INITIAL FIRE SAFETY ASSESSMENT

INITIAL FIRE SAFETY ASSESSMENT Factory Name: Maks Fashion Ltd 1 Kapashgola Road Chawkbazar Chittagong Chittagong Bangladesh 19 Apr 2014 The Alliance for Bangladesh Worker Safety Page 1/16

19 Apr 2014 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

19 Apr 2014 GENERAL INFORMATION General Information Factory Name: Country: Province: City: Maks Fashion Ltd Bangladesh Chittagong Chittagong Zip Code: 4203 Audit Duration: Re-Audit: 1 Days Re-Audit After 0 Months Draft Report June 2, 2014 Final Report June 5, 2014 Are all Action Items From Previous Assessment Completed?: N/A Buildings in Complex: 1 Is the building(s) owned or rented by the Factory: 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): Rented 6 story + tin shed (7th story) 37,800 sft Construction start ted in 1974 and partially completed in 1976. 2 floor extension is completed at 1994. None NA Number of Occupants: 433 The Alliance for Bangladesh Worker Safety Page 3/16

19 Apr 2014 Number of Ancillary Levels (Stories): NA The Alliance for Bangladesh Worker Safety Page 4/16

19 Apr 2014 ASSESSMENT FINDINGS Fire Protection Construction Are exit enclosures provided with fire-resistive rated construction barriers? Exit enclosures are not provided with fire-resistive rated construction barriers Alliance Standards Part 4 Section 4.5 Separation. Exits are not protected by fire doors. Photograph: Photo of doors to exits Factory will need to install fire rated door assemblies at all exits enclosures (e.g. exit stairs) (1.5 hour rating). Fire doors assemblies shall conform to NFPA 252, BS 476 Part 22, EN 1364-1, GB 12955-2008, or IS 3614. Part II. Doors must remain in closed position or be of self-closing type. Doors may be provided with locking hardware from the ingress side provided that a panic bar is installed on any door with an occupant load exceeding 49 persons 27 Aug 2014 Reference Alliance Standards Part 4 Section 4.5 Separation Are openings and penetrations through rated walls and/or assemblies protected? Non-Compliance Level: 2 Floor to floor penetrations in fire rated floor assemblies observed on each floor (e.g ceiling hole, corner of factory floor) used for passing electrical wiring. Visual Assessment: Floor to floor penetrations in fire rated floor assemblies observed on each floor. Floor to floor penetrations shall be protected/sealed with a listed through penetration firestop system tested in accordance with ASTM E814. Confirmation should be provided that any materials used can conform to standard as per Alliance Standard Section 4.7 Penetrations 27 Aug 2014 Includes doors, windows, ducts, piping, etc. Reference Alliance Standards Part 4 Section 4.6 Opening Protectives and Section 4.7 Penetrations The Alliance for Bangladesh Worker Safety Page 5/16

19 Apr 2014 Are separations between hazards provided with fire-resistive rated construction barriers. Medium Non-Compliance Level: 2 Generator room is in ground floor in separate area adjacent to factory building. However, as noted elsewhere, the generator area is not separated from path of egress at south side stair discharge. Additionally, the finished goods storage areas (1st floor) not separated from the cutting section (other occupancy). Photograph: Photo of storage area Photo of generator area Provide fire-resistive rated construction barriers between hazard types. For example: - Generator sets shall be separated from all other occupancy areas by a minimum 2 hour construction. - Rooms used for storage of combustible materials shall be separated from the surrounding occupancy with a minimum 1 hour construction. Consult a qualified fire protection engineer to design the required rated construction barrier. 27 Aug 2014 Reference Alliance Standards Part 4 Section 4.5 Separation Certificates of Occupancy for each building have been issued and are on file. Low The building was originally designed as residential building now being used as commercial (lower floors) and industrial building (upper floors). No credible certificates of occupancy for the current building use were available for review. Factory only has approval from CDA for extension of 5th floor in 1994. Document Review: No Certificates of Occupancy available for review Provide Certificates of Occupancy for review. Approval must be obtained for current use (commercial and industrial occupancy) 03 Jul 2014 Are certificates of occupancy provided for each building or ancillary structure? Occupancy Type Non-Compliance Level: The Alliance for Bangladesh Worker Safety Page 6/16

