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FIRE SAFETY INSPECTION REPORT BEQ KNIT LTD. ZIRABO, ASHULIA, SAVAR, DHAKA Other Factories: Beq Sweaters Ltd., Tammam Design Ltd. April 22, 2014

Page 2 Fire Safety Inspection Report Introduction manufacturing complex was surveyed for fire safety on 4/22/2014 by Hughes Associates, Inc. The purpose of the survey was to identify significant fire safety issues and to provide recommendations for remediation based on applicable standards specified by the Accord. The scope of this initial fire safety inspection was limited to the review and identification of major fire safety issues. The inspection did not include identification of minor deficiencies, which will be further addressed as part of follow-up inspections. Limitations The information in this fire safety inspection report was obtained during a visit to the facility and during interviews with local factory management. It has not been possible to provide independent verification for all the information and data collected, and, therefore, Hughes cannot accept general responsibility for omissions or errors arising from inaccuracies in this report from the information obtained. The findings and recommendations in this report are not intended to imply, guarantee, ensure or warrant compliance with any government regulations. Additionally, the results do not imply in any way that compliance with the findings or recommendations as stated in this report will eliminate all hazards, risks or exposures or that hazards, risks or exposures not referred to in this report do not exist. Compliance with the findings and recommendations stated in this report does not relieve the factory owner from obligation to comply with specific project requirements, industry standards, or the provisions of any local government regulations.

Page 3 General Factory Information Factory name(s): Main building and Accessory sheds Factory Address: Zirabo, Ashulia, Savar, Dhaka Points of Contact: Md. Asaduzzaman Rubel,CSM Lusaka Group 01777789948 rubel@lusakagroup.com Md. Ashraful Alam (Babu),Manager HR Admin and Compliance Lusaka Group 0195654866 hr.factory@lusakagroup.com

Page 4. of Stories Below / Above Grade 0 / 8 High Rise High Rise Comments: The highest occupiable floor is 22.8 m. Occupancy Classification Floor Plans Available G2 Industrial H2 Storage F Business E Assebmbly E Assembly Ground floor layout 1st floor layout Date Of Construction 2002 Major Renovations

Page 5 Other Tenants Comments Floors Occupied By Factory Beq Sweaters Ltd. (5th, 6th) and Tammam Design Ltd. (2nd floor) are two establishments that shares the eight storied building with The 1st and 7th floor contains functions (office, dining, store) that are shared by all factories. Ground, 1st Floor, 3rd Floor, 4th Floor and the 7th Floor. Floor Use Occupant Load G 1 3 4 7 Knitting Section Office, Storage Cutting, Sewing, Storage Finishing, Storage Dining, Storage 70 25 560 160 500 n-combustible Fire-Resistive rth 7 storied building, approximately 15 ft. separation. South Open land East 3 storied building, approximately 6 ft. separation. West Open plot and 3 storied building, approximately 25 ft. separation.

Page 6 Stairs Enclosed in Fire- Rated Construction? Unsealed Penetrations in Stairs Unprotected Openings From Stairs Shafts Enclosed in Fire- Rated Construction Floors with Openings/Penetrations Other Vertical Openings Three (3) exit stairs serve the building. Egress from the ground floor is provided by three (3) exits. On the 1st and 7th floor one of the exit stairs was inaccessible. Each floor, except the 7th, had an adequate number of exits with sufficient exit capacity based on occupant load. The exit capacity of the 7th floor (500) is insufficient for the maximum occupant loads (471). All exits, except those on the 1st and 7th floor, were remotely located. All exits discharged to the exterior of the building. All the exit stairs are open on all floors due to unprotected openings (non-rated doors). Sliding gates and doors with locking features were used at all building exits, exit stairs and exit discharge points. All gates and doors, apart from the southern exit stair on the 1st and 7th floor, were open and unlocked during the inspection. There was storage located in egress paths on the 7th and ground floor. There was storage and unsealed penetrations located in all exit stairs on multiple floors. Egress paths of adequate width was not present on the ground floor. Emergency evacuation plans were located inside some of the exit stairwells. Fire drills are conducted monthly and records were maintained.

Page 7 Floor Occupant Load. Exits Exit Capacity G 1 3 4 7 70 25 560 160 500 3 2 3 3 2 673 471 631 631 471 Number of Exits Adequate Exits Remote Sliding Gates/Doors Used? Egress Doors Swing Correctly? Egress Doors Lockable? All Stairs Discharge to the Exterior? Handrails on at least One Side? Storage Located in Stairs? Storage in Egress Paths?

