Pacific Sunwear

Compliance and CTPAT Vendor Kit

Supported by
STR Responsible Sourcing

Responsible Sourcing Solutions

www.strquality.com
CONTENTS:

INTRODUCTION

WHAT TO EXPECT. HOW TO PREPARE

o Social Compliance Evaluation

o Supply Chain Security Evaluation

SOCIAL COMPLIANCE EVALUATION

SUPPLY CHAIN SECURITY EVALUATION

EVALUATION RATING SYSTEM

o EXPLANATION OF VIOLATIONS

PACIFIC SUNWEAR SECURITY

STANDARDS FOR FACTORIES

PACIFIC SUNWEAR CODE OF CONDUCT

IMPORTANT CONTACTS

REFERENCE SECTION

o SOCIAL COMPLIANCE
EVALUATION CHECKLIST

o DOCUMENT REQUEST LIST

o INTERNATIONAL HEALTH &

SAFETY EVALUATION FORM

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INTRODUCTION
Pacific Sunwear has a long-standing commitment of conducting its business in an ethical and legal
manner. We choose contractors and vendors who share that commitment. As explained in the Pacific
Sunwear Code of Conduct, we strive to maintain consistent standards in all facilities involved in the
manufacture and distribution of our products.

Pacific Sunwear requires that every potential new factory undergo and pass a social compliance audit.
We also require that all active factories conduct and pass annual re-audits. The purpose of these
assessments is to ensure that all of our partners and suppliers comply with local laws and regulations in
every country in which they operate.

No production will be placed, and no purchase orders will be issued to any new factory until they pass a
social compliance audit. Any active factory who fails to submit an annual audit, or fails an audit, will be
deactivated, and lose the right to produce for Pacific Sunwear

This package will help factories prepare for Social Compliance and Supply Chain Security Evaluations
that will be performed STR-RS as described below. The package includes information on what to expect
and how to prepare for the evaluations as well as information concerning factory assessment guidelines.
A Social Compliance Evaluation Checklist and an Explanation of Social Compliance Violations are
included as well as security standards for factories.

WHAT TO EXPECT, HOW TO PREPARE

Social Compliance Evaluation
The audit is a fact-finding process designed to help you identify areas that could be improved to ensure
you are in compliance with Pacific Sunwear standards, country-specific as well as universal legal
requirements related to the factory. This process does not certify full compliance nor does it automatically
approve you for production for any other brands or retailers or qualify you for membership in industry
associations.

Pacific Sunwear performs the audits through its agent, STR-RS. The factory is responsible for the cost of
this audit which is usually $1500-$1800USD. The audit is approximately one (1) full day and consists of
an inspection of the facility, interviews with employees, and a review of relevant documents. The STR-RS
consultant will also place a great deal of focus on education. Upon completion of the assessment, the
consultant will offer corrective actions in order to help factory management make improvements to the
facilities.

Supply Chain Security Evaluation

The security assessment procedures require participation and information from factory management.
The areas in the assessment include internal and external physical security, access controls, packing and
loading, and the information technology security department.

Please allow inspectors to access restricted areas and necessary documents to assess the facility
security and complete the security checklist.

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SOCIAL COMPLIANCE EVALUATION
The following is a simple outline of the audit procedures. The audits do not necessarily follow this order,
however all steps are completed during the audit. In addition, if further steps or documents are needed in
order to have a complete understanding of the facility situation, they may be requested and should be
provided. Management such as factory owner, manager or human resource personnel should be present
during the audit. Otherwise, anyone who has delegated authority to provide the documents needed and
answer the questions from the consultants could assist in the process.

Consultants arrive at the facility and present business cards and a STR-RS badge.
Opening Conference is held with the contact person, preferably management. During this
meeting, the format of the audit is described.
The production manager and the human resource personnel are needed in order to answer a
series of questions regarding production capacity, machines, lead times, hiring practices and
security procedures.
Company policies, handbooks, and management systems are reviewed.
Private employee interviews are conducted. The consultants select the employees to be
interviewed in private, without management present. Employees are asked questions regarding
hours of work, length of employment, their understanding of disciplinary policies of the factory,
hiring policy, and working conditions.
Payroll documentation is reviewed. Payroll journals, timecards, production records, attendance
books, proof of insurance payment or tax payment (if applicable) must all be provided to the
consultants for a complete audit to take place. Consultants are evaluating that the regional
minimum wage is provided to all employees for all hours worked, including overtime
compensation. Also evaluated is whether maximum hours authorized to work, including weekend
and evening hours, are in compliance with regional labour laws.
Employee records are reviewed. Proof of age documentation must be available.
A walkthrough of the facility is conducted. Here the health and safety of the facility is evaluated,
as is the production capacity. Housing units, if provided, also need to be viewed by the
consultants. The eating area used by the workers is also viewed, as is the kitchen if cooking
takes place onsite.
Photographs of the facility are also taken with permission from management.
Copies of operating licenses and other government issued permits are also reviewed.
Security of the facility will be evaluated, with attention to physical security features as well as
factory policies concerning security.
At the conclusion of the audit a Recap is filled out, and all concerns are discussed with the facility
management. Management is requested to sign the Recap, to verify that they understand the
findings. A copy of the Recap is left with management to assist them in resolving the concerns
detected during the audit.

