INITIAL FIRE SAFETY ASSESSMENT

INITIAL FIRE SAFETY ASSESSMENT Cha 72/1/C, Ground-4th FL, Progoti Swarani, Uttar Badda, Dhaka Dhaka The Alliance for Bangladesh Worker Safety Page 1/16

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 2/16

GENERAL INFORMATION General Information Country: Province: City: Bangladesh Dhaka Dhaka Zip Code: 1212 Audit Duration: Re-Audit: 2 Days 16 Hours Re-Audit After 0 Months Draft Report May 22, 2014 Final Report June 25, 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 1 (One) Building used by Shamsher Rezia Fashion and Mansheen Co (BD). Ground floor to 8th floor- Shamsher Rezia Fashion, 9th floor- Mansheen Co (BD) Ltd. Owned Basement + 10 stories 79,990 sft. 2003-06 2010 None N/A The Alliance for Bangladesh Worker Safety Page 3/16

Number of Occupants: Number of Ancillary Levels (Stories): 1300 person. N/A The Alliance for Bangladesh Worker Safety Page 4/16

ASSESSMENT FINDINGS Fire Protection Construction Are openings and penetrations through rated walls and/or assemblies protected? There are two boiler rooms at level 6 & level 2 that are enclosed with 5 inch thick brick walls having 1.5 hours fire rating.the door openings of the boiler rooms are provided with steel sliding doors. Penetrations of fire resistive wall of boiler r Photograph: Photo 1 shows boiler room at level-6 provided with steel sliding door. Photo 2 shows boiler room at level-2 provided with steel sliding door. Photo 3 shows penetrations of fire resistive wall of boiler room at level-6. Provide adequate separation of the boiler rooms from the production floors with properly rated fire doors and protection of penetrations. 15 Aug 2014 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? There are two stair wells serving as exit enclosures provided with 5 inch solid walls of 1.5 hours fire resistance rating. Existing doors on exit enclosures are of "steel sliding doors" which do not have fire resistance rating. Photograph: Photograph shows exit enclosure not provided with fire-rated door. The exit enclosures shall be provided with fire-rated doors to replace the existing steel sliding doors. 15 Aug 2014 The Alliance for Bangladesh Worker Safety Page 5/16

Reference Alliance Standards Part 4 Section 4.5 Separation Occupancy Type Non-Compliance Level: Provide Occupancy Type for each building and structure. Reference Alliance Standards Part 3 Use and Occupancy Construction Type Non-Compliance Level: Provide construction type for each building and ancillary structure. Reference Alliance Standards Table 3.3.1 Height of est Occupied Floor Level Above Grade Non-Compliance Level: Building height-110feet but above grade height-100feet. The Alliance for Bangladesh Worker Safety Page 6/16

Provide maximum height of highest occupied floor level above grade for each type of building and ancillary structure. Fire Protection Systems Is the building protected by an automatic sprinkler system? Although the height of the building is greater than 75 feet it does not have an automatic sprinkler protection. The storage area at ground floor was found to be provided with sprinkler, during the factory visit held on 03/05/14 by the member of Allianc Photograph: (i)production/store area without automatic sprinkler system at occupied floor greater than 75 feet above grade level. (ii)newly sprinkled storage area at ground floor. Install an automatic sprinkler system throughout the building designed by a qualified fire protection engineer in compliance with Alliance Standard Part 5 Section 5.3. 15 Aug 2014 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 Does the building have a Standpipe System? The standpipe system does not meet the class requirements of the Alliance Standard Part 5 Section 5.4. There exists at present hose reel of dia 25 mm and length 30 m. Photograph: Photo Shows hose reel of dia 25 mm Install a standpipe system at required locations designed by a qualified fire protection engineer in compliance with Alliance Standard Section 5.4.2. 15 Sep 2014 Does the building have a standpipe system installed where required. Alliance Standard Part 5 Section 5.4.2 The Alliance for Bangladesh Worker Safety Page 7/16