Page 8 Egress Paths of Adequate Width? Excessive Travel Distances, CPT, DE's Emergency Evacuation Plans Provided? Fire Drills Conducted Records Maintained 7th Floor Evacuation Plan 4th Floor Evacuation Plan automatic sprinkler protection was provide in the factory building. Based on the height of the highest occupied floor (22.8 m), sprinkler is not required.

Page 9 Hose cabinets and Hose reels with 1 in. and 1.5 in. hoses were provided adjacent to western exit stair entrances. Hose Size(s) Provided Locations 1.5 in. 1 in. Outside the Western exit stair enclosure. Exemplar Hose Reels Exemplar Hose Cabinet The fire hose system is supplied by gravity from four (4) roof tanks having a combined reported capacity of 8,000 L (the presence of a dedicated tank was not specified). The tank is fed by an underground cistern, with reported capacity of 300,000 L, accessed from the inside of the Utility shed. A fire pump was not connected to the system. Source(s) Tanks. Location Roof top

Page 10 Capacity 8,000 L Fire Pump A fire alarm system was provided in the building. It consisted of manual alarm switches that were connected to horn units (no visual notification devices were present); each floor had three horns.the devices were interconnected so that activation of a single device provides audible notification throughout the whole building. Fire alarms were found to be absent in the Office area (1st floor). There is no fire alarm panel or system supervision and faulty switches were observed in some of the floors. A functional test revealed that the sirens provided inadequate notification at certain points on the building (southern end). Assertions of regular testing or maintenance of the fire alarm system were made however no records were provided. Type of System Manual Fire Alarm (Audible only) Fire Panel Location ne Visible tification Appliances? Audible tification Appliances? Alarm Annunciation Functional Test Conducted Manual Whole Building Regular Inspection, Testing, & Maintenance?

Page 11 Broken Fire Alarm Switch Exemplar Fire Alarm Horn Single station smoke alarms were located near electric panels throughout the factory.the overall smoke alarm distribution was inadequate and the Dining (7th floor) and Office areas (1st floor) were found to be devoid of such units.the alarms were not tied into the fire alarm system. In the event they detect smoke, they will provide a local alert sound. Type of Detectors Single Station Smoke Alarms Regular Inspection, Testing, & Maintenance? Exemplar Smoke Alarm

Page 12 Portable fire extinguishers, consisting of dry chemical extinguishers were provided throughout the building. Inspection tags show recent and up-to-date inspections. Types Provided Dry chemical Adequate Number/Spacing? Exemplar Fire Extinguisher Only the rthern exit stair had some firefighting equipment staged outside the main floor entrance.types of manual firefighting equipment provided included: Sand/water bucket, fire beater, gaffs, bolt/lock cutter, stretcher, personal protection equipment (gloves,hardhats, respirators) etc. In many of the floors, inadequate and poor quality equipments were observed. Types of Equipment Provided Sand/water bucket, fire beater, gaffs, bolt/lock cutter, stretcher, personal protection equipment (gloves,hardhats, respirators) etc. Location of Equipment Inside the landings of the rthern fire stair enclosure.

Page 13 Emergency lighting (with battery backup) were located inside and outside the exit enclosure walls. Lighting consisted of multiple compact florescent lights that had an Instant Power Supply (IPS). Each floor had a number of illuminated exit signs (a mix of directional and nondirectional) located along the exit access and at exits on each floor; exit signs were found to be missing and broken on many of the floors. The factory reports that these are serviced by normal electricians but no maintenance records were provided. Exits and Exit Access Properly Marked with Exit Signage Emergency Power IPS Emergency Lighting for Exits & Exit Access Regular Inspection, Testing, & Maintenance? Exemplar Fire Exit Sign Exemplar Emergency Lighting One elevator was used to served the ground to seventh floors. Signage stating In Case of Fire Don't Use Lift was not provided outside the elevators on any floor.

Page 14 Automatic Recall Fire Fighter Features Elevator Lobby Elevator entry Elevator interior Two generators (gas and diesel) are provided on the ground floor of the Utility shed. The generator room is not separated from the working areas of Beq Fabrics (adjacent building) by means of fire-rated construction (unprotected openings, penetrations and non-rated doors). Drums containing fuel was located inside the room. Location(s) Single story utility shed on the western side of the site. Inside Fuel Storage Fire Rated Separations Provided?

