The Working Group who formulated the Technical Reference (TR) of 2014, which contains several good “recommended practices” for worker dormitories, did not involve the Singapore Institute of Architects or the NGOs with experience in migrant workers’ welfare, such as TWC2.
This was highlighted by Dr Imran bin Tajudeen – a senior research fellow at the Department of Architecture, National University of Singapore (NUS) – who was one of the panelists in the webinar titled ‘Labour Day Special Webinar – Migrant Workers and the Pandemic in Singapore’ organised by MARUAH, a human-rights non-government organisation, in conjunction with the International Labour Day on 1 May.
At the beginning of his talk, Dr Imran clarified that he is not a practicing architect but has been working with a group of architects. His talk was largely focused on the critical perspectives on the built environment of migrant worker dormitories and the codes enacted to govern the buildings.
Dr Imran showed a photo of a migrant worker dormitory, in which an 8m deep room with no windows on the inner end, has windows on only one side (on the side not captured in the photo) to a corridor, and only one ceiling fan for ventilation.
“It is eight meters deep by six meters wide. There is only one ceiling fan, which stands for the necessary provision of a fan for the ventilation. And so 12 men in a room like this, eight meters deep, only one side,” he explained.
There are about 43 purpose-built dormitories, of which there are various types. In his presentation, Dr Imran used the worst type of dormitories — which he claimed barely meets the existing codes enacted to govern the buildings — for the purpose of illustration.
He proceeded with this “big caveat” that even the practicing architects are unsure of, pointing out that the FEDA does not provide any codes and the purpose of the Act is only for licensing and the standards to be observed.
“The first is the now much-touted FEDA, the Foreign Employees Dormitories Act. But the thing is the FEDA does not give you codes. It does not provide you with any codes. What it does is, for the purpose of licensing and for standards to be observed and for enforcement and continuous improvements. And it says, you refer to BCA, Fire Safety Act, Planning Act, and other prescribed written acts for foreign employee dorms. And the interface with other laws makes this even clearer,” Dr Imran said.
He also highlighted the TR which was endorsed by the Building and Construction Standards Committee (BCSC) on 14 October 2014. He indicated that it is not a code and is not mandatory to follow, adding that it is only a provisional application.
“But instead, it is for a provisional application for two years after which it’s supposed to be reviewed to determine its suitability as a Singapore standard. It mentioned that comments and feedback are welcomed. You can submit using the feedback form provided at the end of the technical reference, it’ll be taken into account for the review after two years,” Dr Imran noted.
Nevertheless, he stated that there has been no review of the TR. The TWC2 was not consulted in the formulation of the TR. Nor was the Singapore Institute of Architects included in the Working Group that prepared the TR.
“When I asked TWC2 recently, they were not consulted for this. I’m surprised because that’s the user group, as we would call it nowadays. They represent rather the user group because the workers themselves cannot form a committee to represent themselves in Singapore,” Dr Imran asserted.
“But neither was the Singapore Institute of Architects, the architects were not consulted. I’ve highlighted a few relevant, the DASL is Dormitory Association of Singapore Limited. Then you have HDB (Housing Development Board), Urban Development Authority (URA), Building and Construction Company (BCA) and Ministry of Manpower (MOM), but not the Singapore Institute of Architects, nor the NGOs. It’s quite interesting,” he added.
And actually only this Technical Reference, which is not mandatory – it is not a code, it is only provisional – It is the only code to actually specifically use the word cross ventilation.[…] only in this non-mandatory, non-code, just recommendations [that] mention cross-ventilation.
As for the Singapore Civil Defence Force (SCDF) Firecode, ventilation is only stipulated for internal corridors but there does not seem to be any statement on bedrooms’ ventilation requirements.
“If we go on to the SCDF Firecode, it does not stipulate anything for bedrooms. It stipulates only something for the internal corridors because it’s about firemen access, for example. If you go through the BCA or Building Control Act’s regulations, then you have a mention of natural ventilation,” Dr Imran noted.
Meanwhile, the Building Control Act (BCA) mentioned that natural ventilation shall be provided by means of one or more openable windows or other openings with an aggregate area of not less than 5 per cent of the floor area of the room or space required to be ventilated.
Dr Imran highlighted that the BCA says specifically in one particular clause that the openings must be to the exterior or else to specified dimensions of airwell or recess of the building.
“But if you recall the earlier image here, these kinds of dormitories, they only have one side with window and openings and it’s not to the outside, is to the corridor, and that corridor is further blocked by, can you see these ledges with awnings to dry your clothes. That’s for 12 men share this six-metre long awning space along their corridor ledge. That’s what you’re looking at. If you’re wondering what these perforated metal sheets and rows of wire are about,” he said.
Following that, Dr Imran hinted that the purpose-built dormitories did not seem to have violated any codes due to the fact that they are all endorsed by the Ministry of Manpower (MOM) in Singapore.
“We do not suspect that any of them violate any codes or any laws whatsoever. And so then the question comes, how come there’s one category of dormitory that has windows only to a corridor. We can’t answer. There’s no other window anywhere else. It’s a dead end. At least it’s only eight meters deep, so it fulfills the 12 meters as a limit of distance from the nearest window to ventilation,” he asserted.
He then showed four photos of migrant workers’ room, in which the room shown in the photos on the left have windows to the outside unencumbered by any corridor, as per the BCA Regulations (on an external wall) while the other room shown in the photo at upper left have windows onto a corridor only and has no windows on its inner or deep end. In contrast the SAF barrack room on the lower right image has windows on two opposite walls for proper cross-ventilation.
“But you see the other rooms or other types of dormitories, they are better. And of course, the one at the bottom right. It’s not even a dormitory. It’s a SAF barrack room. So some of us will ask this question, why is it that we have a double standard? We have very good standards for cross ventilation, the windows you see at the back of the SAF barrack room where the workers in essential services were shifted to,” he explained.
Dr Imran opined that the SAF barrack-room is very well ventilated with only six persons in a room, adding that “it’s so much more provisioned in terms of the living space standards”.
He continued, “Minimum is 4.5sqm GFA of living space per worker, this is from the URA, so they provide much more [in terms of facilities] under the FEDA as well as the TR. So, sometimes it’s a bit uncertain, like say, “strongly encouraged”, rather than compulsory, for sick bays [in the URA Guidelines for Independent Worker Dormitories]. So you’ve got all of these question marks going around.”
Dr Imran then relayed on the time when the TWC2 recommended satellite towns in 2015, saying, “The time of the review and the enactment of FEDA, they actually mentioned maybe you could even have proper satellite towns rather than dormitories. But what has led to the situation, of course, is this also longer term issue, which is the separation of the workers from the rest of society in Singapore.”