FIRE SAFETY INSPECTION REPORT TOYO COMPOSITE KNIT GARMENTS LTD 1, SOUTH KAMALAPUR SARDER COMPLEX, DHAKA Other Factories: Pure Cotton Ltd, Knit and Knitwear Ltd June 7, 2014
Page 2 Fire Safety Inspection Report Introduction manufacturing complex was surveyed for fire safety on 6/7/2014 by Hughes Associates, Inc. The purpose of the survey was to identify significant fire safety issues and to provide recommendations for remediation based on applicable standards specified by the Accord. The scope of this initial fire safety inspection was limited to the review and identification of major fire safety issues. The inspection did not include identification of minor deficiencies, which will be further addressed as part of follow-up inspections. Limitations The information in this fire safety inspection report was obtained during a visit to the facility and during interviews with local factory management. It has not been possible to provide independent verification for all the information and data collected, and, therefore, Hughes cannot accept general responsibility for omissions or errors arising from inaccuracies in this report from the information obtained. The findings and recommendations in this report are not intended to imply, guarantee, ensure or warrant compliance with any government regulations. Additionally, the results do not imply in any way that compliance with the findings or recommendations as stated in this report will eliminate all hazards, risks or exposures or that hazards, risks or exposures not referred to in this report do not exist. Compliance with the findings and recommendations stated in this report does not relieve the factory owner from obligation to comply with specific project requirements, industry standards, or the provisions of any local government regulations.
Page 3 General Factory Information Factory Building Name(s): Factory Address: 1, South Kamalapur Sarder Complex, Dhaka Points of Contact: M. Shafiqul Alam Sunny,Manager Admin Bangas Tallu 88001712088031 sunny@toyopureknit.com
Page 4 s No. of Stories Below / Above Grade 0 / 7 High Rise High Rise Comments: Based off measurement, the building height is approximately 65 ft. at the highest occupiable level. Occupancy Classification G2 Industrial H2 Storage E Assembly F Business Floor Plans Available Ground Floor Third Floor
Page 5 Rooftop Side Elevation Date Of Construction 1993-1995 Major Renovations Comments The first floor used to be residential. During the inspection the floor was gutted and being renovated for future use by the factory. Factory management reports that the construction will be complete within one (1) month. Reportedly once construction is complete, the first floor is to be used for: finishing, offices, childcare, doctor, conference, packaging, and finished goods storage. The offices, child care, and doctor are to be moved from the second floor to the first. In the vacant floor space of the second floor, there are to be sewing, cutting, and finishing sections. The rooftop was also under construction during the inspection. At the time of the inspection no occupant load was present on the floor. The dining, prayer, and canteen rooms, that are to be in a single separate structure accessed from the the exterior of the rooftop, were in the process of being built. Factory management reports that the construction will be complete within two (2). Other Tenants Comments Pure Cotton Ltd occupies the fourth floor and Knit and Knitwear Ltd occupies the fifth floor.
