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INITIAL FIRE SAFETY ASSESSMENT Factory Address: Plot 1175 & 1179, Bashan Sarak, Vogra, PO. National University, Gazipur Sadar, Gazipur Gazipur Dhaka Bangladesh 15 Jun 2016 The Alliance for Bangladesh Worker Safety Page 1/18

15 Jun 2016 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 2/18

15 Jun 2016 GENERAL INFORMATION General Information Factory Address: Country: Province: City: Plot 1175 & 1179, Bashan Sarak, Vogra, PO. National University, Gazipur Sadar, Gazipur Gazipur Dhaka Bangladesh Bangladesh Dhaka Gazipur Zip Code: Audit Duration: Re-Audit: 2 Days Re-Audit After 0 Months Draft Report July 8 2016 Final Report July 14 2016 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): No There are five buildings, two main and three ancillary buildings. 1) 6-story Production Building; 2) 2-story Production Building; 3) Boiler Building; 4) Chemical Shed; 5) Water Treatment Plant. Rented 1) 6-story Production Building; 2) 2-story Production Building. 1) 6-story Production Building: 117,600 SF (19,600 SF each level); 2) 2-story Production Building: 25,420 SF (12,710 SF each level). 1) 6-story Production Building: 2006-2008; 2) 2-story Production Building: 2013-2014; 3) Boiler Building: 2006-2008; 4) Chemical Shed: 2006-2008; 5) Water Treatment Plant: 2006-2008. N/A There are three Ancillary Structures. 1) Boiler Building; 2) Chemical Shed; 3) Water Treatment Plant. 1) Boiler Building: 1,140 SF; 2) Chemical Shed- approximately: 150 SF; 3) Water Treatment Plant: 600 SF. The Alliance for Bangladesh Worker Safety Page 3/18

15 Jun 2016 Number of Occupants: Number of Ancillary Levels (Stories): Occupancy Type: Construction Type: Height of est Occupied Floor Level Above Grade: 1) 6-story Production Building: 783 (GF: 71, 1st: 78, 2nd: 183, 3rd: 168, 4th: 121, 5th: 162); 2) 2-story Production Building: 150 (GF: 0, 1st: 150). 1) Boiler Building: 1 story; 2) Chemical Shed: 1 story; 3) Water Treatment plant: 2 story. Industrial- G2 (RMG) 1) 6-story Production Building: Type-2, with non-rated steel shed on roof; 2) 2-story Production Building: Type- 2; 3) Boiler Building: Type-2; 4) Chemical Shed: Non-rated; 5) Water Treatment Plant: Type-2. 1) 6-story Production Building: 20.42 m (67 ft); 2) 2-story Production Building: 3.81 m (12 ft 6 in); 3) Boiler Building: At grade; 4) Chemical Shed: At grade; 5) Water Treatment Plant: 3.05 m (10 ft). The Alliance for Bangladesh Worker Safety Page 4/18

15 Jun 2016 ASSESSMENT FINDINGS Fire Protection Construction Are openings and penetrations through rated walls and/or assemblies protected? Openings through the rated walls were noticed at the entrance to each exit in the 6 story RCC production building. In stairs 2 and 3, collapsible gates are provided. For the 2 story RCC production building, openings were discovered in the stairs without p Photograph: i) Collapsible gate in the 6 storied main production building. ii) Opening in the stair enclosure of 2 storied RCC production 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. 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? Floors are not properly separated with fire-resistive rated construction barriers and are not provided with proper opening or penetration protection. Visual Assessment: unprotected openings/penetrations were noticed during assessment. Provide fire-resistive rated construction barriers between floors in accordance with Alliance Standard Section 4.5. Consult a qualified fire protection engineer to design the rated construction barriers. Reference Alliance Standards Part 4 Section 4.5 Separation Are separations between hazards provided with fire-resistive rated construction barriers. The Alliance for Bangladesh Worker Safety Page 5/18

