On May 22, 2017, updating an earlier blog post (Egress, toilets, and carcinogens: Cornell’s transition plans during Fine Arts Library construction), I wrote that “transferring outside air from a corridor into the digital fabrication lab would not be compliant with the 2015 Mechanical Code. However, since the corridor seems to be now labeled as a room (‘collaborative area’), it’s probably legal, but barely. The opportunistic and ad hoc manner in which such design decisions are, and have been made, does not inspire confidence.” It is now apparent that the actual use of this new “room”/corridor has confirmed my fears: the ability of this “collaborative area” to function properly as part of an egress path has been seriously undermined by the types of activities assigned to the space.
I’ve written about the impending bathroom crisis for the Department of Architecture at Cornell here and here, caused by the renovation of Rand Hall. When this renovation begins, there will only be a single men’s toilet available for the entire 32,000 square foot floor area comprising the second floor studio and office spaces in Milstein and E. Sibley Hall. As hordes of desperate students and faculty from the second floor trek up to the “private” third floor Frances Shloss studios, it is inevitable that faculty and students on the third floor will take retaliatory action. As they say, the writing is on the wall.
I’m not an Instagram fan, so I end up posting my favorite images here. I took this one in Sibley Hall a few days ago. Sibley Hall is part of the College of Architecture, Art, and Planning at Cornell. When neighboring Rand Hall is closed down for renovation in a few months, this single toilet will be the only viable option for men, not only those in offices and facilities on the second floor of Sibley Hall, but for students and faculty using the 25,000 square feet of studio space in adjacent Milstein Hall. When asked about this at a recent faculty meeting, the Dean of the College stated that the “solution” to this problem will most likely be a request for a Code variance.
I was interrupted today by two workers who needed access to Milstein Hall in order to inspect roof leaks; the green roof itself has been in a state of partial demolition for the last two years, as I described in this blog post from May 2017. There are several areas where water is currently coming down, mainly in the stepped seating area and over the wooden floor area.
Some (but not all) of the Code-compliance problems Cornell is experiencing with their Rand Hall Fine Arts Library proposal result from the large floor area of the combined Rand-Milstein-Sibley Hall building. This combined area far exceeds the allowable area, even if all the buildings were of Type IIB (non-fireproofed steel) construction, like Rand Hall and Milstein Hall. I’ve outlined some of the false statements made by Cornell and its Code consultant in order to get Code variances for this project. But it turns out to be relatively easy to build a 3-hr fire wall between Rand and Milstein Hall, which would allow Rand Hall to be considered as a separate building with its own construction type (IIB) and a compliant floor area. Cornell considered a bizarre and difficult-to-build 2-hr fire wall in its schematic design proposal, which would have been noncompliant in any case since a 3-hr fire wall is needed, but this fire wall disappeared in the design development phase, replaced by a noncompliant 2-hr fire barrier. In order to use this noncompliant fire barrier, a Code variance was needed. It’s actually much easier to build a 3-hr double fire wall, as shown schematically below, since Rand and Milstein Halls are already structurally independent, and each half of the double fire wall only needs to have a 2-hr fire rating. Links to all my blog posts and articles on the Fine Arts Library proposal can be found here.
The New York State DCEA Syracuse Regional Board of Review will determine whether or not to reopen Petition No. 2016-0269, Cornell’s request for a third Code variance for their Fine Arts Library proposal in Rand Hall, at their monthly meeting on June 15, 2017. I sent them a summary of false statements made by Cornell and its Code consultant in their application (petition) for the variance. You can check it out here. Links to all my blog posts and articles on the Fine Arts Library can be found here.
[Update: June 20, 2017] I was just informed that the Hearing Board has declined to reopen Petition No, 2016-0269.
[Updated below] Milstein Hall, Cornell’s architecture building designed by Rem Koolhaas and OMA, has been experiencing problems with its green (vegetated) roof as far back as 2011, when leaks began to appear both at skylights and at the intersection with the brick wall of adjacent Rand Hall (shown in this video). Just about two years ago, in April 2015, an extensive roof repair effort was undertaken, requiring the removal of vegetation and soil medium, as well as rigid insulation panels, in order to examine and repair the roof membrane. For some reason, unknown to me, the green roof was never reassembled, and piles of vegetated soil medium, removed to access the membrane, remain piled up around the edges of the roof along with panels of rigid insulation.
