INITIAL FIRE SAFETY ASSESSMENT

INITIAL FIRE SAFETY ASSESSMENT Factory Name: Assessor: Anzir Apparels Limited, Unit-1 Karim supermarket, Baipal, Baipal, Savar Savar Dhaka Bangladesh Emkay Enterprises 30 Apr 2014 The Alliance for Bangladesh Worker Safety Page 1/24

30 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: www.bangladeshworkersafety.org. The Alliance for Bangladesh Worker Safety Page 2/24

30 Apr 2014 GENERAL INFORMATION General Information Factory Name: Country: Province: City: Anzir Apparels Limited, Unit-1 Bangladesh Dhaka Savar Zip Code: Audit Duration: Re-Audit: 1 Days 0 Hours Re-Audit After 0 Months Draft Report 13 May 2014 Final Report Are all Action Items From Previous Assessment Completed?: To be filled out by the Alliance QA representative N/A Buildings in Complex: There are 6 buildings. 1) Main Building; 2) Knitting Shed; 3) Ancillary Building-1; 4) Ancillary Building-2; 5) Ancillary Building-3; 6) Ancillary Building-4. 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): Rented 1) Main Building - stories above grade: 5, stories below grade: 1, occupied levels: 6; 2) Knitting shed - stories above grade: 1, stories below grade: 0, occupied levels: 1. 1) Main Building: 57,274 SF; 2) Knitting shed: 15,078 SF. 1) Main building: 1996; 2) Knitting shed: 2012. No renovation or addition done. There are 4 ancillary buildings. 1) Ancillary Building-1; 2) Ancillary Building-2; 3) Ancillary Building-3; 4) Ancillary Building-4. 1,160 SF The Alliance for Bangladesh Worker Safety Page 3/24

30 Apr 2014 Number of Occupants: Number of Ancillary Levels (Stories): Occupancy Type: Construction Type: Height of est Occupied Floor Level Above Grade: Total occupant load: 1,050. 1) Main Building: 884 Basement: 166, GF: 113, 1st: 155, 2nd: 153, 3rd: 157, 4th: 140); 2) Knitting Shed: 134; 3) Ancillary Building-1: 20; 4) Ancillary Building-2: 2; 5) Ancillary Building-3: 2; 6) Ancillary Building-4: 8. 1) Ancillary Building-1: 1 story; 2) Ancillary Building-2: 1 story; 3) Ancillary Building-3: 1 story; 4) Ancillary Building-4: 1 story. 1) Main Building - Basement: E3 (Mosque) and G2 (RMG factory), GF: F3 (Market) and G2 (RMG factory), 1st to 4th: G2 (RMG factory); 2) Knitting Shed: G2 (RMG factory); 3) Ancillary Building-1: B2 (Child care and doctor room); 4) Ancillary Building-2: K (Generator room); 5) Ancillary Building-3: K (Boiler room); 6) Ancillary Building-4: K (Guard room). 1) Main Building: Type-1 (RCC frame); 2) Knitting Shed: Non-rated (Prefabricated steel shed); 3) Ancillary Building-1: Non-rated (5 in. brick wall, tin shed roof); 4) Ancillary Building-2: Non-rated (5 in. brick wall, tin shed roof); 5) Ancillary Building-3: Non-rated (5 in. brick wall, tin shed roof); 6) Ancillary Building-4: Non-rated (5 in. brick wall, tin shed roof). 1) Main Building - Building Height: 19.51 m (64.0 ft), Occupiable floor (roof) level height: 19.51 m (64.0 ft), and Occupied floor (4th floor) level height: 13.72 m (45.0 ft.); 2) All other structures are at grade. The Alliance for Bangladesh Worker Safety Page 4/24