15 Jun 2016 The occupancy separation between the office area and the production area on the 1st floor, and the storage area and production area on ground floor of the 6-story Production Building did not seem to be provided. Visual Assessment: The facility survey. 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. Reference Alliance Standards Part 4 Section 4.5 Separation Certificates of Occupancy for each building have been issued and are on file. Low Certificate of occupancy was not provided. It was noticed that the factory has already applied to the Director General, Fire Service & Civil Defence, Dhaka for issuance of a Certificate of Occupancy vide their letter dated 2 September, 2015. That letter w Document Review: Documents reviewed. 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. 15 Sep 2016 Are certificates of occupancy provided for each building or ancillary structure? Fire Protection Systems The Alliance for Bangladesh Worker Safety Page 6/18

15 Jun 2016 Does the building have a Standpipe System? The highest occupied floor of the 6-story Production Building is 66 ft 4 in. which is greater than the 33 ft requirement. The building is only provided with Class II hose stations located in the interior of the floor and in the stairwell. No 2 ½ in. Class Photograph: i) Standpipe system piping. ii) Class II hose station in the stairwell. iii) No hose connection in the stairwell. Revise the existing Standpipe System with a Class III Standpipe System for the facility in accordance with NFPA 14. Prior to any work, the design document of the required Standpipe System shall be submitted to the Alliance for review. Consult a qualified fire protection engineer to design the standpipe system. Does the building have a standpipe system installed where required. Alliance Standard Part 5 Section 5.4.2 Does the building have a fire pump? The facility is provided with an electrically driven non-listed pump of approximately 550 gpm at 51 m capacity. It is located in a shed alongside the exit discharge of exit stair 2. The pump is attached to the ETP without providing any separation between Photograph: i)the existing pump for the Standpipe system. ii) The roof mounted water tank 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 The Alliance for Bangladesh Worker Safety Page 7/18

15 Jun 2016 Are notification and initiation devices for the fire alarm system installed at required locations based on occupancy type? Notification and initiation devices for the fire alarm system were noticed installed in the facility, but they do not seem to be appropriately spaced. The design document provided during the inspection was not approved by the appropriate authority. Photograph: i) Pull station. ii) Gong bell. iii) Smoke detector. iv) No smoke detector in the ceiling. V) The FACP 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. Pull stations at egress points, smoke detectors in air handling equipment, visual and audible devices spaced appropriately based on occupancy type. Reference NFPA 72 Are fire department connections provided and clearly identified for the Fire Protection Systems? The facility is provided with a fire department (Siamese) connection that is connected with under-sized system piping. The Alliance for Bangladesh Worker Safety Page 8/18

15 Jun 2016 Photograph: The existing FDC provided for the facility. 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 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 Documentation for inspection, maintenance, and testing procedures of the standpipe and hose system did not appear to be in accordance with NFPA 25. Document Review: Document reviewed. 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 Is signage for the standpipe system installed at required locations and on required components? Low No signage in accordance with NFPA 14 Chapter 6 was noticed during the assessment. Visual Assessment: The facility survey. Install signage at required locations and on required equipment. Signage must comply with NFPA 14. 30 Sep 2016 Reference NFPA 14 Chapter 6 Are inspection, maintenance, and testing procedures of the fire pump documented and up to date? The Alliance for Bangladesh Worker Safety Page 9/18

15 Jun 2016 Low Documentation provided for inspection, maintenance, and testing procedures did not appear to be accurate, as it was for a diesel generator and not for the existing electrically driven fire pump. Document Review: Document was reviewed. Establish an inspection, testing, and maintenance program for the fire pump. Program must comply with NFPA 25. Reference NFPA 25 Chapter 8 Fire Pumps Means of Egress 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. Exit discharge of stairs 2, 3, & 4 of the 6-story Production Building, and stair 2 of the 2-story Production Building is not directly to the exterior of the building. The discharges are to egress courts serving as a portion of the exit discharge open to t Photograph: i) The exit discharge located on the East side. ii) The exit discharge located on the South side. iii) The exit discharge located on the West side. Route exits directly to the exterior or provide 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 egress court. Alliance Standard Part 6 Section 6.17 Exit Discharge. See Section 16.7.2 and 16.7.3 for exceptions. The Alliance for Bangladesh Worker Safety Page 10/18

