EQUIVALENT INITIAL FIRE SAFETY ASSESSMENT Factory Plot # 33-36 Sector # 07, Chittagong Chittagong Chittagong 08 Jun 2014 The Alliance for Worker Safety Page 1/18
08 Jun 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 2/18
08 Jun 2014 GENERAL INFORMATION General Information Factory Country: Province: City: Chittagong Chittagong Zip Code: 4223 Audit Duration: Re-Audit: 1 Days Re-Audit After 0 Months Draft Report 06-08-2014 Final Report 06-29-2014 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: N/A There are 4 buildings in the factory premises out of which one is main production building and three are ancillary buildings. The buildings are named as: 1) Two story prefab main production building, 2) Four story prefab admin building (under construction), 3) Three story prefab production building (under construction), 4) Single story dinning shed. Owned 1) Two story prefab main production building: Building height (est occupied floor level): 4 m or 13.12 ft [Height up to roof: 7.62 m or 25 ft], Stories above grade: 2, Stories below grade: 0, Occupied levels: 2, 2) Four story prefab admin building (under construction), 3) Three story prefab production building (under construction), 4) Single story dinning shed: Building height (est occupied floor level): 30 cm or 1.00 ft above grade [Height up to roof: 3.65 m or12 ft], Stories above grade: 1, Stories below grade: 0, Occupied levels: 1. Total area of all buildings in the factory premises (except the under construction buildings): 72000 sft. Building wise breakdown as follows: 1) Two story prefab main production building: 59427 sft (Ground floor: 30142 sft, 1st floor: 29285 sft), 2) Four story prefab admin building (under construction), 3) Three story Prefab production building (under construction), 4) Single story dinning shed: 12573 sft. Factory personnel informed the date of building construction as follows: 1) Two story prefab main production building: Finished in 2001, 2) Four story prefab admin building (under construction): Started in 2013 and construction on going, 3) Three story prefab production building (under construction): Started in 2013 and construction on going, 4) Single story dinning shed: Finished in 2013. The Alliance for Worker Safety Page 3/18
08 Jun 2014 Date of Last Building Renovation/Addition: Ancillary Structures in Complex: Approximate Ancillary Structures Area (SF): Number of Occupants: Number of Ancillary Levels (Stories): Occupancy Type: Construction Type: Height of est Occupied Floor Level Above Grade: Factory personnel informed the date of last building renovation or addition as follows: 1) Four story prefab admin building (under construction): Started in 2013 and construction on going, 2) Three story prefab production building (under construction): Started in 2013 and construction on going. 1) Single story dinning shed. 1) Single story dinning shed: 12573 sft. Total number of occupants: 1355. 1) Two story prefab main production building: 1350 (Ground floor: 725, 1st floor: 625), 2) Four story prefab admin building (under construction): 0, 3) Three story Prefab production building (under construction): 0, 4) Single story dinning shed: Ground floor: 5. 1) Single story dinning shed: Building height (est occupied floor level): 30 cm or 1.00 ft above grade [Height up to roof: 3.65 m or 12 ft], Stories above grade: 1, Stories below grade: 0, Occupied levels: 1. 1) Two story prefab main production building: [Ground floor: G2 (Sewing, finishing), K (Boiler, compressor), B2 (Childcare), H2 (Storage), 1stfloor: G2 (Sewing, cutting), F1 (Office)], 2) Four story prefab admin building (under construction): Not in use, 3) Three story Prefab production building (under construction): Not in use, 4) Single story dinning shed: ground floor: E3 (Dinning), K (Kitchen). 1) Two story prefab main production building: Non-rated, 2) Four story prefab admin building (under construction): Non-rated, 3) Three story prefab production building (under construction): Non-rated, 4) Single story dinning shed: Non-rated. 1) Two story prefab main production building: 4 m or 13.12 ft, 2) Four story prefab admin building (under construction): Under construction, 3) Three story Prefab production building (under construction): Under construction, 4) Single story dinning shed: 30 cm or 1.00 ft above grade. The Alliance for Worker Safety Page 4/18
