Findings by maclaren1

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									FLA Audit Profile
Country                                                    Thailand
Factory Name                                               080074581F
IEM                                                        Kenan Institute Asia
Date(s) in Facility                                        July 10-11, 2007
FLA Affiliated Compan(ies)                                 Nordstrom, Inc.
Number of Workers                                          404
Product(s)                                                 Socks
Production Processes                                       Knitting, Linking, Dyeing and Washing, Emboidery, Finishing and Packing

FLA Code/Benchmark                                         Compliance Status Describe noncompliance, risk of             List sources/documentation used Cite and describe local and/or   Describe notable features
                                                                             noncompliance or uncorroborated evidence of for reference and corroborating country laws used for additional implemented by factory
                                                                             noncompliance                               evidence (e.g. worker interviews, reference                      management or Company
                                                                                                                         factory walkthrough, records
                                                                                                                         review, etc.)

1. Code Awareness
GEN 2: Ensure that all Company factories as well as Noncompliance             The factory did not post the Company's Code Visual inspection, management
contractors and suppliers inform their employees                              of Conduct in the workplace nor did they    interviews, worker interviews
about the workplace standards orally and through the                          provide training to the workers. Therefore, and document review
posting of standards in a prominent place (in the local                       workers were unaware of the Company's
languages spoken by employees and managers) and                               Code of Conduct. They only know about their
undertake other efforts to educate employees about                            basic rights, e.g., basic wages.
the standards on a regular basis.
GEN 3: Develop a secure communications channel, Noncompliance                 There is no suggestion box in the factory and   Visual inspection, worker
in a manner appropriate to the culture and situation,                         no sign or any communication conveying to       interview and management
to enable Company employees and employees of                                  the workers what it is. In addition, no         interview
contractors and suppliers to report to the Company                            indication or sign that workers will not be
on noncompliance with the workplace standards, with                           punished or discriminated against for making
security that they shall not be punished or prejudiced                        grievances.
for doing so.
2. Forced Labor
There will not be any use of forced labor, whether in
the form of prison labor, indentured labor, bonded
labor or otherwise.
3. Child Labor
No person will be employed at an age younger than
15 (or 14 where the law of the country of manufacture
allows) or younger than the age for completing
compulsory education in the country of manufacture
where such age is higher than 15.
4. Harassment or Abuse
Every employee will be treated with respect and
dignity. No employee will be subject to any physical,
sexual, psychological or verbal harassment of abuse.

H&A.7 Discipline/Training of Management                    Noncompliance      No training to manager or supervisor            Management interview,
                                                                              regarding disciplinary practice.                supervisor interview and
                                                                                                                              document review
5. Non-Discrimination
No person will be subject to any discrimination in
employment, including hiring, salary, benefits,
advancement, discipline, termination or retirement,
on the basis of gender, race, religion, age, disability,
sexual orientation, nationality, political opinion, or
social or ethnic origin.
6. Health and Safety
Employers will provide a safe and healthy working
environment to prevent accidents and injury to health
arising out of, linked with, or occurring in the course
of work or as a result of the operation of employer
facilities.

                                                                                                                                                                                                                      1
FLA Code/Benchmark                                 Compliance Status Describe noncompliance, risk of             List sources/documentation used Cite and describe local and/or   Describe notable features
                                                                     noncompliance or uncorroborated evidence of for reference and corroborating country laws used for additional implemented by factory
                                                                     noncompliance                               evidence (e.g. worker interviews, reference                      management or Company
                                                                                                                 factory walkthrough, records
                                                                                                                 review, etc.)

H&S.1 General Compliance Health and Safety         Noncompliance      Not all workers received the medical               Safety Officer interviews,           The Labor Protection ACT B.E.
                                                                      examination in year 2007.                          document review                      2541 Section 107

H&S.2 Document Maintenance/Worker Accessibility    Noncompliance      Safety Officer will update the OSH law and         Safety Officer interviews,
and Awareness                                                         regulations by contacting to the Ministry of       document review
                                                                      Labor directly. Current information on OSH
                                                                      laws are not updated and kept in the facility.

