INITIAL FIRE SAFETY ASSESSMENT - EXPANSION

Transcription

1 INITIAL FIRE SAFETY ASSESSMENT - EXPANSION Factory Plot & 68-73, KEPZ North Patenga Chittagong Chittagong 06 Mar 2017 The Alliance for Bangladesh Worker Safety Page 1/23

2 06 Mar 2017 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 2/23

3 06 Mar 2017 GENERAL INFORMATION General Information Factory Country: Province: City: Bangladesh Chittagong Chittagong Zip Code: Audit Duration: Re-Audit: Draft Report 4 Days Re-Audit After 0 Months Mach-09,2017 Final Report March 20, 2017 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): N/A There are 11 buildings in the complex, 2 main and 9 ancillary buildings. Owned 1) Block A: 5-stories. Total Area surveyed: 334,096 SF. Block A: 209,895 SF. 1) All buildings: ) Undocumented canopies on Block A: 2016; 2) Shed attached to Canteen Building: There are 9 ancillary buildings: 1) RC Office Building; 2) RC Restaurant Building (includes a shed); 3) RC Power Room; 4) RC Pump and Chemical Room (includes a metallic veranda); 5) Lamination Shed; 6) Wastage, Cutting Die and Cycle Stand Shed; 7) RC Guard Room 1; 8) RC Guard Room 2; 9) Materials Warehouse and Workshop Shed. Total SF of ancillary buildings: 124,201 SF. 1) RC Office Building: 46,500 SF; 2) RC Restaurant Building (includes a shed): 56,920 SF; 3) RC Power Room: 3,200 SF; 4) RC Pump and Chemical Room (includes a The Alliance for Bangladesh Worker Safety Page 3/23

4 06 Mar 2017 metallic veranda): 2,500 SF; 5) Lamination Shed: 2,900 SF; 6) Wastage, Cutting Die and Cycle Stand Shed: 6,275 SF; 7) RC Guard Room 1: 465 SF; 8) RC Guard Room 2: 190 SF; 9) Materials Warehouse and Workshop Shed: 5,251 SF. Number of Occupants: Total occupants in surveyed buildings: 2,376. 1) Block-A: 2,249 (GF: 657, 1st: 90, 2nd: 750, 3rd: 750, 4th: 2); 2) RC Office Building: 69 (GF: 40, 1st: 9, 2nd: 10, 3rd: 10); 3) RC Restaurant Building: (GF and 1st: Assembly Occupancy for Dining (Two Shifts), 2nd: 0, 3rd: 0); 4) RC Power Room: 0; 5) RC Pump and Chemical Room: 1; 6) Lamination Shed: 17; 7) Wastage, Cutting Die and Cycle stand Shed: 31; 8) RC Guard Room-1: 2; 9) Guard Room-2: 3; 10) Materials warehouse and workshop shed: 4. Number of Ancillary Levels (Stories): Occupancy Type: Construction Type: Height of est Occupied Floor Level Above Grade: 1) RC Office Building: 4-stories; 2) RC Restaurant Building: 4-stories; 3) All other ancillary buildings: 1-story. 1) Block-A: G2, F1, J2, H2; 2) RC Office Building: F1, A; 3) RC Restaurant Building: E3, A; 4) RC Power Room: K; 5) RC Pump and Chemical Room: K; 6) Lamination Shed: G2, H2; 7) Wastage, Cutting Die and Cycle stand Shed: H2; 8) RC Guard Room 1: K; 9) RC Guard Room 2: K; 10) Materials warehouse and workshop shed: H2. 1) Wastage, Cutting Die and Cycle stand Shed: Type-3; 2) All other buildings: Type-2. 1) Block-A: 18.6 m (61 ft); 2) RC Office Building: 12 m (39.5 ft); 3) RC Restaurant Building: 13.3 m (43.5 ft); 4) All other buildings: At grade. The Alliance for Bangladesh Worker Safety Page 4/23

