INITIAL FIRE SAFETY ASSESSMENT

Transcription

1 INITIAL FIRE SAFETY ASSESSMENT Factory Assessor: 107/112 Nazrul Market 1st & 2nd floor, Chawk Bazar, Chittagong Emkay Enterprises 09 Apr 2014 The Alliance for Bangladesh Worker Safety Page 1/28

2 Factory 09 Apr 2014 Introduction to the Report The following report contains a site profile and summary of non-conformities identified during an onsite assessment commissioned by the Alliance for Bangladesh Worker Safety (Alliance) and conducted by a third-party Qualified Assessment Firm (QAF). The assessment was conducted against the Alliance for Bangladesh Worker Safety Assessment Protocols (APs) and Fire Safety and Structural Integrity Standard, which is harmonized with the factory assessment guidelines developed by Bangladesh University of Engineering and Technology (BUET) for the Bangladesh National Tripartite Plan of Action (NTPA). The goal of the Alliance process is to provide clear and practical technical requirements by which Bangladeshi Ready Made Garment (RMG) Factories producing for Alliance members may be consistently and fairly evaluated for fire, structural, and electrical safety in a non-duplicative manner. Each assessment will prompt action plans that will be used by RMG factories to systematically and sustainably improve safety conditions for garment workers. Beyond tracking and reporting on action steps taken in a transparent manner, the Alliance organization and its members will seek to further support factory improvements through technical assistance, training, implementation support for functional Worker Committees, and in some cases financial assistance and wage support for workers if factories are closed for remediation. The contents of the report do not constitute a guarantee of compliance with the applicable laws, the Alliance Standard or the absolute or continued safety against fire, electrical and/or structural integrity issues that may lead to injury or loss of life. The report is designed to provide a non-exhaustive summary of risk issues, based on a limited sampling and duration of time onsite by the named QAF. Neither the QAF nor the Alliance can certify or guarantee the quality, outcome, or effectiveness of actions taken in response to the report. For more information and report feedback please go to: The Alliance for Bangladesh Worker Safety Page 2/28

3 09 Apr 2014 GENERAL INFORMATION General Information Factory Country: Province: City: Bangladesh Chittagong Chittagong Zip Code: 4203 Audit Duration: Re-Audit: 1 Days Re-Audit After 0 Months Draft Report 15 April 2014 Final Report Are all Action Items From Previous Assessment Completed?: Buildings in Complex: Is the building(s) owned or rented by the Factory: Number of Building Levels (Stories): Approximate Building Area (SF): Date of Building Construction: Date of Last Building Renovation/Addition: Ancillary Structures in Complex: Approximate Ancillary Structures Area (SF): To be filled out by the Alliance QA representative N/A Main Building: 01 RCC Building. Rented Main Building: 7 storied (G+5 storied RCC building +tin shed roof). GF Occupied : Market. 1st Floor: R.S.I. Apparels Ltd. & Bank. 2nd floor: R.S.I. Apparels Ltd. 3rd Floor: R.S.I. Apparels Ltd, Shachand Garments. 4th to 5th floor: Kent Garments (Pvt) Ltd.. Roof: Used by all factories. 51,320 (GF to 6th floor) Unknown 1 70 The Alliance for Bangladesh Worker Safety Page 3/28

4 09 Apr 2014 Number of Occupants: 896 Number of Ancillary Levels (Stories): 1 storied RCC Building. The Alliance for Bangladesh Worker Safety Page 4/28

5 09 Apr 2014 ASSESSMENT FINDINGS Fire Protection Construction Are openings and penetrations through rated walls and/or assemblies protected? 01.Exits are not fully protected by continuously fire rated assemblies. 02.Penetrations were found at each landing of stair Opening was found between store and production floor at 5th floor, between production floor and stair at 4th, 2nd & 1st floors. 04.Penetration was found on stair wall at 4th, 2nd & 1st floors. 05. Opening was found between factory and residential building at exterior wall. 06.Opening of generator room was not fire protected. All items are not compliant with Alliance Standards Part 4 Section 4.6 Opening Protectives and Section 4.7 Penetrations. Photograph: 01.Unprotected exit. 02.Unprotected landing penetration. 3. Unprotected opening at 5th floor, at 4th floor, at 2nd floor and stair-1 at 1st floor. 4. Unprotected penetration at 4th floor,stair-2 at 2nd floor,stair-3 at 2nd floor and 1st floor, 05.Opening exterior wall, 06.Opening of generator room. Need to install fire rated door assemblies at all exits. Provide fire-resistive rated (0.75-hour for boiler room and 1.5 hour for generator room) opening protection (Door, Window, Hatch Cover etc.) at opening and penetration through fire rated walls and/or assembly s protection or closed the unprotected openings by fire-restrictive rated barrier as per requirements. Consult a qualified fire protection engineer to design the required rated opening protection. Includes doors, windows, ducts, piping, etc. Reference Alliance Standards Part 4 Section 4.6 Opening Protectives and Section 4.7 Penetrations The Alliance for Bangladesh Worker Safety Page 5/28

