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INITIAL FIRE SAFETY ASSESSMENT Factory Mouza Chandra, Shafipur, Kaliakoir, Gazipur Gazipur Dhaka 24 Mar 2014 The Alliance for Worker Safety Page 1/12

24 Mar 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 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 2/12

24 Mar 2014 GENERAL INFORMATION General Information Factory Country: Province: City: Dhaka Gazipur Zip Code: 1751 Audit Duration: Re-Audit: 3 Days Re-Audit After 0 Months Draft Report April 15, 2014 Final Report May 12, 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: N/A 20 Total Buildings Building #1 - Production Building - 2 story Building #2 Production Building - 3 story Building #3 Production Building - 2 story Building #4 Production Building - 6 story Sheds #1 - Production Building - 1 story (Steel Prefab) Sheds #4 -Production Building - 1 story (Steel Prefab) Ancillary Buildings (1 storied shed type buildings - Leather store, Leather & lining store, Sub-station, Day care & medical center, Male dining & rejection store, Shoe lasting store, Accessories store, Security, residence & dining hall, Cafeteria, Compressor & waste material go-down, Vehicle parking stand Owned Building #1-2 story Building #2-3 story Building #3 2 story Building #4 6 story Sheds #1-1 story (Steel Prefab) Sheds #4-1 story (Steel Prefab) Ancillary Buildings (1 storied shed type buildings) Building #1-46739 sqf Building #2-74,967 sft Building #3 48,420 sft Building #4 154,578 sf Sheds #1-25,458 sft Sheds #4-65,000 sf Ancillary Buildings 108,446 sft Building #1-1990 Building #2-2000 Building #3-2010 Building #4-2011 shade-1 2004 shade-4 1998 NA 14 (Leather store, Leather & lining store, Sub-station, Day care & medical center, Male dining & rejection store, Shoe lasting store, Accessories store, Security, residence & dining hall, Cafeteria, Compressor & waste The Alliance for Worker Safety Page 3/12

24 Mar 2014 material go-down, Vehicle parking stand Approximate Ancillary Structures Area (SF): 108,446 sft Number of Occupants: Approx. 5550 Number of Ancillary Levels (Stories): Single Story The Alliance for Worker Safety Page 4/12

24 Mar 2014 ASSESSMENT FINDINGS Fire Protection Construction Are exit enclosures provided with fire-resistive rated construction barriers? High Non-Compliance Level: 2 Exit enclosures in multi-story buildings (Buildings 1-4) are not protected by fire rated door assemblies. Visual Assessment: Fire rated door assemblies not observed in Buildings 1&4 exit enclosures. 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 in buildings 1 to 4. 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. Fire door assemblies shall conform to NFPA 252, BS 476 Part 22, EN 1364-1, GB 12955-2008, or IS 3614 Part II. Retain the services of qualified fire engineer to assist in specifying and installing fire rated assemblies. Reference Alliance Standards Part 4 Section 4.5 Separation Are separations between hazards provided with fire-resistive rated construction barriers. Non-Compliance Level: 3 There are several areas of the complex of buildings that require separations as per Alliance Standards Part 4 Section 4.5 Separation as follows: - Building #1 - Generator Room & Transformer Rooms (Substation) - Shed #6 - Transformer Room, Diesel sto Photograph: Chemical storage near discharge of canteen In order to meet the requirements for appropriate segregation of occupancies, the factory will need to install the following: Building #1 - Transformer room shall be separated by a minimum 2 hour fire restrictive rated construction. Generator sets shall be separated from all other occupancy areas by a minimum 2 hour construction. Shed #6: Transformer room shall be separated by a minimum 2 hour fire restrictive rated construction. Generator sets shall be separated from chemical storage areas by a minimum 2 hour construction (alternatively combustible chemicals can be stored in separated fire rated building/room). Building #2 - storage of combustible materials shall be separated from the surrounding occupancy (canteen) with a minimum 1 hour The Alliance for Worker Safety Page 5/12