5 06 Mar 2017 ASSESSMENT FINDINGS Expansion Details Are as-built drawings available for new fire safety features of the building? The as built drawings, including the scaled architectural documents for the buildings and ancillary structures, assessed have not been found. Document Review: As built drawings have not been provided. Credible as built drawings for the new fire safety features of the building and ancillary structures under the present assessment shall be prepared in accordance with the Alliance Standards. 12 Jun 2017 Alliance Standard reference 8.20 Fire Protection Construction Are openings and penetrations through rated walls and/or assemblies protected? Wall penetrations exist between a shaft and the compressor room on the 4th floor Block-A. Floor penetrations exist from a PVC soil pipe in the production area of each floor of Block-A and the Restaurant Building. Openings have been found between the chemical storage and the production area on the ground floor of Block-A. Visual Assessment: 1) Opening between chemical storage & production floor; 2) Penetration between shaft & compressor; 3) PVC pipe penetration at Restaurant building; 4) PVC pipe penetration at Block-A. Fire-resistive rated opening or penetration protection for rated walls and The Alliance for Bangladesh Worker Safety Page 5/23

6 06 Mar 2017 assemblies shall be provided in accordance with Alliance Standard Sections 4.6 and 4.7. A qualified fire protection engineer shall be engaged to design the required opening or penetration protection systems. 03 Jun 2017 Includes doors, windows, ducts, piping, etc. Reference Alliance Standards Part 4 Section 4.6 Opening Protectives and Section 4.7 Penetrations Is each floor separated with a fire-resistive rated construction barrier? Each floor is separated by 7 in. thick RC floor slab, including floor tiles, in Block-A and Restaurant Building. Unprotected penetrations were observed through the floors. Photograph: 1)PVC pipe penetration at production building-a; 2)PVC pipe penetration at restaurant building, Visual Assessment: 1) PVC pipe penetration at Block-A; 2) PVC pipe penetration at restaurant building. Provide fire-resistive rated opening or penetration protection for rated walls and assemblies in accordance with Alliance Standard Sections 4.6 and 4.7. Consult a qualified fire protection engineer to design the required opening or penetration protection systems. 26 Aug 2017 Reference Alliance Standards Part 4 Section 4.5 Separation Are exit enclosures provided with fire-resistive rated construction barriers? Exit enclosures are not fire separated from office area at each floor of the Office Building. The Restaurant area is open to Exit enclosures (S-E,S-W) at the ground floor of the Restaurant Building. The Alliance for Bangladesh Worker Safety Page 6/23

7 06 Mar 2017 Photograph: 1) Exit enclosure open to office area; 2) S-E, S-W Exit enclosures open to Restaurant area. Fire-resistive rated construction barriers and associated opening protection for exit enclosures shall be provided in accordance with Alliance Standard Sections 4.5, 4.6, and A qualified fire protection engineer shall be engaged to design the required rated construction barrier and opening protection. 03 Jun 2017 Reference Alliance Standards Part 4 Section 4.5 Separation Are shafts provided with the minimum fire-resistance rating? There are 2 cargo lifts installed in Block-A and one cargo lift installed in the Restaurant Building. The lift shafts are enclosed with 5 in. thick masonry at the periphery. This provides a fire resistance rating of 1.5 hrs, which is less than the minimum required rating of 2 hrs. Photograph: Shaft enclosure Provide fire-resistive rated construction barriers for shafts in accordance with Alliance Standard Section Consult a qualified fire protection engineer to design the required rated construction barrier. 30 Oct 2017 Reference Alliance Standards Part 4 Section through The Alliance for Bangladesh Worker Safety Page 7/23