H&S.3 Written Health and Safety Policy             Noncompliance      Updated OSH regulations and OSH policy not Visual inspection, Safety Officer
                                                                      posted; workers not informed.              interview, worker interviews

H&S.4 Worker Consultation                          Noncompliance      Not all supervisor is trained the safety officer   Safety Officer interviews,           The Notification of the Ministry
                                                                      at supervisor level in the facility.               document review                      of Interior Re: Working Safety
                                                                                                                                                              Relating to Protection of Fire for
                                                                                                                                                              Employees, Chapter 3, and
                                                                                                                                                              Clause 19(3)
H&S.5 Health and Safety Management System          Noncompliance      The second floor area of the washing section       Visual inspection
                                                                      was not equipped with a handrail.
H&S.9 Evacuation Requirements and Procedure        Noncompliance      1. Not all workers received fire drill training.   Safety Officer interview, worker    1. The Notification of Ministry of
                                                                      Factory only arranged fire fighting and            interviews, document review,        Interior Re: Work Safety
                                                                      evacuation training for some workers in each       visual inspection                   Relating to Protection and
                                                                      section. There were 78 workers trained on                                              Prevention of Fire for
                                                                      March 17, 2007. 2. Three fire extinguishers in                                         Employees, Clause 36. 2. The
                                                                      K2 section were blocked by the work station                                            Notification of Ministry of Interior
                                                                      and carton boxes.                                                                      Fire Safety, Chapter 3, Section
                                                                                                                                                             19(1)
H&S.10 Safety Equipment and First Aid Training     Noncompliance      1. No first aid kit installed in linking section. 2. Visual inspection, Safety Officer The Notification of Ministry of
                                                                      No medical supplies for first aid kit in knitting interview, worker interviews,        Interior Re: Prescribing Welfare
                                                                      section 1.                                           documents review                  in Connection with the Health
                                                                                                                                                             and Sanitation of Employee,
                                                                                                                                                             Clause 1
H&S.11 Personal Protective Equipment               Noncompliance      Even though the PPE sign is posted in order Visual inspection                          The Notification of Ministry of
                                                                      to warn the workers using it during work,                                              Interior Machinery Safety,
                                                                      some workers in washing/dying section did                                              Chapter 1, Section 2
                                                                      not wear latex boots and latex gloves during
                                                                      work. Besides, most workers in knitting
                                                                      section in noise area did not wear earplugs
                                                                      when working and worker who used cleaning
                                                                      spray also did not wear goggles or latex
                                                                      gloves.

H&S.13 Chemical Management and Training            Noncompliance      1. Two chemical containers are not labeled in Visual inspection                         1. The Notification of the
                                                                      finishing section. 2.There is no warning sign                                           Ministry of Interior Re: Work
                                                                      (flammable substance, no smoking) posted in                                             Safety Relating to Harmful
                                                                      area of oil storage. Leaking oil contaminating                                          Chemicals, Chapter 1, Clause 4.
                                                                      the environment was detected in this area. 2.                                           2. The Notification of Ministry of
                                                                      No eye wash devices installed in the chemical                                           Interior Re: Work Safety
                                                                      use and storage area or in the washing/dying                                            Relating to Harmful Chemicals,
                                                                      section.                                                                                Clause 13

H&S.14 Material Safety Data Sheets/Worker Access   Noncompliance      Not all MSDS are provided in Thai langauge.        Document review                      The Notification of Ministry of
and Awareness                                                                                                                                                 Interior Re: Work Safety
                                                                                                                                                              Relating to Harmful Chemicals,
                                                                                                                                                              Chapter 1, Clause 8




                                                                                                                                                                                                              2
FLA Code/Benchmark                                        Compliance Status Describe noncompliance, risk of             List sources/documentation used Cite and describe local and/or   Describe notable features
                                                                            noncompliance or uncorroborated evidence of for reference and corroborating country laws used for additional implemented by factory
                                                                            noncompliance                               evidence (e.g. worker interviews, reference                      management or Company
                                                                                                                        factory walkthrough, records
                                                                                                                        review, etc.)