6 09 Apr 2014 Is each floor separated with a fire-resistive rated construction barrier? Typical slab thickness was 125 mm. Internal stair was found from 3rd to 2nd and 2nd to 1st floor, where floor openings were not fire protected. Photograph: Unprotected internal stair. Provide 2-hour fire-resistive rated construction barriers at exit enclosures with 1.5-hour fire-rated opening protection (Door). The new fire rated door will sidehinging swinging outward opening type, with auto closure and panic bar and without locking arrangement. Minimum width of new fire rated door needs to be 1.00 m. Doors need to be free from general locking arrangements. Consult a qualified fire protection engineer to design the required rated construction barriers with opening protection. Reference Alliance Standards Part 4 Section 4.5 Separation Are exit enclosures provided with fire-resistive rated construction barriers? The building was 7 story, with walls of all stairwells having 125 mm (5 in.) masonry brick wall and collapsible gates were installed in most of the exits leading to the stairwell. Exits are not fully protected by continuously fire rated assemblies. Photograph: Opening in stairwell -3. Opening in stairwell-2. Opening in Stairwell-1. Provide 2-hour fire-resistive rated construction barriers at exit enclosures with 1.5-hour fire-rated opening protection (door, window etc.). The new fire rated door will be side-hinging swinging outward opening type, with auto closure and panic bar and without locking arrangement. Minimum width of new fire rated The Alliance for Bangladesh Worker Safety Page 6/28

7 09 Apr 2014 door will be 1.0 m. Every door in a stair enclosure serving more than 4 stories needs to be provided with re-entry provision. Doors need to be free from general locking arrangements. Consult a qualified fire protection engineer to design the required rated construction barriers with opening protection. Reference Alliance Standards Part 4 Section 4.5 Separation Are separations between hazards provided with fire-resistive rated construction barriers. 1. Factory building and adjacent residential building are separated by a 125 mm (5 in.) brick wall on the North side of the building. Exterior wall on the South side of factory building and adjacent residential building was constructed by 5 in brick wall having 1 ft. separation between those buildings. 2. Store and production floor was not separated by proper fire rated barrier on 4th floor and 1st floor. 3. Unprotected boiler room was found at 4th, 3rd and 2nd floor. 4. Generator room was not fire rated construction. 5. Portable generator was open to the stair at 1st floor. 6. Non fire rated construction was found at 4th and 5th floor of exterior wall. 7. No fire rated separation was found at childcare with warehouse and dining at 3rd floor. All of these items are not compliance with Standards Part 4 Section 4.5 Separation; Part 3 Section Boiler or furnace rooms; Storage, Generators. Photograph: 1. North and south side of building, 2. Unprotected store at 4th and 1st floor, 3. Unprotected boiler at 4th,3rd and 1st floor, 4.Unprotected generator room. 5. Portable generator. 6.Non rated construction.7. Unprotected childcare. Factory building needs to be separated from the adjacent building at the stair The Alliance for Bangladesh Worker Safety Page 7/28

8 09 Apr 2014 exposures with a minimum 2 hour fire rated construction with 1.5 hour fire rated opening protection; Rooms used for storage of combustible materials/boiler need to be separated from the surrounding occupancy with a minimum 1 hour fire rated construction with 0.75 hour fire rated opening protection and for generator need to be separated from the surrounding occupancy with a minimum 2 hour fire rated construction with 1.5 hour fire rated opening protection; Rooms used for storage of combustible materials need to be separated from the dining occupancy with a minimum 1 hour fire rated construction with 0.75 hour fire rated opening protection. Consult a qualified fire protection engineer to design the required rated construction barriers. Reference Alliance Standards Part 4 Section 4.5 Separation Certificates of Occupancy for each building have been issued and are on file. Low Non-Compliance Level: 1 Not in compliance. Certificates of Occupancy for building was not available during assessment. Document Review: No occupancy certificate has been shown. Need to collect Occupancy certificate for each building and ancillary structure as per building use from approving authority. 10 Jun 2014 Are certificates of occupancy provided for each building or ancillary structure? Occupancy Type Non-Compliance Level: As per running operation of RMG factory, occupancy Type-G2 (2nd floor to 6th floor) GF: Market Type-F2, 1st floor: Type-G2 & F-1. The Alliance for Bangladesh Worker Safety Page 8/28