8 06 Mar 2017 Are separations between hazards provided with fire-resistive rated construction barriers. Required fire resistance rated construction barriers have not been provided in the following locations: 1) Finishing section and finish goods warehouse on 1st floor of Block-A; 2) 3D room and shaft enclosure on 4th floor of Block-A; 3) Power Room and Maintenance Warehouse, where non-rated windows, doors and other openings exist in the fire-resistive rated barriers, additionally, the spatial separation distance at grade is less than the minimum required 10 ft; 4) Restaurant area not properly fire from staircase (N-E) at ground floor of Restaurant Building; 5) The Restaurant area is open to staircase (S-E,S-W) at ground floor of Restaurant Building; 6) Shaft is open to dinning hall without fire separation at ground floor of Restaurant Building. Photograph: 1) 3D & lift shaft unprotected; 2) Finished goods & finishing section unprotected; 3) less than 10 ft; 4) N-W staircase unprotected with restaurant area; 5) S-E, S-W staircase open to restaurant area; 6) Shaft open to dining area at GF of restaurant building. Provide fire-resistive rated construction barriers (with associated opening protection) between hazard types in accordance with Alliance Standard Sections 3.4 and 4.5. Consult a qualified fire protection engineer to design the required rated construction barrier. 24 Jun 2017 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 No Certificates of Occupancy for any building were provided for review. Document Review: The certificates of occupancy have not been found Apply to appropriate authority in an expeditious manner for issuance of the Certificates of Occupancy for each building and ancillary structure according to building use. The Alliance for Bangladesh Worker Safety Page 8/23

9 06 Mar Apr 2017 Are certificates of occupancy provided for each building or ancillary structure? Fire Protection Systems Is the building protected by an automatic sprinkler system? The occupiable floor height of Block-A is 61 feet. The building is 5-stories and constructed with prefabricated steel. The per floor area is approximate 41,979 SF. Therefore, an automatic Sprinkler System is required. The required design document for installation of the Sprinkler System has been reviewed by the Alliance via their dated Nov-24, It has been reported by the factory that the equipment is currently being procured. Document Review: The design document of the combined system has been reviewed by the Alliance The required combined (Sprinkler and Standpipe) system in Block-A shall be installed following the design document reviewed by the Alliance, and in accordance with the Alliance Standard and NFPA Jun 2017 Reference Alliance Standards Part 3 Section Existing Buildings, Part 5 Section 5.3 Automatic Sprinkler Systems and Section 6.13 Travel Distance Does the building have a Standpipe System? The design document for the installation of a combined (Sprinkler and Standpipe) system has been reviewed by the Alliance via their dated Nov-24, Class I Standpipe System including 1 inch hose connections only in production building-a and Siamese connection & Fire department connections are available in Factory premises. Document Review: The design document of the combined system has been reviewed by the Alliance, Photograph: Hose Connection The required combined (Sprinkler and Standpipe) system shall be installed in production Building-A, Restaurant building, Office building following the design document reviewed by the Alliance, and in accordance with the Alliance Standard and NFPA 13. Prior to installation, the design documents shall be submitted to the Alliance for Review. 03 Jun 2017 The Alliance for Bangladesh Worker Safety Page 9/23

10 06 Mar 2017 Does the building have a standpipe system installed where required. Alliance Standard Part 5 Section Does the building have a fire pump? A fire pump (an electric, a jockey pump and a standby diesel operated pump) was found installed in the fire pump station, but does not appear to have been reviewed by the Alliance. It is to be noted that a 1000 gpm fire pump with a rated pressure of 10 bar has been selected for the combined (Sprinkler and Standpipe) system and will be installed in the facility. The design document of the sprinkler and hydrant system has been reviewed by the Alliance on dated Nov-24, 2016 and that currently being installed. Document Review: The documents of combined (Sprinkler and Standpipe) system, Photograph: Existing Fire Pump A fire pump having the required capacity and head for the water supply of the combined (Sprinkler and Standpipe) system shall be installed in the facility in accordance with the Alliance Standards. 27 May 2017 Alliance Standard Part 5 Fire Protection Systems Trouble or alarm notifications were not indicated on the fire alarm control panel. There is no automatic fire alarm control panel. It is required throughout the production facility. The design document of the automatic fire alarm and system has been reviewed by the Alliance via June-15, Installation is in progress. Visual Assessment: The facility survey. Install an automatic fire alarm and detection system for the facility. System shall comply with the Alliance Standard and NFPA 72. Consult a qualified fire protection engineer and/or authorized fire alarm company to design and install the system. 20 Sep 2017 Alliance Standard Part 13 Section Maintenance of Fire Protection Equipment Are notification and initiation devices for the fire alarm system installed at required locations based on occupancy type? The Alliance for Bangladesh Worker Safety Page 10/23

