From Inspections to Remediation: Creating Factory Corrective Action Plans

Having completed inspections for the Alliance’s 650+ factories, we are now focused on remediating all of the open findings to make the buildings safer for workers. Each inspection results in three factory reports – structural, fire, and electrical – that can be found on our website’s inspection report page. We also post draft Corrective Action Plans (CAPs), which consolidate the open findings listed in the reports and allow the Alliance, the individual member companies, and Qualified Assessment Firms (QAFs) to work with factory owners and management representatives on detailed plans of action for each finding. Each CAP includes information on the proposed action, the person(s) responsible for remediating the open finding, and an estimated date of completion. 

AfterCAP Meeting Pics_Page_1_Image_0001 the factory submits a proposed CAP, we schedule an in-person CAP meeting for factory representatives (including any technical staff) to meet with the Alliance team, Alliance member companies, and QAF engineers. The main goal of the CAP meeting is to provide the factory with a clear plan on how to proceed with remediation. During the meeting, we review the proposed CAP in detail, discuss their plan (and different options) for addressing non-compliance, and answer any questions they have. We also provide guidance on the required qualifications of external consultants who can be engaged for remediation services, as well as information for selecting the right equipment. For example, our team has developed guidelines for understanding the certification and labeling of fire doors as many factories have not purchased approved product.

CAPs are developed through the following process:

  1. QAF completes assessments in structural, fire, and electrical safety
  2. Inspection reports are quality checked and finalized by Alliance experts
  3. Reports are submitted to the factory along with a CAP that lists all open findings
  4. The factory must issue any concerns or changes to the report / CAP within 7 days
  5. The factory must submit its proposed CAP to the QAF within 14 days
  6. CAP reviewed and approved by QAF
  7. CAP meeting takes place at the Alliance office and the CAP is finalized and approved by the Alliance.

After completing nearly 200 CAP meetings so far, we’re finding that they provide important opportunities to:

  • Thoroughly review remediation requirements before factories spend money. A number of factories have started – and even completed – their Detailed Engineering Analyses (DEA) prior to the CAP meeting. During CAP meetings, we have found that some tests were not properly done, and that factories had not selected credible consultants. Although we appreciate factories being proactive, we advise factories to (1) avoid beginning any major work and (2) bring external consultants / engineers they are considering working with to the CAP meetings to review requirements.
  • Build factory knowledge. One factory was required to prepare as-built drawings and a load analysis for a newly constructed office on the mezzanine floor of the existing production building. Factory management had engineers prepare a drawing of the mezzanine floor (with office), and thought that was sufficient. However, a load analysis was required to evaluate the impact of the extra load (of the office) on two columns. During the CAP meeting, I drew a sketch of the present conditions and explained the impact of extra loading – the factory representatives then understood why an additional load analysis was necessary and planned for a qualified structural engineer to conduct one.

CAP meetings are typically 3 – 4 hours long, but one of our longest CAP meetings took 7 hours! In this case, the factory owner was not a technical person but he decided to attend the CAP meeting on his own (without his technical staff), as he wanted to thoroughly understand all of the non-compliances, remediation expectations, and the Alliance guidelines. As he will need to engage a structural engineering firm to assist with remediation, he wants to be prepared to personally ensure that remediation is done properly, and we’re always happy to spend extra time with factory representatives for this purpose.

At the end of the meetings, factories leave with a signed and approved final CAP, which includes official deadline dates by which open findings must be closed. Our remediation team then follows up to monitor progress towards those deadlines via phone, email, and in-person verification visits. This  process will take many months, and we look forward to sharing more about remediation in the future.

 

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