Page 6 Floors Occupied By Factory Ground to third and rooftop. Floor Use Occupant Load G 1 2 3 R Office, generators, transformer, car parking Under construction Offices, child care, sampling, doctor, storage Sewing, finishing, cutting Under construction 16 115 75/150 150 150 Non-Combustible Fire-Resistive No North Open road. South Four (4) story residential, approximate 5 ft. separation. East Side alley with shops, approximate 15 ft. separation. West Three (3) story residential, approximate 5 ft. separation. Stairs Enclosed in Fire- Rated Construction? No Unsealed Penetrations in Stairs Unprotected Openings From Stairs
Page 7 Shafts Enclosed in Fire- Rated Construction Floors with Openings/Penetrations Other Vertical Openings No Two (2) exit stairs serve the building. Egress from the ground floor is provided by two (2) exits. There was also a small non-compliant service stair from the first to ground floor (previously used when the first floor was residential). Factory management reported that this stair is not to be used as an exit stair in the future. Each floor had an adequate number of exits with sufficient exit capacity based on occupant load. The exits on all floors, except those on the ground floor, were not remotely located. All exits, except the west exit stair, discharge to the exterior of the building. All exit stairs were open on all floors due to unprotected openings. The west exit stair was open to the ground floor due to an unenclosed stairwell. There was storage and unsealed penetrations located in each exit stair. Sliding gates with locking features were present at building exits, exit stairs, along egress routes, and at exit discharge. All gates were not open and unlocked during the inspection, specifically the ground floor east exit stair discharge. Emergency evacuation plans were located at inside both exit stair on each floor. Fire drills are conducted every 1-2, records were provided during the inspection. Floor Occupant Load No. Exits Exit Capacity G 1 2 3 R 16 115 75/150 150 150 2 2 2 2 2 500+ 416 416 416 416 Exit Number/Capacity Adequate Exits Remote No
Page 8 Sliding Gates/Doors Used? Egress Doors Swing Correctly? Egress Doors Lockable? All Stairs Discharge to the Exterior? No Discharge Capacity Adequate Handrails on at least One Side? Storage Located in Stairs? Storage in Egress Paths? No Egress Paths of Adequate Width? Excessive Travel Distances, CPT, DE's No Emergency Evacuation Plans Provided? Fire Drills Conducted
Page 9 Records Maintained Exemplar Emergency Evacuation Plan No sprinkler system present in the building. Based on the height of the highest occupiable floor, automatic sprinkler protection is not required. Dry chemical automatic extinguishing spheres were provided throughout the building on all floors occupied by the factory, excluding the first floor and rooftop. Both the first floor and rooftop were under construction during the inspection. Dry chemical automatic extinguishing spheres are not required on theses floors once construction is complete. Hose reels with 1 in. hoses were provided by floor in the factory. The hoses were located inside or outside the east exit stair. Hose Size(s) Provided 1 in.
Page 10 Locations By floor, inside or outside the east exit star. Exemplar Hose Reel The fire hose system is supplied by a fire pump system fed by an underground cistern. The cistern has a reported capacity of 45,000 L. and is accessed from the ground floor. During the inspection the underground cistern was observed to be only partially filled. The fire pump system consists of a diesel fire pump and a jockey pump. Source(s) One (1) tank. Location Ground floor. Capacity 45,000 L. Fire Pump
Page 11 A manual fire alarm system was provided in the building. It consists of manual notification switches and a single horn unit on each floor. By performing a functional test of the system it was confirmed that the activation switches on each floor trigger the fire alarm for the entire building. There was no fire panel connected to the fire alarm system. Records of regular testing or maintenance of the fire alarm system were provided however they were not in accordance with NFPA 72. No fire alarm system was present on the first floor or rooftop (in the proposed dining area) during the inspection, both floors were currently undergoing construction. Type of System Manual fire alarm (visible). Fire Panel Location None Visible Notification Appliances? No Audible Notification Appliances? Alarm Annunciation Functional Test Conducted Manual Whole Building Regular Inspection, Testing, & Maintenance? No
Page 12 Exemplar Manual Fire Alarm Activation Point Exemplar Horn Unit Single station smoke alarms are located in various places throughout the factory. These smoke alarms are not tied into the fire alarm system. In the event they detect smoke, they will provide a local alert sound. Records of regular testing or maintenance of the fire detection system were provided however they were not in accordance with NFPA 72. No detection system was present on the first floor or rooftop during the inspection, both floors were currently undergoing construction. Type of Detectors Single Station Smoke Alarms Regular Inspection, Testing, & Maintenance? No
Page 13 Exemplar Single Station Smoke Alarm Portable fire extinguishers, consisting of a mix of CO2 and dry chemical extinguishers, are provided throughout the building. Inspection tags showed recent and up-to-date inspections. Types Provided CO2 and dry chemical. Adequate Number/Spacing? Exemplar Fire Extinguisher Exemplar Inspection Tag