H&S.17 Ventilation/Electrical/Facility Installation and   Noncompliance      Facility did not conduct environment                 Safety Officer interviews,         The Notification of the Ministry
Maintenance                                                                  inspection regarding dust, lighting, noise and       document review                    of Interior Re: Work Safety in
                                                                             heat in the work place; thus, factory was not                                           Respect to Environmental
                                                                             able to indicate that dust, lighting, noise and                                         Condition, Chapter 1-3
                                                                             heat in work place are acceptable and in line
                                                                             with the legal limits.
H&S.18 Machinery Maintenance and Worker Training Noncompliance               There was inspection of cranes at                    Safety Officer interviews,         The Notification of Ministry of
                                                                             washing/dying section just twice a year by the       document review                    Interior Re: Work Safety
                                                                             authorized engineer; however, the law                                                   Relating to Cranes, Clause 8
                                                                             requires once every 3 months.
H&S.21 Medical Facilities                                 Noncompliance      Based on records of the doctor visiting, it was      Safety Officer interview, worker   Ministerial Regulation B.E.2548
                                                                             noted that a doctor did not visit the factory at     interviews, document review        Re: Prescribing Welfare in the
                                                                             least 6 hours per week to treat workers as the                                          Business Establishment, Clause
                                                                             law stipulates. A doctor only visited the facility                                      2(2)
                                                                             3-4 hours in some weeks.

H&S.25 Food Preparation                                   Noncompliance      The food shop in the canteen has no food             Safety Officer interviews,         The Public Health Act B.E. 2535,
                                                                             hygiene certification; no records of health          document review                    Chapter 8, Sections 38-40
                                                                             examination of cooks are kept.
H&S.26 Drinking Water                                     Noncompliance      Drinking water has not been sent for analysis        Safety Officer interviews,         The Notification of the Ministry
                                                                             to ensure that it is safe to drink.                  document review                    of Labor and Social Welfare Re:
                                                                                                                                                                     Welfare in the Facility, 1(1)

Other                                                     Noncompliance      1. Forklift drivers have not received training.      Safety Officer interviews,         1. The Notification of Ministry of
                                                                             2. No report of air quality testing from boiler      document review                    Interior Machinery Safety,
                                                                             funnel.                                                                                 Chapter 1, Section 5(8) 2. The
                                                                                                                                                                     Notification of Ministry of
                                                                                                                                                                     Industry (2) B.E. 2536 Re: Air
                                                                                                                                                                     Pollution
7. Freedom of Association and Collective
Bargaining
Employers will recognize and respect the right of
employees to freedom of association and collective
bargaining.
8. Hours of Work
Except in extraordinary business circumstances,
employees will (i) not be required to work more than
the lesser of (a) 48 hours per week and 12 hours
overtime or (b) the limits on regular and overtime
hours allowed by the law of the country of
manufacture or, where the laws of such country will
not limit the hours of work, the regular work week in
such country plus 12 hours overtime; and (ii) be
entitled to at least one day off in every seven day
period.
HOW.1 General Compliance Hours of Work                    Noncompliance      From the time record reviewed it was found    Worker interviews, records                Ministerial Regulation Issue 3
                                                                             that some workers have worked overtime over review                                      (B.E. 2541) Issue under the
                                                                             12 hrs/week (14-48 hrs) between January to                                              Labor Protection Act B.E. 2541
                                                                             April 2007. In addition, some workers in
                                                                             knitting section worked overtime more than 36
                                                                             hrs per week (48 hrs) in January 2007.

HOW.3 Meal and Rest Breaks                                Noncompliance      Workers informed that they took a break 15     Worker interviews, records               Labor Protection Act B.E.2541
                                                                             minutes before they worked overtime until      review                                   Section 27
                                                                             9pm. In addition, the time record did not show
                                                                             the break time which was arranged by the
                                                                             factory.

                                                                                                                                                                                                                     3
FLA Code/Benchmark                                     Compliance Status Describe noncompliance, risk of             List sources/documentation used Cite and describe local and/or   Describe notable features
                                                                         noncompliance or uncorroborated evidence of for reference and corroborating country laws used for additional implemented by factory
                                                                         noncompliance                               evidence (e.g. worker interviews, reference                      management or Company
                                                                                                                     factory walkthrough, records
                                                                                                                     review, etc.)