Aside from aesthetic considerations, leaving the rigid insulation boards exposed to the sun, especially with the printed side up, will cause permanent damage to the boards. Here’s some guidance from the manufacturer’s product data sheet (pdf) for their Owens Corning FOAMULAR® 404, 604, 404 RB and 604 RB extruded polystyrene (XPS) rigid foam insulation:
XPS Insulation can be exposed to the exterior during normal construction cycles. During that time some fading of color may begin due to UV exposure, and, if exposed for extended periods of time, some degradation or “dusting” of the polystyrene surface may begin. It is best if the product is covered within 60 days to minimize degradation. Once covered, the deterioration stops, and damage is limited to the thin top surface layers of cells. Cells below are generally unharmed and still useful insulation.
FOAMULAR Extruded Polystyrene (XPS) Insulation is a thermoplastic material with a maximum service temperature of 165°F. In horizontal applications, FOAMULAR XPS Insulation may experience greater solar exposure than in vertical applications and it may be damaged by heat buildup. Simple precautions during construction can minimize the potential for heat related damage. Install only as much FOAMULAR XPS Insulation as can be covered in the same day. For horizontal applications always turn the print side down so the black print does not show to the sun which may, at times, act as a solar collector and raise the temperature of the foam surface under the print.
Some background material can be found in Figure 12 of my Critique of Milstein Hall (Water and Thermal Control).
[Updated July 25, 2017] The green roof has not stopped leaking, even after two years.
[Updated below: May 2, 2017, May 10, 2017, May 22, 2017, and Jan. 19, 2018] Cornell has made transition plans [or try here (pdf) if Cornell’s link is no longer working] for the construction of a Fine Arts Library (FAL) in Rand Hall in order to accommodate the various library, wood shop, metal shop, and digital fabrication functions, currently in Rand Hall, that will be out of service during the two-year construction period. Not mentioned in these transition plans are two items that actually affect Milstein Hall: the 2nd-floor Rand Hall toilet rooms that are used by faculty and students in Milstein Hall (since no toilets were provided on the 2nd-floor Milstein Hall studio level) and a third required exit stair for Milstein Hall’s 2nd-floor level, currently in Rand Hall. I’ve asked the AAP Dean and the FAL project manager what plans are in place for temporary toilets and egress, but have not yet gotten a reply. In the meantime, I’ve published a Cornell Chronicle parody on that subject.
There are other transition issues as well. A temporary digital fabrication lab is being constructed across from my office in E. Sibley Hall. It will house, among other things, 3-D printers, at least one of which uses toxic and carcinogenic materials. The room itself appears to have no ventilation system that supplies fresh air, in apparent violation of the 2015 NY State Mechanical Code. I’ve written a series of emails to Cornell’s mechanical systems designer as well as the director of facilities for the College to try to get some answers to my questions and concerns. After three weeks of waiting and promises of a reply (“The project team, including Facilities Engineering and Environmental Health & Safety, is reviewing the information you have provided and will respond to your concerns once the review has been completed.”), I still haven’t heard anything. Here is the last email I wrote to Cornell’s mechanical designer, dated April 19, 2017:
I haven’t received a reply to my last email, dated April 10, 2017, so I’ll repeat my main questions and concerns. Since the questions are technical in nature, and since you are the responsible mechanical engineer for this project, I would appreciate a response directly from you.
The safety data sheet for the “Stratasys” printer says that it should be used “only outdoors or in a well-ventilated area,” and the 2015 NYS Mechanical Code seems to require that “Ventilation systems shall be designed to have the capacity to supply the minimum outdoor airflow rate.” Your plans for 240 E. Sibley don’t seem to have any mechanical ventilation system for outdoor air—only transfer grilles that pull in return air from the adjacent spaces.
