INITIAL FIRE SAFETY ASSESSMENT - EXPANSION

INITIAL FIRE SAFETY ASSESSMENT - EXPANSION 228/1, Tin Sharak, Luxmipura, Joydevpur, Gazipur Joydebpur, Gazipur The Alliance for Bangladesh Worker Safety Page 1/18

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

GENERAL INFORMATION General Information Country: Province: City: Bangladesh Dhaka Joydebpur, Gazipur Zip Code: 1700 Audit Duration: Re-Audit: 2 Days Re-Audit After 0 Months Draft Report Sept 05 2016 Final Report Oct 01 2016 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): Number of Occupants: N/A There are 6 buildings, one main (previously audited) and 5 ancillary buildings. Rented N/A, the main factory building was audited previously. N/A 1) Warehouse shed: 1995; 2) Generator House: 1995; 3) Substation shed-1 & -2: 1995; 4) Security office block: 1995; None There are 5 Ancillary Structures. 1) Warehouse shed; 2) Generator House; 3) Substation shed-1; 4) Substation shed-2; 5) Security office block. There are 5 Ancillary Structures. 1) Warehouse shed: 9,200 SF; 2) Generator House: 3,324 SF; 3) Substation shed-1: 510 SF; 4) Substation shed-2: 510 SF; 5) Security office block: 450 SF. Total occupants: 75. 1) Warehouse shed: 68; 2) Generator House: 2; 3) Substation shed-1: 1; 4) Substation The Alliance for Bangladesh Worker Safety Page 3/18

shed-2: 1; 5) Security office block: 3. Number of Ancillary Levels (Stories): Occupancy Type: 1) Warehouse shed: 1-story; 2) Generator House: 2-story; 3) Substation shed-1 & -2: 1-story; 4) Security office block: 1-story. 1) Warehouse shed: H2, B2, D2, and G2; 2) Generator House: K; 3) Substation shed-1 & -2: accessory occupancy; 4) Security office block: F1. Construction Type: All buildings are Type 2. Height of Highest Occupied Floor Level Above Grade: 1) Generator House: 14 ft 4 in; 2) All other buildings at grade. The Alliance for Bangladesh Worker Safety Page 4/18

ASSESSMENT FINDINGS Expansion Details Are as-built drawings available for new fire safety features of the building? High The as built drawing including the scaled architectural documents for the warehouse shed was available, but that do not represent present scenario. The required as built drawings including the scaled architectural documents for the new fire safety features of the generator house, substation sheds, and security office block were not available during the inspection. Document Review: The available documents were reviewed. Credible as built drawings for the new fire safety features of the building and structures under assessment shall be prepared in accordance with the Alliance Standards. 21 Dec 2016 Alliance Standard reference 8.20 Fire Protection Construction Are openings and penetrations through rated walls and/or assemblies protected? High Non-Compliance Level: 3 Steel doors, glass windows, ventilation ducts, sky lights were noticed in the rated walls of sub-station, wastage storage, and in the East exterior wall of the main factory building. Photograph: i) The Steel door, and the glass window in the North exterior wall of the Sub-Station shed. ii) The steel door in the wastage storage on the North of the Sub-Station. iii) The glass window in the East exterior wall, in the ground level of the main factory building. iv) The sky light in the East exterior wall, on the ground level of the main factory building. v) The ventilation duct in the west exterior wall of the Sub-station. 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. The Alliance for Bangladesh Worker Safety Page 5/18

31 Dec 2016 Includes doors, windows, ducts, piping, etc. Reference Alliance Standards Part 4 Section 4.6 Opening Protectives and Section 4.7 Penetrations Are separations between hazards provided with fire-resistive rated construction barriers. The sub-stations, a wastage storage, and a boiler room are located on the East side of the main factory building at a distance of 6 ft 2 inches from the main factory building, where spatial separation is required. The exterior of the main factory building on the East, and the exteriors on the West and on the South of the wastage room, the exteriors on the North and on the West of the Sub-station sheds are not provided with fire-resistive rated construction barriers. Photograph: i) The separation distance of 6 ft 2 inch that exists between the main factory building and the sub-station sheds. 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. 31 Mar 2017 Reference Alliance Standards Part 4 Section 4.5 Separation Certificates of Occupancy for each building have been issued and are on file. Low Non-Compliance Level: 3 Required certificate of occupancy was not provided. The Alliance for Bangladesh Worker Safety Page 6/18

