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EQUIVALENT INITIAL FIRE SAFETY ASSESSMENT Factory Nayabari, Kanchpur, Sonargaon, Narayanganj. Sonargaon Dhaka 14 Nov 2013 The Alliance for Worker Safety Page 1/15

Factory 14 Nov 2013 Introduction to the Report The following report contains a site profile and summary of non-conformities identified during an onsite assessment commissioned by the Alliance for Worker Safety (Alliance) and conducted by a third-party Qualified Assessment Firm (QAF). The assessment was conducted against the Alliance for Worker Safety Assessment Protocols (APs) and Fire Safety and Structural Integrity Standard, which is harmonized with the factory assessment guidelines developed by University of Engineering and Technology (BUET) for the National Tripartite Plan of Action (NTPA). The goal of the Alliance process is to provide clear and practical technical requirements by which i Ready Made Garment (RMG) Factories producing for Alliance members may be consistently and fairly evaluated for fire, structural, and electrical safety in a non-duplicative manner. Each assessment will prompt action plans that will be used by RMG factories to systematically and sustainably improve safety conditions for garment workers. Beyond tracking and reporting on action steps taken in a transparent manner, the Alliance organization and its members will seek to further support factory improvements through technical assistance, training, implementation support for functional Worker Committees, and in some cases financial assistance and wage support for workers if factories are closed for remediation. The contents of the report do not constitute a guarantee of compliance with the applicable laws, the Alliance Standard or the absolute or continued safety against fire, electrical and/or structural integrity issues that may lead to injury or loss of life. The report is designed to provide a non-exhaustive summary of risk issues, based on a limited sampling and duration of time onsite by the named QAF. Neither the QAF nor the Alliance can certify or guarantee the quality, outcome, or effectiveness of actions taken in response to the report. For more information and report feedback please go to: www.bangladeshworkersafety.org. The Alliance for Worker Safety Page 2/15

14 Nov 2013 GENERAL INFORMATION General Information Factory Country: Province: City: Dhaka Sonargaon Zip Code: 1400 Audit Duration: Re-Audit: Re-Audit After 0 Months Draft Report June 30, 2014 Final Report June 30, 2014 Are all Action Items From Previous Assessment Completed?: Buildings in Complex: 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): N/A 3: Main, Warehouse, Stitching Owned Main: 4, Warehouse: 1, Stitching: 6 Main: 128,000 sq ft (each floor greater than 30,000 sq ft); Warehouse: unknown; Stitching: 190,000 sq. ft. (each floor is 35,000 sq ft) Main: Unknown; Storage: Unknown; Stitching: 2013 2013 None N/A Number of Occupants: 2800 The Alliance for Worker Safety Page 3/15

14 Nov 2013 Number of Ancillary Levels (Stories): Occupancy Type: Construction Type: Height of est Occupied Floor Level Above Grade: N/A G2 All: Unrated steel construction Main: 45 ft.; Stitching: 66 ft. The Alliance for Worker Safety Page 4/15

14 Nov 2013 ASSESSMENT FINDINGS Fire Protection Construction Is each floor separated with a fire-resistive rated construction barrier? Both Main and Stitching building are constructed of unprotected steel construction. As these floors are greater than 2 stories and greater than 22,000 sq. ft. each, protection for the construction is required. The Stitching building is greater than 65 ft. Photograph: (1) Unprotected steel construction in Main Building; (2) Unprotected steel construction in Stitching Building Provide fire-rated construction for the Main and Stitching building. As an alternate, automatic sprinkler protection can be provided throughout the original Main Building. Reference Alliance Standards Part 4 Section 4.5 Separation Are exit enclosures provided with fire-resistive rated construction barriers? Exits stairs are not separated by fire rated construction and do not have fire doors. Photograph: Non-rated door to exit stair Provide fire-resistive rated construction barriers for exit enclosures in accordance with Alliance Standard Section 6.3.1.2. Consult a qualified fire protection engineer to design the required rated construction barrier. Reference Alliance Standards Part 4 Section 4.5 Separation The Alliance for Worker Safety Page 5/15