30 Apr 2014 ASSESSMENT FINDINGS Fire Protection Construction Are openings and penetrations through rated walls and/or assemblies protected? 1. Exits were not fully protected by continuous fire rated assemblies. 2. Unprotected openings were noticed at Knitting Shed which are open to the egress route of stair-1 from the Main Building. 3. Unprotected openings were noticed in accessories storage at the ground floor which are open to the egress path. 4. Unprotected penetrations in rated wall were found at ground floor of Main Building which are open to the egress path. 5. Unprotected opening was found at ground floor between production area and wastage storage. Photograph: 1. Unprotected exit, 2. Unprotected opening of knitting shed, 3. Unprotected opening of accessories storage, 4. Penetration in rated wall at ground floor. Provide fire-resistive rated opening and 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 protectives and penetration systems. Includes doors, windows, ducts, piping, etc. Reference Alliance Standards Part 4 Section 4.6 Opening Protectives and Section 4.7 Penetrations Are exit enclosures provided with fire-resistive rated construction barriers? The building is 5-stories, walls of stairwell-1 and stairwell-2 were 5" masonry brick wall and outer wall of intermediate landings were open in both stairwells. Collapsible gates were installed in most of the exits leading to the stairwell. Photograph: 1. Exit enclosure of stair-1, 2. Exit enclosure of stair-2. Provide fire-resistive rated construction barriers and associated opening protection for exit enclosures in accordance with Alliance Standard Sections 4.5 and 4.6. Consult a qualified fire protection engineer to design the required rated construction barrier. The Alliance for Bangladesh Worker Safety Page 5/24

30 Apr 2014 Reference Alliance Standards Part 4 Section 4.5 Separation Are separations between hazards provided with fire-resistive rated construction barriers. 1. Unprotected boiler room was noticed at ground floor which was open with washing section. 2. Unprotected generator room was noticed at ground floor which was open with stair-1 of Main Building. 3. There was five (5 in.) brick wall between office and production area at 1st floor of Main Building. 4. Storage areas (finished goods at 4th floor and wastage storage at G.F) were not separated by rated construction. Photograph: 1. Unprotected boiler room, 2. Unprotected generator room, 3. 5 in. brick wall between office space and production area, 4. Unprotected finished goods storage. Provide fire-resistive rated construction barriers 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. 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 Occupancy certificate for buildings was not available during inspection. Document Review: No occupancy certificate has been shown. 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. Are certificates of occupancy provided for each building or ancillary structure? Fire Protection Systems The Alliance for Bangladesh Worker Safety Page 6/24

30 Apr 2014 Does the building have a Standpipe System? No Class-I standpipe hose connection (65 mm dia.) and Class-II stand pipe hose connection (40 mm dia.) were found in the factory building. Non-class (25 mm dia.) standpipe hose connection (1 per floor) was found at stair-1. No hose was found at 4th floor of Main Building or Knitting Shed. Minimum pressure of 65 psi was not tested during the audit. Further evaluation is required by the owner. Photograph: Non-class (25 mm dia.) standpipe system. Install standpipe system at required locations. Standpipe system must comply with NFPA 14. The hydraulic calculations should be submitted and reviewed by Alliance prior to start of work. All standpipe system installation activities shall be submitted for reviewed by the Alliance prior to commencement of installation in accordance with Section 5.4.3.2. Does the building have a standpipe system installed where required. Alliance Standard Part 5 Section 5.4.2 Are notification and initiation devices for the fire alarm system installed at required locations based on occupancy type? Pull stations at egress points: Manual fire alarm boxes were installed but not at all exits. Smoke detectors: Only standalone smoke detectors were available on some floors but numbers of smoke detectors were not sufficient. Visual and audible devices: audible and visual alarms were not found. Photograph: Manual fire alarm call point. 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 shall be submitted for review by the Alliance prior to commencement of installation. Pull stations at egress points, smoke detectors in air handling equipment, visual and audible devices spaced appropriately based on occupancy type. Reference NFPA 72 Does the building have a fire pump? The Alliance for Bangladesh Worker Safety Page 7/24

30 Apr 2014 No dedicated fire pump was found during inspection. Visual Assessment: No dedicated fire pump was found. Install a dedicated fire pump for the facility in accordance with NFPA 20 to supply the demands of the connected fire protection systems along with a stored source of water sufficient to meet the demands in accordance with NFPA 22. Fire pump installation is to be tested for final acceptance in presence of Alliance and a final inspection of the installation shall be conducted by the Alliance prior to final acceptance of the installation by the Alliance as per clause 5.5.5. Acceptance testing of the installation shall be in accordance with NFPA 20, 22, and 25 testing requirements. Documentation of all testing shall be submitted to the Alliance for review prior to final acceptance by the Alliance. The pump is to be connected to an alternative power source such as a generator. The generator is to be configured with an ATS (auto starter). Alliance Standard Part 5 Fire Protection Systems Trouble or alarm notifications were not indicated on the fire alarm control panel. No fire alarm control panel was available. Visual Assessment: No fire alarm control panel was found. 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. Alliance Standard Part 13 Section 13.10 Maintenance of Fire Protection Equipment The Alliance for Bangladesh Worker Safety Page 8/24

