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EQUIVALENT INITIAL FIRE SAFETY ASSESSMENT Factory 191-192 Baizid Bostami Road, Nasirabad Industrial Area, Chittagong 24 May 2014 The Alliance for Bangladesh Worker Safety Page 1/13

24 May 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 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 2/13

24 May 2014 GENERAL INFORMATION General Information Factory Country: Province: City: Bangladesh Chittagong Chittagong Zip Code: 4210 Audit Duration: Re-Audit: 1 Days Re-Audit After 0 Months Draft Report 05-29-2014 Final Report 06-24-2014 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 N/A There are 11 buildings in the factory premises out of which four are main production buildings and seven are ancillary buildings. The buildings are named as: 1) Two story R.C.C. Building-A, 2) Three story R.C.C. Building-B, 3) Single story packaging shed, 4) Four story new packaging building, 5) Five story head office building, 6) Three story warehouse building, 7) Single story thread production Shed, 8) Single story utility Shed, 9) Single story storage Shed, 10) Single story packaging store shed, 11) Single story boiler & store shed. Owned Information provided below as per following format: est occupied floor level [Height up to roof], Stories above grade, Stories below grade, Occupied level. 1) Building-A: 3.45 m or 11.33 ft [6.45 m or 21.167 ft], 2, 0, 2. 2) Building-B: 6.45 m or 21.167 ft [9.45 m or 31.00 ft], 3, 0, 3. 3) Single story packaging shed: 76 cm or 2.5 ft above grade [10.25 m or 33.63 ft], 1, 0, 1. 4) New packaging building: 9.15 m or 30 ft [12.15 m or 40 ft], 4, 0, 4. 5) Head office building: 11.72 m or 38.45 ft [14.02 m or 46 ft], 5, 0, 5. 6) Warehouse building: 8.94 m or 29.33 ft [11.9 m or 39 ft], 3, 0, 3. 7) Thread production Shed: 30 cm or 1 ft above grade [4.24 m or 13.9167 ft], 1, 0, 1. 8) Utility Shed: 30 cm or 1 ft above grade [3.65 m or 12 ft], 1, 0, 1. 9) Storage Shed: 30 cm or 1 ft above grade [4.57 m or 15 ft], 1, 0, 1. 10) Packaging store shed: 30 cm or 1 ft above grade [6.1 m or 20 ft], 1, 0, 1. 11) Boiler & store shed: 30 cm or 1 ft above grade [7.63 m or 25 ft], 1, 0, 1. Total area of all buildings in the factory premises: 170269 sft. Building wise breakdown as follows: 1) Two story R.C.C. Building-A: 6345 sft (Ground floor: 2880 sft, 1st floor: 3465 sft), 2) Three story R.C.C. Building-B: 28500 sft (Ground floor: 9500 sft, 1st floor: 9500 sft, 2nd floor:9500 sft), 3) Single story packaging shed: 27710 sft, 4) Four story new packaging building: 12716 sft (Ground floor:2112 sft, 1st floor: 4972 sft, 2nd floor: 2816 sft, 3rd floor: 2816 sft), 5) Five story head office building: 22498 sft (Ground floor: 5050 sft, 1st floor: 4912 sft, 2nd floor: 4912 sft, 3rd floor: 4912 sft, 4th floor: 2712 sft), 6) Three story warehouse building: 31360 sft (Ground floor: 10080 sft, 1st floor: 10640 sft, 2nd floor: 10640 sft), 7) Single story thread production Shed: 12960 sft, 8) Single story utility Shed: 4480 sft, 9) Single story storage Shed: 2250 sft, 10) Single story packaging store shed: 13550 sft, 11) Single story boiler & store shed: 7900 sft. Factory personnel informed the date of construction as follows: Started in 1993 and finished in 1995 (All buildings). Factory personnel informed the date of last building renovation or addition as follows: 1) Five story head office The Alliance for Bangladesh Worker Safety Page 3/13

