Remediation Verification Visits: Tracking Factory Progress After Inspections Are Done

With all Alliance factories inspected, a common question we get is: how do you know factories are making the required safety improvements?  The Alliance’s 32-member remediation team is entirely focused on the answer to this question — in partnership with my team, I spend five days a week in factories to verify they are making progress.

584 of our factories have received approved CAPs and are now in the remediation phase of the Alliance program. Alliance factories have an average of 87 open findings listed in their CAPs.

After the inspection, factories rely on their approved Corrective Action Plans (CAP) for guidance on how to manage remediation (you can read more about the CAP development and approval process in my colleague Wahid’s blog post). Factories work with their internal engineering teams and/or external consultants to close the findings in order to improve the safety of their factories. These changes can be physical or organizational in nature, including:

  • Hiring new or managing current staff to cover duties required of a structural load manager or fire safety officer
  • Engaging firms to create design drawings for fire safety systems (such as sprinklers or fire alarms) and complete detailed engineering assessments
  • Re-wiring electrical systems to address hotspots found during thermographic scans
  • Retro-fitting columns and beams to comply with structural requirements based on the size, occupancy, and loads of the factory
  • Installing fire doors and protecting egress (exit) routes

The list of remediation items that our factories must complete is extensive but the Alliance team is ready to advise and guide them through every step of the process. One of our most important duties is to confirm that remediation is being done according to the Alliance Standard. We do this by visiting each factory for a remediation verification visit (RVV) roughly six weeks after the CAP meeting has taken place. Each team — consisting of one structural, one electrical, and one fire safety engineer — visits one or two factories a day, depending on factory size and location. With a complete list of items the factory needs to fix and deadlines for completion, factory CAPs are crucial to helping us properly focus our factory visits! The full RVV process is listed below:

As of June 15th, 505 factories had received their 1st remediation verification visits (RVVs), and we hope to visit each Alliance factory at least once by our 2nd anniversary in July.

  • Before the RVV. Before a factory begins remediation, we ask that factories submit plans and drawings to us; this check allows us to approve items such as a system’s design so it is installed correctly from the beginning or structural retrofitting plans (to help the factory avoid re-work). We also answer technical questions posed by internal factory engineers and help calibrate consultants to be sure they understand Alliance requirements. Just before the six-week deadline, an Alliance case coordinator reaches out to the factory to request remediation evidence for items with upcoming deadlines. The case coordinator then reviews that evidence, schedules the RVV, and preps the assigned Alliance case manager (with his remediation team) on factory status.
  • During the RVV. Using evidence submitted and the approved CAP, we visit the factory and verify any remediation that has been reported as done (and often check on items that are overdue but not yet completed). Brands are also invited to participate in the RVV, and we request worker representatives (and union representatives, where applicable) be present during the RVV opening and closing meetings. Our main goals are to 1) determine whether the reported remediation is done and 2) confirm that remediation has been done correctly. This time in the field is a great opportunity to interact with factory staff and answer any outstanding questions. It is also useful for the Alliance team to determine which factories are progressing and which are falling behind, so we can alter our outreach accordingly. During the closing meeting, the RVV team prepares an onsite report regarding the progress of remediation in all three areas (structural, electrical and fire) and provides a hard copy of the report to factory management.
  • After the RVV. The team members create a presentation with RVV findings and update the CAP to reflect the factory’s current remediation status. We also share findings with the other remediation teams to calibrate our technical guidance and identify trends across factories.  1st Remediation Verification Visit_Page_1

In general, we can place factories into several categories based on RVVs: (1) not submitting evidence with overall lack of motivation; (2) not submitting evidence but actually making progress on the ground; (3) verified evidence but erring in some aspects of remediation; and (4) verified evidence and making good progress. During a recent RVV, the factory we visited had not submitted any evidence prior to our arrival. We scheduled the visit regardless because there were items that were due — we have also found that many factory managers do not communicate extensively by email, and therefore do not always send evidence when requested. This situation turned out to be the case at this factory; though it was still behind in remediation progress overall, the factory had actually completed 26% of the items in its CAP. We were pleased to see some progress made, but also needed to push for more effort to close outstanding items, and to guide where remediation had gone wrong.

The Alliance team is starting to escalate factories that are not remediating at a fast enough pace. Though unfortunate, we believe this policy is necessary to encourage lagging factories and weed out others that have no intention of ever remediating. We are, however, also seeing highly motivated factories that are progressing swiftly and are focused on remediating correctly. We aim to highlight some of these factories through case studies in the coming weeks as a way to reward success and share best practices. We are also excited to see that some factories will soon be ready for final inspection because they are close to completing all items in their CAPs! These factories could serve as good resources for other factories that are making slower progress, so we look forward to sharing their stories. Remediation is a challenging effort, and while the Alliance team is here to support factories in any way possible, we also believe that factory collaboration and brand support are essential for continued success.