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SUPPLY CHAIN SECURITY EVALUATION

The Homeland Security Department and U. S. Customs Service launched the Customs – Trade
Partnership Against Terrorism (C-TPAT) with the goal of securing trade channels against terrorism and
protecting U. S. borders. The C-TPAT program calls on the trade industry to support government efforts
by securing their supply chain within the domestic United States and aboard. The Factory Security
Checklist is added to the STR-RS social compliance audit, and evaluates the existing security practices at
the factory compared to those recommended by C-TPAT and U.S. Customs.

Pacific Sunwear is committed to enhancing security throughout its entire supply chain in order to comply
with the requirements set forth by the U. S. Customs and Border Protection in the C-TPAT program. All
factories are required to allow the security audits, which will be conducted by STR-RS. The audit will
consist of a walkthrough of the facility. The walkthrough must include all work floors, vehicle parking
areas, warehouses, storage facilities, and packing and loading areas.

Facilities that have already been visited have found the audit to be educational. The security audit will
provide insight for implementing sound security practices within each area of inspection.

Areas of Inspection
 Physical Security: The security aspects of the grounds, buildings, and parking areas are
assessed for their security measures/mechanisms in place, and their potential for breach. The
manner in which cargo is secured and segregated is also assessed.
 Access Controls: The policies and practices regarding visitors, subcontractors, packages, etc. are
examined. Restriction to entry points and hazardous materials are also assessed thoroughly.
 Procedural Security: Procedures regarding seals, alerts, loading verification, interaction with law
enforcement agencies, etc. are examined.
 Education and Training Awareness: The training of employees regarding security procedures,
both proactive and reactive, is examined. Internal auditing practices are also assessed.
 Personnel Security: Areas of examination include hiring practices, documentation, and
background checks.
 Information Technology Security: Determines the degree to which the supplier protects its
system and information from unauthorized use and outside intrusion.

Necessary Documents
It would be greatly appreciated if the following information (as applicable) could be made available for the
audit. The confidentiality of all proprietary information will be respected. Any technologies and/or
processes unique to your operation will not be disclosed.

Internal operating policies and procedures (Company Policy)

- Specific to packing and loading
- Access controls
- Basic security practices
Prior supplier (subcontractor) names and locations
Company licenses, required industry licenses and insurance
Hiring policies and procedures, company handbook
Logbooks used to sign in visitors and vehicles
Employee files with copies of official identification documents
Security training and education materials
Bill of Lading
Shipping information (work orders, bill of lading, delivery slips, invoices)

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 Packing lists
Quota documents
Testing reports

EVALUATION RATING SYSTEM

Each factory will be subject to regular evaluations (audits). Should a factory be rated non-compliant
with the Pacific Sunwear Code of Conduct and Country Labor Regulations, a verification audit of the
particular factory will be required. The following represents the grading scale:

Satisfactory: No findings or Minor findings (e.g. Machine maintenance required that

does not pose an immediate threat; Accidental miscalculation of benefits; Etc.)
Needs Improvement: Findings that represent moderate risk (e.g. Missing age
documents, Excessive hours, etc.) Findings must be corrected, verified, and closed
out in the CAPA process (see below)
Needs Major Improvement: Unacceptable practices that represent significant risk
(e.g. Minimum Wages not guaranteed, Deficient Overtime payment, etc.)
Zero Tolerance: (e.g. Forced labor, Child labor, Unpaid wages, No fire safety
equipment, etc.)
Denied: Access to the factory denied with or without a reason.

Upon completion of the audit, if there are violations disclosed, the factory will receive a Violation
Recommendation Summary and the time period in which to expect the re-audit. The factories are
expected to implement the changes outlined in the Violation Recommendation Summary before the re-
audit. Pacific Sunwear reserves the right to discontinue business with any factories that do not strive to
comply with Pacific Sunwear Compliance Program Guidelines.

