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EQUIVALENT INITIAL STRUCTURAL SAFETY ASSESSMENT A-23, 24, 25, 26 BSCIC, Industrial Estate, Kalurghat, Chittagong The Alliance for Bangladesh Worker Safety Page 1/15

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 2/15

GENERAL INFORMATION General Information Country: Province: City: Bangladesh Chittagong Chittagong Zip Code: 4212 Audit Duration: Re-Audit: Re-Audit After 0 Months Draft Report Date : 06-28-2014 Final Report Date : 06-30-2014 Are all Action Items From Previous Assessment Completed?: Buildings in Complex : Number of Building Levels (Stories) : Approximate Building Area (SF) : Date of Building Construction : Date of Last Building Renovation/Addition : Is the Building mixed use?: Ancillary Structures in Complex : Number of Ancillary Levels (Stories) : N/A 3 Main Buildings 1 Ancillary Building 1) Six Story RCC main production building-1: 6 (Grade + 5) 2) Ten Story RCC main production building: 10 (Grade + 9) 3) Six Story RCC main production building-2: 6 (Grade + 5 + Occupied Roof) 477919.00 sf 1) Six Story RCC main production building-1: Finished in 2004, 2) Six Story RCC main production building-2: Finished in 2005, 3) Ten Story RCC main production building: Finished in 2006, 4) Single story prefab ETP shed: Finished in 2005. 1) Six story RCC main production building-1: Renovation ongoing No 1) Single story prefab ETP shed. 1 (Grade) The Alliance for Bangladesh Worker Safety Page 3/15

Approximate Ancillary Structures Area (SF) : 7360 sf Number of Occupants : 2353 Exterior Facade Description : Structural System Description : Six & Ten Story RCC main production building-a,b,c&d: The buildings are RCC framed structures with infilled masonry walls. The main door of the building is a glass door and the windows are of sliding glass type. Building is a Moment Resisting Frame with monolithic beam slab. Foundation is combined footing with wooden pile foundation and pile Foundation. The Alliance for Bangladesh Worker Safety Page 4/15

ASSESSMENT FINDINGS Structural System Design Are the available FoS for the columns adequate based on Preliminary calculation? High Building A: Considering minimum concrete compressive strength: 2045 psi; Live Load: 42 psf; FoS of the columns are inadequate based on preliminary calculations: Central Column: 1.65, Corner Column: 1.55, Edge Column: 1.40 Building B: Consid Uploaded Document: Uploaded Document Engage a qualified structural engineer to perform a detailed assessment within 6 weeks. The assessment should include core testing to assess concrete strength. 30 Jul 2014 Provide results of preliminary calculations in space provided. a) column capacity; FoS > 1.86 - Safe b) column capacity; FoS 1.5-1.86 - Needs Evaluation c) Column capacity; FoS 1.25-1.5 - Needs Evaluation d) Column capacity; FoS <1.25 - Unsafe In case of a critically low FoS (<1.25), consider Immediate Escalation Protocol Can documentation be provided that the building is compliant with the requirements for wind loading and storm surge loadings as detailed in BNBC Part 6 Section 1.5.3? Building A, B, C, D: There is no clear information available in the design documents to understand the consideration of storm surge and wind loading. Document Review: Document Review shows that there is no clear information available in the design documents to understand the consideration of storm surge and wind loading. Engage a qualified structural engineer to confirm satisfactory structural performance of the buildings under wind loading and storm surge. 2006 BNBC Part 6 Section 1.5. Compliance may be waived if the The Alliance for Bangladesh Worker Safety Page 5/15

Owner provides satisfactory evidence of a cyclone operations plan that includes full evacuation of the factory in advance of any approaching cyclone" Have provisions been made in floors or decks for a concentrated load (such as heavy equipment, water tanks, stored materials, etc) applied at a location wherever this load acting upon an otherwise unloaded floor would produce stresses greater than those caused by a uniform load? 1) Six Story RCC main production building A: There are 2 water tanks, each having a capacity of 2 tons of water storage. There is no analytical information on the provision of these tanks in the design. 2) Six Story RCC main production building B: Ther Visual Assessment: Visual Assessment show that, 1) Six Story RCC main production building A Engage a qualified structural engineer to confirm and document that provisions have been made to accommodate these water tanks. If provisions have not been made, have a qualified structural engineer develop a remediation plan. Alliance Standard Part 8 Section 8.13 and 8.14 Are credible structural design documents available for review and kept on site? Building A, B, C, D: A set of as-built structural design documents & soil test reports are available for review but do not match measurements taken onsite. The design report is also not available, and is required as per BNBC 2006 clause 1.9.1.1. Document Review: Document Review of all of the buildings reveals that a set of as-built structural design documents & soil test reports are available for review but do not match measurements taken onsite. The design report is also not available, and is re Have a qualified structural engineer prepare credible as-built documents based on the requirements of Part 8 Section 8.19 of the Alliance Standard. Alliance Standard Part 8 Section 8.19 Required Structural Documentation for New and Existing Factories Can credible structural documentation indicating general conformance with 2006 BNBC or other comparable applicable international model building code The Alliance for Bangladesh Worker Safety Page 6/15