HOW.18 Annual Leave/Wage Payments                      Noncompliance      Worker who had retired already and back to       Worker interviews, records      Labor Protection Act B.E.2541
                                                                          work with this factory again will not receive    review, management interviews   Section 30
                                                                          annual leave although he/she works
                                                                          consecutively 1 year.
9. Wages, Benefits and Overtime Compensation

WAGES AND BENEFITS: Employers recognize that
wages are essential to meeting employees’ basic
needs. Employers will pay employees, as a base, at
least the minimum wage required by local law or the
prevailing industry wage, whichever is higher, and
will provide legally mandated benefits.
OVERTIME COMPENSATION: In addition to their
compensation for regular hours of work, employees
will be compensated for overtime hours at such
premium rate as is legally required in the country of
manufacture or, in those countries where such laws
will not exist, at a rate at least equal to their regular
hourly compensation rate.
WBOT.5 Holidays, Leave, Legal Benefits and                Noncompliance   Workers who receive wage on a piece-rate         Workers interview, records      Labor Protection Act B.E.2541
Bonuses                                                                   basis did not receive the wage for holiday or    review, management interviews   Section 60
                                                                          day of leave in an amount equivalent to the
                                                                          average rate they received during the
                                                                          payment period prior to such holiday or day of
                                                                          leave.
WBOT.12 Overtime Compensation for Piece Rates          Noncompliance      The workers in linking section who receive       Workers interview, records      Labor Protection Act B.E.2541
and Other Incentive Schemes                                               wages on a piece-rate basis receive overtime     review, management interviews   Section 61
                                                                          pay less than 1.5 times of the piece-rate of
                                                                          wages of working day for work done.

WBOT.14 Voluntary Wage Deductions                      Noncompliance      Factory provided convenient store on site.   Worker interviews, records          Labor Protection Act B.E.2541
                                                                          Workers are able to buy goods such as        review                              Section 76
                                                                          consumer products from this shop in advance.
                                                                          Then a wage deduction will be made from the
                                                                          worker's wage for the goods that they have
                                                                          taken; therefore, there was not consent from
                                                                          both parties for this deduction.

Other                                                  Noncompliance      The factory required the workers to take day     Worker interviews, records      Labor Protection Act B.E.2541
                                                                          off on Saturday between May to June 2007.        review, management interviews   Section 75
                                                                          However, the factory did not pay 50% of
                                                                          wages for that temporarily suspended
                                                                          business.
10. Miscellaneous
Subcontracting, homework and other issues not
covered by above benchmarks and code
requirements.




                                                                                                                                                                                                                  4
FLA Audit Profile                                                                                                                                                                 Note from Nordstrom: After submitting the remediation
Country                                            Thailand                                                                                                                       plan for the outstanding FLA audit to the factory,
Factory Name                                       080074581F                                                                                                                     Nordstrom has regretfully ceased efforts due to the
IEM                                                Kenan Institute Asia                                                                                                           termination of business relationships between the factory
Date(s) in Facility                                July 10-11, 2007                                                                                                               and Nordstrom. Due to the termination of business
FLA Affiliated Compan(ies)                         Nordstrom, Inc.                                                                                                                relationships, the company's leverage for implementing
Number of Workers                                  404                                                                                                                            remediation has diminished completely. For further
Product(s)                                         Socks                                                                                                                          comment, please contact Nordstrom directly.
Production Processes                               Knitting, Linking, Dyeing and Washing, Emboidery, Finishing and Packing

FLA Code/Benchmark                                 Compliance Status                                                                                   Remediation                                                                                            Status
                                                                       Description of noncompliance, risk of                  Company Internal Audit   Company Remediation Plan   Target        Factory Response     Company Follow-Up        Documentation   Completed, Pending,
                                                                       noncompliance or uncorroborated evidence of            Findings (optional)                                 Completion    (optional)           (cite date of follow-                    On-going
                                                                       noncompliance                                                                                              Date                               up)


GEN 2: Ensure that all Company factories as well      Noncompliance    The factory did not post the Company's Code of
as contractors and suppliers inform their employees                    Conduct in the workplace nor did they provide
about the workplace standards orally and through                       training to the workers. Therefore, workers were
the posting of standards in a prominent place (in the                  unaware of the Company's Code of Conduct.
local languages spoken by employees and                                They only know about their basic rights, e.g.,
managers) a                                                            basic wages.