A. EXPLANATION OF VIOLATIONS
The type of violation and the extent of deviance are a consideration in the assessment of risk level. A
determinant factor in the assessment will be whether the violation was deemed willful. Willful violation
would be considered manipulative and result in a failing audit status.
A violation occurs when a contractor violates either a law of his/her country or a standard in the Code of
Conduct. The categories listed provide general standards upon which monitors assess the workplace
environment. Please note that individual country regulations and restrictions MAY be more restrictive than
these generalities.
Discrimination:
Religious Discrimination: This type of discrimination occurs when the employees are treated differently
according to their religion. This includes denial of work, denial of promotions, differing pay rates, differing
benefits, and differing disciplinary practices. Also, religious observance, i.e. prayer breaks, holidays,
should not be prohibited.
Racial Discrimination: This type of discrimination occurs when employees are treated differently on the
basis of their race. As with any discrimination, this includes denial of work, denial of promotions, differing
pay rates, differing benefits, and differing disciplinary practices.
Gender Discrimination: This refers to any instance where a female employee is treated differently due to
her gender. Examples include pregnancy testing, firing pregnant employees, denial of promotions, denial
or employment, different pay scales for the same job, and other differential treatment.
Medical Discrimination: This may occur when employers screen potential applicants for hire and require
medical examinations. The exam itself is not discriminatory but if the results of the exam are used in an
exclusionary manner to prevent an employee from being hired, this is discriminatory. Employees who
become ill or injured should not be fired for this cause.
Pregnancy Testing: This can be viewed as gender and medical discrimination. While it may not be
against the law, it is viewed as discrimination by human rights groups and the general public. Similarly to

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medical discrimination, if the results of a pregnancy test are used to exclude women from employment,
this is discrimination. Manufacturers should be careful not to allow contractors to conduct these tests.
No Harassment
To harass is to wear out or exhaust, to irritate or torment persistently. Sexual harassment is the making
of unwanted and offensive sexual advances or of sexually offensive remarks or acts. Some companies
may use harassment techniques to pressure employees to behave a certain way. Many countries have
laws prohibiting harassment of employees involved in union activities as well as prohibition of sexual
harassment in the workplace. Harassment is not an acceptable form of management.

Forced Labor:
This occurs when an employer forces their employees to work against their will, ability, or in a manner
outside the provisions of the labor contract. Examples include instances when the employer requires
overtime against the will of the employee or sick employees are not allowed to leave the factory to go
home.

No Child Labor:
Child labor violations include not only employing underage children but also employing a minor in a
prohibited job, such as a night shifts or hazardous work stations. Proof of age documentation must be
available for all employees in the form of birth certificate, government identification card, or other official
documents in order to verify age and thereby compliance with legal age limitations. Also, additional
documents may be required for minors, including school completion certificates, doctor certificates, or
permission from parents.

Wages and Benefits:

Off Clock Work: If employees work off the clock, they may be paid in cash, which leads to tax and social
security problems. They also cannot be guaranteed the minimum wage and/or overtime.
Cash Pay: In Canada and the U.S.A. cash pay is a violation because if an employee is paid in cash, then
the records can be altered, allowing for evasion of taxes and social security. Furthermore, employers can
violate minimum wage and overtime regulations.
Unpaid training: A violation occurs if the employer does not pay a trainee the amount that he/she should
receive according to the law.
Minimum Wage: The minimum wage is set either nationally, regionally, or by occupation. If an employee
is paid by piece instead of hour, the employee must receive a wage equal to or above minimum wage.
Any compensation below the minimum wage set by an individual country is a violation.
Overtime: All hours worked above the normal workweek must be compensated at the overtime rate
specified by the individual country’s labor code. This is regardless of any industry practice which may
deny workers overtime. Overtime is to be paid within the working month or as specified by individual
country law.
Record Keeping: The employer must keep adequate records on his employers including their personal
information (name, address…), wages, hours worked, and money received. Also, in some countries,
contractors need to have factory license and health insurance for the employees.
Excessive Deductions: This occurs when an employer subtracts more money than required or is legally
permitted from the employee’s pay.

Work Hours:
Time Cards: All hours worked must be tracked in order to ensure correct payment of minimum wage and
overtime. Absence of an adequate system of tracking hours worked means that correct pay for hours
worked cannot be verified. Time card violations occur if an employer shaves off time or manipulates the
hours punched on the timecard. Sometimes, one employee has multiple time cards or one employee
punches in for all employees. In order to avoid these problems, time cards should include employee
name, week ending date, employee signature, and the employee should initial any changes made to this
record.
Freedom of Association:
Most countries require that employers allow employees the freedom to choose to associate or not to
associate with trade unions and other employee organizations. Even where these rights are restricted by

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the country law, employers should facilitate worker organizations within the company. Employees should
be allowed to select worker representatives and representatives should have access to company
management in order to address grievances and other issues.

Health and Safety:

Violations occur when factories have unsanitary or unhealthy conditions that pose a danger to employees’
well being. Sanitary conditions, good lighting and ventilation, employee training, and emergency
preparation are all necessary for an acceptable work environment.