9 09 Apr 2014 Not Applicable. Provide Occupancy Type for each building and structure. Reference Alliance Standards Part 3 Use and Occupancy Construction Type Non-Compliance Level: Type-1: (RCC frame) Ground Floor to 5th Floor Non-Rated: (Brick wall with tin shed) 6th Floor Photograph: Non-rated construction. Not Applicable. Provide construction type for each building and ancillary structure. Reference Alliance Standards Table Height of est Occupied Floor Level Above Grade Non-Compliance Level: The total height of the building above grade was 21.34m (70 ft) (07 storied) and the height occupiable floor level was m (60 ft.) Not Applicable. Provide maximum height of highest occupied floor level above grade for each type of building and ancillary structure. Fire Protection Systems The Alliance for Bangladesh Worker Safety Page 9/28

10 09 Apr 2014 Does the building have a Standpipe System? Not in Compliance per Alliance Standard Part: 5, Section 5.4. Class-II standpipes (40 mm dia) were available inside at all floors except Ground Floor to 2nd floor. No Class-I (65 mm dia) hoses were found in the factory building. 25 mm dia standpipe hose connections were available inside the floor at 1st & 2nd floors. Minimum pressure of 65 Psi was not tested during the audit. Further evaluation is required by the owner. Photograph: Standalone standpipe system, Class-II hose Install a standpipe system at required locations designed by a qualified fire Protection engineer. Modify or install the standpipe System (Class-I and Class- II) to meet the requirements of Alliance Standard's Section 5.4. Consult a qualified fire protection engineer before modify or installing a new system. Does the building have a standpipe system installed where required. Alliance Standard Part 5 Section Does the building have a fire pump? Not in compliance. No dedicated fire pump was found on the day of inspection. Visual Assessment: No fire pump was noticed during this assessment. Provide a dedicated fire pump in accordance with NFPA 20 to supply the demands of water to the connected fire protection systems along with a stored source of water sufficient to meet the demands per NFPA 22. Alliance Standard Part 5 Fire Protection Systems Are notification and initiation devices for the fire alarm system installed at required locations based on occupancy type? Not in compliance: Pull stations at egress points: Manual fire alarm devices were installed. Piano switches were used as fire alarm call points. Smoke detectors: No centralized detection system was available. Only standalone smoke detectors were available in a very few locations in this factory building. The Alliance for Bangladesh Worker Safety Page 10/28

11 09 Apr 2014 Visual and audible devices: No visual alarm was noticed. Photograph: Manual fire alarms Consult a qualified fire protection engineer to design the pull stations at egress points, smoke detectors in air handling equipment, visual and audible devices spaced appropriately based on occupancy type. Pull stations at egress points, smoke detectors in air handling equipment, visual and audible devices spaced appropriately based on occupancy type. Reference NFPA 72 Standpipe system piping is free of mechanical damage, leakage, and corrosion? Not in compliance. Standpipe system piping was not free of mechanical damage, leakage, and corrosion. Damaged hoses were found at many of the hose locations. Photograph: Damaged hose pipe Repair or replace damaged piping. Repair and replacement must comply with NFPA 14 and NFPA 25. NFPA 25 Chapter 6 Standpipe and Hose Systems Are fire department connections provided and clearly identified for the Fire Protection Systems? Not in compliance. No fire department connections are provided per the requirements of Alliance Standard Part 5 Section Fire Department Connection. Visual Assessment: No fire department connection was noticed during this assessment. Fire department (Siamese) inlet connections need to be provided to allow fire department pumper equipment to supplement the fire protection systems. Fire department outlet connections need to be provided to allow fire department pumper vehicles to pump water into the standpipe system and another to draft water from ground-level or underground water storage tanks. Connections need to match the Fire Service and Civil Defense hose thread standard. Also The Alliance for Bangladesh Worker Safety Page 11/28