15 Jun 2016 Landings are provided with the same width in the direction of egress travel as the stair clear width provided at each level and at intermediate landings. Existing landings that are less than the stair width, shall reduce the overall available capacity of the stair. Landings are not provided with the same width in the direction of egress travel as the stair clear width at stair 3 of floor level 5. The landing measures only 30 in. versus 82 in. clear stair width. Photograph: The stair landing is less than the stair clear width for level 5, stair 3. In Accordance with Alliance Standard Section 6.9.2.2, increase the landing widths to make it equal to the width of the stairs or reduce the overall available capacity of the stairs as calculated in Section 6.5 (this may also effect the maximum occupant load of any floor or story of the building). Alliance Standard Part 6 Section 6.9 Stairs and Section 6.5 Interior exit stairways and ramps terminate at an exit discharge except where terminating at a rated exit passageway. Interior exit stairways # 2,# 3, and # 4 of the 6 story production building do not terminate at an exit discharge. They terminate on the ground floor of the building and are not separate from the interior of the floor. Photograph: Termination of interior exit stairway 3 on the ground floor. Exits shall discharge directly to the exterior of the building unless meeting the requirements of Alliance Standard Section 6.17.2 or 6.17.3. 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. Alliance Standard Part 6 Section 6.14 Exit Enclosures The Alliance for Bangladesh Worker Safety Page 11/18

15 Jun 2016 Exit access corridors serving an occupant load exceeding 30 are separated by walls having a fire-resistance rating of 1 hr. On the 1st floor of the 6-story Production Building, an exit access corridor exists between the office area and the finishing section. The corridor walls are not provided with a fire resistance rating of 1 hr. Photograph: Exit access corridor on level 2 of the main production building. 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. 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. 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 are not locked in the direction of egress during the working hours, but locking features are provided in the collapsible gates and steel doors, that are installed in the means of egress as well as exit stairs. Photograph: i) The steel door with locking feature, at stair # 4, on the ground level. ii) The collapsible gate, at stair # 2, level 5. 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. 15 Aug 2016 Alliance Standards Part 6 Section 6.8 Doors and Gates The Alliance for Bangladesh Worker Safety Page 12/18

15 Jun 2016 Doors along the path of egress have a minimum width of 0.8 m (32 in) and have required ratings. Stair 4 does not seem to be provided with properly rated/listed doors. Also a fire door installed between the production floor and finished goods storage area was kept open by the use of plug put underneath the door leaf, and another fire door at level 6, Photograph: i) The fire door installed in the stair enclosure 1, level 4. ii) The non rated, and non listed fire door installed in the stair enclosure 4, at level 4. iii) The fire door that is kept open by the use of a plug. Provide magnetic hold open devices to the fire doors to keep them open during the working hours, and integrate them with the automatic fire alarm and detection system. Provide design drawings for Alliance review and approval prior to commencing any work. Replace non-compliant doors and frames in the means of egress with side-swinging 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. 31 Aug 2016 Alliance Standard Part 6 Section 6.5.6 Minimum Widths. Increased occupant loads will require a door width greater than 0.8 m. All doors in a means of egress are of the side-hinged swinging type. Steel sliding doors as well as Thai-Al. glass sliding doors were noticed installed in the means of egress in the 6 story production building. Photograph: i)a grill type of steel sliding door. ii) Thai-Al. glass sliding door., Visual Assessment, Photograph: i)a grill type of steel sliding door. ii) Thai-Al. glass sliding door., Visual Assessment Replace non-compliant doors and frames in the means of egress with sideswinging 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, selfclosing, fire rated door assemblies (door and frame) with latching panic hardware. Alliance Standards Part 6 Section 6.8 Doors and Gates The Alliance for Bangladesh Worker Safety Page 13/18