11 06 Mar 2017 The design document of the automatic fire alarm and detection system has been reviewed by the Alliance via June-15, Automatic fire alarm, detection and central station monitoring(control panel) installation is in progress. Visual Assessment: The Facility Survey. Install initiating devices and notification appliances as required by the Alliance Standard and NFPA 72. This includes electrical supervision of all valves controlling fire protection systems (sprinklers, fire pumps, water supplies, etc.). Connect devices to an automatic fire alarm and detection system for the facility. All fire alarm installations or modifications shall be documented with shop drawings and submitted for review by the Alliance prior to commencement of installation. 20 Sep 2017 Pull stations at egress points, smoke detectors in air handling equipment, visual and audible devices spaced appropriately based on occupancy type. Reference NFPA 72 Is the fire alarm and detection system monitored by a central station monitoring service or directly connected to the Fire Service and Civil Defense? The design document of the automatic fire alarm and detection system has been reviewed by the Alliance via on dated June-15, Automatic fire alarm and detection installation is on-going. Document Review: Document Review of the facility survey. Upon completion of installation of the fire alarm control panel, arrange for direct connection of the fire alarm and detection system to a central station monitoring service or the Fire Service and Civil Defense as per Alliance Standard Section Until that time, a person trained to contact the Fire Service and Civil Defense in the event of fire alarm activation shall be provided. An annunciator shall be located in a constantly attended location (such as a fire control room) to alert this person. 30 Jun 2017 Alliance Standard Part 5 Section Monitoring Fire extinguishers are inspected, tested, and maintained as required. The Alliance for Bangladesh Worker Safety Page 11/23

12 06 Mar 2017 A monthly fire extinguisher checklist has been provided towards initial inspection, but it does not comply with NFPA 10 Chapter 10, and no records towards testing and maintenance have been provided. Document Review: The provided document has been reviewed. An inspection, testing, and maintenance program shall be established for all fire extinguishers and prepare proper documentation. Program must comply with NFPA Jul 2017 NFPA 10 Chapter 7 Means of Egress 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. Aisle distance was measured to be more than 36 inches throughout the facility except on Level 2 of finished goods area of Block A. Photograph: There are no aisles on level 2 of finished goods area of production building. Aisles with the minimum unobstructed clear width of 0.9 m (36 in) based on occupant load shall be provided following Alliance Standards 15 Jun 2017 Alliance Standard Part 6 Section 6.5 Egress Width and BNBC Table Means of egress are free from impediments, obstructions, and stored materials. Means of egress was found obstructed due to stand pipe system pipe line at 4th floor of Block A. Photograph: Means of egress are obstructed. Relocate the standpipe system pipe line from the noted location, and the stairwells shall be maintained free of impediments, obstructions, and stored materials in accordance with the Alliance Standards. The Alliance for Bangladesh Worker Safety Page 12/23

13 06 Mar Jun 2017 Alliance Standard Part 6 Section Impediments to means of egress and 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. Fire doors (UL Certified) have been provided in Block-A and the Restaurant Building. Office Building and others buildings have been observed with Locking features, including hasps, locks, slide bolts, etc. Photograph: Locking features Remove all locking devices from all egress doors and means of egress components in accordance with Alliance Standard Section 6.8. If locks are required for security reasons, utilize special door locking features complying with NFPA May 2017 Alliance Standards Part 6 Section 6.8 Doors and Gates Doors along the path of egress have a minimum width of 0.8 m (32 in) and have required ratings. Doors were found compliant in Block-A, the Restaurant Building, and the Office Building. Side-hinged swing type doors have been found all other ancillary structures in the facility. Visual Assessment: The facility survey. Non-compliant doors and frames shall be replaced in the means of egress with side-swinging doors. Door swing must be in the direction of travel. Replacement doors shall be a minimum width of 0.8 m (32 in), and are listed, approved, self-closing, fire rated door assemblies (door and frame) with latching panic hardware. 28 Oct 2017 Alliance Standard Part 6 Section Minimum Widths. Increased occupant loads will require a door width greater than 0.8 m. The Alliance for Bangladesh Worker Safety Page 13/23