08 Jun 2014 ASSESSMENT FINDINGS Fire Protection Construction Are openings and penetrations through rated walls and/or assemblies protected? An unprotected opening was found through the rated wall of production area on the 1st floor towards the staircase and passageway. Also, there is an opening at the boiler room on the ground floor. Also, the doors at different locations are not fire rated. Photograph: Openings and penetrations through rated walls are not protected. Install fire rated doors and windows or fill in unprotected openings with fire resistive rated assemblies. 15 Nov 2014 Includes doors, windows, ducts, piping, etc. Reference Alliance Standards Part 4 Section 4.6 Opening Protectives and Section 4.7 Penetrations Are exit enclosures provided with fire-resistive rated construction barriers? There are 4 staircases in the 2 story main building. Among them 3 numbers of staircases is required. Two (stair-2 and stair-3) out of these three are exterior stair which are provided with fire rated doors and another one is RCC stair (stair-1 )in which fire door is not installed as a result exit enclosure is not fire rated which is required as per Alliance Standard. In stair-1 enclosure there are openings other than exit of production floor but in the direction of opening there is no occupancy and also there is no other opening of production floor within 10 ft distance. So, only installing the fire door can make smoke free enclosure. Internal stair is not the required stair and it is open to the production floor. So, in accordance to Alliance standard 4.5.3.2, this stair enclosure is not required. Photograph: No fire door is used in one exit enclosure at 1st floor of the main building. Provide outward opening, side-swinging, self-closing, non-lockable fire doors of 1 hr rating in all stairwell enclosures. Consult a qualified fire protection engineer to design the required rated construction barriers. 01 Oct 2014 The Alliance for Worker Safety Page 5/18
08 Jun 2014 Reference Alliance Standards Part 4 Section 4.5 Separation Are separations between hazards provided with fire-resistive rated construction barriers. Non-Compliance Level: 3 The main store (H2) and the production area (G2) is separated by a wooden door on the ground floor which is not fire resistive rated barrier. Also, wire mesh is used to separate the finished store area (H2) and production area (G2) on the ground floor. Fire resistive barrier is required to provide separation between these occupancies. Photograph: Separations between hazards are not provided at different points of the building. Provide fire-resistive rated construction barriers between hazard types following Table 4.4.1 of Alliance Standard. Consult a qualified fire protection engineer to design the required rated construction barrier. 24 Dec 2014 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: 1 No occupancy certificate is available for any building in the factory premises. Document Review: No document found. Apply to BEPZA for issuance of occupancy certificate and pursue the matter to expedite. 20 Aug 2014 Are certificates of occupancy provided for each building or ancillary structure? Fire Protection Systems The Alliance for Worker Safety Page 6/18
08 Jun 2014 Does the building have a Standpipe System? Non-Compliance Level: 1 Height of the highest occupied floor of the main building is 13.12 ft (4 m) above grade. Therefore standpipe system is not required as per Alliance Standard Part 5 Section 5. 4.2. But class-ii stand pipe is installed in the building. No approved hydraulic calculation is available for this installed class II stand pipe. Photograph: class-ii stand pipe is available in the building. The system is to be compliant with the requirements of NFPA 14. The hydraulic calculations should be reviewed by Alliance. Testing of the installation shall be conducted in accordance with NFPA 14 acceptance testing requirements. Documentation of all testing shall be submitted for review by the Alliance. The Owner shall contact the Alliance prior to conducting the final acceptance testing of the standpipe installation to allow the Alliance the option of witnessing this testing and conduct a final inspection of the installation. 30 Sep 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? Non-Compliance Level: 1 A dedicated fire pump set is available with backup power; however it does not comply with the requirements of Alliance Standards and NFPA 20. Hydraulic calculation for installed standpipe systems is not also available. Photograph: Fire pump is available in the premises. Fire pump installation is to be tested for final acceptance in presence of Alliance and a final inspection of the installation shall be conducted by the Alliance prior to final acceptance of the installation by the Alliance as per clause 5.5.5. Acceptance testing of the installation shall be in accordance with NFPA 20, 22, and 24 testing requirements. Documentation of all testing shall be submitted to the Alliance for review prior to final acceptance by the Alliance. 30 Sep 2014 Alliance Standard Part 5 Fire Protection Systems The Alliance for Worker Safety Page 7/18