be produced? All of the buildings were designed and constructed before 2006. No documentation indicating general conformance with an applicable code was found. Document Review: Document review shows that all of the buildings were designed and constructed before 2006, however documentation does not indicate general conformance with any applicable code. Engage a qualified structural engineer to develop the required documents to confirm the structural integrity of the buildings. Documents must comply with Alliance Standard Part 8 Section 8.19 and 8.20. Reference Alliance Standards Part 8 Section 8.2 Structural Integrity of Existing Buildings If the structure has been previously expanded, was the structural impact on the entire structure analytically evaluated and confirmed by a qualified structural engineer. 1) Six Story RCC main production building A: There is no evidence of previous expansion of the structure. 2) Six Story RCC main production building B: There has been horizontal & vertical expansion where 1 floor is added and at north side & east side, Document Review: Document Review supported by visual inspection reveals that there is no information on the structural impact of the new construction on the existing structures., Visual Assessment, Document Review: Document Review supported by visual inspection reveals that there is no information on the structural impact of the new construction on the existing structures., Visual Assessment Have a qualified structural engineer complete an analytical evaluation of the structural impact of the addition. Reference Alliance Standards Part 8 Section 8.1 Applicability of Building Code. The Alliance for Bangladesh Worker Safety Page 7/15

Where density of operations, storage of materials, or equipment weights require live load capacity in excess of 2.0 kn/m2 (42 psf), do the design documents confirm that the required load capacity exists? Or has the load capacity been analytically confirmed and certified by an Alliance-qualified structural engineer? 1) Six Story RCC main production building A: The density of operation at the 4th floor exceeds 42 psf. The estimated live load of that floor is about 60 psf, but there is no analytical confirmation of strength that can support this load. 2) The density Visual Assessment: Visual Assessment show that Have a qualified structural engineer confirm that capacity to support the load is available. Load Plans complying with Alliance Standard Part 8 Section 8.20.4.3 should also be developed Alliance Standards Part 8 Section 8.15 Minimum Floor Design Loads Are Certificates of Occupancy available for review? Low Non-Compliance Level: 1 The factory has not obtained the Certificate of Occupancy from the authority. Document Review: Document review shows that the factory has not obtained the Certificate of Occupancy from the authority. Apply for issuance of Certificate of Occupancy and pursue the matter to obtain the same. Alliance Standard Part 8 Section 8.3 Preliminary Structural Assessment Structural System Construction Are the performance of key structural elements such as columns, slender columns, flat plates and transfer structures satisfactory? High Non-Compliance Level: Some hair line cracks have been found on beam surface at 8th and 9th floor of building-c. The Alliance for Bangladesh Worker Safety Page 8/15

Alliance Standard Part 8 Section 8.3.3 If yes, have the structural members constructed with MCAC been investigated by an appropriate program of in-situ testing and representative destructive testing or core samples? The structural members constructed with MCAC have not been investigated by an appropriate program of in-situ testing and representative destructive testing or core samples. The column stress calculated taking into account the strength of concrete shows ov Visual Assessment: Fos Calculation shows that the column constructed of MCAC is overstressed. The FoS is under the acceptable limit (1.86). Conduct destructive testing or core samples under the guidance of qualified engineer. Reference Alliance Standards Part 7 Building Materials Section 7.2 Masonrychip aggregate concrete (MCAC) Are any structural elements constructed with MCAC exposed to rainfall or other sources of water sealed with a protective coating to prevent water intrusion? 1) Six Story RCC main production building-a, B & D: The roof of the building is of MCAC aggregate but no protective sealing is provided. 2) Ten Story RCC main production building-c: There is no exposed MCAC in the building. Exposed portion is made of s Visual Assessment: A visual inspection showa that Provide a protective coating at the structural elements constructed with MCAC exposed to rainfall or other sources of water. Have protective coating approved by the Alliance or a qualified structural engineer. Alternatively, provide a 2% slope on the expo The Alliance for Bangladesh Worker Safety Page 9/15

Alliance Standards Part 7 Building Materials Section 7.2 Masonry-chip aggregate concrete (MCAC). Are structural steel members free of corrosion, physical damage or other types of deterioration? There are structural steel members in all buildings. Corrosion has been found in these steel members. Visual Assessment: A visual assessment shows that there are structural steel members in all buildings. Corrosion has been found in these steel members. Complete further testing on areas of deterioration in order to understand the level of corrosion and weakening of the member and have a qualified structural engineer develop a remediation plan. Alliance Standard Part 8 Section 8.26 Have all areas of needed maintenance, including areas with efflorescence, dampness, standing water on rooftops, and corrosion been addressed. Building A: Standing water on roof and dampness at fifth floor were observed. Building B: Standing water on roof and dampness at second floor were observed. Also, dampness at expansion joint was observed at fourth floor. Building C: Standing water o Visual Assessment: Visually confirmed. Under guidance from a qualified structural engineer, address all areas of needed maintenance by correcting the identified issues. Alliance Standard Part 8 Section 8.26 Durability and Maintenance The Alliance for Bangladesh Worker Safety Page 10/15