(1) Where is the required outdoor air coming from for this room?
(2) How is your design consistent with the manufacturer’s recommendation that the printer be used “only outdoors or in a well-ventilated area”?
(3) How can you be sure that particulate matter containing toxic or carcinogenic byproducts from the printer will not be exhausted directly in front of the rear entrance to Sibley Hall and a short distance from the food truck?
The context for my concern is that the material used by the printer is both toxic and carcinogenic, and nanoparticles are created as a byproduct of the printing process, some of which are so small that they pass through HEPA filters.
The manufacturer’s safety sheet says:
This chemical is considered hazardous by the 2012 OSHA Hazard Communication Standard (29 CFR 1910.1200)
Suspected of causing cancer
Suspected of damaging fertility of the unborn child
May cause respiratory inflammation
May cause damage to organs through prolonged or repeated exposure
Carcinogenicity: Classification based on data available for ingredients. Contains a known or suspected carcinogen.
Reproductive toxicity: Classification based on data available for ingredients. Contains a known or suspected reproductive toxin
SARA 311/312 Hazard Categories
Acute health hazard: YES
Chronic Health Hazard: YES
From https://www.uvm.edu/safety/shop/3d-printer-safety: Nanoparticles (ultrafine particles less than 1/10,000 of a millimeter) are one of the by-products emitted during the 3D printing process. Recent studies have shown that 3D printing using a low-temperature polylactic acid (PLA) feedstock can release 20 billion particles per minute, while a higher temperature acrylonitrile butadiene styrene (ABS) feedstock can release 200 billion.
Nanoparticles are of concern for the following reasons:
• They are very small,
• They have large surface areas, and
• Can interact with the body’s systems, including the skin, lungs, nerves and the brain.
Exposures to nanoparticles at high concentrations have been associated with adverse health effects, including total and cardio-respiratory mortality, strokes and asthma symptoms. While PLA feedstock is designed to be biocompatible, the thermal decomposition products of ABS feedstock have been shown to have toxic effects on lab rodents.
Thank you for your attention to this matter.
Links to all my writings and blog posts on the Fine Arts Library can be found here.
[UPDATE: May 2, 2017] I still haven’t heard back from “the Project Team”; meanwhile construction is underway, and one can easily see how any fresh air originating in the existing duct outside the room that manages to find its way through the grilles (at the top of the storefront partition) will be sucked directly into the existing return grille, also at the top of its wall, without providing much benefit to the occupants within the so-called “breathing zone” (Figure 1 below). In fact, it’s possible that particulate matter from the 3-D printers will find itself in a zone with no air movement at all, given the geometry of the room and the placement of grilles only at the top of the walls.
[UPDATE: May 10, 2017] I just received an email response from the AAP Dean indicating how Cornell intends to deal with Milstein Hall toilets (still trying to figure it out) and egress (temporary stair through the glass curtain wall) during the construction of a Fine Arts Library in Rand Hall:
Thank you for your question regarding the transition. Regarding egress, my understanding is that an egress stair will be provided directly from the Kwee studios by removing a glass panel and providing a temporary egress stair. I am told this will be part of the CD drawings.
Regarding the bathrooms, the project team is working with the city to determine the number of accessible and non-accessible fixtures not including Rand Hall. A solution is not yet final, but the team is aware of the issue.
[UPDATE: May 22, 2017] On May 19, 2017, I received a copy of a “health review,” concerning the Sibley Hall Digital Fabrication Lab, jointly written by Cornell’s Director of Occupational Health, Safety, Fire and Emergency Services and Cornell’s Director of Facilities Engineering. I emailed the following reply today to the AAP Director of Facilities (copied to other relevant parties):
Thanks for stopping by today and confirming that each 3D printer will now be placed in a separate “box” that filters air for nanoparticles and VOCs before returning the air to the room. This seems better than the original design in which the 3D printers were placed in the temporary digital fabrication lab (240 E. Sibley) without any specialized exhaust system. Still, even if 99.97% of nanoparticles are captured in this way, the 0.03% that escape constitute a potential release of 20,000,000,000 x 0.0003 = 6,000,000 toxic and carcinogenic particles into the breathing zone per minute. (“Recent studies have shown that 3D printing using a low-temperature polylactic acid (PLA) feedstock can release 20 billion particles per minute” – https://www.uvm.edu/safety/shop/3d-printer-safety).