14 Nov 2013 Are separations between hazards provided with fire-resistive rated construction barriers. Hazards such as storage, boilers, generators, etc. are not separated from the production areas with rated construction. Photograph: Storage open to production areas Provide fire-resistive rated construction barriers between hazard types in accordance with Alliance Standard Sections 3.4.2 and 4.5. Consult a qualified fire protection engineer to design the required rated construction barrier. 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: Are certificates of occupancy provided for each building or ancillary structure? Fire Protection Systems Does the building have a fire pump? Fire pump information was unavailable. Document Review: No document provided Install a dedicated fire pump for the facility in accordance with NFPA 20. Also, install a water storage tank in accordance with NFPA 22. The Alliance for Worker Safety Page 6/15

14 Nov 2013 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? Only pull stations and smoke alarms are installed. Visual Assessment: Non-automatic fire alarm system installed Install initiating devices and notification appliances as required by the Alliance Standard and NFPA 72. Devices should be part of an automatic fire alarm and detection system for the facility. Pull stations at egress points, smoke detectors in air handling equipment, visual and audible devices spaced appropriately based on occupancy type. Reference NFPA 72 Does the building have a Standpipe System? Non-Compliance Level: 2 A Class II standpipe system is provided in both buildings but information as to the design of the systems was not available. Document Review: No document provided for review, Photograph, Document Review: No document provided for review, Photograph, Document Review: No document provided for review, Photograph, Document Review: No document provided for review, Photograph Install a Class III standpipe system at required locations. Standpipe system must comply with NFPA 14. Submit detailed plans and calculations to Alliance for review. Does the building have a standpipe system installed where required. Alliance Standard Part 5 Section 5.4.2 The Alliance for Worker Safety Page 7/15

14 Nov 2013 Is the fire alarm and detection system monitored by a central station monitoring service or directly connected to the Fire Service and Civil Defense? No automatic fire alarm system installed. Manual pull stations and single station smoke alarms are installed. Photograph: Pull station and smoke alarm Install a new automatic fire alarm and detection system. Once installed, arrange for direct connection of the fire alarm and detection system to a central station monitoring service or the Fire Service and Civil Defence per Alliance Standard Part 5 Sectio Alliance Standard Part 5 Section 5.7.5 Monitoring Are fire department connections provided and clearly identified for the Fire Protection Systems? Non-Compliance Level: 2 Fire department connections are provided for the Stitching Building but no signage has been provided. Photograph: Fire department connections Install signage at required locations and on required equipment. Signage must comply with NFPA 14. Alliance Standard Part 5 Section 5.5.4 Fire Department Connections Is signage for the standpipe system installed at required locations and on required components? Low The signage for the standpipe system was not in accordance with NFPA 14. Photograph: Inadequate signage provided Install signage at required locations and on required equipment. Signage must comply with NFPA 14. The Alliance for Worker Safety Page 8/15

14 Nov 2013 Reference NFPA 14 Chapter 6 Means of Egress Doors along the path of egress have a minimum width of 0.8 m (32 in) and have required ratings. Doors are wider than 0.8 m but are not rated at exit stairs. Photograph: (1) Door in Main building; (2) Door in Stitching building Provide fire doors at all openings into the stair enclosures. Doors should be listed, labeled, and have a minimum 90 min rating. Doors should swing in the direction of egress. 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. Sliding doors are present in the Main building Photograph: Sliding door at exit Replace all non-compliant doors in the means of egress with side-hinged swinging type doors. Alliance Standards Part 6 Section 6.8 Doors and Gates The Alliance for Worker Safety Page 9/15

14 Nov 2013 Means of egress are free from impediments, obstructions, and stored materials. The paths from the South stair of the Stitching building have many obstructions and tripping hazards. Photograph: (1) Tripping hazards/vent; (2) Obstructed path on west side of building Revise exit path to maintain clear path of egress from building at all times. Alliance Standard Part 6 Section 6.3.8 Impediments to means of egress and Section 6.3.9 Reliability Stairwells are not utilized as storage spaces. Non-Compliance Level: Alliance Standard Part 13 Section 13.9 Safety Inspections Occupant loads are posted for every assembly and production floor in a conspicuous space near the main point of egress. No occupant load signs are provided. Visual Assessment: No signage provided 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. The Alliance for Worker Safety Page 10/15