Page 14 Each floor had firefighting equipment staged inside or outside each exit stair. Types of manual firefighting equipment provided included: water/sand bucket, bolt/lock cutter, hard hat, fire beater, gaff, rope, stretcher, and respirator. Types of Equipment Provided Water/sand bucket, bolt/lock cutter, hard hat, fire beater, gaff, rope, stretcher, respirator. Location of Equipment By floor, inside or outside each exit stair. There were multiple florescent lights that have an alternate Instant Power Supply (IPS) on each floor. It was observed that some of these IPS lights were connected to on/off switches. An emergency lighting bulb was observed to be missing from the east exit stair on the first floor. Each floor had a number of illuminated exit signs (a mix of directional and non-directional) located along the exit access and at exits. It was observed that some of these exit signs were connected to on/off switches. Records of regular testing or maintenance of the emergency lighting system were provided however they were not in accordance with The ACCORD Standard. No emergency lighting system was present on the first floor or rooftop during the inspection, both floors were currently undergoing construction. Exits and Exit Access Properly Marked with Exit Signage Emergency Power IPS Emergency Lighting for Exits & Exit Access No Regular Inspection, Testing, & Maintenance? No
Page 15 Exemplar Exit Sign Exemplar Directional Exit Sign Exemplar "IPS" Emergency Light No elevators were provided in the building however two elevator shafts were provided in the building. The shafts were sealed on all floors except the ground floor. The doors to the shafts were non fire-rated construction. Factory management reported no intent to install elevators in the building in the future. Three (3) diesel generators that serve the building are located on the ground floor. Additional fuel storage (seventeen 55 gallon drums) was present in a room adjacent to the generator room. Both rooms did not have proper fire-rated separations.
Page 16 Location(s) Ground floor. Inside Fuel Storage Fire Rated Separations Provided? No Generator #1 Generator #2 Diesel Fuel and Machine Oil Storage
Page 17 One (1) boiler is provided on the third floor with no proper separation between the boiler room and the factory floor. The boiler was not present during the inspection, factory management reported that the boiler was in the process of being repaired. Location(s) Third floor. Fire Rated Separations Provided? No Boiler Room One (1) transformer located on the ground floor serves the building. The transformer did not have proper fire-rated separations due to the fact that it was unenclosed and open to the surrounding area. Location(s) Ground floor. Fire Rated Separations Provided? No
Page 18 Transformer The building had dedicated storage rooms on the ground (finished goods storage), second (accessory store), and third (waiting for packing room) floors. All dedicated storage rooms were not provided with adequate fire-rated separations. Also, storage was open to the factory floor on the second and third floor. Fire Rated Separations Provided? No Open to Factory Floors? Open to Exit Discharge? No The day-care room is the second floor and does not have direct access to an exit stair. The measured travel distance to the nearest exit stair was approximately 36 ft. Reportedly, the daycare room is to be moved to the first floor in one (1) month once the renovation of the first floor is complete.
Page 19 Findings & Recommendations Table 1 summarizes the major fire safety issues identified during the inspection. Recommendations have been provided to address each issue. An implementation schedule shall be developed by the factory to remediate each of the findings. The specific timing of improvements, including any requested extensions due to design / installation constraints, shall be submitted to the Accord for approval.
Page 20 Table 1. Findings And Recommendations No. Category Finding Recommendation Remediation Timeframe F-1 Fire Rated Construction The generator/transformer areas on the ground floor are not separated by fire-rated construction. One generator has unprotected openings, a non-rated door, and unsealed penetrations. The other generator and the transformer are open to the ground floor. Separate the generator/transformer rooms by a minimum 2-hr fire-rated construction. Seal and/or protected all openings to maintain the required fire separations. Seal the existing generator room entrance and provide an exterior entrance from the adjacent alley. Within 3
Page 21 F-2 Fire Rated Construction Areas used for combustible storage are not separated by firerated construction. Specifically the ground floor finished goods storage, the second floor accessory store, and the third floor waiting for packing room. Provide dedicated storage rooms separated by minimum 1-hr fire-rated construction. Within 3
Page 22 F-3 Fire Rated Construction All exit stairs are not separated from work areas and other spaces on each floor by firerated construction. Provide minimum 1.5-hr fire rated doors and seal all unprotected openings to separate the exit stairs from work areas and other building spaces on all floor levels. Ensure that the fire doors are self-closing and positive latching and that they are provided with fire exit (panic) hardware where serving production floors. Within 3 If fire doors are required to be held open for functional reasons, provide automaticclosing devices tied to the fire alarm system.