14 06 Mar 2017 Aisles are provided with the minimum unobstructed clear width of 0.9 m (36 in) based on occupant loads. Aisles were not noticed on level 5 and few places of the production areas on levels 3 & 4 in the production building and on level 2 of the Restaurant building. Aisles were found obstructed on level 2 (Finished goods area) of the production building, chemical room of RC pump and chemical room and Wastage unit-1 & unit-2 of Wastage, cutting die and cycle stand shed. Photograph: No aisles mark in Restaurant 1st floor. Aisles obstructed at finished goods areas of production building. Aisles obstruction in production. Provide proper aisle clear width minimum of 0.9 m (36 in) and provide marking. Keep aisles free of storage. Relocate equipment if necessary to provide proper width. The path of egress travel along a means of egress shall not be interrupted by any obstruction. The capacity of the means of egress shall not be reduced along the path of travel. 03 Jun 2017 er occupancy loads will require a greater width to accommodate the increased load. Alliance Standard Part 6 Section 6.5 Egress Width 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. In Block A, there are four exits and all exits are directly to the exterior of the building. In office building there are two exits and both exits are not directly to the exterior of the building. In the Restaurant Building, there are three exits where two of them (S-W, S-E) are not directly to the exterior of the building. Photograph: Direct exit of production building. Exit not direct in Restaurant building. Provide an Egress Court in accordance with Alliance Standard Section for non-compliant arrangements. Consult a qualified fire protection engineer to design and/or approve the required egress court. 30 Jun 2017 Alliance Standard Part 6 Section 6.17 Exit Discharge. See Section and for exceptions. Landings are provided on both sides of doors used along the path of egress. Doors do not swing out over stairs. The Alliance for Bangladesh Worker Safety Page 14/23

15 06 Mar 2017 Landing has not been provided on the outside of the exit door of stair # 1 & 2 at all the floors of Block-A. Photograph: Landing obstructed by the fire door at all the floor of staircase 1 & 2. Landings in the noted locations and in the similar other locations shall be provided in accordance with the Alliance Standards. A qualified fire protection engineer shall be engaged to solve this issue. 10 Jun 2017 Alliance Standards Part 6 Section 6.8 Doors and Gates Exterior exit stairs are separated from the building with the required rating. The rating of the exterior wall shall extend 3.05 m (10 ft) beyond the ends of the stair structure. There is an open window inside emergency staircase-1 on the 4th floor of Block-A. Photograph: Opening at 4th floor of emergency staircase-1. Provide a fire-resistive rated assembly between the exterior exit stairs (and 10ft beyond the ends of the stairs) and the building to achieve the required separation. Enclose any openings (windows, etc.) with required fire rated construction within that 10 ft wall section. The rated assembly should be designed and/or approved by a qualified fire protection engineer. 04 Jun 2017 Alliance Standard Part 6 Section Three stories or less 1-hr rating. Four stories of more 2-hr rating Interior exit stairways and ramps terminate at an exit discharge except where terminating at a rated exit passageway. Stairs (S-E, S-W) at the ground floor of Restaurant Building do not terminate at an exit discharge directly outside the respective buildings. Stair-1 & 2 of office building do not terminate at an exit discharge directly outside the respective buildings. The Alliance for Bangladesh Worker Safety Page 15/23