08 Jun 2014 Are notification and initiation devices for the fire alarm system installed at required locations based on occupancy type? Non-Compliance Level: 1 Pull stations, smoke detectors, visual and audible devices are placed where required throughout the premises. But in the dining shed centralized smoke detectors were not available. Photograph: Notification and initiation devices for the fire alarm system installed at required locations in two story prefab shed based on occupancy type. Install automatic or manual fire alarm and detection systems throughout all new and existing buildings and structures where required in 5.7.3.2 through 5.7.3.9. 30 Sep 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? Fire department inlet connection is not available but outlet connection (pillar hydrant) is provided. Outlet connections match fire service and civil defense hose thread standard. Connections are clearly identifiable for the fire protection system. Photograph: Only outlet connection (pillar hydrant) is available in the premises. Install fire department connections where required and in compliance with the Standard. Fire department (Siamese) inlet connections shall be provided to allow fire department pumper equipment to supplement the fire protection systems. Connections shall match the Fire Service and Civil Defense hose thread standard. 24 Dec 2014 Alliance Standard Part 5 Section 5.5.4 Fire Department Connections Fire extinguishers are inspected, tested, and maintained as required. The Alliance for Worker Safety Page 8/18
08 Jun 2014 Extinguishers are inspected monthly by the factory's staff, but no document was found in support of i) annual maintenance of extinguishers by a servicing agent and ii) annual testing of nozzle of CO2 extinguisher. These are required as per NFPA 10. Document Review: No document was found in support of i) annual maintenance of extinguishers by a servicing agent and ii) annual testing of nozzle of CO2 extinguisher. Fire extinguishers are to be inspected, tested, and maintained in accordance with NFPA 10 requirements. 24 Dec 2014 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? Non-Compliance Level: 1 An automatic fire alarm and detection system is available in the factory, but currently there is no monitoring company in. Fire service and civil defense is not also capable of monitoring fire alarm and detection systems of the factories. Visual Assessment: Automatic fire alarm and detection system is available in the factory. Arrange for direct connection of the fire alarm system to a central monitoring station or Fire Service and Civil Defense as per Alliance Standard. Until that time that monitoring can be set up, arrange a monitoring system using factory's own central detection system and personnel. A person shall be assigned to contact the fire department in the event of fire alarm activation. An annunciator shall be located in a constantly attended location (such as a fire control room) to alert this person. 24 Dec 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 Inspection, maintenance, and testing procedures of the standpipe and hose are not documented and up to date. The Alliance for Worker Safety Page 9/18
08 Jun 2014 Document Review: No document found regarding inspection, maintenance and testing procedures of the standpipe and hose system. Establish an inspection, maintenance, and testing program for the standpipe and hose system. Program must comply with the requirements of NFPA 25 Chapter 6 Table 6.1.1.2. 23 Dec 2014 Reference NFPA 25 Chapter 6 Standpipe and Hose Systems Table 6.1.1.2 Are inspection, maintenance, and testing procedures of the fire pump documented and up to date? Low Inspection, maintenance, and testing procedures of the fire pump is not documented. Document Review: No document found. Establish an inspection, maintenance, and testing program for the fire pump. Program must comply with NFPA 25. 23 Dec 2014 Reference NFPA 25 Chapter 8 Fire Pumps Is signage for the standpipe system installed at required locations and on required components? Low Non-Compliance Level: 1 Signage for the existing standpipe system is installed at different locations but not compliant with the requirements of NFPA 14 Chapter 6. Photograph: Signage for standpipe installed at some locations. Install required identification signs at the required locations. Signage must comply with NFPA 14 Chapter 6. 19 Aug 2014 Reference NFPA 14 Chapter 6 Means of Egress The Alliance for Worker Safety Page 10/18
08 Jun 2014 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. Non-Compliance Level: 3 There are locking arrangements like hasps, locks, slide bolts at the exit doors but doors are not locked. This violates the Alliance Standard. Photograph: Collapsible gate is available at the main exit of the main building. Remove all hasps, locks, slide bolts, or other locking devices at the noted locations. 23 Jul 2014 Alliance Standards Part 6 Section 6.8 Doors and Gates Doors along the path of egress have a minimum width of 0.8 m (32 in) and have required ratings. Non-Compliance Level: 3 Out of a total of three stairways, only two stairways are provided with fire rated doors but no credible certificate was found. Another stairway is not provided with any door. Photograph: Door widths were sufficient but did not have required rating. Exits connecting three or fewer stories shall be enclosed with a minimum 1-hr fire-resistance rating. Provide fire door of required rating to access the corridor. 01 Oct 2014 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. Non-Compliance Level: 3 Some of the doors in means of egress are rolling shutter, sliding steel type and some doors are not provided. This violates Alliance Standard. Photograph: All doors in the means of egress are not side-hinged swinging type. The Alliance for Worker Safety Page 11/18