12 09 Apr 2014 need to ensure reservation of the required amount of water for fire-fighting. Consult a qualified fire protection engineer to design this requirement. Alliance Standard Part 5 Section Fire Department Connections Portable fire extinguishers have been selected based on potential fire class and hazards? Portable fire extinguishers have been not selected per potential fire class and hazards in accordance with NFPA 10 Chapter 5. Visual Assessment: No foam type extinguisher has been found during this assessment. Need to install Portable fire extinguishers per potential fire class and hazards in accordance with NFPA 10 Chapter 5. NFPA 10 Chapter 5 Fire extinguishers are inspected, tested, and maintained as required. Not in compliance. There were maintenance check lists with each extinguisher and the acting fire safety officer checked only the expiration date on a monthly interval without a proper checklist covering all the issues as per NFPA 10. While interviewing the person responsible for this it was found that only pressure gauge (where available) and expiration dates are checked. Photograph: Check list of extinguisher Establish an inspection, testing, and maintenance program for all fire extinguishers. Program must comply with the requirements of NFPA 10 NFPA 10 Chapter 7 The Alliance for Bangladesh Worker Safety Page 12/28

13 09 Apr 2014 Is the fire alarm and detection system monitored by a central station monitoring service or directly connected to the Fire Service and Civil Defense? Not in Compliance per Alliance Standard Part 5 Section No centralized detection system was found. Only standalone smoke detectors were available in a few locations in the factory building. Manual fire alarmz were installed. Piano switches were used as fire alarm call points. Photograph: Standalone smoke detector Centralized fire alarm and detection system needs to be installed and the control panel of this system shall be monitored by a central station monitoring service or directly connected to the Fire Service and Civil Defense. Trouble or alarm notifications should be indicated on the fire alarm control panel. Until that time that a central station monitoring service or direct connection to the Fire Service and Civil Defense can be set up, a person need to be assigned to contact the fire department in the event of fire alarm activation. An annunciator needs to be located in a constantly attended location to alert this person. 27 May 2014 Alliance Standard Part 5 Section Monitoring Are inspection, maintenance, and testing procedures of the standpipe and hose system documented and up to date? Including inspection and testing of hoses if provided. Low Non-Compliance Level: 1 No documents of inspection, testing, and maintenance procedures of the standpipe system were found during the day of inspection. Document Review: No document was provided during this visit. Establish an inspection, testing, and maintenance program for the standpipe and hose system. Program needs to be compliant with the requirements of NFPA 25. Reference NFPA 25 Chapter 6 Standpipe and Hose Systems Table The Alliance for Bangladesh Worker Safety Page 13/28

14 09 Apr 2014 Is signage for the standpipe system installed at required locations and on required components? Low Non-Compliance Level: 1 Not in compliance. Only signage was found at 2nd & 3rd floor. Photograph: Signage of standpipe system Install required identification signs at the noted locations. Signage must comply with NFPA Jun 2014 Reference NFPA 14 Chapter 6 Means of Egress Occupant loads on each level (floor) do not exceed the capacity of the available means of egress. The total workers of 2nd floor is 366. Total width of stair is ( ) = 3.12 m and landing widths ( ) = 2.81 m. The effective widths of stair was reduced for providing landing widths as per Alliance Standard Section Required total widths of stair 2.93 m per occupant 8 mm per BNBC Table 4.3.2, which is more than effective widths of stairs. Therefore per Alliance Standard Part 6 Section 6.4, the occupant loads on each level (floor) exceed the capacity of the available means of egress at 2nd floor. Visual Assessment: Counting the occupants, measuring the stairs and calculating the capacity. Reduce the occupant load per the capacity of the floor and the available means of egress. Alternately, provide additional exit capacity or provide automatic sprinkler protection throughout the building. 13 May 2014 Alliance Standard Part 6 Section 6.4 Occupant Load Aisles are provided with the minimum unobstructed clear width of 0.9 m (36 in) based on occupant loads. The minimum width was found to be less than 0.9 m (36 in.) on 5th, 3rd, 2nd The Alliance for Bangladesh Worker Safety Page 14/28