16 06 Mar 2017 Photograph: Exit discharge do not terminate directly. Exits shall discharge directly to the exterior of the building unless meeting the requirements of Alliance Standard Section or If requirements are not met, route exits directly to the exterior or provide an exit passageway in accordance with Alliance Standard Section 6.15 for non-compliant arrangements. Consult a qualified fire protection engineer to design and/or approve the required exit passageway. 04 Jun 2017 Alliance Standard Part 6 Section 6.14 Exit Enclosures Occupant loads are posted for every assembly and production floor in a conspicuous space near the main point of egress. Occupant loads have been found posted in a few locations at the floor level near the doors at the entrance to stair enclosures of Block A, the Restaurant Building and the Office Building. No occupant loads have been found posted in the assembly points of the facilities. Visual Assessment: The Facility Survey. Post the occupant load for all assembly and production floor areas in a conspicuous space near the main exit or exit access doorway for the space in accordance with Alliance Standard Section May 2017 Alliance Standards Part 6 Section Posting of Occupant Load Emergency power for means of egress illumination is verified at least once per year. If battery operated lights are used, these lights are tested on a monthly basis. Functional testing of battery powered lights is provided for a minimum 90 min once per year. No document was provided towards monthly testing or annual functional testing of battery (IPS) powered Fog lights. Document Review: No document has been provided. Develop a testing and maintenance program that ensures the emergency power for all egress lighting is verified at least once per year. If batteryoperated lights are used, these lights shall be tested on a monthly basis. Functional testing of battery powered lights shall be provided for a minimum 30 min once per year. The Alliance for Bangladesh Worker Safety Page 16/23

17 06 Mar May 2017 Alliance Standards Part 10 Section Illumination of Exit Signs and Means Of Escape Lighting 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 have been placed at the entrances to the exit stairs and to the exit doors, but the directional signs are not appropriately located where there is a change in the path of egress, specifically the floor area of Block-A. Visual Assessment: The Facility Survey Provide continuously illuminated exit signs per Alliance Standard Section Signs shall be placed at all required exits and along egress paths, especially where there is a change in direction for the path of travel. 31 May 2017 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 the elevation of the walking surfaces have been found to be greater than ½ inch at all the exit stairs in Block-A. Photograph: Changes in elevation at emergency stair exit Limit abrupt changes in elevation for walking surfaces to 1/4 in. or less unless provided with a beveled slope of 1 in 2 that do not exceed 1/2 in. in accordance with Alliance Standard Section Jun 2017 Alliance Standard Part 6 Section Walking Surfaces The Alliance for Bangladesh Worker Safety Page 17/23

18 06 Mar 2017 Illuminated exit signs are provided with battery backup or emergency power and are continuously illuminated. All exit signs in the buildings and structures assessed are internally illuminated by a rechargeable 6V built-in battery, but they are not capable of providing power for 90 minutes duration in accordance with the Alliance Standards. Photograph: Emergency illumination of exit sign Provide an emergency power source (battery back-up or connection to emergency power system) to provide compliant illumination of exit signs. 04 Jun 2017 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. No Records regarding monthly, as well as once per year, functional testing of battery (IPS) back up lights for exit signs were found. Document Review: Document review have not found during audit. 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. 04 Jun 2017 Alliance Standard Part 10 Section Illumination of Exit Signs and Means Of Escape. 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.). The Alliance for Bangladesh Worker Safety Page 18/23

19 06 Mar 2017 Handrails are not provided on both sides of the stairways at all floors of office building and 2nd floor to 3rd floor at (S-W)staircase of Restaurant building. The open guard pattern spacing was measured to be 14 inches at all floors of Restaurant building (N-W, N-E) staircase. Photograph: No handrail at all staircase of office building. No handrail at 2nd to 3rd floor of (S-W) staircase of Restaurant building. Open guard pattern spacing more than 8 in. Provide handrails on both sides of each stairway. Intermediate handrails shall be provided when the stair width exceeds 2.2 m (87 in.). Mount new handrail at a height consistent with existing height (between 30 in. and 44 in). The spacing between vertical members will not exceed 200 mm (8 inch). 30 Jun 2017 Alliance Standard Part 6 Section 6.9 Stairs and 6.12 Handrails and Guards 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 The stair designation signs have been found in a few places of stair-1 & 2 of Block-A, but were not found at each floor entrance from the stair to the floor both in English and Bengali in all the factory premises. Photograph: Designation found Designation not found Install signage adjacent to each stair door at the entrance from the stair to the floor indicating the stair name and the floor level in both English and Bengali. 13 Apr 2017 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. No record was found of people being trained and certified in fire fighting, first aid, and rescue training by the appropriate authority. Document Review: No document was found during assessment Provide training and certification for the required number of people (18% of The Alliance for Bangladesh Worker Safety Page 19/23

