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EQUIVALENT INITIAL FIRE SAFETY ASSESSMENT 171-181, Baizid Bostami Road Nasirabad I/A, Chittagong Chittagong The Alliance for Bangladesh Worker Safety Page 1/14

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 2/14

GENERAL INFORMATION General Information Country: Province: City: Bangladesh Chittagong Chittagong Zip Code: 4210 Audit Duration: Re-Audit: Re-Audit After 0 Months Draft Report June 18, 2014 Final Report June 30, 2014 Are all Action Items From Previous Assessment Completed?: Buildings in Complex: Is the building(s) owned or rented by the : 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 Sewing Owned 7 19,578 SF * 7 stories unknown unknown A Childcare, Doctor & Training; B Security & Documentation 0 Number of Occupants: 2920 The Alliance for Bangladesh Worker Safety Page 3/14

Number of Ancillary Levels (Stories): Occupancy Type: Construction Type: Height of est Occupied Floor Level Above Grade: N/A Sewing Reinforced concrete Exposed steel roof shed 21.62 m The Alliance for Bangladesh Worker Safety Page 4/14

ASSESSMENT FINDINGS Fire Protection Construction Are openings and penetrations through rated walls and/or assemblies protected? Penetrations are not protected with listed firestop systems. Visual Assessment: Unprotected penetrations Install listed firestop systems at every penetration through floors and fire rated walls. 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? All exit stairs in the factory building are open to all levels, with no fire rated separation. Visual Assessment: Unenclosed stairs Protect all required egress stairs with a shaft enclosure including 2-hour firerated construction. Install fire rated doors in doorways through these walls. Reference Alliance Standards Part 4 Section 4.5 Separation Is each floor separated with a fire-resistive rated construction barrier? Non-Compliance Level: The Alliance for Bangladesh Worker Safety Page 5/14

Reference Alliance Standards Part 4 Section 4.5 Separation Are separations between hazards provided with fire-resistive rated construction barriers. Storage areas and hazardous areas are open to rest of building. The warehouse and transformer rooms are open into the stairs. Photograph: The storage areas on the ground and 1st floors present a greater hazard than the predominate occupancies of the sewing factory. Provide fire-resistive rated construction barriers between hazard types in accordance with Alliance Standard Sections 3.4.2 and 4.5. Separate stairs with 2-hour rated construction. Consult a qualified fire protection engineer to design the required rated Reference Alliance Standards Part 4 Section 4.5 Separation Fire Protection Systems Does the building have a fire pump? No fire pump was installed. Visual Assessment: No fire pump Install a fire pump that will deliver the greatest calculated demand of the required automatic protection systems. Design per NFPA 20 and submit for approval. Alliance Standard Part 5 Fire Protection Systems The Alliance for Bangladesh Worker Safety Page 6/14

Does the building have a Standpipe System? Non-Compliance Level: 1 Hose stations were installed on each floor for use by building occupants. Photograph: A hose rack installed outside on the rear wall near the boiler. Install a Class III standpipe system at required locations. Standpipe system must comply with NFPA 14. 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? Non-Compliance Level: 1 There is a manual fire alarm system in the factory. The system is activated with switches at the entrances to the stairs. The system is interconnected throughout the building so that all floors are notified when switches are activated. Horns were installed for notification. Single station smoke alarms were installed. These are battery powered and not connected to the fire alarm system. Visual Assessment: Non automatic fire alarm Install strobes for notification. Install smoke detectors in required locations connected to the fire alarm system. Comply with Alliance standards and NFPA 72. 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? No centrally reporting system was present. Visual Assessment: No central fire alarm reporting The Alliance for Bangladesh Worker Safety Page 7/14

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 Part 5 Section 5.7.5 Monitoring. Until that time that a central station monitoring Alliance Standard Part 5 Section 5.7.5 Monitoring Means of Egress Means of egress are free from impediments, obstructions, and stored materials. Stairs included thresholds and sliding gate tracks. The alley was cluttered, and the available egress width was reduced by storage of sand and barrels. The dining area on the roof included thresholds and there were pipes installed on the roof which created tripping hazards. On the 3rd and 4th floors boxed goods were piled so as to encroach into the egress aisles. One exit from the boiler area into the alley was blocked with trash. Photograph: Photograph 1 Remove tripping hazards including thresholds and pipes on the roof in the egress paths. Install 1:12 ramps instead of thresholds. Relocate all stored goods and trash to fire rated storage rooms. Clear trash and other materials from the alleys and other ex Alliance Standard Part 6 Section 6.3.8 Impediments to means of egress and Section 6.3.9 Reliability Doors along the path of egress have a minimum width of 0.8 m (32 in) and have required ratings. All doors were unrated. Visual Assessment: Unrated doors Protect all egress stairs with a shaft enclosure including 2-hour fire-rated construction. Install fire rated doors in stair doorways. Install listed, labeled, approved, automatic-closing, side-swinging, fire rated doors in fire rated frames with latching The Alliance for Bangladesh Worker Safety Page 8/14