Document Review: No document was available. 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 Nov 2016 Are certificates of occupancy provided for each building or ancillary structure? Fire Protection Systems Does the building have a Standpipe System? High Under the existing Standpipe System in the complex, an unspecified 1 ½ inch hose station was noticed on the N-E exterior wall outside the warehouse shed. In considerations to the highest occupied floor in the ancillary structures under the assessment that is not more than 10 m above grade, Standpipe System is not required. But as the main factory building in the complex is 5 stories, a Class III Standpipe System is required for the buildings including the ancillary structures. Accordingly, the design document as prepared and submitted on behalf of the factory and has already been reviewed and approved by the Alliance via their letter dated May 26 2016. Document Review: The document was reviewed., Photograph: i) The existing hose station., Visual Assessment: The facility survey. The ancillary structures under the present assessment shall be integrated with the Standpipe System that is currently being installed in the complex. Install standpipe system at required locations in accordance with approved drawings, Alliance Standard Section 5.4, and NPFA 14. Standpipe system must comply with NFPA 14. 31 Dec 2016 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 7/18

Are notification and initiation devices for the fire alarm system installed at required locations based on occupancy type? High Pull station by the side of the exit door, sounder, strobes, and smoke detectors were noticed in the ancillary structures. The warehouse shed that is provided with a false ceiling made by the indigenous method with bamboo, and smoke detectors were noticed installed only to that, the roof ceiling above is not provided with the required detectors. Also no heat detectors were noticed in the toilet of the warehouse shed. The smoke detectors were also noticed installed on the bottom cord in the substation shed instead of pitched roof ceiling in accordance with the Standards. Photograph: i) Pull station in the warehouse shed. ii) The bell and the strobe in the generator house. iii) The smoke detector in the warehouse shed. iv) The smoke detector on the bottom cord of the pitched roof truss. v) No heat detector in the toilet. Ensure integration of the ancillary structures assessed to the the fire alarm system intended for installation in the main factory building in accordance with the Standards. The design document for installation of the fire alarm system shall be submitted for review by the Alliance. Consult a qualified fire protection engineer to this effect. 31 Dec 2016 Pull stations at egress points, smoke detectors in air handling equipment, visual and audible devices spaced appropriately based on occupancy type. Reference NFPA 72 Fire extinguishers are inspected, tested, and maintained as required. The document provided was a checklist for the inspection, maintenance and testing. The procedures followed do not comply with the requirements of NFPA 10. Document Review: The document available was reviewed. The Alliance for Bangladesh Worker Safety Page 8/18

Establish an inspection, testing, and maintenance program for all fire extinguishers. Program must comply with the requirements of NFPA 10. 18 Jan 2017 NFPA 10 Chapter 7 Is the fire alarm and detection system monitored by a central station monitoring service or directly connected to the Fire Service and Civil Defense? In Bangladesh, either a central station monitoring service provider or a direct connection to the Fire Service and Civil Defense for monitoring of the fire alarm and detection system is available. Since the structures under assessment are all ancillary structures, no separate and dedicated in-house monitoring system of the fire alarm and detection system are required to them, but obviously these are required to be integrated with the central in- house monitoring system of the complex. Document Review: No approved design document on the fire alarm and detection system was available., Visual Assessment: The facility survey. Ensure integration of all the ancillary structure fire panels to the complex's constantly attended fire alarm system annunciator location (such as the fire control room) in accordance with the Standards. A person trained to contact the Fire Service and Civil Defence in the event of fire alarm activation shall be provided at this location. Alliance Standard Part 5 Section 5.7.5 Monitoring 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 No record was available towards inspection, maintenance, and testing procedures of the existing Standpipe System. Document Review: No document was available for review. Establish an inspection, maintenance, and testing program for the standpipe and hose system. Program must comply with the requirements of NFPA 25. 31 Mar 2017 The Alliance for Bangladesh Worker Safety Page 9/18

Reference NFPA 25 Chapter 6 Standpipe and Hose Systems Table 6.1.1.2 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. High Exit discharges for the sub-station sheds, the electrical room, the wastage shed, and the boiler room on the East outside the exterior wall of the main factory building are not directly to the exterior of the structures. They are to the egress court which is not open to sky, and is 1575 mm (6 ft 2 in.) in width. The walls of the egress court do not have the required rating due to existence of non rated window openings, glass windows, and ventilation ducts. Photograph: i) The non rated egress court. 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. 30 Nov 2016 Alliance Standard Part 6 Section 6.17 Exit Discharge. See Section 16.7.2 and 16.7.3 for exceptions. Exit access corridors serving an occupant load exceeding 30 are separated by walls having a fire-resistance rating of 1 hr. High The exit access on the East, and on the West, in the warehouse shed where the medical center, toilets, and childcare rooms are located, requires corridors. At present the corridors do not have a fire resistance of 1 hour, are serving an occupant load of 38. There is no automatic sprinkler system in this area. Photograph: i) The exit access corridor on the West. ii) The exit access corridor on the East., Visual Assessment: The facility survey. 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. 31 Dec 2016 Alliance Standard Part 6 Section 6.3 and Part 4 Section 4.5. Does not apply if The Alliance for Bangladesh Worker Safety Page 10/18