20 06 Mar 2017 total workers) in fire fighting, first aid, and rescue training by an appropriate authority in accordance with the Alliance Safety Training Curriculum. 31 Oct 2017 Alliance Standard Part 13 Human Element Programs An emergency evacuation plan has been developed and communicated to all employees. The evacuation plan provided for review does not appear to include all components required by the Alliance Standards. The plan was also not found to be communicated to all employees. Document Review: The document provided has been reviewed. Develop an emergency evacuation plan including all components required by the Alliance Standards and communicate the plan to all employees as per Alliance Standard Section Apr 2017 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. No emergency egress maps were noticed posted at the entrance to each exit stair or main point of egress in Block-A, the Restaurant Building or the Office Building. Document Review: Documents have not been provided. Develop an emergency evacuation plan incorporating all components required by the Alliance Standards and communicate the plan to all employees as per Alliance Standard Section Apr 2017 Alliance Standards Part 13 Section 13.4 Evacuation Plan The Alliance for Bangladesh Worker Safety Page 20/23

21 06 Mar 2017 Fire Drills are conducted at required intervals based on building use type. According to the documents provided, the last Fire Drill was conducted on Sept , but only conducted twice a year. Document Review: The documents provided have been reviewed. Conduct fire drills on a quarterly basis as outlined in BNBC Part 4 Appendix A. Fire drills shall be conducted under the direction of a Fire Safety Director. 30 Apr 2017 Alliance Standards Part 13 Section 13.3 Fire Drills Training programs are implemented and documented in accordance with the Alliance Safety Training Curriculum. No documents were found during assessment for training programs implementation and documentation in accordance with the Alliance Safety Training Curriculum Document Review: The documents have not been provided during assessment. Implement training programs and document in accordance with the Alliance Safety Training Curriculum. 16 Apr 2017 Alliance Standards Part 13 Fire Department pre-planning has been completed. Low Non-Compliance Level: 1 No document has been provided for fire department pre-planning. Document Review: NO document shown during the audit. Complete Fire Department pre-planning activities with the local Fire Service and Civil Defence in accordance with Alliance Standard Section (2). The Alliance for Bangladesh Worker Safety Page 21/23

22 06 Mar Apr 2017 Alliance Standards Part 13 Section 13.1 Fire Safety Director A written housekeeping policy is established and enforced. Low Non-Compliance Level: 1 The written housekeeping policy for the facility is established and enforced, but it does not appear to be in compliance with the Alliance Standard. Document Review: The Documents review during 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. 31 Oct 2017 Alliance Standards Part 13 Section 13.6 Housekeeping A hot-work permit program has been established. Low Non-Compliance Level: 1 The document provided towards a hot work permit program does appear to be in accordance with the Alliance Standards and NFPA 51B. The provided document is a policy where the permit part is absent. Document Review: The document provided has been reviewed. Develop a hot work permit program. The program must comply with the requirements of NFPA 51B. 19 Aug 2017 Alliance Standards Part 13 Section 13.4 Hot Work Permit and NFPA 51B Smoking is only allowed at designated areas. Low Non-Compliance Level: 1 The factory has a No Smoking Policy with the strict prohibition of smoking in the factory complex. However, no designated area, including, the required signs throughout the factory complex assessed have been noticed to this effect during the inspection. The Alliance for Bangladesh Worker Safety Page 22/23

23 06 Mar 2017 Document Review: The documents provided have been reviewed., Visual Assessment: The facility survey. Smoking is prohibited in garment factory buildings or similar uses. Post "No Smoking" signs in English and Bengali at all building entrances. If the Owner designates a smoking area outside the building, information on the location of these areas shall be posted on the "No Smoking" signs. 08 Apr 2017 Alliance Standards Part 13 Section 13.5 Smoking The Alliance for Bangladesh Worker Safety Page 23/23