Question 2 and its answer… confirm that the digital fabrication lab is not directly provided with outside air, but instead: “The Makeup Air Unit in Room 200UA delivers fresh air to the second floor. This air is then transferred into Room 240 through grilles located at the top of the glass partition wall.” Based on a conversation I had with Senior Technical Staff of the International Code Commission (ICC), transferring outside air from a corridor into the digital fabrication lab would not be compliant with the 2015 Mechanical Code. However, since the corridor seems to be now labeled as a room (“collaborative area”), it’s probably legal, but barely. The opportunistic and ad hoc manner in which such design decisions are, and have been made, does not inspire confidence.
Relatively little is known about the risks of exposure to 3D printers. A recent study says: “It is well-known that both gases and particles are emitted during thermal processing of many thermoplastic materials. However, little is known about the types and magnitudes of emissions from desktop FFF 3D printers and how they vary according to filament material or printer characteristics. In 2013, we published the first known measurements of emissions of ultrafine particles (UFPs: particles less than 100 nm in diameter) resulting from the operation of a single make and model of commercially available desktop FFF 3D printer using both ABS and PLA filaments. These findings were crucial, as exposure to emissions from thermal decomposition of thermoplastics has been shown to have toxic effects in animals, and exposure to UFPs from other sources has been linked to a variety of adverse human health effects.” (Parham Azimi, et al., “Emissions of Ultrafine particles and Volatile Organic Compounds from Commercially Available Desktop Three-Dimensional Printers with Multiple Filaments,” Environmental Science & Technology, at https://pubs.acs.org/doi/pdf/10.1021/acs.est.5b04983, emphasis added).
It saddens me that students, faculty, and administrators in AAP feel the need to introduce toxic and carcinogenic materials into the educational environment. The competition to keep pace with our peers, and to prepare our students for professional practice in architecture, has apparently reached the point where even Monty Python’s prescient “Architect’s Sketch,” featuring “rotating knives” in a corridor where “blood pours down these chutes,” seems like a quaint anachronism.
On another note, I was told by the AAP Director of Facilities that no new toilet rooms will be provided for architecture students during the time when code-mandated toilet rooms in Rand Hall become inaccessible due to construction of the Fine Arts Library. Instead, a code variance will be sought.
[UPDATE: Jan. 19, 2018] Cornell has successfully petitioned for a New York State code variance (Petition No. 2017-0515) so that they will not need to provide an adequate number of toilets during the construction of the library in Rand Hall. There is only a single (shared) toilet for men on the entire second floor of the combined E. SIbley-Milstein Hall, a floor which encompasses an area of over 30,000 square feet and contains well over 300 occupants (with a legal occupancy over 500). In addition, Mike Niechwiadowicz, Ithaca’s Director of Code Enforcement, made a determination that a third exit was not required from Milstein Hall based on the “occupancy of the L.P. Kwee Studios” on the second floor of Milstein Hall. It’s not clear whether he also considered the classroom/critique spaces on the second floor of E. Sibley Hall that exit through Milstein Hall and therefore increase the occupant load beyond what would be computed if considering only the L.P. Kwee Studios in Milstein Hall. Based on past experience, it’s unlikely that there are any calculations to support his judgment. Niechwiadowicz, you may remember, is the very same “code expert” who insisted that Milstein Hall’s crit room needed only one exit. Needless to say, his code opinion was overturned at the July 18, 2013, meeting of the NY State Capital Region Board of Review and Cornell was forced to create, at great expense, a second exit from the crit room space—by breaking through the wall separating the crit room and the auditorium.