19 Apr 2014 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: Provide maximum height of highest occupied floor level above grade for each type of building and ancillary structure. Fire Protection Systems Does the building have a Standpipe System? The Alliance for Bangladesh Worker Safety Page 7/16

19 Apr 2014 Factory has a hose reel system with two Class II connections on each factory floor. However, no standpipe system is installed as per Alliance Standard Part 5 Section 5.4.2. Visual Assessment: No Type I hose connections were observed at the factory per Alliance Standard Part 5 Section 5.4.2. Install a standpipe system at required locations designed by a qualified fire protection engineer. System should include rated fire pump and Class III standpipe hose connections (65 mm) in each stairwells at each floor level including occupiable roofs. 26 Aug 2014 Does the building have a standpipe system installed where required. Alliance Standard Part 5 Section 5.4.2 Does the building have a fire pump? They do not have automatic fire pump. They have only manual electric submersible pump for lifting and refilling overhead tank from deep tube well to provide water supply of fire hose reel system. Visual Assessment: No fire pump was observed at the factory. Installation of approved standpipe will require the installation of rated fire pump. Install the fire pumps in accordance with NFPA 20. Consult with a qualified fire engineer to properly design and install pump system. 26 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? As per Alliance Standard 5.7.3.6 an automatic fire alarm and detection system shall be provided; however, the factory only has a manual alarm system at this time. Visual Assessment: Only manual alarm and detection system observed. Install automatic fire alarm system with sufficient smoke/heat detectors as per NFPA 72. Automatic detectors should be tied into the fire alarm system. Alarm system should initiate occupant notification upon activation of detectors in addition to the manual fire alarm stations. All fire alarm installations shall be The Alliance for Bangladesh Worker Safety Page 8/16

19 Apr 2014 submitted for review by the Alliance for review prior to commencement of installation. In the interim, review and confirm the working order of existing manual alarm system. 16 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 Are fire department connections provided and clearly identified for the Fire Protection Systems? Medium During the assessment it was observed that the fire department connection was not provided and clearly identified. Visual Assessment: Through visual assessment it was verified that the connections were not provided. Upon installation of compliant standpipe system, fire department (Siamese) inlet connections should be installed to allow fire department pumper equipment to supplement the fire protection systems. Fire department outlet connections shall be provided to allow fire department pumper vehicles to draw water from ground-level or underground water storage tanks. Connections shall match the Fire Service and Civil Defense hose thread standard. Signage for standpipe system is not in compliance with NFPA 14 Chapter 6 (e.g. no sign on Fire Department connection indicating STANDPIPE in 1 in lettering) 18 Nov 2014 Alliance Standard Part 5 Section 5.5.4 Fire Department Connections Is the fire alarm and detection system monitored by a central station monitoring service or directly connected to the Fire Service and Civil Defense? Medium Factory does not have a automatic and centrally connected fire alarm system with annunciator panel and therefore, it is not possible to have the system monitored by a central station or directly connected to fire department. Visual Assessment: No central station monitoring service was observed at the factory. Installation of automatic fire alarm system (as noted elsewhere) should include an fire alarm control panel/annunciator. Until that time that a central station monitoring service or direct connection to the Fire Service and Civil Defence can be set up, a person shall be assigned to contact the fire department in the The Alliance for Bangladesh Worker Safety Page 9/16