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. Doors in the egress stairs and exits include sliding doors and sliding gates. Photograph: Sliding steel door at the top of Northwest stair. Install side-swinging doors with panic hardware. Doors should swing in the direction of egress. Alliance Standards Part 6 Section 6.8 Doors and Gates Occupant loads on each level (floor) do not exceed the capacity of the available means of egress. Non-Compliance Level: 2 Gnd floor load= 10 capacity=622, 1st floor load=125 capacity=622, 2, 3, 4 & 5 l=696 capacity=622, Roof canteen l=700 capacity=622 Visual Assessment: Occupant capacity exceeded Limit the number of allowable occupants per floor to 622 on all floors. Alternately, provide automatic sprinkler protection throughout the building to increase the occupant capacity to 995. Alliance Standard Part 6 Section 6.4 Occupant Load 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. Non-Compliance Level: 2 Stairs included sliding gates with tracks at the floors, locked open. Gates often reduced the available door width to 3-4. A threshold and a sliding gate locked open were installed at the roof. The Alliance for Bangladesh Worker Safety Page 9/14

Photograph: Sliding gate locked open. Remove all hasps, locks, sliding gates, tracks, bolts and other non-compliant devices. Alliance Standards Part 6 Section 6.8 Doors and Gates Stairwells are not utilized as storage spaces. Non-Compliance Level: 1 The top of the elevator shaft in the stair was covered with cardboard. Visual Assessment: Storage in stairwell Remove all combustibles from the stairs. Alliance Standard Part 13 Section 13.9 Safety Inspections The number of means of egress from any floor or story is not less than 2 except where a single exit is permitted or where a greater number is required. Non-Compliance Level: Alliance Standard Part 6 Section 6.6 Number of Means of Egress Occupant loads are posted for every assembly and production floor in a conspicuous space near the main point of egress. No occupant load signs are posted. The Alliance for Bangladesh Worker Safety Page 10/14

Visual Assessment: No signage provided Install occupant load signs at every floor landing in each stair. Alliance Standards Part 6 Section 6.4.4 Posting of Occupant Load 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 installed on one or no sides of the stairs. Visual Assessment: Insufficient handrails Install handrails on both sides of all stairs. Install handrails at stair discharge steps and ramps. 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. Doors were not equipped with required hardware. Visual Assessment: No re-entry provided Install fire rated doors and include re-entry hardware at the 3rd floor. Alliance Standards Part 6 Section 6.8 Doors and Gates 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 Alliance for Bangladesh Worker Safety Page 11/14

Non-Compliance Level: 2 Egress was through alleys which included uneven walking surfaces. Visual Assessment: Uneven exit discharge Regrade egress alleys to create a smotth and level walking surface. Alliance Standard Part 6 Section 6.3.4 Walking Surfaces All paths of egress are provided with compliant means of illumination. Non-Compliance Level: 1 Some emergency lights were present and installed on emergency power. Visual Assessment: Insufficient exit lighting Provide illumination of egress paths at all times the building is occupied. 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. 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. Non-Compliance Level: 1 Lighted exit signs were installed only at the exits, and were equipped with battery backup. Visual Assessment: Insufficient exit signage Provide continuously illuminated exit signs at all required exits and along egress paths, especially where path has a change of direction. Alliance Standard Part 6 Section 6.11 Exit Signs Stair designation signs are provided at each floor entrance from the stair to the The Alliance for Bangladesh Worker Safety Page 12/14

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: 2 Stair designation signs are not provided at all floor entrances. Visual Assessment: No signage provided Install stair designation signs at every floor landing. Alliance Standard Part 6 Section 6.9 Stairs Fire Safety Programs Storage areas underneath the cutting tables are clear of combustibles. Combustibles were store under the cutting tables. Visual Assessment: Storage under tables Remove all storage from under cutting tables and similar obstructions. Alliance Standard Part 17 Section 13.7.2 Cutting tables. The Alliance for Bangladesh Worker Safety Page 13/14

A written housekeeping policy is established and enforced. Low On the 3rd and 4th floors boxed goods were piled so as to encroach into the egress aisles. The warehouse area included a large pile of trash with no aisles. One exit from the boiler area into the alley was blocked with trash. Alleys were cluttered. Photograph: Photograph 1 Relocate all stored goods and trash to fire rated storage rooms. Clear trash and other materials from the alleys and other exit paths. Keep all exit aisles clear on the factory floors. Alliance Standards Part 13 Section 13.6 Housekeeping The Alliance for Bangladesh Worker Safety Page 14/14