15 Jun 2016 Landings are provided on both sides of doors used along the path of egress. Doors do not swing out over stairs. Non-Compliance Level: 1 A landing has been provided on the interior side of the doors installed for the chemical storage and boiler room. Photograph: i) No landing on the exterior. Provide a landing on the exteriors of the chemical storage and boiler room, as well as other similar locations. Alliance Standards Part 6 Section 6.8 Doors and Gates All occupied roofs are provided with parapets or guards with a minimum height of 1067 mm (42 in.). The occupiable roof of the 6-story Production Building is provided with guards with a height of 45 in., but the open guards have a pattern such that a sphere of approximately 14 in. in diameter can pass through the openings. Photograph: The open guards on the roof level. The open guards pattern shall be corrected such that a sphere 8 in. in diameter cannot pass through in accordance with the Alliance Standard. 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 occupant loads are posted without showing the name of the posts, numbers of visitors, or the date at exit access doorways of the buildings under assessment. It was also not posted for the assembly point located on the ground level. Photograph: The occupant load posting in the main production building. Post the occupant load for all assembly and production floor areas in a The Alliance for Bangladesh Worker Safety Page 14/18

15 Jun 2016 conspicuous space near the main exit or exit access doorway for the space in accordance with Alliance Standard Section 6.4.4. 31 Aug 2016 Alliance Standards Part 6 Section 6.4.4 Posting of Occupant Load All paths of egress are provided with compliant means of illumination. On level 3, adjacent to finished goods storage, the aisles are not provided with compliant means of illumination. '0' lux was measured against the required minimum 2.5 lux. Photograph: The area is lacking compliant means of illumination. 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 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 are provided at entrances to the exits, but not along the path of egress. Photograph: i) Illuminated exit sign at entrance. ii) A production floor where directional signs are required. 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 The Alliance for Bangladesh Worker Safety Page 15/18

15 Jun 2016 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). The walking surfaces in the exit discharge, the door sills on the East and South side, and the roof level of the 6 story production building has changes in elevation that exceed Alliance Standards. Photograph: i) Walking surface in the exit discharge, South side. ii) Walking surface at roof level, door sill. 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 6.3.4. Alliance Standard Part 6 Section 6.3.4 Walking Surfaces 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 are not provided on both sides of each stairway in the 2 story production building. Handrails are provided on both sides of the stairways of the 6 story production building, but the mounting heights of the handrails of stair # 4, at landing, lev Photograph: i) The handrail on one side only. ii) The mounting height of handrail is less than the minimum required. iii) The pattern of open guard is more than the required. Provide handrails on both sides of each stairway. Mount new handrail and relocate existing handrail at a height between 30 in. and 44 in. The spacing between vertical members will not exceed 200 mm (8 inch). Alliance Standard Part 6 Section 6.9 Stairs and 6.12 Handrails and Guards Every door in a stair enclosure serving more than 5 stories is provided with reentry unless it meets the requirements of Alliance Standards Part 6 Section 6.8.3.1. The Alliance for Bangladesh Worker Safety Page 16/18

15 Jun 2016 Re-entry provisions are not provided for the 6 story production building. Visual Assessment: The facility survey. Provide re-entry to floor levels from the stairwells in accordance with Alliance Standard Section 6.8.3. Alliance Standards Part 6 Section 6.8 Doors and Gates 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 ramp that is used on the ground floor adjacent to stair no. 2 is not provided with handrails on both sides of the ramp Photograph: i) The ramp on the ground floor requiring handrails on both sides. Provide handrails on both sides of the ramp in accordance with the Standards. Alliance Standard Part 6 Section 10 Ramps 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 in English and Bengali are not provided adjacent to the door, at each floor entrance from the stairs to the floors of the buildings in accordance with the Standards. Visual Assessment: The facility survey. Install signage adjacent to each stair door indicating the stair name and the floor level in both English and Bengali. 31 Aug 2016 Alliance Standard Part 6 Section 6.9 Stairs The Alliance for Bangladesh Worker Safety Page 17/18

15 Jun 2016 Fire Safety Programs Training programs are implemented and documented in accordance with the Alliance Safety Training Curriculum. No document was available in support of implementation and documentation of Training programs in accordance with the Alliance Safety Training Curriculum. Document Review: No document was available. Implement and document the training programs for the workers in accordance with the Alliance safety Training Curriculum. Alliance Standards Part 13 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 each exit stair or main point of egress. Visual Assessment: The facility survey. Create and post emergency evacuation maps at the entrance to each stair or main point of egress. Alliance Standards Part 13 Section 13.4 Evacuation Plan The Alliance for Bangladesh Worker Safety Page 18/18