GEN 3: Develop a secure communications channel, Noncompliance          There is no suggestion box in the factory and no
in a manner appropriate to the culture and situation,                  sign or any communication conveying to the
to enable Company employees and employees of                           workers what it is. In addition, no indication or
contractors and suppliers to report to the Company                     sign that workers will not be punished or
on noncompliance with the workplace standards,                         discriminated against for making grievances.
with secur

H&A.7 Discipline/Training of Management            Noncompliance       No training to manager or supervisor regarding
                                                                       disciplinary practice.
H&S.1 General Compliance Health and Safety         Noncompliance       Not all workers received the medical
                                                                       examination in year 2007.
H&S.2 Document Maintenance/Worker Accessibility Noncompliance          Safety Officer will update the OSH law and
and Awareness                                                          regulations by contacting to the Ministry of
                                                                       Labor directly. Current information on OSH laws
                                                                       are not updated and kept in the facility.
H&S.3 Written Health and Safety Policy             Noncompliance       Updated OSH regulations and OSH policy not
                                                                       posted; workers not informed.
H&S.4 Worker Consultation                          Noncompliance       Not all supervisor is trained the safety officer at
                                                                       supervisor level in the facility.
H&S.5 Health and Safety Management System          Noncompliance       The second floor area of the washing section
                                                                       was not equipped with a handrail.
H&S.9 Evacuation Requirements and Procedure        Noncompliance       1. Not all workers received fire drill training.
                                                                       Factory only arranged fire fighting and
                                                                       evacuation training for some workers in each
                                                                       section. There were 78 workers trained on
                                                                       March 17, 2007. 2. Three fire extinguishers in
                                                                       K2 section were blocked by the work station and
                                                                       carton boxes.

H&S.10 Safety Equipment and First Aid Training     Noncompliance       1. No first aid kit installed in linking section. 2.
                                                                       No medical supplies for first aid kit in knitting
                                                                       section 1.
H&S.11 Personal Protective Equipment               Noncompliance       Even through the PPE sign is posted in order to
                                                                       warn the workers using it during work, some
                                                                       workers in washing/dying section did not wear
                                                                       latex boots and latex gloves during work.
                                                                       Besides, most workers in knitting section in
                                                                       noise area did not wear earplugs when working
                                                                       and worker who used cleaning spray also did
                                                                       not wear goggles or latex gloves.
H&S.13 Chemical Management and Training            Noncompliance       1. Two chemical containers are not labeled in
                                                                       finishing section. 2.There is no warning sign
                                                                       (flammable substance, no smoking) posted in
                                                                       area of oil storage. Leaking oil contaminating
                                                                       the environment was detected in this area. 2. No
                                                                       eye wash devices installed in the chemical use
                                                                       and storage area or in the washing/dying
                                                                       section.
H&S.14 Material Safety Data Sheets/Worker Access Noncompliance         Not all MSDS are provided in Thai langauge.
and Awareness
                                                                                                                                                                                                                                                                   5
FLA Code/Benchmark                                    Compliance Status                                                                                    Remediation                                                                                        Status
                                                                          Description of noncompliance, risk of                   Company Internal Audit   Company Remediation Plan   Target       Factory Response   Company Follow-Up       Documentation   Completed, Pending,
                                                                          noncompliance or uncorroborated evidence of             Findings (optional)                                 Completion   (optional)         (cite date of follow-                   On-going
                                                                          noncompliance                                                                                               Date                            up)


H&S.17 Ventilation/Electrical/Facility Installation   Noncompliance       Facility did not conduct environment inspection
and Maintenance                                                           regarding dust, lighting, noise and heat in the
                                                                          work place; thus, factory was not able to indicate
                                                                          that dust, lighting, noise and heat in work place
                                                                          are acceptable and in line with the legal limits.