24 May 2014 Renovation/Addition: Ancillary Structures in Complex: Approximate Ancillary Structures Area (SF): building: One stair is under construction. 1) Two story R.C.C. Building-A, 2) Four story new packaging building, 3) Five story head office building, 4) Single story utility Shed, 5) Single story storage Shed, 6) Single story packaging store shed, 7) Single story boiler & store shed. 1) Two story R.C.C. Building-A: 6345 sft (Ground floor: 2880 sft, 1st floor: 3465 sft), 2) Four story new packaging building: 12716 sft (Ground floor:2112 sft, 1st floor: 4972 sft, 2nd floor: 2816 sft, 3rd floor: 2816 sft), 3) Five story head office building: 22498 sft (Ground floor: 5050 sft, 1st floor: 4912 sft, 2nd floor: 4912 sft, 3rd floor: 4912 sft, 4th floor: 2712 sft), 4) Single story utility Shed: 4480 sft, 5) Single story storage Shed: 2250 sft, 6) Single story packaging store shed: 13550 sft, 7) Single story boiler & store shed: 7900 sft. Number of Occupants: Total no. of occupant: 525. The breakdown of occupant load is as follows: 1) Two story R.C.C. Building-A: 33 (Ground floor: 2, 1st floor: 31), 2) Three story R.C.C. Building-B: 26 (Ground floor: 22, 1st floor: 2, 2nd floor: 2), 3) Single story packaging shed: 100, 4) Four story new packaging building: 66 (Ground floor: 50, 1st floor: 10, 2nd floor: 4, 3rd floor: 2), 5) Five story head office building: 85 (Ground floor: 5, 1st floor: 40, 2nd floor: 14, 3rd floor: 24, 4th floor: 2), 6) Three story warehouse building: 97 (Ground floor: 2, 1st floor: 25, 2nd floor: 70), 7) Single story thread production Shed: 94, 8) Single story utility Shed: 3, 9) Single story storage Shed: 2, 10) Single story packaging store shed: 7, 11) Single story boiler & store shed: 12. Number of Ancillary Levels (Stories): Occupancy Type: Construction Type: Height of est Occupied Floor Level Above Grade: Information provided below as per following format: est occupied floor level [Height up to roof], Stories above grade, Stories below grade, Occupied level. 1) Two story R.C.C. Building-A: 3.45 m or 11.33 ft [6.45 m or 21.167 ft], 2, 0, 2. 2) Four story new packaging building: 9.15 m or 30 ft [12.15 m or 40 ft], 4, 0, 4. 3) Five story head office building: 11.72 m or 38.45 ft [14.02 m or 46 ft], 5, 0, 5. 4) Single story utility Shed: 30 cm or 1 ft above grade [3.65 m or 12 ft], 1, 0, 1. 5) Single story storage Shed: 30 cm or 1 ft above grade [4.57 m or 15 ft], 1, 0, 1. 6) Single story packaging store shed: 30 cm or 1 ft above grade [6.1 m or 20 ft], 1, 0, 1. 7) Single story boiler & store shed: 30 cm or 1 ft above grade [7.63 m or 25 ft], 1, 0, 1. 1) Two story R.C.C. Building-A: [Ground floor: F1 (office), J2 (Chemical Store), H2 (storage), 1st floor: F1 (office & lab)], 2) Three story R.C.C. Building-B: [Ground floor: G2 (cotton Production), K1 (compressor), 1st floor: H2 (Storage), 2nd floor: E4 (Dining, capacity: 50), H2 (Storage)], 3) Single story packaging shed: G2 (Packaging production), 4) Four story new packaging building: [Ground floor: F1 (office), 1st floor: H2 (sub Storage)), G2 (Block making), 2nd floor: H2 (Storage), 3rd floor: H2 (Storage)], 1) Two story R.C.C. Building-A: Type 1, 2) Three story R.C.C. Building-B: Type 1, 3) Single story packaging shed: Non-rated, 4) Four story new packaging building: Type 1, 5) Five story head office building: [Ground floor to 3rd floor: Type 1, 4th floor: Non-rated (Only ceiling)], 6) Three story warehouse building: Type 1, 7) Single story thread production Shed: Non-rated, 8) Single story utility Shed: Non-rated, 9) Single story storage Shed: Non-rated, 10) Single story packaging store shed: Non-rated, 11) Single story boiler & store shed: Nonrated. 1) Two story R.C.C. Building-A: 3.45 m or 11.33 ft, 2) Three story R.C.C. Building-B: 6.45 m or 21.167 ft, 3) Single story packaging shed: 76 cm or 2.5 ft above grade, 4) Four story new packaging building: 9.15 m or 30 ft, 5) Five story head office building: 11.72 m or 38.45 ft, 6) Three story warehouse building: 8.94 m or 29.33 ft, 7) Single story thread production Shed: 30 cm or 1 ft above grade, 8) Single story utility Shed: 30 cm or 1 ft above grade, 9) Single story storage Shed: 30 cm or 1 ft above grade, 10) Single story packaging store shed: 30 cm or 1 ft above grade, 11) Single story boiler & store shed: 30 cm or 1 ft above grade. The Alliance for Bangladesh Worker Safety Page 4/13