08 Jun 2014 Replace all non-compliant doors and frames in the means of egress with doors that are listed, approved, automatic-closing, side-swinging, fire rated doors in compatible fire rated frames with latching panic hardware. 01 Oct 2014 Alliance Standards Part 6 Section 6.8 Doors and Gates 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. There is a 4 ft wide egress court with an unprotected opening from production building which serves the exit discharge of the stair-3. The exit discharge of stair-2 and internal stair is exterior to the building and enters in dining shed. The exit discharge of stair-1 is directly exterior to the building. Photograph: the exit discharge of stair-1 is directly to outside of the building. The discharge of stair-2 and internal stair is exterior to the building and then re enter in dining shed. The exit discharge of stair-3 passes through egress court for final discharge. Egress courts less than 3050 mm (10 ft) in width (as measured from the building and the adjacent property line) shall be provided with walls having a 1 hr fire resistance rated construction for a distance of 3050 mm (10 ft) above the floor of the court in accordance to Alliance standard 6.17.2. The exit access corridor of dining shed with occupant load greater than 30 has to be protected with 1 hour fire resistance rating. 01 Oct 2014 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. The exit discharge of the internal stair and stair-2 is directly outside of the building and then re-enters into the dining shed. Then, this exit discharge is passed through a non-rated passageway. The Alliance for Worker Safety Page 12/18
08 Jun 2014 Photograph: A non-rated passageway with a occupant load greater than 30 was found in the non-sprinklered dining shed. The exit access corridor of dining shed with occupant load greater than 30 has to be protected with 1 hour fire resistance rating. 30 Sep 2014 Alliance Standard Part 6 Section 6.3 and Part 4 Section 4.5. Does not apply if an automatic sprinkler system is installed throughout the building. 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. There are two external steel staircases at the main building, but these staircases are not separated from the production building which has an opening within 10 feet of its span. As as per Alliance Standard, exterior exit staircases shall be separated from the building with the rating requirements. The rating of the exterior wall shall extend 3.05 m (10 ft) beyond the ends of the stair structure. Photograph: The external steel staircases are not separated with required rating from the main building. Provide a fire-resistive rated assembly between the exterior exit stairs and the building up to 10 ft beyond the end of the stair to achieve the required separation. The rated assembly should be approved and designed by a qualified fire protection engineer. 01 Oct 2014 Alliance Standard Part 6 Section 6.3.1.2. Three stories or less 1-hr rating. Four stories of more 2-hr rating Occupant loads are posted for every assembly and production floor in a conspicuous space near the main point of egress. Occupant loads are not posted in a conspicuous space near the main exits or exit access doorways as per Alliance Standard. Visual Assessment: Occupant loads are not posted for assembly and production floor in a conspicuous space near the main point of egress. Post the occupant load for every assembly and production floor in a facility in a conspicuous space near the main exit or exit access doorway for the space. The Alliance for Worker Safety Page 13/18
08 Jun 2014 06 Aug 2014 Alliance Standards Part 6 Section 6.4.4 Posting of Occupant Load All paths of egress are provided with compliant means of illumination. Aisles, exit doors, and stairways are provided with the required means of illumination, but all the paths of egress are not illuminated as required in accordance with the Alliance Standard. Photograph: All the paths of egress are not provided with proper illumination. Install appropriate means of illumination at the noted locations. The means of egress paths shall be illuminated at all times the building is occupied. Illumination shall be a minimum of 10 lux for all corridors, exit doors, and stairways. Aisles shall be provided with a minimum 2.5 lux. 24 Dec 2014 Alliance Standards Part 6 Section 6.7 Egress Illumination and Part 10 Section 10.12 Illumination of Exit Signs and Means Of Escape 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. Record of verifying emergency power for means of egress illumination was not found as required in accordance with Alliance Standards. Document Review: No document was found regarding functional testing of battery powered signs. Develop a testing and maintenance program that ensures the operation of all exist 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. 06 Aug 2014 Alliance Standards Part 10 Section 10.12 Illumination of Exit Signs and Means Of Escape Lighting The Alliance for Worker Safety Page 14/18