H&S.18 Machinery Maintenance and Worker               Noncompliance       There was inspection of cranes at
Training                                                                  washing/dying section just twice a year by the
                                                                          authorized engineer; however, the law requires
                                                                          once every 3 months.
H&S.21 Medical Facilities                             Noncompliance       Based on records of the doctor visiting, it was
                                                                          noted that a doctor did not visit the factory at
                                                                          least 6 hours per week to treat workers as the
                                                                          law stipulates. A doctor only visited the facility 3-
                                                                          4 hours in some weeks.
H&S.25 Food Preparation                               Noncompliance       The food shop in the canteen has no food
                                                                          hygiene certification; no records of health
                                                                          examination of cooks are kept.
H&S.26 Drinking Water                                 Noncompliance       Drinking water has not been sent for analysis to
                                                                          ensure that it is safe to drink.
Other                                                 Noncompliance       1. Forklift drivers have not received training. 2.
                                                                          No report of air quality testing from boiler funnel.


HOW.1 General Compliance Hours of Work                Noncompliance       From the time record reviewed it was found that
                                                                          some workers have worked overtime over 12
                                                                          hrs/week (14-48 hrs) between January to April
                                                                          2007. In addition, some workers in knitting
                                                                          section worked overtime more than 36 hrs per
                                                                          week (48 hrs) in January 2007.

HOW.3 Meal and Rest Breaks                            Noncompliance       Workers informed that they took a break 15
                                                                          minutes before they worked overtime until 9pm.
                                                                          In addition, the time record did not show the
                                                                          break time which was arranged by the factory.
HOW.18 Annual Leave/Wage Payments                     Noncompliance       Worker who had retired already and back to
                                                                          work with this factory again will not receive
                                                                          annual leave although he/she works
                                                                          consecutively 1 year.
WBOT.5 Holidays, Leave, Legal Benefits and            Noncompliance       Workers who receive wage on a piece-rate
Bonuses                                                                   basis did not receive the wage for holiday or day
                                                                          of leave in an amount equivalent to the average
                                                                          rate they received during the payment period
                                                                          prior to such holiday or day of leave.
WBOT.12 Overtime Compensation for Piece Rates         Noncompliance       The workers in linking section who receive
and Other Incentive Schemes                                               wages on a piece-rate basis receive overtime
                                                                          pay less than 1.5 times of the piece-rate of
                                                                          wages of working day for work done.
WBOT.14 Voluntary Wage Deductions                     Noncompliance       Factory provided convenient store on site.
                                                                          Workers are able to buy goods such as
                                                                          consumer products from this shop in advance.
                                                                          Then a wage deduction will be made from the
                                                                          worker's wage for the goods that they have
                                                                          taken; therefore, there was not consent from
                                                                          both parties for this deduction.
Other                                                 Noncompliance       The factory required the workers to take day off
                                                                          on Saturday between May to June 2007.
                                                                          However, the factory did not pay 50% of wages
                                                                          for that temporarily suspended business.




                                                                                                                                                                                                                                                                   6
FLA Audit Profile
Country                                Thailand
Factory Name                           080074581F
IEM                                    Kenan Institute Asia
Date(s) in Facility                    July 10-11, 2007
FLA Affiliated Compan(ies)             Nordstrom, Inc.
Number of Workers                      404
Product(s)                             Socks
Production Processes                   Knitting, Linking, Dyeing and Washing, Emboidery, Finishing and Packing

FLA Code/Benchmark                     Compliance Status      [Status]                       Description of noncompliance, risk of      Updates (Cite Date of Follow-Up)         Third-Party Verification   Company Verification Follow-Up
                                                              Completed, Pending, On-going   noncompliance or uncorroborated evidence Company Follow-Up            Documentation External     Documentation Company Follow-Up (cite      Documentation
                                                                                             of noncompliance                                                                    Verification               date of planned or follow-up
                                                                                                                                                                                 (Date)                     visit, if appropriate)
GEN 2: Ensure that all Company          Noncompliance                                        The factory did not post the Company's
factories as well as contractors and                                                         Code of Conduct in the workplace nor did
suppliers inform their employees about                                                       they provide training to the workers.
the workplace standards orally and                                                           Therefore, workers were unaware of the
through the posting of standards in a                                                        Company's Code of Conduct. They only
prominent place (in the local languages                                                      know about their basic rights, e.g., basic
spoken by employees and managers) a                                                          wages.