24 May 2014 ASSESSMENT FINDINGS Fire Protection Construction Are exit enclosures provided with fire-resistive rated construction barriers? Non-Compliance Level: 3 There is one stair in the new packaging building. A glass window is provided in staircase with production. At ground floor level, the stairs open into packaging production area. There are 2 exit stairs in building-b and head office building. None of the stairs are fire rated and the stairs open into thread production area on ground floor. Photograph: Exit enclosures were not provided with required fire-resistive rated construction barriers. Provide 2 hr fire-resistive rated construction barriers at exit enclosures of 4 or more story buildings. Provide 1 hr fire-resistive rated construction barriers at exit enclosures of 3 or less story buildings. Consult a qualified fire protection engineer Reference Alliance Standards Part 4 Section 4.5 Separation Are openings and penetrations through rated walls and/or assemblies protected? The generator room has a direct opening to packaging store. The chemical store of the packaging store shed has a direct opening to packaging reel store and workshop. Boiler shed also has opening to reel store of warehouse ground floor. Such unprotected openings are not allowed according to Alliance Standards. Photograph: Numerous unprotected openings were found. Install fire rated doors and windows or fill in unprotected openings with fire resistive rated assemblies. Includes doors, windows, ducts, piping, etc. Reference Alliance Standards Part 4 Section 4.6 Opening Protectives and Section 4.7 Penetrations The Alliance for Bangladesh Worker Safety Page 5/13

24 May 2014 Are separations between hazards provided with fire-resistive rated construction barriers. Medium The generator room is kept without fire separation between packaging reel store and raw material store. Chemical store and dining area on 1st floor of warehouse building are separated by glass and aluminum partitions. Boiler room and packaging reel store are not separated by fire-resistive rated construction barriers. MS plate is used for separation above the wall. Chemical store and raw material store of building A is separated from the thread production area by steel door instead of fire rated door. Stores on 1st floor, 2nd floor and 3rd floor of new packaging building were separated by glass partition with packaging shed production. These different occupancies need to be fire separated according to Alliance Standards. Photograph: Occupancy separations are not fire rated. 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. Reference Alliance Standards Part 4 Section 4.5 Separation Fire Protection Systems Does the building have a Standpipe System? Height of the highest occupied level of the head office building is 11.72m (38.45 ft) which is more than 10 m (33 ft). A standpipe system needs to be installed throughout the building where the highest occupied floor is more than 10 m (33 ft) above grade as per Alliance Standard. One class-ii standpipe hose connection (40 mm) is installed on each floor of this building. There is no class-i standpipe hose connection (65 mm) in required stairs including occupied roof. There is no hydraulic design for the installed system. Photograph: Standpipe system was found in the building and water throw was measured 78 ft. Install a NFPA 14-compliant standpipe system at required locations designed by a qualified fire protection engineer. All standpipe system installations and hydraulic calculations shall be submitted for review by the Alliance prior to commencement of insta Does the building have a standpipe system installed where required. Alliance Standard Part 5 Section 5.4.2 The Alliance for Bangladesh Worker Safety Page 6/13