Are all non-structural elements suspended from, attached to, or resting atop the structure adequately anchored and braced to resist earthquake forces? All of the buildings have some racks which are not braced or anchored properly to resist earthquake forces. Also there are plastic water tanks on the roof of all of the buildings which are not braced for earthquake forces. Visual Assessment: Visual inspection shows that all of the building have some racks which are not braced or anchored properly to resist earthquake forces. Also, there are plastic water tanks on the roof of all of the buildings which are not braced for ear Adequately anchor and brace all non-structural elements to resist earthquake forces to comply with the BNBC and Alliance Standard. Alliance Standards Part 8 Section 8.18 Seismic Bracing of Key Non-Structural Elements and 2006 BNBC Part 6 The Alliance for Bangladesh Worker Safety Page 11/15

If the building is currently being renovated or expanded, are the Construction Practices and Safety requirements of Section 9 being followed? 1) Six Story RCC main production building A, C & D: No renovation or expansion work is ongoing. 2) Six Story RCC main production building B: Building B is being extended Horizontally & vertically. However, the safety requirements are not adequately Visual Assessment: Visual observation shows that, 1) Six Story RCC main production building A, C & D The management should ensure that the construction practices and safety being adhered to as per BNBC or standard. Alliance Standard Part 9 Construction Practices and Safety. Is expansion joint material free from cracking and other forms of deterioration? Low 1) Six Story RCC main production building A: There are two expansion joints which are filled with mortar. This will make the expansion joints ineffective. 2) Six Story RCC main production building B: There is one expansion joint which is filled with mo Visual Assessment: Visually confirmed. Remove the blockages from the existing expansion joints. A qualified structural engineer should be involved for maintenance of expansion joints. Alliance Standard Part 8 Section 8.26 Durability and Maintenance Is the building free of active signs of water intrusion or ponding due to lack of performance of the façade system? Low The Alliance for Bangladesh Worker Safety Page 12/15

Building A: Dampness at 5th floor due to water ingress through exterior facade. Building B: Dampness at 2nd floor due to water ingress through exterior facade. Building D: Dampness at dining shed due to water ingress through exterior facade. Visual Assessment: Visual inspection shows several areas of dampness due to lack of performance of the facade system. Repair the exterior façade system to prevent water intrusion. 31 Oct 2014 Alliance Standard Part 8 Section 8.26 Durability and Maintenance Structural Safety Programs Are floor loads in compliance with posted plans? Building A, B, C, D: Load plans have been prepared, but are not in compliance with the Alliance Standard. Visual Assessment: Document review shows that Have a qualified structural engineer develop Floor Loading Plans per the requirements of Part 8 Section 8.20.5.3. Alliance Standard Part 8 Section 8.10 Floor Loading Plans (Load Plans). Is a program in place to ensure that the live loads for which a floor or roof is or has been designed will not be exceeded? All buildings: There are no programs that will ensure that the designated load in each floor will not be exceeded. Document Review: All buildings Develop a program to ensure that all live loads for which a floor or roof has been designed for will not be exceeded. The designated Load Manager shall oversee this program and ensure it is enforced. The Alliance for Bangladesh Worker Safety Page 13/15

Alliance Standard Part 13 Section 13.7 and Part 8 Section 8.9. Have Load Plans been prepared for each floor documenting the actual maximum operational loading that is intended and/or allowable on each floor. Low Building A, B, C, D: Load plans have been prepared, but are not in compliance with the Alliance Standard. Document Review: Document review shows that, Building A, B, C, D Have a qualified structural engineer develop Floor Loading Plans per the requirements of Part 8 Section 8.20.5.3. Alliance Standard Part 8 Section 8.10 Floor Loading Plans (Load Plans) Are Floor Load Plans posted as required? Low Building A, B, C, D: Load plans have been prepared, but are not in compliance with the Alliance Standard. Document Review: Document review shows that, Building A, B, C, D Have a qualified structural engineer develop Floor Loading Plans per the requirements of Part 8 Section 8.20.5.3. Alliance Standard Part 8 Section 8.20.5.3 Are areas used for storage of work materials and work products, clearly marked to indicate the acceptable loading limits as described in the Load Plan for that floor? Low All buildings: Load plans have been prepared, but are not in compliance with the Alliance Standard. There are no markings on the floor to designate spaces and height for storage of work materials. Visual Assessment: Visual assessment shows that, for all buildings, load plans have been prepared, but are not in compliance with the Alliance Standard. There are no markings on the floor to designate spaces and height for storage The Alliance for Bangladesh Worker Safety Page 14/15

of work materials. Provide signage or the appropriate markings at all areas used for storage to indicate the acceptable loading limits detailed in the Load Plan. Alliance Standard Part 8 Section 8.11 Floor Load Markings The Alliance for Bangladesh Worker Safety Page 15/15