19 Apr 2014 event of fire alarm activation. An annunciator shall be located in a constantly attended location to alert this person. 01 Jul 2014 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 As noted elsewhere, factory does not have a standpipe system as defined by Alliance standard (only hose reel system with Class II connections and rooftop gravity tank). For existing hose reel system, although it was reported that testing occurs, no detailed testing reports were available for review. Document Review: No documentation on installation or testing of fire hose systems available. Any newly installed or revised standpipe system needs to be evaluated for compliance with the design pressure and flow demands of NFPA 14 or BNBC as cited in 5.4.3. Standalone standpipe systems shall be confirmed to meet the local BNBC requirements with a minimum 450 kpa (65 psi) pressure at the hydraulically most remote hose connection or NFPA 14. This testing should be documented and available for review. 27 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? Low As noted elsewhere, factory does not have a standpipe system as defined by Alliance standard (only hose reel system with Class II connections and rooftop gravity tank). For existing hose reel system, the required standpipe signage was not observed. Visual Assessment: Required standpipe signage was not observed Upon installation of compliant standpipe system, include required identification signs at the noted locations. Signage must comply with NFPA 14. 27 Aug 2014 The Alliance for Bangladesh Worker Safety Page 10/16

19 Apr 2014 Reference NFPA 14 Chapter 6 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. It was found during the assessment that the doors of egress were open. Additionally, doors are locked in such a way so that shutters cannot be slid or closed against the exits during occupied time. However, there is locking system in place and so it cannot be guaranteed they remain unlocked at all times when building is occupied. Visual Assessment: Doors were observed with a locking system in place. Remove all hasps, locks, slide bolts, or other locking devices at the noted locations. If locks are required for security reasons, utilize special door locking features complying with NFPA 101. 17 Jun 2014 Alliance Standards Part 6 Section 6.8 Doors and Gates All doors in a means of egress are of the side-hinged swinging type. All stairs doors are steel collapsible and not side hinged and swinging as per Alliance Standards Part 6 Section 6.8 Doors and Gates. Visual Assessment: No side-hinged swinging doors were noted at the factory. Remove all sliding or rolling doors at and within the exit stairs and along all portions of the means of egress. Replace with side-hinged swinging type doors in compliance with Standard. As noted elsewhere, exit enclosures require fire rated door assemblies (which should be side-hinged). 26 Aug 2014 Alliance Standards Part 6 Section 6.8 Doors and Gates The Alliance for Bangladesh Worker Safety Page 11/16

19 Apr 2014 Exterior exit stairs are separated from the building with the required rating. The rating of the exterior wall shall extend 3.05 m (10 ft) beyond the ends of the stair structure. As noted elsewhere, fire rated door assemblies do not separate the interior occupied areas, including the exterior exit stairs. Also notable, the exterior stairs are not suitably braced and are highly deteriorated in some places. Photograph: Photo of exterior stairs As noted elsewhere, fire door assemblies should be installed to separate the exterior stairs with the required rating. The rating of the exterior wall shall extend 3.05 m (10 ft) beyond the ends of the stair structure. Additionally the stair should be suitably anchored/braced and all deteriorated materials immediately repaired or replaced. 27 Aug 2014 Alliance Standard Part 6 Section 6.3.1.2. Three stories or less 1-hr rating. Four stories of more 2-hr rating Interior exit stairways and ramps terminate at an exit discharge except where terminating at a rated exit passageway. All stair discharges into area exposed to other Ground floor exits that do not have sufficient fire rating. Visual Assessment: Ground floor of factory did not have any fire rated doors. Interior exit stairways and ramps shall terminate at an exit discharge except where terminating at an exit passageway is constructed to meet the same rating requirement as the exit that is being served and shall not be less than 1 hr fire-resistance rated construction, therefore a fire rated exit passageway would need to be established for both stair discharges. 26 Aug 2014 Alliance Standard Part 6 Section 6.14 Exit Enclosures Occupant loads are posted for every assembly and production floor in a conspicuous space near the main point of egress. Medium The Alliance for Bangladesh Worker Safety Page 12/16