Environmental Standards:
International environmental standards, and most country regulations, require control of air emissions,
wastewater processes, labeling of chemicals, storage of hazardous materials, reduction or elimination of
PCB and asbestos use, and many other issues. Employers must monitor their work environment to
determine noise and temperature levels, emission levels for chemicals and pollution, and other areas that
may present hazards to employees and the community as a whole. Then they must take the necessary
steps to ensure that all processes are within national or international limits. This allows the company to
take responsibility of caring for their employees and their community.

Subcontracting:
Many possible violations result from subcontracting. If work is sent outside the factory, then the factory
can no longer guarantee the conditions in which the work is produced. Therefore, there is a risk of child
labor, homework, minimum wage and overtime violations, etc.

Homework:
Like subcontracting, homework can result in violations because the conditions in which the work is done
are unknown. Child labor, overtime, and minimum wage violations are common results of homework. In
order to avoid these violations, any homework conducted must be meticulously tracked, including records
of exact hours worked, files of all home worker employees, and documented health and safety and child
labor checks conducted by factory personnel. A copy of all home workers’ records is to be kept and
readily available on file in the factory.

PACIFIC SUNWEAR SECURITY STANDARDS FOR FACTORIES

Physical Security
1. Grounds: Unbroken fencing must surround the factory premises and gates must have adequate
locking devices.
2. Parking: The parking lot must have lighting, and private vehicles must not park in the immediate
vicinity of the shipping/loading dock areas.
3. Buildings: External and internal doors must have adequate locks while all windows must have
locks that prevent opening from outside. Windows and doors must be locked at all times when
building is not occupied.
4. Adequate lighting must be provided inside and outside the factory, including all access points.
5. International, domestic, high-value, and dangerous goods cargo must be marked and segregated
within the warehouse of the factory by a safe, caged, or otherwise fenced-in area.
6. The packing and loading areas must be segregated from the rest of the factory in a way that is
sufficient to provide secure access restriction

Access Controls
1. Employees’ identities must be verified by security personnel before being allowed onto factory
grounds.
2. Employees must be issued a factory [photo] identification badge and this badge must be
displayed at all times while on factory grounds.

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 3. Visitors and vendors must present government issued photo identification to be verified and
logged by security personnel before receiving a visitor’s badge.
4. Visitors and vendors must be monitored by an authorized employee during their visit at the
facility.
5. Access to the packing, loading, shipping, cargo and hazardous material storage areas must be
restricted to authorized personnel only. The facility must have procedures to verify the identity
and authorize all persons entering these areas.
6. The facility must have procedures in place to challenge unauthorized/unidentified persons.

Procedural Security
1. The facility must have procedures to ensure the timely movement of incoming/outgoing goods.
2. Factory must be able to provide documented proof regarding the origin of product components for
any given shipment upon request by the Client or its agent.
3. The factory must have verification procedures in place so that all shipments are properly labeled,
marked, weighed, counted, and documented.
4. The factory must have procedures to track and locate goods and materials throughout the facility.
5. Facility must have procedures to detect and report product and material shortages or overages
during the receiving process, while conducting inventory, and before shipping.
6. The factory must have procedures in place to maintain the integrity of data by preventing
unauthorized personnel from making any unauthorized changes.
7. The factory must have procedures to notify local law enforcement agencies and/or Customs and
Border Protection in the event anomalies or illegal activities or suspicious behavior is detected.
8. The factory must have formal, written procedures pertaining to their security policies. These
procedures must be updated continuously as well.

Personnel Security
1. The factory must conduct pre-employment screening and interviewing of all prospective
employees, including contract and temporary employees.
2. As a standard hiring procedure, a copy of the employee’s government issued identity document
must be made. This applies to temporary, import, and contract workers as well.

Information Technology
1. The factory must protect its IT system from illegal use and access through the use of firewalls,
employee passwords, and anti-virus software.
2. The factory must have a written security policy for the facility computer information systems. This
policy should define which employees are to be granted user rights and define acceptable use of
hardware and software.

Education and Training Awareness

1. The factory must have a mandatory security-training program for all of its employees to cover, at
a minimum, recognizing internal conspiracies, maintaining product integrity, challenging
unauthorized access, and promoting threat awareness.

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CODE OF CONDUCT

PACIFIC SUNWEAR’S CODE OF CONDUCT

Management System

Publicly available policy committed to Social Accountability and compliance with applicable
laws and other requirements.

1. The factory is to operate in full compliance with the laws of their respective countries
and with all applicable laws, rules, and regulations, including those regarding labor,
worker health and safety and the environment.

2. The factory shall allow the Social Compliance Officer unrestricted access to all areas of
the facilities and to all relevant records at all times, whether or not advance notice has
been provided.

Child Labor

No person shall be employed at an age younger than 16 or over the age for completion of
compulsory education or country legal working age, whichever is higher.