Does the building have a fire pump? The facility has an electrically driven fire pump that is located at north-east corner of basement. The pump did not appear to fulfill the requirements for the system demand of the standpipe system. Photograph: Photograph Shows electrically driven fire pump with jockey pump. An electrically driven fire pump shall be installed to replace the non-compliant fire pump.the new pump shall be in compliance with Alliance Standard Section 5.5. 31 Aug 2014 Alliance Standard Part 5 Fire Protection Systems Are notification and initiation devices for the fire alarm system installed at required locations based on occupancy type? Fire alarm and smoke detectors are installed at different locations but they are standalone and their connections are not centralized to a control panel. Photograph: Standalone smoke detector and fire alarm connections not centralized to control panel. The fire alarm system shall be improved by installing Pull stations at each exit, automatic smoke detection throughout, and visual and audible notification devices spaced appropriately based on NFPA 72. 15 Jul 2014 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? During document review and subsequent visual assessment, no such central command station for monitoring fire alarm and detection system has been found. The Alliance for Bangladesh Worker Safety Page 8/16

Document Review: No such command station was found during document review. There shall be a central command station for monitoring fire alarm and detection system in compliance with the Alliance Standard Part 5, Section 5.7.5. 31 Jul 2014 Alliance Standard Part 5 Section 5.7.5 Monitoring Are there additional areas of non-compliance related to the Fire Protection Systems? Non-Compliance Level: 1 Not Applicable 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 The facility has a standpipe and hose system. However no documentation was provided to show that inspection, testing, and maintenance procedure have been implemented. Document Review: No such documents have been found. Establish an inspection, maintenance and testing program for the standpipe & hose system. 15 Aug 2014 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? The Alliance for Bangladesh Worker Safety Page 9/16

Low During visual assessment, no signage for the standpipe system has been provided at required locations. Visual Assessment: No signs for valves, hose connections, etc. have been found. There shall be signage for the standpipe system installed at required locations and on required components in compliance with NFPA 14. 31 Jul 2014 Reference NFPA 14 Chapter 6 Are inspection, maintenance, and testing procedures of the fire pump documented and up to date? Low The facility has a fire pump, but no documentation in support of inspection, testing and maintenance (ITM) of the fire pump was found. Document Review: No such documents have been found. An inspection, maintenance and testing program shall be established for the pump. The program shall comply with NFPA 25,Chapter 8, Fire Pumps. 15 Aug 2014 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. The Alliance for Bangladesh Worker Safety Page 10/16

The exit does not discharge directly to the exterior of the building. Currently,the exit discharges to an open space on the ground floor marked for emergency assembly. There is an exit door at the exterior wall close to the landing of the main stair on Photograph: Photograph shows (i)open space for assembly at ground floor, (ii) an exit door that is an access to exit passageway. There shall be exit discharge directly to the exterior of the building at the time of an emergency in compliance with Alliance Standard Part6 Section 6.17. The adjacent exit passageway shall also be in conformity with Alliance Standard Part6 Section 6.15. 31 Aug 2014 Alliance Standard Part 6 Section 6.17 Exit Discharge. See Section 16.7.2 and 16.7.3 for exceptions. Means of egress are free from impediments, obstructions, and stored materials. Means of egress were not free from impediments, obstructions, and stored materials. Huge stock piles of packing materials were found in basement. Photograph: Photograph shows huge stock piles of packing materials in basement. There shall be written corporate and plant policies established on housekeeping to ensure scheduled cleaning for floor, wall, ceiling, supply and return air ventilation systems in compliance with Alliance Standards Part 13 Section 13.6. Also there shall be promptly rescheduling of skipped cleanings & providing a documented line of authority for authorizing a cleaning delay and rescheduling. As a general rule the maximum tolerable deposit thickness for loose fluffy lint is 13 mm (1/2 in.) over a maximum of 46.5 m2 (500 ft2). Limit dense deposits to 6 mm (1/4 in.) and oil saturated deposits to 3.2 mm (1/8) in.). 11 Sep 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. The Alliance for Bangladesh Worker Safety Page 11/16