30 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? No centralized fire alarm and detection system was available. Only standalone smoke alarms were found on some floors but numbers of smoke alarms were not sufficient. Manual fire alarm boxes were installed but not at all exits. Photograph: 1. Standalone smoke alarm, 2. Fire alarm call point. Install a new automatic fire alarm and detection system. Once installed, arrange for direct connection of the fire alarm and detection system to a central station monitoring service or the Fire Service and Civil Defence as per Alliance Standard Section 5.7.5. Until that time, a person trained to contact the Fire Service and Civil Defence 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. Alliance Standard Part 5 Section 5.7.5 Monitoring Are fire department connections provided and clearly identified for the Fire Protection Systems? No fire department connections are provided. Visual Assessment: No fire department connection was found. Provide Fire Department (Siamese) connections in accordance with Alliance Standard Section 5.5.4. Connections shall match the Fire Service and Civil Defence hose thread standard. Alliance Standard Part 5 Section 5.5.4 Fire Department Connections Are portable fire extinguishers installed throughout the building at required locations and mounted at the correct height? Portable fire extinguishers were not found on the 4th floor. Also the mounting height of fire extinguishers were measured above 5 feet in some locations of the GF through 2nd floor. The Alliance for Bangladesh Worker Safety Page 9/24

30 Apr 2014 Photograph: Height of extinguisher Install fire extinguishers at locations and heights in accordance with BNBC Part 4 and NFPA 10. BNBC Part 4 Section 4.10 and NFPA 10 Fire extinguishers are inspected, tested, and maintained as required. Non-Compliance Level: 1 While there were maintenance checklists with each extinguisher and expiration dates were checked monthly by the compliance officer, a proper checklist covering all the issues as per NFPA 10 chapter 7 were not completed. Photograph: Inspection checklist 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 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 Plan and record of inspection, maintenance and testing of standpipe and hose system was not available during inspection. Document Review: No document was provided during inspection. Establish an inspection, testing, and maintenance program for the standpipe system. Program must comply with NFPA 25. Any newly installed standpipe system needs to be evaluated for compliance with the design pressure and flow demands of NFPA 14 or BNBC Section 5.4.3. Reference NFPA 25 Chapter 6 Standpipe and Hose Systems Table 6.1.1.2 The Alliance for Bangladesh Worker Safety Page 10/24

30 Apr 2014 Is signage for the standpipe system installed at required locations and on required components? Low Non-Compliance Level: 1 No signage for the standpipe system has been installed at required locations and on required components. Photograph: No signage in standpipe system. Install required signage for the standpipe system identification at the noted locations. Signage needs to comply with NFPA 14 Chapter 6. Reference NFPA 14 Chapter 6 Means of Egress Occupied roofs are provided with the minimum number of exits required as a story. The roof of Main building is occupiable (accessible). Stair-1 was not constructed up to the roof. Visual Assessment: Stair-1 was not constructed up to the occupied roof. Occupied roofs shall be provided with the minimum number of exits (stairs) required as a story. 13 Aug 2014 Alliance Standards Part 6 Section 6.6 Number of Means of Egress Aisles are provided with the minimum unobstructed clear width of 0.9 m (36 in) based on occupant loads. The minimum widths of aisles were measured more than 0.9 m (36 in) at GF to 4th floor, but no aisle markings were found in the basement of Main Building or in the Knitting Shed. Photograph: No aisles marking. Provide required number of aisles with a minimum unobstructed clear width of The Alliance for Bangladesh Worker Safety Page 11/24