an automatic sprinkler system is installed throughout the building. Doors along the path of egress have a minimum width of 0.8 m (32 in) and have required ratings. High Doors in the path of egress in the daycare rooms and in the medical rooms, in the warehouse shed on the South side were noticed more than 0.8 m (32 in.), but that do not have required rating. Photograph: i) The door in the daycare room. ii) The door in the medical room. Replace non-compliant doors and frames in the means of egress with sideswinging 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. 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. High Non-Compliance Level: 1 All doors in the means of egress are of side- hinged swing type except 1 collapsible gate and 1 rolling shutter on the East of the warehouse shed. Photograph: i) The rolling shutter. ii) The collapsible gate. 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. 31 Dec 2016 Alliance Standards Part 6 Section 6.8 Doors and Gates Occupant loads are posted for every assembly and production floor in a conspicuous space near the main point of egress. Occupant loads were not noticed posted in a conspicuous space near the exit The Alliance for Bangladesh Worker Safety Page 11/18

doors and the main point of egress. Occupant loads are not posted for the assembly point also. Visual Assessment: The facility survey. 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. Alliance Standards Part 6 Section 6.4.4 Posting of Occupant Load Emergency power for means of egress illumination is verified at least once per year. If battery operated lights are used, these lights are tested on a monthly basis. Functional testing of battery powered lights is provided for a minimum 90 min once per year. The testing procedure did not appear to be compliant with the Standards. The record provided indicates the measured illumination level on the surface of the exit signs, inside the corridor, and the stairways, and in the aisles, taken on August 07 2016, and nothing mentioned about the monthly as well as once per year functional tests on each of the battery (IPS) powered lights in accordance with the Standards. Document Review: The document provided was reviewed. Develop a testing and maintenance program that ensures the emergency power for all egress lighting is verified at least once per year. If batteryoperated lights are used, these lights shall be tested on a monthly basis. Functional testing of battery powered lights shall be provided for a minimum 30 min once per year. Alliance Standards Part 10 Section 10.12 Illumination of Exit Signs and Means Of Escape Lighting 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 collapsible gate sill with projections that exceeds 12.7 mm (1/2 in.) was noticed on the East exterior in the warehouse shed. Photograph: The projected collapsible gate sill. The Alliance for Bangladesh Worker Safety Page 12/18

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. 31 Mar 2017 Alliance Standard Part 6 Section 6.3.4 Walking Surfaces Emergency power for exit signs is tested at least once per year. If battery operated, these lights are tested on a monthly basis. Functional testing of battery powered signs is provided for a minimum 90 min once per year. Records provided do not appear to be in compliance with the Alliance Standards. Document Review: The document provided was reviewed. Develop a testing and maintenance program that ensures the emergency power for exit signs is verified at least once per year. If battery-operated signs are used, these signs shall be tested on a monthly basis. Functional testing of battery powered signs shall be provided for a minimum 90 min once per year. Alliance Standard Part 10 Section 10.12 Illumination of Exit Signs and Means Of Escape. All paths of egress are provided with compliant means of illumination. Non-Compliance Level: 1 The illumination in the corridor between the medical center and the daycare on the South of the warehouse shed was noticed to be 48 Lux, which is more than the required 10 Lux. Surface illumination of the exit sign illuminated by lamps contained within the sign and installed on the exit door on the East of the corridor was measured to be 32 Lux, which is less than the required 50 Lux. Visual Assessment: The facility survey. Install appropriate means of illumination at the noted locations. The source of illumination shall provide not less than 50 lux at the illuminated surface with a contrast of not less than 0.5. Approved self-luminous signs, which provide evenly illuminated letters having a minimum luminance of 0.2cd/m2, may also be used. 31 Mar 2017 The Alliance for Bangladesh Worker Safety Page 13/18