24 May 2014 Does the building have a fire pump? A fire pump is available, however it does not comply with the requirements of Alliance Standards and NFPA 20. Hydraulic calculation for installed standpipe system is not available. Photograph: A dedicated fire pump was noticed in the factory premises. Bring current pump up to standard or install a pump dedicated for fire fighting or fire protection following the requirements of NFPA 20. Fire pump installation is to be tested for final acceptance in presence of Alliance and a final inspection of the ins 10 Sep 2014 Alliance Standard Part 5 Fire Protection Systems Are fire department connections provided and clearly identified for the Fire Protection Systems? Medium Non-Compliance Level: 3 Fire department (Siamese) inlet and outlet connection are not provided to allow fire department pumper equipment to supplement the fire protection systems as per the Alliance Standard. Visual Assessment: No fire department connection was found. Provide fire department connection as required by Alliance Standard. 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 Signage for the available class II standpipe system is not installed. Visual Assessment: Signage for class II standpipe system was not found. The system is to be compliant with the requirements of NFPA 14. Install required identification signs at the noted locations. 09 Aug 2014 Reference NFPA 14 Chapter 6 Means of Egress The Alliance for Bangladesh Worker Safety Page 7/13

24 May 2014 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. Non-Compliance Level: 3 The external steel stairs of warehouse and building-b do not have a fire separation from the building beyond 10 feet of its span as required. Photograph: Exterior exit stairs are not fire separated from warehouse building and building-b. Close all openings across the span of the stair and 10 feet on each side from the ground level to roof or 10 ft above the topmost landing. Alliance Standard Part 6 Section 6.3.1.2. Three stories or less 1-hr rating. Four stories of more 2-hr rating The number of means of egress from any floor or story is not less than 2 except where a single exit is permitted or where a greater number is required. In the four story new packaging building there is only one exit, and in head office building there is a single exit provided on 3rd floor and 4th floor and another exit (stair) is under construction. This violates Alliance Standards. Visual Assessment: The number of emergency exit doors were counted. Provide a minimum of two code-compliant exit stairs for new packaging building and head office building. Alliance Standard Part 6 Section 6.6 Number of Means of Egress 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. There are steel sliding doors with locking arrangements on 1st floor and 2nd floor of warehouse building. This violates Alliance Standards. There are steel doors with locking arrangements on the 2nd floor of building-b, which is also a violation. Also, an electrical locking arrangement is found on the head office building exit door. Photograph: Locking devices were found at exit doors. Remove all hasps, locks, slide bolts, or other locking devices at the noted locations. 12 Jul 2014 The Alliance for Bangladesh Worker Safety Page 8/13

24 May 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. Door widths are more than 0.8 m, but 4 doors along the path of egress (i.e. doors leading to staircase) at 1st, 2nd, 3rd, and 4th floors of head office are not fire rated doors. Exit doors of northeast stair in warehouse building are not rated fire doors. There is no rated fire door at the stair of 4 story new packaging building. Stairs of building-b and building-a also need fire doors. Photograph: Steel sliding door found on the 2nd floor of the warehouse., Visual Assessment, Photograph: Steel sliding door found on the 2nd floor of the warehouse., Visual Assessment Provide 1 hr fire protective opening assemblies in 1 hr rated exit enclosures. Provide 1.5 hr fire protective opening assemblies in 2 hr rated exit enclosures. 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. Some of the doors in the means of egress are sliding type steel and glass doors. This violates Alliance Standards. Photograph: Some exit doors were not side-hinged swinging type. Replace all collapsible, sliding, roll-down gates and shutters in means of egresses with side-hinged swinging type doors of proper width and rating, that swing in the direction of egress. Alliance Standards Part 6 Section 6.8 Doors and Gates Interior exit stairways and ramps terminate at an exit discharge except where terminating at a rated exit passageway. Interior exit stairway terminates at a non-rated exit passageway. In the new packaging building, the stairs open into packaging production area on ground floor. In building-b, the stairs open into thread production area on ground floor. Photograph: The stair of new packaging building is found open to new packaging production area and stairs of building-b are found open into thread production area. Provide the exit stair with the required exit enclosure in accordance with Alliance standard 6.14 or provide an automatic sprinkler system on the discharging egress floor and arrange in accordance with 6.17.3. The Alliance for Bangladesh Worker Safety Page 9/13