During visual assessment it has been found that doors are not locked in the direction of egress. But locking features are there which have not yet been removed. Photograph: Photograph shows locking features that are not removed. All locking features shall be removed from exit doors in compliance with Alliance Standard. 07 Jun 2014 Alliance Standards Part 6 Section 6.8 Doors and Gates Doors along the path of egress have a minimum width of 0.8 m (32 in) and have required ratings. Existing doors along path of egress have minimum width of 0.8 m (32 inch) but do not have required rating. Photograph: Non rated steel sliding doors instead of rated fire door. Replace sliding door with a minimum 0.9 m (39 in.) side-swinging fire rated door with automatic closer and latches. Enclose remainder of opening with fire resistance rated construction. 20 Aug 2014 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. Non-Compliance Level: 2 Existing doors in a means of egress are not of side-hinged swinging type.they are steel sliding doors and do not have required rating. Photograph: Non rated steel sliding doors in a means egress with locking features not removed. Replace sliding door with a minimum 0.9 m (39 in.) side-swinging fire rated door with automatic closers and latches. Enclose remainder of opening with fire resistance rated construction. 20 Aug 2014 Alliance Standards Part 6 Section 6.8 Doors and Gates The Alliance for Bangladesh Worker Safety Page 12/16

Aisles are provided with the minimum unobstructed clear width of 0.9 m (36 in) based on occupant loads. Non-Compliance Level: 1 During the inspection existing aisles were found to have an unobstructed clear width of 32 inches. Photograph: Showing measurement of Aisles less than 36 inch in production floor Aisles should be marked so that a minimum 36 in. clear width is maintained. 20 Jun 2014 er occupancy loads will require a greater width to accommodate the increased load. Alliance Standard Part 6 Section 6.5 Egress Width All occupied roofs are provided with parapets or guards with a minimum height of 1067 mm (42 in.). The roof is occupiable and provided with parapet height of 24 inches. Photograph: Showing height of parapet wall. The height of parapet shall be increased to 42 inches in compliance with Alliance Standard part6 Section 6.12 15 Aug 2014 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. During inspection, there have been no occupant loads found that are posted for every assembly and production floor in a conspicuous space near the main point of egress. Document Review: During documents review and inspection no records/posts in favor of posting of occupant loads were found. There shall be posting of occupant loads for every assembly and production The Alliance for Bangladesh Worker Safety Page 13/16

floor in a conspicuous space near the main point of egress in compliance with Alliance Standard Part 6, Section 6.4.4. 20 Jun 2014 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 have been provided on one side of each stairway. Photograph: Shows handrails on one side only. There shall be handrails on the other side of each stairway in compliance with Alliance standard part 6, section 6.9. 15 Aug 2014 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. There is no re-entry provision for the building that is a high rise one-10 stories (100 feet in height)above finished ground. Photograph: Front view of the building having 10 stories. The re-entry provision shall be provided in compliance with Alliance Standards Part 6, Section 6.8 31 Aug 2014 Alliance Standards Part 6 Section 6.8 Doors and Gates Are there additional areas of non-compliance related to the Means of Egress? Non-Compliance Level: 1 The Alliance for Bangladesh Worker Safety Page 14/16

Not Applicable Are there additional areas of non-compliance related to the Means of Egress? Non-Compliance Level: Not Applicable Fire Safety Programs Are there additional areas of non-compliance to report? Non-Compliance Level: 1 Not Applicable A Fire Safety Director position has been filled. Low The position of a fire safety director is required to be filled to ensure all duties The Alliance for Bangladesh Worker Safety Page 15/16

and activities that are performed in compliance with Alliance Standards Part 13, Section 13.1. Document Review: No document in favor of filled position of a fire safety director has been 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 in compliance with Alliance Standards Part 13 Section 13.1. 15 Aug 2014 Alliance Standards Part 13 Section 13.1 Fire Safety Director A written housekeeping policy is established and enforced. Low At basement, huge finished goods packing materials have been found which may cause potential fire safety risk. Photograph: Shows huge finished goods packing materials without maintaining aisles and clearing space from ceiling to top of storage. There shall be written corporate and plant policies established on housekeeping to ensure scheduled cleaning for floor, wall, ceiling, supply and return air ventilation systems in compliance with Alliance Standards Part 13 Section 13.6. Also there shall be promptly rescheduling of skipped cleanings & providing a documented line of authority for authorizing a cleaning delay and rescheduling. As a general rule the maximum tolerable deposit thickness for loose fluffy lint is 13 mm (½ in.) over a maximum of 46.5 m2 (500 ft2). Limit dense deposits to 6 mm (¼ in.) and oil saturated deposits to 3.2 mm ( in.). 11 Sep 2014 Alliance Standards Part 13 Section 13.6 Housekeeping The Alliance for Bangladesh Worker Safety Page 16/16