30 Apr 2014 0.9 m (36 in) with proper marking on all floors. 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 6.17.2 are met, at grade or provides direct access to grade. Exit discharge shall not reenter a building. Stair-02 terminates at ground floor in the corridor of the market. Stair-01 terminates at an egress court which is comprised of the space between the Knitting Shed and Ancillary Building-1 (childcare & doctor room) at ground floor. Width of that egress court was found to be 1.82 m, the window and exit door of Knitting Shed is in line with this egress court. Photograph: 1. Exit discharges of stair-2 at ground floor, 2. Egress court of stair-1. Route exits directly to the exterior or provide an exit passageway in accordance with Alliance Standard Section 6.15 or an Egress Court in accordance with Alliance Standard Section 6.17.2 for non-compliant arrangements. Consult a qualified fire protection engineer to design and/or approve the required exit passageway or egress court. Alliance Standard Part 6 Section 6.17 Exit Discharge. See Section 16.7.2 and 16.7.3 for exceptions. Exit access corridors serving an occupant load exceeding 30 are separated by walls having a fire-resistance rating of 1 hr. There is an exit access corridor between the accessories storage and staircase at ground floor serving occupant load more than 30, but the corridor was not protected by 1-hour fire rated construction. Photograph: Unprotected exit access corridor. Provide fire-resistive rated assemblies for exit access corridors in accordance with Alliance Standard Section 6.3.1.1 or provide an automatic sprinkler system throughout the story or building per NFPA 13. Consult a qualified fire protection engineer to design the required rated assembly or sprinkler system. The Alliance for Bangladesh Worker Safety Page 12/24

30 Apr 2014 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. Means of egress were found obstructed on most of the floors. Cartons were stored in stair-1 and stair-2 of the 4th floor. Some aisles were blocked at 4th and 1st floors. Also, materials stored on the ramp of the basement. Photograph: 1. Material stored in the means of egress, 2. Material stored on the ramp. Remove all impediments, obstructions, and stored materials from the means of egress. Keep all elements of the means of egress (exit path, aisles, stairs, corridors, etc.) continuously free and clear of all obstructions in accordance with Alliance Standard Section 6.3.9. 15 Oct 2014 Alliance Standard Part 6 Section 6.3.8 Impediments to means of egress and Section 6.3.9 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 unlocked in the direction of egress only during working hours. Hasps, locks, other locking devices were available on the doors. Photograph: Locking devices in doors. 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 101. Alliance Standards Part 6 Section 6.8 Doors and Gates The Alliance for Bangladesh Worker Safety Page 13/24

30 Apr 2014 All doors in a means of egress are of the side-hinged swinging type. Collapsible gates were installed in most of the exits leading to the stairwell-1 and stairwell-2. Photograph: Collapsible gate in means of egress. Replace non-compliant doors and frames in the means of egress with sideswinging doors. 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. 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-02 terminates at the ground floor in the corridor of the market. A ramp from the basement terminates inside the Knitting Shed at the ground floor. Both the exit passageways were not protected by rated construction. Photograph: 1. Unprotected exit passageway of stair-2, 2. Ramp discharge inside the knitting section. Terminate both stair-2 and the ramp discharge directly outside the building or construct a rated exit passageway which leads directly outside the building. Consult a qualified fire protection engineer to assist with the design fo these requirements. Alliance Standard Part 6 Section 6.14 Exit Enclosures Stairwells are not utilized as storage spaces. Not in compliance. Stairwells were used for storage of finished goods cartons at 4th floor of main building. Photograph: Materials in exit stairway. The Alliance for Bangladesh Worker Safety Page 14/24

30 Apr 2014 Remove all stored materials in the stairwells from noted locations. 10 Oct 2014 Alliance Standard Part 13 Section 13.9 Safety Inspections Doors along the path of egress have a minimum width of 0.8 m (32 in) and have required ratings. The minimum widths of doors were measured 0.66 m (26 in) at the basement and 0.71 m (28 in) at ground floor. Most of the doors in the factory were nonrated (collapsible gate). Photograph: Minimum width of door at ground floor. Replace non-compliant doors and frames in the means of egress with sideswinging doors. 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. Alliance Standard Part 6 Section 6.5.6 Minimum Widths. Increased occupant loads will require a door width greater than 0.8 m. Are there additional areas of non-compliance related to the Means of Egress? There were exposures to the exterior walls of stair-1 and the window of the production was within 10 ft. (3.05 m) angular distance. Photograph: Angular exposure. Enclose all the exposures (openings) in the exterior wall of stair-1 with 2-hour rated construction. The rated assembly should be design by a qualified fire protection engineer. Not Applicable The Alliance for Bangladesh Worker Safety Page 15/24