Page 23 F-4 Fire Rated Construction The boiler room on the third floor is not separated by fire-rated construction due to unprotected openings and penetrations. Separate the boiler room by a minimum 2-hr fire-rated construction. Seal and/or protected all openings to maintain the required fire separations. Within 3
Page 24 F-5 Fire Rated Construction Unprotected penetrations are located in the fire-rated floor/ceiling assembly from the second to fourth floor. The piping that penetrates the floor/ceiling assembly is not fire-rated construction (plastic piping). Seal all penetrations and openings in floor/ceiling assembly and provide firerated penetrations to maintain the fire separation. Within 3 F-6 Fire Rated Construction Possible unsealed penetrations and openings are located in all exit stair enclosures. Specifically, non firerated paneling was present in each exit stair. What penetrations, if any, behind the paneling was not able to be observed during the inspection. Seal all penetrations and openings in exit stair enclosure walls to maintain the fire separation. Within 3
Page 25 F-7 Fire Rated Construction A combustible liquid storage area (diesel fuel and machine oil) was present on the ground floor. The area was not separated by fire-rated construction and open to the surrounding areas. Separate the combustible liquid storage area by a minimum 2-hr fire-rated construction. Seal and/or protected all openings to maintain the required fire separations. Within 3
Page 26 F-8 Fire Rated Construction Areas used for combustible storage on the second and third floor were open to the factory floor and not separated by fire-rated construction. Provide dedicated storage rooms separated by minimum 1-hr fire-rated construction. Where separate storage rooms are not feasible, provide defined storage areas and limit the storage arrangement as follows: - Maximum height of 2.4m and maximum area of 23m2 - If sprinkler protected: maximum height of 3.66m and maximum area of 93m2 Within 3 Separate areas of unenclosed combustible storage by a minimum clear distance of 3m.
Page 27 F-9 Fire Rated Construction The west exit stairs were not enclosed in fire-rated construction on the ground floor. Enclose the west exit stairs with 2-hr fire rated construction on the ground floor for either scenario. First, if the exit is to be altered to discharge directly outside or second, if the ground floor is sprinklered. Within 6 Alternately, if a 2-hr fire-rated exit passageway leading directly outside (vestibules to separate any storage areas) is provided, no enclosure is required at the ground floor exit discharge location.
Page 28 F-10 Fire Rated Construction The area used for parking of personal motor vehicles on the ground floor is open to egress paths. Separate the parking area on the ground floor from other spaces by 1- hr fire resistive rated construction. If not possible due to egress routes, cease to utilize the area for parking of personal motor vehicles. Ensure that two (2) exits, separate from the car parking area, are provided from the ground floor. Within 6 Alternately, provide sprinkler protection on the ground floor in accordance with NFPA 13. F-11 Fire Rated Construction The finished goods storage room on the ground floor discharges to an exit enclosure if a 2-hr fire-rated exit passageway is constructed from the bottom of the west exit stair to the outside. If a 2-hr fire-rated exit passageway is constructed, provide a 2-hr fire-rated vestibule on the finished goods storage room side. Provide a 1.5-hr fire rated door on the exit passegway side and a 1-hr fire-rated door on the storage room side. Within 6
Page 29 F-12 Egress Egress doors and gates with locking features are provided at building exits, exit stairs, along egress routes, and at exit discharge. All gates were not open and unlocked during the inspection, specifically the ground floor east exit stair discharge. Remove locking features from all egress doors and gates. If locks are required for security reasons, utilize special door locking features complying with NFPA 101. Immediate
Page 30 F-13 Egress Storage was located in all exit stairs. Specifically the ground floor of he west exit stair and the first floor of the east exit stair. Remove all storage from exit stairs and egress paths. Immediate
Page 31 F-14 Egress Collapsible gates are provided at building exits, exit stairs, along egress routes, and at exit discharge. Replace all gates and sliding doors along the means of egress with side-hinged, swinging egress doors. If locks are required for security reasons, utilize special door locking features complying with NFPA 101. Within 1 month
Page 32 F-15 Egress The day-care room on the second floor does not have direct access to an exit stair. The measured travel distance to the nearest exit stair was approximately 36 ft. Reportedly, the daycare room is to be moved to the first floor in one (1) month once the renovation of the first floor is complete. Once moved to the first floor, locate the day-care room such that it has direct access to an exit stair. If not possible, relocate the day-care room to ground floor with maximum travel distance of 9m (30 ft) to an exit. Within 3 F-16 Egress The south exit stair discharges inside the building on the ground floor to a car parking area. Modify stair to discharge directly outside. Alternately, provide 2-hr firerated exit passageway leading directly outside (vestibules to separate any storage areas). Within 6 Alternately, provide sprinkler protection for the ground floor in accordance with NFPA 13.