19 Apr 2014 It was noted during the assessment that Occupant loads are not posted for every assembly and production floor in a space near the main point of egress. For this factory, occupant loads were not posted at all. Visual Assessment: No occupant load signs were observed at the factory. Post maximum occupant load for all areas (near exit). Floor loads must be limited to the available capacity of the exit stairs. 01 Jul 2014 Alliance Standards Part 6 Section 6.4.4 Posting of Occupant Load 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). Medium It was noted that in all the locations of steel collapsible gates, there is a lip if 2 inches which exceeds the requirements noted in standard. Photograph: Photo of Lip of Steel collapsible gate. Provide a uniform lip at the noted locations (slope should not exceed 1 in 20 in the direction of travel). Any protrusions or lips must be smoothed down to less than 1/4 in. 18 Nov 2014 Alliance Standard Part 6 Section 6.3.4 Walking Surfaces 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. Medium Re-entry requirements have not been met per Alliance Standards Part 6 Section 6.8.3.1 as fire rated door assemblies with proper latching systems have not been installed. As noted in other areas, fire rated door assemblies are required for the exit enclosure. Visual Assessment: Fire rated door assemblies not provided for the exit enclosure. During installation of fire rated door assemblies assure that every door in a stair enclosure serving more than 4 stories is provided with re-entry unless it meets the requirements of Alliance Standards Part 6 Section 6.8.3.1. The Alliance for Bangladesh Worker Safety Page 13/16

19 Apr 2014 27 Aug 2014 Alliance Standards Part 6 Section 6.8 Doors and Gates 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.). Medium Non-Compliance Level: 2 It was noted that the South stairway has one side handrail from the Ground Floor to the top floor of the factory. Photograph: Photos of south stair Handrails shall be provided on both sides of each exit stairway and ramp. New handrails shall have a minimum height of 865 mm (34 in.) and a maximum height of 965 mm (38 in.) as measured from the leading edge of the tread. Handrails with a circular cross section shall have an outside diameter of at least 11/4 inches (32 mm) and not greater than 2 inches (51 mm). If the handrail is not circular, it shall have a perimeter dimension of at least 4 inches (102 mm) and not greater than 61/4 inches (160 mm) with a maximum crosssection dimension of 21/4 inches (57 mm). Edges shall have a minimum radius of 0.01 inch (0.25 mm). 18 Nov 2014 Alliance Standard Part 6 Section 6.9 Stairs and 6.12 Handrails and Guards Stair designation signs are provided at each floor entrance from the stair to the 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 This was a partial non-compliance. While the signs indicating floor level are posted adjacent to the door, the stairs have not been designated. Visual Assessment: No stair names were designated at each stair level. Install signage adjacent to each stair door indicating the stair name and the floor level at the noted locations. 01 Jul 2014 Alliance Standard Part 6 Section 6.9 Stairs Fire Safety Programs The Alliance for Bangladesh Worker Safety Page 14/16

19 Apr 2014 Storage areas underneath the cutting tables are clear of combustibles. Medium During the assessment it was noted that storage was observed under the cutting table located on the 1st Floor. The height of the cutting table was measured at around 2.875ft (See Photo # F19) Photograph: Storage was observed packed thickly under the cutting table Remove all combustibles stored underneath the cutting tables at the 1st floor location. 26 Aug 2014 Alliance Standard Part 17 Section 13.7.2 Cutting tables. A written housekeeping policy is established and enforced. Low No written housekeeping policy is established. Factory was not visually clean and free of dust. Document Review: No written housekeeping policy available for review. Establish written corporate and plant policies on housekeeping to ensure scheduled cleaning for floor, wall, ceiling, supply and return air ventilation systems. Promptly reschedule skipped cleanings. Provide 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 (⅛ in.)." 26 Nov 2014 Alliance Standards Part 13 Section 13.6 Housekeeping A hot-work permit program has been established. Low It was discovered during the assessment that the factory did not establish a hot-work permit program as required by Alliance Standards Part 13 Section 13.4 Hot Work Permit and NFPA 51B. Document Review: No hot work permit was available for review. The Alliance for Bangladesh Worker Safety Page 15/16

19 Apr 2014 Develop a hot work permit program. The program must comply with the requirements of NFPA 51B 18 Nov 2014 Alliance Standards Part 13 Section 13.4 Hot Work Permit and NFPA 51B The Alliance for Bangladesh Worker Safety Page 16/16