Page 15 Generator Room Utility Building The Boiler was provided on the ground floor of the Utility shed. The boiler room is not separated from the working areas of Beq Fabrics (adjacent building) by means of fire-rated construction (unprotected openings, penetrations and fire-rated doors). Location(s) Single story utility shed on the western side of the site. Fire Rated Separations Provided? Boiler Room

Page 16 transformer was provided in the factory building. Dedicated storage rooms on all floors had either unsealed penetrations or unprotected openings along the peripheral walls that compromise the fire barrier. Also, the transient storage areas on the 2nd, 3rd and 4th floors were open to the production areas and not adequately separated by fire-rated construction doors. Fire Rated Separations Provided? Open to Factory Floors? Open to Exit Discharge? The majority of the factory functions are located on the ground, 3rd and 4th floor of the building. The Dining area (7th floor) and Office area (1st floor) is shared with other establishments (Tammam Design Ltd. and Beq Sweaters Ltd.). The Daycare facility is located on a two storied shed on the western part of site. The Generator and Boiler is located on the single storied utility building on the western end of the site.

Page 19 Findings & Recommendations Table 1 summarizes the major fire safety issues identified during the inspection. Recommendations have been provided to address each issue. An implementation schedule shall be developed by the factory to remediate each of the findings. The specific timing of improvements, including any requested extensions due to design / installation constraints, shall be submitted to the Accord for approval.

Page 19 Table 1. Findings And Recommendations. Category Finding Recommendation Remediation Timeframe F-1 Fire Rated Construction Flammable liquid storage area is not separated by fire-rated construction (openings, non-rated doors, penetrations). The chemical store in the Washing plant (ground floor) is exposed to the working areas. Separate the hazardous materials / flammable liquid storage room by a minimum 2- hr fire-rated construction. Seal and/or protected all openings to maintain the required fire separations. Within 3

Page 20 F-2 Fire Rated Construction The boiler, generator and EMR room is not separated from the working areas of Beq Fabrics (adjacent building) by means of fire-rated construction (openings, non-rated doors, penetrations). Separate the boiler, generator and EMR room from the adjacent working areas by a minimum 2-hr fire-rated construction. Seal and/or protected all openings to maintain the required fire separations. Within 3

Page 21 F-3 Fire Rated Construction The Fabrics store on the 7th floor was not separated from the dining areas (openings and unrated doors). The Finished goods store (4th floor) exceeded the permitted limits and was open to the working areas. Other storage areas like the Bonded wear house (3rd floor), Fabrics store (2nd floor) and Accessories store (1st floor) also had issues related to separation. Provide dedicated storage rooms separated by minimum 1-hr fire-rated construction. Where separate storage rooms are not feasible, provide defined storage areas and limit the storage arrangement as follows: - Maximum height of 2.4m and maximum area of 23m2 - If sprinkler protected: maximum height of 3.66m and maximum area of 93m2 Separate areas of unenclosed combustible storage by a minimum clear distance of 3m. Within 3

Page 22 F-4 Fire Rated Construction The exit stairs are not separated from work areas on each floor by fire-rated construction. 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. 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. Within 3 If fire doors are required to be held open for functional reasons, provide automaticclosing devices tied to the fire alarm system.

Page 23 F-5 Fire Rated Construction Unsealed penetrations and openings are located in exit stair enclosures. Seal all penetrations and openings in exit stair enclosure walls to maintain the fire separation. Within 3 Penetrations were observed in multiple locations such as the Western stair enclosure (7th floor), rthern stair enclosure (7th floor), Western stair enclosure (4th floor) etc.

Page 24 F-6 Fire Rated Construction The exit discharge path of the Southern exit stair to the assembly point has a width less than 10 ft. and unprotected openings at a height of less than 10 ft. Exterior building wall adjacent to passageway shall be rated 1-hr up to 10 ft. above grade. Within 3

Page 25 F-7 Egress Egress doors / gates with locking features are provided at building exits, exit stairs, along egress routes, exit discharge. Locking features were found in numerous locations through out the building. Apart from the exit gates for the Southern stair enclosure (on the 7th and 1st floor) all gates/doors were found to be open and unlocked during the inspection. Remove locking features from all egress doors / gates. If locks are required for security reasons, utilize special door locking features complying with NFPA 101. Immediate F-8 Egress Storage in the path of egress was found in various locations through out the building eg : Fabrics store (7th floor), Spinning section (ground floor). Keep egress paths and stairs clear of storage. Immediate