Page 33 F-17 Egress The exits on all floors, except the ground, are not remotely located from each other such that a single fire event could compromise both exits. An approximate exit separation of 77 ft. is required however an approximate exit separation of 58 ft. is present on the floors. All distances were calculated from measurements taken during the inspection. Provide additional exit that is remotely located from either existing exit stair. Alternately, provide sprinkler protection in accordance with NFPA 13. If provided, an approximate exit separation of 51 ft. is permitted. Within 6 F-18 Fire Protection The fire alarm system is antiquated, not a listed system, and does not provide alarm and notification features consistent with acceptable standards. Replace the fire alarm system with a new, listed addressable fire alarm system in accordance with NFPA 72. Design within 4, install within 9
Page 34 F-19 Fire Protection Inspection, testing, and maintenance for the fire alarm system was not in accordance with NFPA 72. Inspect, test and maintain the fire alarm system, and keep written records on-site, in accordance with NFPA 72. Within 3 F-20 Fire Protection The building is equipped with single-station smoke alarms. Smoke alarm activation sounds only a local alarm and does not provide automatic fire alarm notification of occupants. Replace the single-station smoke alarms with automatic smoke detectors tied into the fire alarm system as per NFPA 72. Within 6 No smoke detection system was present on the rooftop and first floor. Both areas were under construction during the inspection.
Page 35 F-21 Fire Protection The fire alarm system does not appear to provide adequate audible notification coverage for the rooftop and first floor. Both areas were under construction during the inspection. Once construction of the rooftop and first floor is complete, provide notification appliances such that the fire alarm system is audible throughout in accordance with NFPA 72. Within 6 On the rooftop, it does not appear that the location of the existing rooftop horn unit (within the exit stair enclosure) will provide adequate audible notification coverage for the rooftop dining area. The rooftop dining area is to be accessed from the exterior. The first floor was completely gutted and undergoing renovations during the inspection. F-22 Egress Lighting Manual on-off switches are provided for some emergency lighting and exit signage units throughout the building. Remove manual on/off switches from emergency lighting and exit signage units to prevent them from being switched off. Within 1 month
Page 36 F-23 Egress Lighting An emergency lighting unit located on the first floor of the east exit stair was missing a bulb. Reguarly test the emergency lighting system on each floor and replace/repair lights as needed. Within 1 month
Page 37 F-24 Egress Lighting Based on the number and location of emergency lights observed, adequate illumination levels are not anticipated along egress routes in the rooftop dining area and on the first floor. Provide emergency fixtures to provide adequate illumination along the means of egress. Provide a minimum illumination of 10 lux at the floor level within exit stairs and exit discharge paths and minimum 2.5 lux along exit access aisles. Within 3 Both areas are currently under construction. F-25 Egress Lighting Inspection, testing, and maintenance for the emergency lighting system was not in accordance with The ACCORD standard. Inspect, test and maintain the emergency lighting system in accordance with The ACCORD standard. Keep written records on-site. Within 3