The City of Ithaca just sent me a 3-page excerpt from a New York State Variance document* related to Cornell’s Fine Arts Library proposal (links to all my writings and blog posts on this subject can be found here). This was in response to a Freedom of Information Law (FOIL) request that I had made on March 8, 2017. No records of any meetings or correspondence related to this project were provided, even though City officials attended numerous meetings with Cornell staff, provided specific fire-safety recommendations to them, and even wrote a letter stating that Cornell’s proposal was “acceptable.” That there is no City of Ithaca paper trail for this project—violating the spirit, if not the letter, of the FOIL legislation—did not surprise me, since I had the same experience with the earlier Milstein Hall project at Cornell. Nevertheless, I sent the following email to the City of Ithaca, asking that they investigate how it is possible that no records of meetings and correspondence exist for the Fine Arts Library proposal:
From: Jonathan Ochshorn
Date: Friday, April 28, 2017 at 10:26 AM
To: “email@example.com” <firstname.lastname@example.org>
Subject: Re: Your FOIL Request has been granted – ID 20170263
RE: ID 20170263
Thank you for sending a 3-page excerpt including the decision rendered by the Capital Region – Syracuse Board of Review for petition 2015-0432. However, I had requested “all documents, including records of meetings or phone conversations, related to the proposed Fine Arts Library in Rand Hall at Cornell University (863-883 University Ave., Ithaca, NY 14850) beginning in Jan. 2014 and continuing up to the present date…”
How is it possible that there is no documentation of meetings attended by representatives from the City of Ithaca in connection with this project, or even of a letter written by the City that was specifically mentioned in the transcript of that hearing?
Are important records being destroyed or deleted by the City, or are records of meetings—in which City officials make important life-safety recommendations to Cornell—either not made, or not maintained? Either way, this seems like a serious ethical and legal problem, and I ask that you investigate why letters written by and meetings attended by Mike Niechwiadowicz, City of Ithaca Director of Code Enforcement—including those that were specifically cited in the transcript of the hearing for petition 2015-0432—are not being provided under the Freedom of Information Law.
The New York State Committee on Open Government states: “All records are subject to the FOIL, and the law defines ‘record’ as ‘any information kept, held, filed, produced or reproduced by, with or for an agency… in any physical form whatsoever. . .’” Please investigate whether the Freedom of Information requirements are being faithfully executed by City of Ithaca agencies, that is, whether key records are being willfully deleted, or—even more troubling—whether meetings are being attended and key decisions are being made and communicated to outside parties (like Cornell University) without any record-keeping at all.
Following are excerpts from the Hearing transcript (petition 2015-0432), attended by Mr. Niechwiadowicz, that provide evidence of letters and meetings for which no documentation seems to be available. Key passages are highlighted.
Mike Niechwiadowicz, Director of Code Enforcement for the City of Ithaca, provided the following testimony at the 2016 Variance Hearing in Syracuse: “…I’m the one that made the determination that the levels 2 and above resulted in three stories as opposed to two stories. And the reason being is that per Building Code section 505.2.1, a mezzanine is limited to one-third of the area — of the floor area of the room or space containing the mezzanine or mezzanines.”
Question from the Hearing Board about why the 2015 Hearing didn’t catch the mezzanine assumption error: “So we didn’t catch it in 2015?”
Response from Cornell’s code consultant Deruyscher: “No, it was discussed at that point that it looked like, and our determination and our discussion was that it looked that way. The City did go through, and this is a very fine, I want everybody to understand, it’s a very fine detail of exactly how those measurements are done. We had an opinion, that we met the code. The City said, not sure. It went to a number of different people, and I guess I would let the City talk about that specific item if there was a question.”
Question: “There was mention in the analysis that there was a letter from the City [of Ithaca] that everything was acceptable. I didn’t see that in my packet. Is that still the case, is that in the record?
Mike Niechwiadowicz: “I can address that, it unfortunately didn’t get to the packet, however, let me get into slightly more detail… So we’ve been involved in cooperatively working with Cornell and the designers, so we’re very aware of what’s going on here.”
* I had already received complete records of the 2015 and 2016 Code variance hearings related to the Fine Arts Library through a FOIL request to New York State, and I placed these variance documents online (scroll down to the bottom of this document).