Page 26 F-9 Egress General storage was located in all the three stair enclosures. Remove all storage from exit stairs and egress paths. Immediate F-10 Egress Concertina type retractable doors were predominantly used in all the exits. Rolling steel doors with locking features were also found along the path of egress. Replace all gates / sliding doors along the means of egress with side-hinged, swinging egress doors. If locks are required for security reasons, utilize special door locking features complying with NFPA 101. Within 1 month

Page 27 F-11 Egress Emergency Evacuation Plans were posted within/next to exit stairs on the 1st, 2nd and Ground floor. Provide readily visible/identifiable emergency evacuation plans within/next to all exit stairs. Within 1 month F-12 Egress Exit capacity (471) is not adequate for the occupant load (500) for the dining area on the 7th floor. Immediately reduce occupant load to less than the available exit capacity. Or Within 3 Unlock the Southern stair exit and provide a means of egress that does not require passage through the hazardous area. F-13 Egress The main egress door serving the Office area on the 1st floor does not swing in the direction of egress travel. Modify the egress door to swing in the direction of egress travel. Within 3

Page 28 F-14 Egress The exits are not remotely located from each other such that a single fire event could compromise both exits. The Southern exit stair was found to be locked on the 1st and 7th floors. On these floors the rthern and Western, being the only functional stairs on the floors, were found to be non-remote. Modify exit arrangement and insure that the Southern stair is usable on the mentioned floors. Provide sprinkler protection in accordance with NFPA 13. Within 3 F-15 Egress The egress path to the southern exit stair (7th floor) has to go through an area of increased hazard (combustible storage). Provide 1-hr fire rated passageway that provides safe access to the Exit stair. Within 3

Page 29 F-16 Fire Protection The fire alarm system is antiquated, not a listed system, and does not provide alarm and notification features consistent with acceptable standards. Replace the fire alarm system with a new, listed addressable fire alarm system in accordance with NFPA 72. Design within 4, install within 9

Page 30 F-17 Fire Protection The building is equipped with single-station smoke alarms. Smoke alarm activation sounds only a local alarm and does not provide automatic fire alarm notification of occupants. Remove all single-station smoke alarms. Provide automatic smoke detection throughout the building in accordance with NFPA-72. Within 1 On all floors, except on the 1st and 7th floors, the smoke alarms were only provided near electrical panels. Smoke alarms were not present on the 1st and 7th floors. F-18 Fire Protection Inspection, testing, and maintenance records for the fire alarm system were not in accordance to NFPA 72. Inspect, test and maintain the fire alarm system, and keep written records on-site, in accordance with NFPA 72. Within 3 F-19 Egress Lighting The florescent emergency lights inside the exit stair enclosures had manual on-off switches. Remove manual on/off switches from emergency lighting units to prevent them from being switched off. Within 1 month

Page 31 F-20 Egress Lighting Based on the number and location of emergency lights observed, adequate illumination levels are not anticipated along egress routes. The emergency lights were found to be inadequate in most of the stair enclosures. Test the emergency lighting system on each floor and provide additional emergency fixtures to provide adequate illumination along the means of egress. Provide a minimum illumination of 10 lux at the floor level within exit stairs and exit discharge paths and minimum 2.5 lux along exit access aisles. Within 3 F-21 Egress Lighting Exit signs were found to be missing in many areas such as the Dining area (7th floor), the Southern and Western exit stairs, the Office area (1st floor), Washing areas (ground floor) etc. Provide exit signs above all exits to the exterior and all doors to the exit stairs. Within 3

Page 32 F-22 Egress Lighting Broken and burned out exit signs were found on the 7th and 4th floor. Regularly inspect all exit signage and replace/install lights as needed to illuminate signs. Within 3 F-23 Egress Lighting Emergency lights were found to be missing on several floors eg: rthern stair enclosure (ground floor) etc. Reguarly test the emergency lighting system on each floor and replace/repair lights as needed. Within 3

Page 33 F-24 Egress Lighting Inspection, testing, and maintenance records for the emergency lighting system were not available. Inspect, test and maintain the emergency lighting system in accordance with The ACCORD standard. Keep written records on-site. Within 3