GEN 3: Develop a secure                   Noncompliance                                      There is no suggestion box in the factory
communications channel, in a manner                                                          and no sign or any communication
appropriate to the culture and situation,                                                    conveying to the workers what it is. In
to enable Company employees and                                                              addition, no indication or sign that workers
employees of contractors and suppliers                                                       will not be punished or discriminated
to report to the Company on                                                                  against for making grievances.
noncompliance with the workplace
standards, with secur


H&A.7 Discipline/Training of           Noncompliance                                         No training to manager or supervisor
Management                                                                                   regarding disciplinary practice.
H&S.1 General Compliance Health and Noncompliance                                            Not all workers received the medical
Safety                                                                                       examination in year 2007.
H&S.2 Document Maintenance/Worker      Noncompliance                                         Safety Officer will update the OSH law and
Accessibility and Awareness                                                                  regulations by contacting to the Ministry of
                                                                                             Labor directly. Current information on OSH
                                                                                             laws are not updated and kept in the
                                                                                             facility.
H&S.3 Written Health and Safety Policy Noncompliance                                         Updated OSH regulations and OSH policy
                                                                                             not posted; workers not informed.
H&S.4 Worker Consultation              Noncompliance                                         Not all supervisor is trained the safety
                                                                                             officer at supervisor level in the facility.
H&S.5 Health and Safety Management     Noncompliance                                         The second floor area of the washing
System                                                                                       section was not equipped with a handrail.
H&S.9 Evacuation Requirements and      Noncompliance                                         1. Not all workers received fire drill training.
Procedure                                                                                    Factory only arranged fire fighting and
                                                                                             evacuation training for some workers in
                                                                                             each section. There were 78 workers
                                                                                             trained on March 17, 2007. 2. Three fire
                                                                                             extinguishers in K2 section were blocked
                                                                                             by the work station and carton boxes.

H&S.10 Safety Equipment and First Aid Noncompliance                                          1. No first aid kit installed in linking section.
Training                                                                                     2. No medical supplies for first aid kit in
                                                                                             knitting section 1.




                                                                                                                                                                                                                                              7
FLA Code/Benchmark                       Compliance Status   [Status]                       Description of noncompliance, risk of          Updates (Cite Date of Follow-Up)         Third-Party Verification   Company Verification Follow-Up
                                                             Completed, Pending, On-going   noncompliance or uncorroborated evidence Company Follow-Up                Documentation External     Documentation Company Follow-Up (cite      Documentation
                                                                                            of noncompliance                                                                        Verification               date of planned or follow-up
                                                                                                                                                                                    (Date)                     visit, if appropriate)
H&S.11 Personal Protective Equipment Noncompliance                                          Even through the PPE sign is posted in
                                                                                            order to warn the workers using it during
                                                                                            work, some workers in washing/dying
                                                                                            section did not wear latex boots and latex
                                                                                            gloves during work. Besides, most workers
                                                                                            in knitting section in noise area did not wear
                                                                                            earplugs when working and worker who
                                                                                            used cleaning spray also did not wear
                                                                                            goggles or latex gloves.
H&S.13 Chemical Management and           Noncompliance                                      1. Two chemical containers are not labeled
Training                                                                                    in finishing section. 2.There is no warning
                                                                                            sign (flammable substance, no smoking)
                                                                                            posted in area of oil storage. Leaking oil
                                                                                            contaminating the environment was
                                                                                            detected in this area. 2. No eye wash
                                                                                            devices installed in the chemical use and
                                                                                            storage area or in the washing/dying
                                                                                            section.
H&S.14 Material Safety Data        Noncompliance                                            Not all MSDS are provided in Thai
Sheets/Worker Access and Awareness                                                          langauge.