Forced Labor

There shall not be any use of forced labor, whether in the form of prison labor, indentured
labor, bonded labor or otherwise.

Working Conditions

The factory, bearing in mind the prevailing knowledge of the industry and of any specific
hazards, shall provide a safe and healthy working environment, including
systems and training designed to help prevent accident and injuries. The factory shall
appoint a senior management representative who is responsible for the health and safety of
all personnel, and is accountable for the implementation of the health and safety elements
of this standard.

Freedom of Association and Right to Collective Bargaining

The factory shall recognize and respect the right of employees to freedom of association and
collective bargaining.

Discrimination

No person shall 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.

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Disciplinary Practices

Every employee shall be treated with respect and dignity. The factory shall not engage in or
support the use of corporal punishment, mental or physical coercion and verbal abuse
including but not limited to threats of violence and sexual harassment.

Compensation/Hours

The company shall ensure that wages paid for a standard working week shall meet at least
the legal or the local industry minimum standards, which ever is greater and shall always be
sufficient to meet the basic needs of personnel and to provide some discretionary income.

Environmental

All factories must comply with applicable environmental laws and regulations.

1. The factory has an environmental plan or management system, such as ISO 14001.

2. The factory has procedures for notifying local community authorities in case of accident
discharge or any other environmental emergency.

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IMPORTANT CONTACTS
Please contact the following individuals for assistance at any stage of the audit process.

Pacific Sunwear STR-Responsible Sourcing

Contact person James Choi David Vargas
Manager, Regulatory and Social Account Representative
Title
Compliance
Address: 3450 E Miraloma Ave 5777 W. Century Blvd Ste 1790
Address Anaheim, CA 92806 Los Angeles CA 90045

714-414-4580 310-215-0554 ext 522

Phone
Email jchoi@pacsun.com David.vargas@strrs.com

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REFERENCE SECTION
A. SOCIAL COMPLIANCE EVALUATION CHECKLIST
This preparatory checklist is an overview of a standard social compliance audit. It represents the general
guidelines against which STR-RS’s consultants will measure your facility.

Child Labor
 Copies of adequate proof of age documents available for all employees, including photo
identification
 Visual check of all areas of factory to ensure that no children are in the facility (even if the
children are not working, it is not advisable for children to be on the premises)
 Documents such as proof of age and signed and valid labor contracts are available for randomly
selected employees on the work floor

Wage and Hour

 The number of employees present matches the number of timecards punched and number of
people on payroll
 Average hours worked as shown on timecards does not exceed legal limit
 All deductions shown on pay journal are legal and made with the employee’s consent
 Hours worked and overtime are calculated and compensated correctly
 Employees are aware of terms of either written or oral employment contracts
 Employee reports match findings of payroll and timecard records

Employee Environment
 Employees are selected randomly to be privately interviewed
 The interviews are used to confirm the working conditions viewed, the records audited, and the
statements of factory management
 Employees freely have access to restroom breaks and potable water
 Do employee reports match other findings?

Quota, Shipping, Subcontracting

 Packing, shipping, and trash areas are checked for evidence of diverted shipments
 Names and addresses of subcontractors are disclosed
 Labels and work on production floor match work orders
 Appropriate security procedures, policies, and documentation

Health and Safety: First Aid

 At least one easily accessible first aid kit per clearly separated work area, or one first aid kit for
every 100 workers
 At least one person per first aid kit who is trained in first aid application
 Ideal contents of first aid kit to include: adhesive bandages, flexible fabric bandages, combine
pad, ammonia inhalants, instant cold packs, elastic bandages, burn cream, cotton balls, first aid
cream, disposable gloves, adhesive tape, forceps (tweezers), eye wash, antiseptic wipes, and
rubbing alcohol

Health and Safety: Exits

 At least two exist per floor that are clearly marked, unlocked, and unblocked
 Exit signs visible
 Emergency lights in stairwells and at exits

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  Exit doors open outward and are at least two people wide
 Exits open directly to outside or exterior stairwell

Health and Safety: Aisles

 Main and secondary aisles are at least two people wide
 Main aisles are clearly marked and are illuminated during emergencies
 All aisles must be clear of obstruction and kept clean of sewing scraps

Health and Safety: Evacuation Plan

 Illustrated evacuation plan in clear view on each work floor
 Evacuation plan in native language of workers
 Evacuation drills conducted at least semi-annually

Health and Safety: Fire Equipment

 Accessible fire extinguishers and/or hoses in clear view on each floor
 Adequate number and location: one extinguisher per clearly separated work area; one
extinguisher per 25 employees; one extinguisher per 75 feet circumference
 Fire extinguishers mounted on walls or columns; visible and accessible
 Fire extinguishers are serviced annually, with tags indicating dates of service
 Written instructions on operation of a fire extinguisher should be posted in the employees’ native
language