15 09 Apr 2014 and 1st floor which is not in compliance with Alliance Standard Part 6 Section 6.5 Egress Width Photograph: The minimum width of aisles. Aisles need to be provided with a minimum unobstructed clear width of 0.9 m (36 in.). er occupancy loads will require a greater width to accommodate the increased load. Alliance Standard Part 6 Section 6.5 Egress Width The path of egress along the means of egress is not reduced at any point along the path of travel and is sufficient for the occupant load. The width of each flight of stairs were not same in a single floor at stair-1, 2 & 3. The path of egress along the means of egress was reduced at all stairs as the exit doors (collapsible gate) of these stairs were fixed at the end of the stair. This is not in compliance with Alliance Standard Part 6 Section Means of Egress Continuity. Photograph: Collapsible gate at stair. Ensure the path of egress along the means of egress remain uniform as per requirement of occupant load. Alliance Standard Part 6 Section 6.5 Egress Width and BNBC Table Exit discharge is directly to the exterior of the building, unless the requirements of are met, at grade or provides direct access to grade. Exit discharge shall not reenter a building. Exit discharge of stair 1 & 2 terminated inside the market place, which was not separated by rated walls/assemblies per Alliance Standard Part 6 Section 6.17 Exit Discharge. Photograph: Interior exit discharge at ground floor of stair-1, Interior exit discharge at ground floor of stair-2 Interior exit stairways and ramps need to terminate at an exit discharge or outside the building. The exception is where an exit terminates at an interior exit passageway that is constructed to meet the same rating requirement as the exit stair. Alternately, 1/2 of the exits (capacity and number) can discharge The Alliance for Bangladesh Worker Safety Page 15/28

16 09 Apr 2014 inside the building where automatic sprinkler protection is provided throughout per NFPA 13. The rated assembly or sprinkler system need to be approved and/or designed by a qualified fire protection engineer. Alliance Standard Part 6 Section 6.17 Exit Discharge. See Section and for exceptions. Exit access corridors serving an occupant load exceeding 30 are separated by walls having a fire-resistance rating of 1 hr. The exit access corridors of the ground floor serve more than 30 persons, the corridor's walls were made of 5 in. brick wall with non-rated openings. These corridors were not separated by proper fire rated barrier per Alliance Standard Part 6 Section Photograph: Unprotected corridor at ground floor. Exit access corridors serving an occupant load exceeding 30 shall be separated by walls having a fire resistance rating of 1-hour and with 0.75-hour opening protection or provided with automatic sprinkler protection throughout the building as per NFPA 13. The rated assembly or sprinkler system need to be approved and/or designed by a qualified fire protection engineer. Alliance Standard Part 6 Section 6.3 and Part 4 Section 4.5. Does not apply if an automatic sprinkler system is installed throughout the building. Means of egress are free from impediments, obstructions, and stored materials. Aisle was obstructed by finished cartons at 4th floor. Stair landing-3 at 4th floor was used as a pantry. Photograph: Obstruction of aisles, Obstruction of stair landing by pantry Means of egress need to be maintained continuously free and clear of all obstructions or impediments to full instant use in case of fire or other emergency. 06 May 2014 Alliance Standard Part 6 Section Impediments to means of egress and The Alliance for Bangladesh Worker Safety Page 16/28

17 09 Apr 2014 Section Reliability Doors are not locked in the direction of egress under any conditions. All hasps, locks, slide bolts, and other locking devices have been removed where required. Doors in the path of egress were found unlocked in the direction of egress only in working hour. Locking devices were provided on doors. Photograph: Locking system of doors Remove all hasps, locks, slide bolts, or other locking devices from all doors. 13 May 2014 Alliance Standards Part 6 Section 6.8 Doors and Gates All doors in a means of egress are of the side-hinged swinging type. Collapsible gates were installed at many of the exits. Photograph: Collapsible door All roll-down, collapsible, sliding gates and shutters in the means of egress need to be replaced with fire-rated, outward-opening, side-hinged swinging, self-closing type doors per Alliance Standard Section: 6.8. Doors must be free from general locking arrangements. Alliance Standards Part 6 Section 6.8 Doors and Gates Stairs have a minimum width of 0.9 m (35 in.). Minimum width of stair was measured to be less than 0.9 m (35 in.) at 3rd floor. This internal stair was also a main stair for egress of the 3rd floor. Photograph: Minimum width of stair Provide stair having minimum width of 0.9 m. If new stair needs to be installed, building should also be assessed structurally so that the new construction The Alliance for Bangladesh Worker Safety Page 17/28