24 May 2014 Alliance Standard Part 6 Section 6.14 Exit Enclosures 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. Non-Compliance Level: 1 In 4 story new packaging building there is one stair discharge on ground floor where production of paper package are ongoing. Also, in building-b there are 2 exit stairs. Among them one exit discharge is directly to the exterior of the building but the other one is open into the thread production area on ground floor. This violates the Alliance Standard. Photograph: In new packaging building and building-b an exit discharge does not meet the exterior of the building. Provide rated exit passageway i.e. protected path of egress from the exit enclosure to the public way. The rating of the exit passageway is to be equal to fire rating requirement of the exit that is being served and shall not be less than 1 hr fire-resist Alliance Standard Part 6 Section 6.17 Exit Discharge. See Section 16.7.2 and 16.7.3 for exceptions. Ramps do not have a running slope greater than 1 in 8 (12.5 percent) and have handrails on both sides of the ramp. Medium Non-Compliance Level: 3 The slope of the ramp is not greater than 1 in 8, but handrails are not provided on both sides, which violates the Alliance Standard. Photograph: Ramp without handrails was found on ground floor of warehouse building. Provide handrail on both sides of the ramp. Alliance Standard Part 6 Section 10 Ramps 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.). Medium Only exterior steel stairs have both side handrails, but other stairs only have handrails on only one side. It is not allowed as per Alliance Standards. The Alliance for Bangladesh Worker Safety Page 10/13

24 May 2014 Photograph: All the stairs have handrails on only one side, except the exterior steel stair. Provide handrails on both sides of each stairway. Provide handrail of height between the range 865 mm (34 in.) and 965 mm (38 in.). Alliance Standard Part 6 Section 6.9 Stairs and 6.12 Handrails and Guards All paths of egress are provided with compliant means of illumination. Medium Non-Compliance Level: 1 Exit doors on 1st floor of warehouse building and stairways of new packaging building and packaging production shed are not provided with 10 lux illumination as required. Visual Assessment: Aisles, exit doors and stairways were found insufficiently illuminated. 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 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 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. Medium Non-Compliance Level: 1 There were some exits available where they did not provide any exit sign. Mainly at 4-story new packaging building. And some exits have exit sign which have self-battery backup. Also, 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 requirements stated in Alliance Standards. Photograph: Exit sign was found at some entrances to exits but some exits available where they did not provide any exit sign. 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. Alliance Standard Part 6 Section 6.11 Exit Signs Fire Safety Programs Are the required number of people trained and certified in fire fighting, first aid, and rescue training by the appropriate authority. The Alliance for Bangladesh Worker Safety Page 11/13

24 May 2014 Non-Compliance Level: 1 Total occupant is 525. Record kept by the factory shows that 30 workers had been trained by proper authority but no certificate had been issued. Document Review: No certificate regarding fire training has been found. Train and certify at least 132 workers (25 percent of total occupant) in fire fighting, first aid and rescue by the proper authority. Alliance Standard Part 13 Human Element Programs Are all applicable permits up to date including Fire License & Boiler License. Low Fire licenses do not cover existing constructed area (licensed area-164,020 sq.ft. but existing constructed area-170,269 sq.ft.). Trade license, factory license, BERC certificate and boiler license, and electrical license are up-todate. Document Review: The following documents were provided by factory personnel Update the fire licenses from fire service and civil defense authority. 26 Jul 2014 Alliance Standard Part 13 Human Element Programs The Alliance for Bangladesh Worker Safety Page 12/13

24 May 2014 The Alliance for Bangladesh Worker Safety Page 13/13