Health and Safety: Restrooms

 Restrooms are clean and functional, with running water and covered waste containers
 Adequate number of water closets: 1 per 25 female employees, 1 per 50 male employees, and/or
1 per 40 employees regardless of gender for a workforce of 150 or more
 Toilets are cleaned daily, and supplies such as toilet tissue, soap, and towels must be available
 Toilets must be segregated by gender
 Toilets must be provided with adequate privacy (doors on stalls)

Health and Safety: Work Environment

 Adequate climate control and ventilation; suggested temperature range is 15 to 30 degrees
Celsius (60 to 86 degrees Fahrenheit)
 Adequate lighting for cutting, sewing, finishing, and warehouse; suggested lighting for cutting,
sewing, and finishing is 300 to 500 foot candles, and suggested lighting for warehouse operations
is 30 to 50 foot candles
 Noise control; suggested noise level is 85 decibels. Employees should not be subjected to more
than 85 decibels for 8 continuous hours. An environment where noise level is above 85 decibels
requires hearing protection.
 Protective equipment must be provided to workers; recommended protective gear includes cover
guards and belt guards for sharp objects or exposed moving parts, appropriate footwear for
special areas of the facility, cutting gloves for cutters, other as appropriate

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 B. DOCUMENT REQUEST LIST

In preparation for the site visit, the following documents should be made available to facilitate the visit.
Pacific Sunwear or its appointed representative (STR-RS) will expect to review these documents as part
of the monitoring process.

Document Name Yes No N/A

Child Labor
Employee files (including job application, employment contracts, discipline letters, etc.)
Copies of adequate proof of age documents available for all employees, including photo ID
Restrictions on workers below the age of unrestricted employment

Wage and Hour (for four payroll periods)

Payroll journal
Timecards or time registers
Piece rate tickets
Signed pay stubs (if employees do not sign the payroll journal)
Proof of payment of tax, social security, or applicable benefits from employee deductions
Explanation of deductions on employee wages

Factory Policies and Structure

Employee handbook / terms and conditions of employment
Government Licenses, Certificates of Operation
Wage and hour policies
Disciplinary Procedure and Policy
Security structure (Alarm system documentation, Security Guards)
Union membership documentation

Health and Safety

Inspection Reports re: sanitation, fire safety, worker safety, structural safety, etc.
Machinery inspection / service logs
Policies / procedures on use of personal protective equipment
Accident / injury log
Emergency medical procedures
Evacuation plan and procedures

Dormitories
Government Licenses, Certificates of Operation, Inspection Reports re: sanitation, fire and
structural safety, etc.
Dormitory rules and regulations

Quota, Transshipment, Subcontracting

Quota and shipping documents
Names, addresses, and functions of subcontractors

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C. INTERNATIONAL HEALTH & SAFETY EVALUATION FORM

VENTILATION AND SANITATION

Must
Yes No Improve

* Facilities adequately ventilated, cooled or heated for the local environment?   

* Windows, fans, air conditioners or heaters are operational for air circulation, ventilation and   
provide an acceptable work floor temperature. (Recommended 16 C - 30 C.)
* Exhaust fans are kept clean of accumulated dust and debris.   
* Exhaust fans are operational at all times during work hours.   
* Chemicals are contained in a separate, well-ventilated room with open windows available.   
* Are hazardous fumes neutralized or scrubbed?   
* Is there sufficient ventilation in enclosed spaces where heat generation is operated?   
* Is there appropriate ventilation in areas where workers engage in strenuous activity such   
as continuous lifting of heavy objects?
* A sufficient number of toilet facilities are made available.   
Ratio (toilet facilities/employee population): Employees Water closets
1 – 15 1
16 – 35 2
36 – 55 3
56 – 80 4
81 – 110 5
111 – 150 6
* Toilets are cleaned daily.   
* Toilets are provided with appropriate privacy (stalls with doors).   
* Toilets are plumbed with running water and basic supplies (western toilets).   
* Supplies: soap, towels, toilet paper.   
* Non-Western or squat toilets provide clean running water.   
* Toilets are lighted and ventilated.   
* Unrestricted access to toilets at all times.   
* Toilets are available on each floor, and are separated according to gender.   
* Employees have access to clean water for washing within close proximity to toilet..   
* Food preparation areas are separate from the work area.   
* Eating facilities are covered protecting the employees from the elements (sun and rain).   
* There are adequate facilities for eating and is well lighted—tables and chairs provided.   
* Food preparation area has a refrigeration unit, fire equipment, and potable water.   
* Unrestricted potable water is provided all employees.   
* Food preparation area is cleaned and disinfected daily.   
* Canteen or food service personnel are outside contractors and not considered employees   
of the production facility.