18 09 Apr 2014 does not put any adverse effect on the existing structure. Alliance Standard Part 6 Section 6.5 Egress Width. Applies to existing construction. Landings are provided on both sides of doors used along the path of egress. Doors do not swing out over stairs. A collapsible gate was fixed at the end of the stair- 1 & 3 of building hence no landing available at that location. Photograph: Stair-1 without landing, Stair-3 without landing. Remove the collapsible gates from the above locations. Alliance Standards Part 6 Section 6.8 Doors and Gates Interior exit stairways and ramps terminate at an exit discharge except where terminating at a rated exit passageway. Stair-1 and stair-2 of building terminate in the open market place at ground floor without terminated outside the building or in a rated exit passageway Photograph: Unprotected exit discharge at ground floor of stair 1, Exit discharge at ground floor of stair-2. Need to terminate both of these stair discharges directly outside the building or need to construct 1-hour rated exit passageway of both stairs which leading directly outside the building or need to provide with automatic sprinkler protection throughout the building as per NFPA 13. The rated assembly or sprinkler system need to be approved and/or designed by a qualified fire protection engineer. Alliance Standard Part 6 Section 6.14 Exit Enclosures The Alliance for Bangladesh Worker Safety Page 18/28

19 09 Apr 2014 Doors along the path of egress have a minimum width of 0.8 m (32 in) and have required ratings. Minimum widths of exits were found less than 0.8 m (32 in) at 3rd floor at stair- 3 & ground floor at stairs 2 & 3. Photograph: Minimum widths of exits at Ground Floor of Stair-1. Minimum widths of exits at Ground Floor of stair-2. Minimum widths of exits at 3rd floor. Exits need to be provided with a minimum clear width of 0.8 m (32 in.). Alliance Standard Part 6 Section Minimum Widths. Increased occupant loads will require a door width greater than 0.8 m. All paths of egress are provided with compliant means of illumination. No emergency light was available. Photograph: Exit without illumination of exit sign and emergency light. Install appropriate means of illumination at required locations in the means of egress per the Alliance Standard. Upon installation, begin verification and testing of the emergency illumination. If battery operated lights are used, these lights shall be tested on a monthly basis. Functional testing of battery powered lights shall be provided for a minimum 90 min once per year. Alliance Standards Part 6 Section 6.7 Egress Illumination and Part 10 Section Illumination of Exit Signs and Means Of Escape The Alliance for Bangladesh Worker Safety Page 19/28

20 09 Apr 2014 Handrails are provided on both sides of each stairway. Intermediate handrails are provided when the stair width exceeds 2.2 m (87 in.). Handrails are not mounted lower than 760 mm (30 in.) or higher than 1100 mm (44 in.). Main stair: Handrails have been provided on only one side of each stairway having minimum height 762 mm (30 in.). Maximum width of stair was found to be 1.37 m (54 in.). Internal Stair: Handrails are provided on both sides of stairs; the existing handrails height were more than 30 in. but spacing of vertical members were more than 200 mm (8 in.) in all of the stairs. Photograph: Handrails of main stair, Handrails of Internal Stair Install handrails on the both sides of the stairs. A minimum height of 865 mm (34 in.) and a maximum height of 965 mm (38 in.) as measured from the leading edge of the tread need to be maintained when installing new handrails. The spacing between vertical members should not exceed 200 mm (8 in.). Alliance Standard Part 6 Section 6.9 Stairs and 6.12 Handrails and Guards Occupant loads are posted for every assembly and production floor in a conspicuous space near the main point of egress. Not in compliance per Alliance Standard Part 6 Section Occupant loads are not posted for every assembly and production floor in a conspicuous space near the main point of egress. Visual Assessment: No signage was found during visit. The occupant load needs to be posted for every assembly and production floor in the facility in a conspicuous space near the main exit or exit access doorway for the space. 30 Jun 2014 Alliance Standards Part 6 Section Posting of Occupant Load The Alliance for Bangladesh Worker Safety Page 20/28

21 09 Apr 2014 Means of egress have a minimum ceiling height of 2.3 m (7 ft 6 in.) with projections from the ceiling not less than 2.03 m (6 ft 8 in.). Not in compliance with Alliance Standard Part 6 Section Headroom. Height of exits were found less than 2.03 m at roof. Height of ceiling was found 5 ft 10 in. at roof. Photograph: Height of exit, Height of ceiling. Ensure a minimum ceiling height in the means of egress maintain minimum 2.3m (7 ft 6 in.) with projection from the ceiling not less than 2.03 m (6 ft 8 in.) Alliance Standard Part 6 Section Headroom Illuminated exit signs are placed at entrances to exits and along the path of egress anywhere the continuation of egress is not obvious or there is a change in the direction of the path of travel. Illuminated exit signs were placed at a few entrances to exits but not along the path of egress where required. Photograph: Illuminated Exit signs, Non-Illuminated exit sign Install illuminated exit signs with backup power and continuous graphics at entrances to exits and along the path of egress anywhere the continuation of egress is not obvious or there is a change in the direction of the path of travel. Alliance Standard Part 6 Section 6.11 Exit Signs Changes in elevation of walking surfaces do not exceed 6.35 mm (1/4 in) unless provided with a beveled slope of 1 in 2 that does not exceed 12.7 mm (1/2 in). Changes in elevation (2 in.) without beveled slope was found between finishing and sewing section in 4th floor of Main Building. Photograph: Change in elevation at 4th floor The Alliance for Bangladesh Worker Safety Page 21/28

