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INITIAL FIRE SAFETY ASSESSMENT - EXPANSION Hatimara Road, Barenda, Kashimpur, Gazipur, Gazipur Dhaka The Alliance for Worker Safety Page 1/11

30 Oct 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 Worker Safety (Alliance) and conducted by a third-party Qualified Assessment Firm (QAF). The assessment was conducted against the Alliance for Worker Safety Assessment Protocols (APs) and Fire Safety and Structural Integrity Standard, which is harmonized with the factory assessment guidelines developed by University of Engineering and Technology (BUET) for the National Tripartite Plan of Action (NTPA). The goal of the Alliance process is to provide clear and practical technical requirements by which i 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 Worker Safety Page 2/11

GENERAL INFORMATION General Information Country: Province: City: Dhaka Gazipur Zip Code: 1346 Audit Duration: Re-Audit: 1 Days Re-Audit After 0 Months Draft Report 08.11.16 Final Report 13.11.16 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 There are 5 buildings in the complex, 4 main and 1 ancillary building. 4 main buildings (including GF through 3rd of building-2) and 1 ancillary were previously assessed. This assessment includes 4th through 6th of building 2. Owned 7-stories 4th through 6th: 57,600 SF 2012-2013 (Main Building) 2015-2016: Expansion of building 2 (4th through 6th). One ancillary structure which was previously assessed. N/A The Alliance for Worker Safety Page 3/11

Number of Occupants: 2,050 Number of Ancillary Levels (Stories): Occupancy Type: N/A G2 Construction Type: Type 1 Height of Highest Occupied Floor Level Above Grade: 23 m (75.5 ft) The Alliance for Worker Safety Page 4/11

ASSESSMENT FINDINGS Expansion Details Are as-built drawings available for new fire safety features of the building? High As-built drawings are not available for new fire safety features of the building. Document Review: According to document review of this factory. Prepare as-built drawings for new fire safety features of the building. 04 Dec 2016 Alliance Standard reference 8.20 Fire Protection Construction Are separations between hazards provided with fire-resistive rated construction barriers. A machine Oil tank was found which is not separated from the production floor with fire-resistive rated construction barriers. It produces extreme heat which effects the production floor. Photograph: Oil tank is not separated. 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. 07 May 2017 Reference Alliance Standards Part 4 Section 4.5 Separation Certificates of Occupancy for each building have been issued and are on file. Low The Alliance for Worker Safety Page 5/11

Occupancy certificate was not found during the assessment. Document Review: According to the document review of the factory. 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. 25 Dec 2016 Are certificates of occupancy provided for each building or ancillary structure? Fire Protection Systems Is the building protected by an automatic sprinkler system? High Height of the highest occupied floor of the building is 23 m (75.5 ft). Thus sprinkler system is required for the building. Install automatic fire sprinkler systems throughout the facility in accordance with Alliance Standards and NFPA 13. Develop shop drawings and hydraulic calculations, including all details as outlined in NFPA 13. All sprinkler system installations shall be submitted for review to the Alliance prior to commencement of installation. Manufacturing areas and storage less than 12 feet high is classified Ordinary Hazard (Group 2). Sprinkler systems should be designed to deliver 0.20 gpm/ft2 over the most remote 1500 square feet, 250 gpm hose allowance, 90 minute water supply duration. Acceptance testing of the installation shall be conducted in accordance Allaince Standard Section 5.3.4. 03 Aug 2017 Reference Alliance Standards Part 3 Section 3.5.3 Existing Buildings, Part 5 Section 5.3 Automatic Sprinkler Systems and Section 6.13 Travel Distance Trouble or alarm notifications were not indicated on the fire alarm control panel. High Central fire alarm and detection system was not found during the assessment of the factory. Install an automatic fire alarm and detection system for the facility. System The Alliance for Worker Safety Page 6/11

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. 04 Dec 2016 Alliance Standard Part 13 Section 13.10 Maintenance of Fire Protection Equipment Are notification and initiation devices for the fire alarm system installed at required locations based on occupancy type? High Notification and initiation devices for the fire alarm system were not found during the assessment. 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. 05 Feb 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? Central fire alarm and detection system was not found during the assessment of the factory. Install a new fire alarm and detection system. Once installed, arrange for direct connection of the 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 service or direct connection to the Fire service and Civil Defense can be set up, 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. The Alliance for Worker Safety Page 7/11

11 Dec 2016 Alliance Standard Part 5 Section 5.7.5 Monitoring Are fire department connections provided and clearly identified for the Fire Protection Systems? Non-Compliance Level: 1 Fire department connections were found, but no signage is provided. Photograph: Identification sign was not found. Provide clear identification signage for fire department connections. 07 May 2017 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 Inspection, maintenance and testing documents fot the standpipe and hose system were not found during the assessment. Document Review: According to the document review of the factory. 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. 07 May 2017 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 Signage was not found for the standpipe system. The Alliance for Worker Safety Page 8/11

Install signage at required locations and on required equipment. Signage must comply with NFPA 14. 25 Dec 2016 Reference NFPA 14 Chapter 6 Are inspection, maintenance, and testing procedures of the fire pump documented and up to date? Low Inspection, maintenance and testing documents were not found during the assessment. Document Review: According to the document review of the factory. Establish an inspection, testing, and maintenance program for the fire pump. Program must comply with NFPA 25. 07 May 2017 Reference NFPA 25 Chapter 8 Fire Pumps Means of Egress 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. High During the assessment, locking devices were found on the production floor. Photograph: Locking device. 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. 04 Dec 2016 Alliance Standards Part 6 Section 6.8 Doors and Gates Occupant loads are posted for every assembly and production floor in a The Alliance for Worker Safety Page 9/11

conspicuous space near the main point of egress. Occupant loads were not posted for assembly points. 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 6.4.4. 04 Dec 2016 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 are not provided in the stair. Photograph: Both side handrails are missing. Provided handrails on both sides of each stairway. Mount new handrails at a height between 34 in. and 38 in. as per Alliance Standard Section 6.12. 07 May 2017 Alliance Standard Part 6 Section 6.9 Stairs and 6.12 Handrails and Guards Fire Safety Programs Storage areas underneath the cutting tables are clear of combustibles. Storage areas underneath the cutting table are not clear of combustibles. Photograph: Combustible materials underneath the cutting table. Remove all combustibles stored underneath the cutting tables in accordance with Alliance Standard Section 13.7.2. 04 Dec 2016 The Alliance for Worker Safety Page 10/11

Alliance Standard Part 17 Section 13.7.2 Cutting tables. The Alliance for Worker Safety Page 11/11