Notes:

WORKFLOOR
Must

16
 Yes No Improve

* Aisle space between each workstation allows for free body movement and adequate room   
for emergency evacuation.
Minimum width per secondary aisle: 36 inches
Minimum width per primary aisle: 60 inches
* All work areas are well illuminated. Suggested light levels in foot candles:   
Pressing, Inspection, Cutting and Manufacturing: 300 – 500
Warehouses: 20 – 50
Office (general): 28 – 50
* Aisles are clear of production, tables and chairs.   
* Unobstructed vision of the work floor from the employee work station.   
* Work floor is marked with yellow emergency lines leading to exit doors; pathways are clear   
of all obstructions.
* Trash cleared from heat generating machinery, boilers, furnaces, compressors, etc.   
* Empty pallets are stored flat rather than on edge or side in a specified area.   
* All doors are 48 inches wide or greater (122 cm).   
* All doors open outwards.   
* Emergency exits are marked with letters 18 cm high and illuminated with emergency   
lights.
* Emergency signs are visible up to 100 ft.   
* Emergency lights are located above exits and on stairwells.   

Notes:

MAINTENANCE
Must
Yes No Improve

* Grounds and facility are cleared of rubbish daily.   

* Facility is maintained to acceptable local standards. (paint, windows, grounds)   
* Rubbish is removed to a legitimate dump site, not deposited directly into the environment.   
* Is chemical waste released directly into the environment?   
* Facility has procedures for recycling or reusing materials whenever possible.   
* Machines are maintained as required by manufacturing instructions and have all pulley   
guards in place.
* Personal safety equipment is provided at no charge to the workers.   
* Workers exposed to hazardous chemicals, heat and noise wear designated protective   
equipment.
* Employees are not subject to noise of 85 or more decibels for 8 continuous hours.   
* All cutting machines are fitted for ―two-click‖ operation.   
* All open roll mills are fitted with emergency brake systems.   
Must
Yes No Improve

* Safety devices and conditions to check include:   

Front and side guards on abrasive wheels
Needle guards and pulley guards on sewing machines
Knife guards on cutting machines
Plastic eye guard on button-sewing machines

17
 Emergency release and pressing bed controls on pressing machine
Finger guard for automatic welt pocket machines
* Individual machines have an individual power shut-off switch within reach of the operator.   
* Factory inspection logs and service records are maintained for compressors, boilers,   
embroidery machines and other factory equipment.
* Factory provides all production workers, during orientation and ongoing training, instruction   
in general factory safety and in the safe operation of their machines.

Notes:

FIRE SAFETY
Must
Yes No Improve

Fire Equipment
* Fire extinguishers and/or hoses, with water pressure sufficient to power the hose, are   
placed no further than 75 feet from any employee.
* There is approximately one fire extinguisher for every 25 employees.   
* Extinguishers are placed in accessible, clearly marked locations.   
* A satisfactory number of employees are trained to use extinguishers.   
* Operating instructions are placed, in local language, near the extinguishers.   
* Other fire fighting equipment is available (hoses, sprinklers, etc.).   
* Fire equipment is serviced by the fire department or other outside agency every 6 months   
and are tagged with inspection dates.
* Fire extinguishers are checked monthly.   
* Fire extinguishers are mounted on walls and columns and are visible and accessible.   
* Fire extinguishers are labeled with the type of fire they are to be used for:   
Class A - Ordinary combustible material fires
Class B - Flammable liquid, gas or grease fires
Class C - Electrical equipment fires
* Combustible materials are stored in a contained area with fire equipment within.   
Outside material storage - 75 ft
Internal flammable liquids - 10 ft
* Fire hydrants are flushed and hoses tested annually.   
Fire Alarms
* The fire alarm is audible throughout the facility.   
* Facility has visual plus visual or personal notification procedure to supplement the audible   
alarm.
Must
Yes No Improve

* All alarm devices are tested at minimum twice annually.   

* All personnel are informed of the fire alarm system during new employee orientation.   
Emergency Exits
* Evacuation plot plan is posted, indicating which doors are to be used for emergency exits.   
* Emergency exit doors are unlocked and unobstructed.   
* There are at least two unlocked, accessible exits on each work floor.   
* Exits open directly to the outdoors or exterior stairway.   
* Corridors leading to exits are clear, and approximately 36 inches wide.   

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* No employee workstation is more than 200 feet from an exit   
* Evacuation drills are conducted twice annually. Drill must include alarms, fire fighting   
equipment, emergency shutdown, evacuation routes and gathering areas.
* All exit routes are adequately lighted.   
* Emergency lighting is provided for up to 60 minutes.   
* Exits are marked with signs visible up to 100 feet.   
* Employees are trained in evacuation procedures and the use of all fire equipment.   
* Practice evacuations are conducted at least semi-annually.   
* Supervisors or other personnel should be trained in basic first aid procedures.   