30 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.). Handrails were provided only on open sides of stair-1 and stair-2 with a height of 712 mm (28 in.) and the spacing between the vertical members were measured more than 8 inch. Maximum width of stair-2 was measured 2.74 m (108 in.). But intermediate handrail was not found during inspection as per the Alliance standard. Photograph: 1. Handrail on one side of stair-1, 2. Handrail on one side of stair- 2. 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 needs to be maintained when installing new handrails. The spacing between vertical members will not exceed 200 mm (8 inch). Install intermediate handrails on stair-2 since stair width exceeds 2.2 m (87 in.). Alliance Standard Part 6 Section 6.9 Stairs and 6.12 Handrails and Guards All occupied roofs are provided with parapets or guards with a minimum height of 1067 mm (42 in.). The roof of Main building is occupiable (accessible). No parapets or guards were provided in the occuoiable roof. This roof can be used for assembly or other similar purposes. Photograph: Absence of parapet wall at roof. Provide parapet in every occupied roofs with same fire rating of outer wall of the building and a minimum height of 1067 mm (42 in.). Alliance Standard Part 6 Section 12 Handrails and Guards Occupant loads are posted for every assembly and production floor in a conspicuous space near the main point of egress. The Alliance for Bangladesh Worker Safety Page 16/24

30 Apr 2014 Occupant loads were not posted for any assembly and production floor in a conspicuous space near the main point of egress. Visual Assessment: No signage was found during inspection. Post the occupant loads for every assembly and production floor in a facility in a conspicuous space near the main exit or exit access doorway for the space. Alliance Standards Part 6 Section 6.4.4 Posting of Occupant Load 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.). Minimum ceiling height was measured to be 1.93 m (6 ft 4 in) in the means of egress at the basement of the Main Building. Photograph: Minimum ceiling height Provide a minimum ceiling height in the means of egress of 2.3 m (7 ft 6 in) with projections from the ceiling not less than 2.03 m (6 ft 8 in) in accordance with Alliance Standard Section 6.3.3. Alliance Standard Part 6 Section 6.3.3 Headroom All paths of egress are provided with compliant means of illumination. No emergency lighting was found during inspection. Visual Assessment: No emergency light was found during this inspection. Install emergency lighting for all paths of egress in accordance with Alliance Standard Section 6.7. Illumination needs to be a minimum of 10 lux for all corridors, exit doors and stairways. Illumination for aisles needs to be a minimum of 2.5 lux. Egress lighting shall be provided with emergency power or supplemented with battery powered lights that provide a minimum of 10 lux for not less than 30 mins in the event of failure of normal lighting. Alliance Standards Part 6 Section 6.7 Egress Illumination and Part 10 Section 10.12 Illumination of Exit Signs and Means Of Escape The Alliance for Bangladesh Worker Safety Page 17/24

30 Apr 2014 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 only at some exits. Photograph: Non-illuminated exit sign. Provide continuously illuminated exit signs per Alliance Standard Section 6.11. 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. Alliance Standard Part 6 Section 6.11 Exit Signs 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 testing plan or records were available during inspection. Document Review: No document was shown during inspection. 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. 17 Oct 2014 Alliance Standard Part 10 Section 10.12 Illumination of Exit Signs and Means Of Escape. Ramps do not have a running slope greater than 1 in 8 (12.5 percent) and have handrails on both sides of the ramp. The running slope of ramp was measured to be 22.5%. Also, no handrail was found for the ramp during the inspection. Photograph: No handrail for ramp. The Alliance for Bangladesh Worker Safety Page 18/24

30 Apr 2014 Re-construct the ramp with a maximum running slope no greater than 1 in 8 (12.5 percent) or provided steeps following Alliance Standard Section 6.9. Also, handrail shall be provided on both sides of the ramp with a minimum height of 865 mm (34 in.) and a maximum height of 965 mm (38 in.). Alliance Standard Part 6 Section 10 Ramps 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). Non-Compliance Level: 1 Change in elevation was found in the egress route without beveled slope and marking in the basement. Photograph: Changes in elevation of walking surfaces. Provide a uniform slope/ramp for the walking surface. Slope should not exceed 1 in 20 in the direction of travel. Any changes in elevation (protrusions or lips) must not exceed 1/4 in. Alliance Standard Part 6 Section 6.3.4 Walking Surfaces 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 Stair designation signs were not posted at any of the stairs. Visual Assessment: Stair designation signs were not found during this inspection. Install signage adjacent to each stair door indicating the stair name and the floor level in both English and Bengali. Alliance Standard Part 6 Section 6.9 Stairs The Alliance for Bangladesh Worker Safety Page 19/24

