed current system of ventilation comprising some remaining low-level air bricks and the remaining two ‘egg crate’ return air grilles per floor from the original system are sited in open plan areas close to staircase core doors.

Given the blatant absence of any acceptable fresh air ventilation as required under Workplace Regulations, combined with the long history of staff complaints and the clear breach of Building Regulations (in a building occupied by local Building Control), the need for enforcement action seemed fairly obvious.

The HSE involved its experts at the Health and Safety Laboratory, but amazingly concluded in writing that: “The two grilles created negative pressure which ‘sucked’ air through the air bricks sited in the perimeter service boxing.”

And by some form of spurious calculation it concluded there was sufficient air for 50 per cent occupation – clearly physically impossible and a breach of regulations in itself. Air from the few unblocked holes varies from chill wind to zero depending on the weather.

It is worth noting how the HSE’s letter even talks about “extract rate” when the air clearly short circuits from the adjacent door and is not
supply air available to offices.

It ignored completely all meeting rooms and smaller/individual offices, etc.

The lack of any mechanical air supply was not investigated, as CIBSE Guidance listed in regulations did not apply to existing buildings – only
new ones!

I obtained written submissions from CIBSE Technical and IOSH, which stated the obvious true position on the application of ‘guidance’ - that is in effect the technical reality of the regulations.

The HSE remains unmoved by all the obvious wealth of evidence that contradicts it – resulting in a building services version of Monty Python’s dead parrot sketch.

Its official stance in writing leaves the way open for all existing offices and similar buildings to have their ventilation systems effectively removed - which is very bad news for office workers, and even worse news for the building services industry.

Far from buildings getting greener and healthier, we are potentially heading back to pre-Victorian atmospheres, with stale air and easy spread
of infections.

John Dooley, chartered surveyor


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