H&S.17 Ventilation/Electrical/Facility   Noncompliance                                      Facility did not conduct environment
Installation and Maintenance                                                                inspection regarding dust, lighting, noise
                                                                                            and heat in the work place; thus, factory
                                                                                            was not able to indicate that dust, lighting,
                                                                                            noise and heat in work place are
                                                                                            acceptable and in line with the legal limits.

H&S.18 Machinery Maintenance and         Noncompliance                                      There was inspection of cranes at
Worker Training                                                                             washing/dying section just twice a year by
                                                                                            the authorized engineer; however, the law
                                                                                            requires once every 3 months.
H&S.21 Medical Facilities                Noncompliance                                      Based on records of the doctor visiting, it
                                                                                            was noted that a doctor did not visit the
                                                                                            factory at least 6 hours per week to treat
                                                                                            workers as the law stipulates. A doctor only
                                                                                            visited the facility 3-4 hours in some weeks.

H&S.25 Food Preparation                  Noncompliance                                      The food shop in the canteen has no food
                                                                                            hygiene certification; no records of health
                                                                                            examination of cooks are kept.
H&S.26 Drinking Water                    Noncompliance                                      Drinking water has not been sent for
                                                                                            analysis to ensure that it is safe to drink.
Other                                    Noncompliance                                      1. Forklift drivers have not received
                                                                                            training. 2. No report of air quality testing
                                                                                            from boiler funnel.
HOW.1 General Compliance Hours of        Noncompliance                                      From the time record reviewed it was found
Work                                                                                        that some workers have worked overtime
                                                                                            over 12 hrs/week (14-48 hrs) between
                                                                                            January to April 2007. In addition, some
                                                                                            workers in knitting section worked overtime
                                                                                            more than 36 hrs per week (48 hrs) in
                                                                                            January 2007.
HOW.3 Meal and Rest Breaks               Noncompliance                                      Workers informed that they took a break 15
                                                                                            minutes before they worked overtime until
                                                                                            9pm. In addition, the time record did not
                                                                                            show the break time which was arranged
                                                                                            by the factory.

HOW.18 Annual Leave/Wage                 Noncompliance                                      Worker who had retired already and back
Payments                                                                                    to work with this factory again will not
                                                                                            receive annual leave although he/she
                                                                                            works consecutively 1 year.

                                                                                                                                                                                                                                                 8
FLA Code/Benchmark                  Compliance Status   [Status]                       Description of noncompliance, risk of       Updates (Cite Date of Follow-Up)         Third-Party Verification   Company Verification Follow-Up
                                                        Completed, Pending, On-going   noncompliance or uncorroborated evidence Company Follow-Up             Documentation External     Documentation Company Follow-Up (cite      Documentation
                                                                                       of noncompliance                                                                     Verification               date of planned or follow-up
                                                                                                                                                                            (Date)                     visit, if appropriate)
WBOT.5 Holidays, Leave, Legal       Noncompliance                                      Workers who receive wage on a piece-rate
Benefits and Bonuses                                                                   basis did not receive the wage for holiday
                                                                                       or day of leave in an amount equivalent to
                                                                                       the average rate they received during the
                                                                                       payment period prior to such holiday or day
                                                                                       of leave.
WBOT.12 Overtime Compensation for   Noncompliance                                      The workers in linking section who receive
Piece Rates and Other Incentive                                                        wages on a piece-rate basis receive
Schemes                                                                                overtime pay less than 1.5 times of the
                                                                                       piece-rate of wages of working day for
                                                                                       work done.
WBOT.14 Voluntary Wage Deductions   Noncompliance                                      Factory provided convenient store on site.
                                                                                       Workers are able to buy goods such as
                                                                                       consumer products from this shop in
                                                                                       advance. Then a wage deduction will be
                                                                                       made from the worker's wage for the
                                                                                       goods that they have taken; therefore,
                                                                                       there was not consent from both parties for
                                                                                       this deduction.
Other                               Noncompliance                                      The factory required the workers to take
                                                                                       day off on Saturday between May to June
                                                                                       2007. However, the factory did not pay
                                                                                       50% of wages for that temporarily
                                                                                       suspended business.




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