24 Mar 2014 construction. Building #1 - Chemicals should be stored in room with minimum 2-hr rated construction. Building #2 - Synthetic Material store separated by minimum 1-hr fire-rated construction Shed #8 - Rejection store separated from dining by minimum 1-hr fire rated construction Building #4 - Finished good store separated from production by minimum 1-hr fire rated construction Consult a qualified fire engineer to design the fire rated assemblies for these areas. 23 Sep 2014 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 Highest Occupied Floor Level Above Grade Non-Compliance Level: The Alliance for Worker Safety Page 6/12

24 Mar 2014 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 fire pump? High Non-Compliance Level: 3 The factory does not have automatic fire pump. The factory only has manual electric submersible pump for lifting and refilling overhead tank from deep tube well to provide water supply of fire hose (standpipe) system. Photograph: Manual water pump Installation of approved standpipe and sprinkler system (mentioned elsewhere) will require the installation of a 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. Alliance Standard Part 5 Fire Protection Systems Does the building have a Standpipe System? High Non-Compliance Level: 2 Factory has a system of fire hose pipes (five type II connections with hose located at exterior of buildings) however, standpipe system does not meet the criteria of the Alliance Standard Part 5 Section 5.4.2. Standpipes systems are required for buildings Photograph: Photo of one of five Type II connections located on grounds Install standpipe systems in Buildings #2 & #4. All installation and design requirements outlined in BNBC Part 4 Chapter 4 for combined standpipe and automatic sprinkler systems shall be replaced by the requirements of NFPA 14 with a minimum pressure of 450 kpa (65 psi) at the hydraulically most remote hose connection. Standalone standpipe systems shall meet the local BNBC requirements with a minimum 450 kpa (65 psi) pressure at the hydraulically The Alliance for Worker Safety Page 7/12

24 Mar 2014 most remote hose connection or NFPA 14. System should be designed by a qualified fire protection engineer. Class III (65 mm and 40 mm fittings) standpipe hose connections shall be located in all required stairwells at each floor level including occupiable roofs. For buildings with sprinklers (as required for Building #4) Class II standpipe hose connections (40 mm) are not be required. Does the building have a standpipe system installed where required. Alliance Standard Part 5 Section 5.4.2 Are notification and initiation devices for the fire alarm system installed at required locations based on occupancy type? High Non-Compliance Level: 2 An automatic fire alarm and detection system is not provided throughout all moderate hazard industrial occupancies (production areas) and assembly occupancies including: Building's 1-4 Shade #1 Shade #4 Shade #14 Shade #13 Shade #8 Visual Assessment: Automatic fire alarm and detection system no observed in required areas including Install automatic fire alarm systems in the noted locations (consult a qualified fire engineer for design and installation of detection and alarm system). NOTE: For building #4 where sprinkler system is recommended, it is not necessary to install both sprinklers and automatic alarm system. 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 building protected by an automatic sprinkler system? High Non-Compliance Level: 1 As per Alliance Standards Part 3 Section 3.5.3 Existing Buildings building #4 (90 ft) will require an automatic sprinkler system to be installed. Visual Assessment: No sprinkler system observed in Building 4 as required. Install an automatic sprinkler system throughout Building #4 designed by a qualified fire protection engineer. The Alliance for Worker Safety Page 8/12

24 Mar 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 Are fire department connections provided and clearly identified for the Fire Protection Systems? Non-Compliance Level: 3 Fire department connections are not provided as per Alliance Standard Part 5 Section 5.5.4 Fire Department Connections Visual Assessment: No fire department connections observed. Install Fire department (Siamese) inlet connections in the current (or newly installed) standpipe system 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 Defence hose thread standard. Alliance Standard Part 5 Section 5.5.4 Fire Department Connections 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 Non-Compliance Level: 3 As noted elsewhere, factory does not have compliant standpipe system. The current system has not been evaluated for compliance with the design pressure and flow demands of NFPA 14 or BNBC as per Alliance Standard 5.4.3. Document Review: No shop drawings, design drawings or inspection/testing/maintenance records were available to confirm design pressure. Following installation of required standpipe systems, the 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. Reference NFPA 25 Chapter 6 Standpipe and Hose Systems Table 6.1.1.2 The Alliance for Worker Safety Page 9/12