22 09 Apr 2014 Reduce the change of elevation with beveled slope not exceeding 12.7 mm (1/2 in). Also mark with additional signage or floor markings. Alliance Standard Part 6 Section Walking Surfaces Illuminated exit signs are provided with battery backup or emergency power and are continuously illuminated. No battery backup or emergency power has been provided for illuminated exit signs. Visual Assessment: Backup power was not provided for illuminated exit sigm Provide an emergency power source, either by battery back or by connecting to the emergency power system. Emergency power for exit signs shall be verified at least once per year. If battery-operated signs are used, these lights shall be tested on a monthly basis. Functional testing of battery powered signs shall be provided for a minimum 90 min once per year. It is recommended that equipment should be numbered, with inspections, deficiencies, and follow-up noted in a log. Alliance Standards Part 6 Section 6.11 Exit Signs and Part 10 Section Illumination of Exit Signs and Means of Escape Emergency power for exit signs is tested at least once per year. If battery operated, these lights are tested on a monthly basis. Functional testing of battery powered signs is provided for a minimum 90 min once per year. Emergency power connection or battery backup was not provided for illuminated exit signs. Visual Assessment: Backup power was not provided for illuminated exit sign. Need to provide emergency power connection or battery backup for illuminated exit signs. Develop a testing and maintenance program that ensures the emergency power for exit signs is tested at least once per year. If battery operated signs are used, these lights are tested on a monthly basis. Functional testing of battery powered signs is provided for a minimum 90 min once per year. It is recommended that equipment should be numbered, with inspections, deficiencies, and follow-up noted in a log. 30 Jun 2014 The Alliance for Bangladesh Worker Safety Page 22/28

23 09 Apr 2014 Alliance Standard Part 10 Section Illumination of Exit Signs and Means Of Escape. Compliant guards are provided on the open sides of egress components where the elevation exceeds 760 mm (30 in) above the ground or floor below. Height of guards were found to be 686 mm (27 in.) high at 3rd floor. Photograph: Height of guards Guards need to be provided at the open side of means of egress that exceed 760 mm (30 in.) above the floor or finished ground level. New guard shall have a minimum height of 1067 mm (42 in.) and the spacing between the vertical members shall not exceed 200 mm (8 in.). Alliance Standard Part 6 Section Guards Stair treads are of nominal uniformity. The height of top riser is 4 in. lower than adjacent bottom riser of 2nd floor at stair-1. The height of riser was found to be 10 in. at the 5th floor at stair-2. Photograph: Height of riser, 10 in. Any tread height exceeding more than 50% of the adjacent tread heights or 75 mm (3 in.), whichever is less need to be modified to be within this tolerance. Provide maximum height of riser of 215 mm (8 in). Alliance Standards Part 6 Section 6.9 Stairs. Any tread height exceeding more than 50% of the adjacent tread heights or 75 mm (3 in.), whichever is less, shall be modified to be within this tolerance Exit signs have appropriate illumination levels and contrasting graphics. Low Non-Compliance Level: 1 Not in compliance The Alliance for Bangladesh Worker Safety Page 23/28

24 09 Apr 2014 Visual Assessment: Illumination function of some exit sign were not working during this assessment. Need to provide continuously illuminated exit signs in all required exits. Exit signs may be illuminated either by lamps external to the sign or by lamps contained within the sign. The source of illumination shall provide not less than 50 lux at the illuminated surface with a contrast of not less than 0.5. Approved self-luminous signs which provide evenly illuminated letters having a minimum luminance of 0.2cd/m2 may also be used. Alliance Standard Part 10 Section Exit Signs Stair designation signs are provided at each floor entrance from the stair to the floor in English and Bengali. Signs indicate the name of the stair and the floor level. Signs are posted adjacent to the door. Low Non-Compliance Level: 1 No stair designation sign was posted in any of the stair. Photograph: No stair designation sign Stair designation signs need to be provided at each floor entrance from all stairs to the floor in English and Bengali. Signs need to be indicate the name of the stair and the floor level. Signs shall be posted adjacent to the door. 27 May 2014 Alliance Standard Part 6 Section 6.9 Stairs Fire Safety Programs Are the required number of people trained and certified in fire fighting, first aid, and rescue training by the appropriate authority. Non-Compliance Level: 1 No worker training by the appropriate authority. Document Review: No document was found during this assessment. Need to get training of required number of people and certified in firefighting, first aid, and rescue training by the appropriate authority Alliance Standard Part 13 Human Element Programs The Alliance for Bangladesh Worker Safety Page 24/28