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 The structures assessed are ancillary and at grade except the generator house which is 2-stories. The 1st floor is under construction, illuminated exit signs are provided at the entrances to the exits, but only for the exterior doors. In some other locations on the floor of the warehouse shed, continuation of egress is not easy to see and there is a change in the direction of the path of travel. Visual Assessment: The facility survey. 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. 31 Mar 2017 Alliance Standard Part 6 Section 6.11 Exit Signs Ramps do not have a running slope greater than 1 in 8 (12.5 percent) and have handrails on both sides of the ramp. Non-Compliance Level: 1 Ramps used in the means of egress, in the exit court on the West exterior of the warehouse have a running slope of 1 in 24 (4.17 %), but handrails are provided only on one side of the ramps. Photograph: i) Handrails of the ramps only on one side. Provide handrails on both sides of the ramp in accordance with the Standards. 31 Mar 2017 Alliance Standard Part 6 Section 10 Ramps Fire Safety Programs Are the required number of people trained and certified in fire fighting, first aid, and rescue training by the appropriate authority. High The Alliance for Bangladesh Worker Safety Page 14/18

Total no. of occupants in the. is about 2400 persons, including 74 persons in the ancillary structures assessed. It has been noticed that in total 110 people, about 4.58 % versus the required 18 % @ 6 % each in fire fighting, first aid, and rescue training has been trained and certified by the FS & CD authority. Document Review: The documents provided were reviewed. Provide training and certification for the required number of people (25% of total workers) in fire fighting, first aid, and rescue training by an appropriate authority in accordance with the Alliance Safety Training Curriculum. 31 Mar 2017 Alliance Standard Part 13 Human Element Programs An emergency evacuation plan has been developed and communicated to all employees. The emergency evacuation has not been developed and communicated to all employees as yet. Document Review: The emergency evacuation has not been developed and communicated to all employees as yet. Develop an emergency evacuation plan which includes all components required by the Alliance Standards and communicate the plan to all employees as per Alliance Standards Part 13 Section 13.1. Alliance Standards Part 13 Section 13.1 Fire Safety Director Emergency egress maps are posted at the entrance to each exit stair or main point of egress. No emergency egress maps were noticed posted at the main point of egress in the ancillary structures assessed. Visual Assessment: The facility survey. Create and post emergency egress maps at the entrance to each exit stair or main point of egress as per Alliance Standards Section 13.4. The Alliance for Bangladesh Worker Safety Page 15/18

Alliance Standards Part 13 Section 13.4 Evacuation Plan Fire Drills are conducted at required intervals based on building use type. Documentation provided shown that Fire Drills were conducted three time a year versus quarterly. Document Review: The document provided was reviewed. Conduct fire drills on a quarterly basis as outlined in BNBC Part 4 Appendix A. Fire drills shall be conducted under the direction of a Fire Safety Director. Alliance Standards Part 13 Section 13.3 Fire Drills Training programs are implemented and documented in accordance with the Alliance Safety Training Curriculum. Non-Compliance Level: 1 The records provided was for the training program in accordance with the Alliance Safety Training Curriculum for 2 sessions, held on April 23 2016 for a total of 56 people working in different sections including sewing, of the main factory building other than the sections housed in the ancillary structures. The implementation and documentation of the training programs in accordance with the Alliance Safety Training Curriculum for the personnel working in the ancillary structures could not be ascertained. Document Review: The documents provided were reviewed. Ensure implementation and documentation of the training programs in accordance with the Alliance Safety Training Curriculum for the people working on the ancillary structures under assessment also. Alliance Standards Part 13 A Fire Safety Director position has been filled. Low The Alliance for Bangladesh Worker Safety Page 16/18

The position of a Fire Safety Director with an individual that has had sufficient training to be able to carry the required duties in accordance with the Standards has not been filled. Document Review: No document was available. Create a Fire Safety Director position and fill the position with an individual that has sufficient training to be able to carry out the required duties in accordance with Alliance Standard Section 13.1. 31 Mar 2017 Alliance Standards Part 13 Section 13.1 Fire Safety Director Fire Department pre-planning has been completed. Low The Fire Department pre-planning has not been completed. Document Review: No document provided was reviewed. Complete Fire Department pre-planning activities with the local Fire Service and Civil Defence in accordance with Alliance Standard Section 13.1.1(2). Alliance Standards Part 13 Section 13.1 Fire Safety Director Are all applicable permits up to date including Fire License & Boiler License. Low Non-Compliance Level: 1 Applicable permits were reviewed, and their status is shown as under: i) Fire License- valid up to June 30 2017. ii) BERC certificate for waiver from the requirement of a license- valid up to May 11 2019. iii) Boiler license- valid up to January 11 2017. iv) Electrical technician permit, Class A, B, C in favor of Md. Masum Prodhan is valid up to June 09 2017, while the same in favor of Md. Monirul Islam was expired on June 11 2016. Document Review: The documents provided were reviewed. Apply to appropriate authority in an expeditious manner for issuance of all applicable licenses and keep them up to date. Alliance Standard Part 13 Human Element Programs The Alliance for Bangladesh Worker Safety Page 17/18

The Alliance for Bangladesh Worker Safety Page 18/18