08 Jun 2014 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. Illuminated exit signs are placed at entrances to exits, but along the path 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. This condition fails to satisfy the requirements stated in Alliance Standards. Photograph: Along the path of egress additional exit signs or directional signs are not provided. Install illuminated exit signs 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. 24 Dec 2014 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. No record of testing emergency power for exit signs was found as per Alliance Standard. Document Review: No document found. Develop a testing and maintenance program that ensures the emergency power for exit signs is tested at least once per year. If battery operated signs are used, these signs are tested on a monthly basis. Functional testing of battery powered signs is provided for a minimum 90 min once per year. 06 Aug 2014 Alliance Standard Part 10 Section 10.12 Illumination of Exit Signs and Means Of Escape. 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.). The Alliance for Worker Safety Page 15/18
08 Jun 2014 One stairway has handrails on both sides which are mounted at 44 inches. The other two stairways in the building only have handrails on one side and are mounted at 27 inches and 30 inches. Photograph: Handrails were not provided on both sides of each stairway. Provide handrails on both sides of each stairway. Provide intermediate handrail when the stair width exceeds 2.2m (87 inch). Provide handrail of height between the range 865 mm (34 in.) and 965 mm (38 in.). 24 Dec 2014 Alliance Standard Part 6 Section 6.9 Stairs and 6.12 Handrails and Guards Fire Safety Programs Are the required number of people trained and certified in fire fighting, first aid, and rescue training by the appropriate authority. Record kept by the factory shows that 40 workers had been trained by proper authority but no certificate had been issued. Document Review: No certificate found. Train and certify at least 339 numbers of workers which is 25% of total occupant in fire fighting, first aid and rescue by the proper authority. 24 Dec 2014 Alliance Standard Part 13 Human Element Programs An emergency evacuation plan has been developed and communicated to all employees. Workers are aware of the evacuation procedure upon sounding of the alarm, however no procedure defining the evacuation process was available. Visual Assessment: Document as evacuation plan was not found. Develop an emergency evacuation plan which includes duties and responsibilities of various people/groups, interfacing between groups and fire brigade, headcount and identification of trapped victims, physically disabled people and their rescue, etc. and all components required by the Alliance Standards and communicate the plan to all employees. The evacuation plan shall include provisions to assist physically disabled persons. A list of all employees with physical disabilities shall be kept by the Fire Service Director. The Alliance for Worker Safety Page 16/18
08 Jun 2014 10 Aug 2014 Alliance Standards Part 13 Section 13.1 Fire Safety Director Fire Department pre-planning has been completed. Low Fire department pre-planning was not found. Document Review: Fire Department pre-planning has not been completed. Complete fire department pre-planning activities with the local Fire Service and Civil Defense. 06 Aug 2014 Alliance Standards Part 13 Section 13.1 Fire Safety Director A hot-work permit program has been established. Low A hot-work permit program is not established. It is required as per Alliance Standards. However, hot-work is not going on in the factory right now. Document Review: No document found. Develop a hot-work permit program. The program must comply with the requirements of NFPA 51B. In general, this program should address the process of request and approval of authorities, necessary checks prior to approval, standby fire watch and fire fighting equipment, sounding of alarm procedure, duration and expiry of permit and re-approval procedure, etc. 24 Dec 2014 Alliance Standards Part 13 Section 13.4 Hot Work Permit and NFPA 51B Are all applicable permits up to date including Fire License & Boiler License. Low Electrician license is not available. Factory license, fire licenses, and trade license are up-to-date. Boiler license, and boiler operator license are available. Document Review: Electrician license not available. The Alliance for Worker Safety Page 17/18
08 Jun 2014 Apply to Biddyut Paridaptor for electrician license. 06 Aug 2014 Alliance Standard Part 13 Human Element Programs The Alliance for Worker Safety Page 18/18