14 Nov 2013 Alliance Standards Part 6 Section 6.4.4 Posting of Occupant Load All paths of egress are provided with compliant means of illumination. Emergency lights are provided at exits in Main factory. Emergency lights are provided throughout in Stitching building. Photograph: Emergency light at exit in Main building Install emergency lighting for all paths of egress including all aisles in Main building in accordance with Alliance Standard Section 6.7. Alliance Standards Part 6 Section 6.7 Egress Illumination and Part 10 Section 10.12 Illumination of Exit Signs and Means Of Escape 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). Abrupt change in elevation in exterior exit discharge. Photograph: (1) Abrupt elevation change at west discharge of Main building; (2) Uneven discharge path from South stair of Stitching building Level the egress walking surface to eliminate any potential trip hazards. Alliance Standard Part 6 Section 6.3.4 Walking Surfaces The Alliance for Worker Safety Page 11/15

14 Nov 2013 Handrails are provided on both sides of each stairway. Intermediate handrails are provided when the stair width exceeds 2.2 m (87 in.). Handrails are not mounted lower than 760 mm (30 in.) or higher than 1100 mm (44 in.). Handrails are provided on both sides; however, in Main Building South stair, the handrail did not continue to the bottom of the stair run. Also, in the Stitching building, the handrails were not connected at the ends. Photograph: (1) Handrails stop before end of stair run; (2) Handrails not connected at rail ends Complete the handrail to the end of the stair run. Connect the handrails at the end to provide a continuous surface. Alliance Standard Part 6 Section 6.9 Stairs and 6.12 Handrails and Guards 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. Non-Compliance Level: Develop a testing and maintenance program that ensures that the operation of all exit signs is verified at least once per year. If battery-operated signs are used, these signs should be tested on a monthly basis. Functional testing of battery powered sign Alliance Standards Part 10 Section 10.12 Illumination of Exit Signs and Means Of Escape Lighting 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: The Alliance for Worker Safety Page 12/15

14 Nov 2013 Illuminated exit signs are placed at entrances to exits but not along the paths of egress. Additional exit signs or directional signs are not provided where there is a change in direction and where the continuation of egress is not obvious. Alliance Standard Part 6 Section 6.11 Exit Signs 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. Non-Compliance Level: Develop a testing and maintenance program that ensures that the emergency power for exit signs is tested at least once per year. If battery operated signs are used, these signs should be tested on a monthly basis. Functional testing of battery powered sig Alliance Standard Part 10 Section 10.12 Illumination of Exit Signs and Means Of Escape. 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 Stair designation signs are not provided. Visual Assessment: No signage provided Install signage adjacent to each stair door indicating the stair name and the floor level in both English and Bengali. Alliance Standard Part 6 Section 6.9 Stairs Fire Safety Programs The Alliance for Worker Safety Page 13/15

14 Nov 2013 Emergency egress maps are posted at the entrance to each exit stair or main point of egress. Non-Compliance Level: Post emergency egress maps at the entrance to each exit stair or main point of egress in six story RCC main production building [Well Designers Ltd, Sanzi Textiles Ltd. and Well Fashion Ltd.] as required in Alliance Standards Part 13 Section 13.4. Alliance Standards Part 13 Section 13.4 Evacuation Plan A hot-work permit program has been established. Low No documented hot work program was in place. Document Review: No document provided Develop a hot work permit program. The program must comply with the requirements of NFPA 51B. Alliance Standards Part 13 Section 13.4 Hot Work Permit and NFPA 51B A Fire Safety Director position has been filled. Low Non-Compliance Level: Create a Fire Safety Director position and fill the position with an individual that has had sufficient training to perform the required duties. The Alliance for Worker Safety Page 14/15

14 Nov 2013 Alliance Standards Part 13 Section 13.1 Fire Safety Director The Alliance for Worker Safety Page 15/15