30 Apr 2014 Exit signs have appropriate illumination levels and contrasting graphics. Low The existing illuminated exit signs have appropriate illumination levels and contrasting graphics but most of the exit signs were not illuminated. Photograph: Absence of illumination in exit sign Provide continuously illuminated exit signs at all required exits and along egress paths, especially where path has a change of direction. Exit signs may be illuminated either by lamps exterior to the sign or 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 0.2 cd/m2 may also be used. Alliance Standard Part 10 Section 10.12.1 Exit Signs 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 fire safety training has been conducted with any of the workers in this factory. Only in-house training has been conducted. Photograph: In-house training document. Provide training and certification for the required number of people in fire fighting, first aid, and rescue training by an appropriate authority in accordance with the Alliance Safety Training Curriculum. Alliance Standard Part 13 Human Element Programs Are there additional areas of non-compliance to report? This factory utilizes 85% of the basement, 50% of the GF, and 100% of the 1st to 4th floors of the 5-story building. The remaining 15% of basement is used as mosque and 50% of the GF is used as market place. The fire safety The Alliance for Bangladesh Worker Safety Page 20/24

30 Apr 2014 management for these different tenants are not the same and there was no full separation between the various tenants at the GF of this building. Photograph: Evidence of multi-tenancy The factory needs to ensure that building management and factory management are on the same page with regards to fire safety and the fire protection systems in order to protect the entire building per the Alliance Standard. 03 Oct 2014 Not Applicable An emergency evacuation plan has been developed and communicated to all employees. An emergency evacuation plan has not been developed and communicated to all employees. Document Review: No document was found during this inspection. Develop an emergency evacuation plan which includes all components required by the Alliance Standards and communicate the plan to all employees. 03 Oct 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 not posted at the entrance to all exit stairs. Photograph: Emergency egress map Post emergency egress maps at the entrance to each exit stair or main point of egress. 03 Oct 2014 Alliance Standards Part 13 Section 13.4 Evacuation Plan The Alliance for Bangladesh Worker Safety Page 21/24

30 Apr 2014 Fire Drills are conducted at required intervals based on building use type. Fire drills are conducted every month without proper documentation. Last fire drill conducted on 28 Apr 2014. Photograph: Documentation of fire drills Conduct fire drills on a quarterly basis as outlined in BNBC Part 4 Appendix A for all garment facilities. Fire drills shall be conducted under the direction of a Fire Safety Director. All other requirements for fire drills shall be conducted in accordance with BNBC Part 4 Appendix A. 03 Oct 2014 Alliance Standards Part 13 Section 13.3 Fire Drills 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 at the time of the assessment and has not conducted safety training curriculum per Alliance Standards Part 13. Document Review: No document was shown during inspection. Implement training programs and document in accordance with the Alliance Safety Training Curriculum. Alliance Standards Part 13 A Fire Safety Director position has been filled. Low Non-Compliance Level: 1 No fire safety director has been designated for this factory. Document Review: Post of fire safety director was not found. 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. The Alliance for Bangladesh Worker Safety Page 22/24

30 Apr 2014 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 this inspection. Complete fire department pre-planning activities with the local Fire Service and Civil Defence. 03 Oct 2014 Alliance Standards Part 13 Section 13.1 Fire Safety Director A written housekeeping policy is established and enforced. Low Non-Compliance Level: 1 A written housekeeping policy was not established and enforced. Document Review: No written housekeeping policy was found. 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. 28 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 has shown during inspection. Develop a hot work permit program. The program must comply with the requirements of NFPA 51B. The Alliance for Bangladesh Worker Safety Page 23/24

30 Apr 2014 Alliance Standards Part 13 Section 13.4 Hot Work Permit and NFPA 51B Are all applicable permits up to date including Fire License & Boiler License. Low Non-Compliance Level: 1 Fire license valid up to 30 June 2014, Trade license valid up ot 30 June 2014, Industry license valid up to 31 Dec 2014, Boiler license valid up to 03 Mar 2015 and boiler operator license were found but waiver certificate from BERC was not available during this inspection. Photograph: 1. Fire license, 2. Industry license, 3. Boiler license. Apply to appropriate authority in an expeditious manner for issuance of all applicable permits and licenses for each building and ancillary structure. 03 Oct 2014 Alliance Standard Part 13 Human Element Programs The Alliance for Bangladesh Worker Safety Page 24/24