25 09 Apr 2014 An emergency evacuation plan has been developed and communicated to all employees. No emergency evacuation plan has been developed and communicated to all employees. Document Review: No document was found during this visit. Need to develop an emergency evacuation plan which includes all components required by the Alliance Standards and communicate the plan to all employees. 30 Jun 2014 Alliance Standards Part 13 Section 13.1 Fire Safety Director Emergency egress maps are posted at the entrance to each exit stair or main point of egress. Emergency egress maps were posted only at stair-1. Photograph: Location of emergency egress map Post emergency egress maps at the entrance to each exit stair or main point of egress. 30 Jun 2014 Alliance Standards Part 13 Section 13.4 Evacuation Plan Training programs are implemented and documented in accordance with the Alliance Safety Training Curriculum. Non-Compliance Level: 1 The factory has not received the Alliance Safety Training Curriculum from Alliance at the date of assessment and has not conducted safety training curriculum as per Alliance Standards Part 13. Document Review: No document related to the Alliance Safety Training has been shown during this assessment. Training programs need to be implemented and documented in accordance with the Alliance Safety Training Curriculum. The Alliance for Bangladesh Worker Safety Page 25/28

26 09 Apr 2014 Alliance Standards Part 13 Are all applicable permits up to date including Fire License & Boiler License. Low Trade license, Industry license, Boiler license, Fire License were available and valid. BERC waiver certificate was available but not valid. Boiler operator license and Electrician license were not available. Photograph: Fire License. Boiler license. Factory needs to have a valid waiver certificate for full capacity from BERC. Factory needs to have a valid boiler operator and electrician license. 30 Jun 2014 Alliance Standard Part 13 Human Element Programs A Fire Safety Director position has been filled. Low Non-Compliance Level: 1 No fire safety director posted in this factory, which is not in compliance with Alliance Standards Part 13 Section 13.1 Fire Safety Director Document Review: No post of fire safety director was available Create a Fire Safety Director position and fill the position with an individual that has had sufficient training to be able to carry the required duties. Alliance Standards Part 13 Section 13.1 Fire Safety Director Fire Department pre-planning has been completed. Low Non-Compliance Level: 1 Fire Department pre-planning has not been completed. Document Review: No document was found during visit. The Alliance for Bangladesh Worker Safety Page 26/28

27 09 Apr 2014 Need to complete fire department per-planning activities with the local Fire Service and Civil Defence. 30 Jun 2014 Alliance Standards Part 13 Section 13.1 Fire Safety Director A written housekeeping policy is established and enforced. Low Non-Compliance Level: 1 No written housekeeping policy has been established and enforced. Document Review: No document related to housekeeping policy has been shown during this assessment. Establish written corporate and plant policies on housekeeping to ensure scheduled cleaning for floor, wall, ceiling, supply and return air ventilation systems. Promptly reschedule skipped cleanings. Provide a documented line of authority for authorizing a cleaning delay and rescheduling. As a general rule the maximum tolerable deposit thickness for loose fluffy lint is 13 mm (½ in.) over a maximum of 46.5 m2 (500 ft2). Limit dense deposits to 6 mm (¼ in.) and oil saturated deposits to 3.2 mm (⅛ in.). 06 Jan 2015 Alliance Standards Part 13 Section 13.6 Housekeeping A hot-work permit program has been established. Low Non-Compliance Level: 1 No hot-work permit program has been established. During visit no hot-work operation was ongoing in the facility. Document Review: No document related to hot-work permit program has been shown during this assessment. Develop a hot work permit program. The program must comply with the requirements of NFPA 51B. Alliance Standards Part 13 Section 13.4 Hot Work Permit and NFPA 51B The Alliance for Bangladesh Worker Safety Page 27/28

28 09 Apr 2014 The Alliance for Bangladesh Worker Safety Page 28/28