24 Mar 2014 Means of Egress All paths of egress are provided with compliant means of illumination. Non-Compliance Level: 2 Building #4: not all exits have emergency lights installed and therefore these paths of egress are not provided with compliant means of illumination as per Alliance Standards Part 6 Section 6.7 Egress Illumination and Part 10 Section 10.12 Illumination of Visual Assessment: Emergency lights not observed at all exits of Building #4. Install emergency lighting at all exits and all paths of egress in Building #4. Confirm through testing (light meter) or other certification that all means of egress in ALL buildings will have illumination of 10 lux for all corridors, exit doors, and stairways and no less than 30 min in the event of failure of normal lighting. 23 Sep 2014 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 provided with battery backup or emergency power and are continuously illuminated. Non-Compliance Level: 2 According to management, exit signs are tested every month (documentation reviewed). However, during the assessment it was found that a couple of the exit signs in Building #1 and Shed #2 were not working. Visual Assessment: Some exit signs in Building #1 and Shed #2 were not working Battery power for all exit signs should be checked regularly in a systematic way with documented records available for review. Emergency power for exit signs shall be verified at least once per year. If battery-operated signs are used, these lights shall be tested on a monthly basis. Functional testing of battery powered signs shall be provided for a minimum 90 min once per year. It is recommend that equipment should be numbered, with inspections, deficiencies, and follow-up noted in a log. 09 Sep 2014 Alliance Standards Part 6 Section 6.11 Exit Signs 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) The Alliance for Worker Safety Page 10/12

24 Mar 2014 unless provided with a beveled slope of 1 in 2 that does not exceed 12.7 mm (1/2 in). Non-Compliance Level: 1 At Shed #1, one of the exits has a concrete lip that exceeds requirement. (slope is around 40%) Visual Assessment: Concrete lip observed at exit of Shed #1. Remove or re install concrete lip at exit with beveled slope of 1 in 2 and less than 1/2 inch. 16 Sep 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. Non-Compliance Level: 1 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 in Building #4. As noted in other areas, fire rated door assemblies are required for t Visual Assessment: Fire rated door assemblies with proper latching systems have not been installed in Building #4 During installation of fire rated door assemblies noted elsewhere assure that every door in a stair enclosure serving more than 4 stories (Building #4 only) is provided with re-entry unless it meets the requirements of Alliance Standards Part 6 Section 6.8.3.1. Alliance Standards Part 6 Section 6.8 Doors and Gates Fire Safety Programs Chemicals and other flammable materials are stored within approved enclosures. Non-Compliance Level: 3 As noted elsewhere, in building #1, the chemical storage room is not fire rated The Alliance for Worker Safety Page 11/12

24 Mar 2014 and is located in close proximity to the exit discharge of the canteen. Additionally, diesel fuel is being stored outside of generator room that is not fire rated (Shed #6) Photograph: Photo of Diesel outside Shed #6 (generator room) Construct a chemical storage room following the requirements of BNBC Part 3 Section 2.4 (2 or 4 hour rated construction depending on the total volume and classification of chemicals stored) or alternatively move chemical storage to an area separate from other occupancy types. As noted elsewhere, generator room should have appropriate fire rated segregation or diesel fuel stored in another (fire rated) area. 29 Apr 2014 A hot-work permit program has been established. Low Non-Compliance Level: 1 Factory has a procedure before doing any hot work. Officially, permission is provided and the work is monitored. However, the program does not consist of a formal written procedure with permit system. Document Review: No formal written procedure with permit system available for review. Develop a written hot work permit program. The program must comply with the requirements of NFPA 51B. Develop a maintenance and contractor safety policy that includes procedures for conducting hot work (e.g. welding). All hot work should be conducted with a proper permit and precautions must be available in case of fire (e.g. fire watch, fire extinguisher, etc.). 09 Sep 2014 Alliance Standards Part 13 Section 13.4 Hot Work Permit and NFPA 51B The Alliance for Worker Safety Page 12/12