Notes:

FIRST AID AND MEDICAL SERVICES

Must
Yes No Improve

* Is there a hospital, clinic or other medical facility in proximity of the workplace?   

Type of facility: ____________________ Distance: __________ km
* Is there at least one of the employees on each shift qualified to render first aid?   
* Is this person licensed?   
* Are controlled substances issued to the workers?   
Prescription drugs 
Narcotics 
Sedatives 
* A ―substance dispense‖ record is maintained listing medication and condition.   
* Are medical procedures performed within the facility and/or employee housing units?   
* A Serious Injury Illness Log is maintained listing that lists information on every injury   
requiring medical treatment.
* Have first aid kits been supplied by a reputable medical supply company indicating that   
they are adequate for a particular area or operation?

* First aid kit contents:

Adhesive bandages  Adhesive tape 
Ammonia inhalants  Antiseptic wipes 
Burn cream  Combine pad 
Disposable gloves  Elastic bandages 
Eye wash  First aid cream 
Flexible fabric bandages  Forceps (tweezers) 
Instant cold packs  Alcohol 
Cotton balls 
Must
Yes No Improve

* One stocked first aid kit is made available for every 100 workers in a facility.   
* Workers are encouraged to seek first aid, and are informed of proper procedures for   
seeking necessary assistance.
* First aid supplies are available on each floor.   
* First aid kits are always available for use.   
* Kits are inspected periodically, and restocked whenever necessary.   

19
* Are emergency numbers for injury or accident prominently posted?   
* Are records kept for injuries and accidents?   
* Does the factory operate a medical clinic?   
If yes, describe: ______________________________________________
* If so, does the clinic give injections?   
* Are proper procedures followed regarding needle use and disposal?   

Notes:

ELECTRICAL SAFETY AND PROTECTIVE EQUIPMENT

Must
Yes No Improve

* Electrical panels with circuit breakers are installed and maintained in satisfactory condition.   
* Electrical cords are in good condition, continuous in length and without splices, or taped   
repairs.
* Power cords to production equipment are grounded, i.e. containing a third prong.   
* Impact-resistant goggles or other eyewear are provided to workers subject to flying objects,   
metal tailings, persistent glare, toxic/hazardous liquids, or a high degree of dust.
* Machine operators applying glue and solvents have mouth-guards. (Paper guards do not   
screen out dangerous substances.)
* Workers routinely subject to noise measured at more than 80 decibels are provided   
earplugs.
* Workers using sharp objects or who are subjected to toxic substances are provided   
protective gloves.
* Dangerous equipment and machinery has safety guards.   
* Workers in washing plants, dye houses or similar operations are provided protective   
footwear.
Must
Yes No Improve

* Emergency generators are maintained on-site, with regulated ―brown-outs.‖   

* Emergency candles and/or flashlights are kept on the premises.   

Notes:

CHEMICALS AND HAZARDOUS MATERIALS

Chemical and Gas Storage and Usage

Chemicals and how they are stored: Gases and how they are stored: STORAGE

([FL] flammable [CR] corrosive (cylinder/line system)

[OX] oxidizer [CB] combustible) List gases used by the facility:
FL CR OX CB CYL LINE
    
Container size: Annual volume used:

20
     
Container size: Annual volume used:

    
Container size: Annual volume used:

    
Container size: Annual volume used:

    
Container size: Annual volume used:

Must
Yes No Improve

* Chemicals and hazardous materials are stored in an area designed for and dedicated to   
the storage of such substances.
* Secondary containment materials are appropriate for the type of chemicals stored.   
* Anything related to hazardous materials is labeled appropriately.   
Areas of concern:
Yes No Yes No
Storage area is properly labeled.   Labels include chemical name.  
Containers are properly labeled.   Labels include chemical abstract.  
Chemical use areas are properly identified.   Waste is properly identified.  
No Smoking signs posted where required.   Emergency codes appear where required.  
All secondary containers clearly labeled.   (IMDG/IATA/NFPA)
* Storage areas equipped with:
Yes No Yes No
Signs that warn against mixing hazards.   Sprinklers.  
Proper ventilation.   FIFO tracking documentation.  
Fire extinguishers.   Temperature control.  
Material Safety Data Sheet
Must
Yes No Improve

* Organization has acquired and implemented a MSDS program.   

Must
Yes No Improve

* MSDS is listed by company and by chemical.   

* MSDS resources are available in appropriate language(s).   
* MSDS resources are centrally located.   
* MSDS resources are departmentally located.   
* Organization’s training program includes documented MSDS education.   
* MSDS training is ongoing.   
Frequency of training: _______________________________________
* There are specially trained staff (emergency personnel) who can respond to situations   
regarding hazardous materials.
Staff Use of Chemicals: Safety
* There is a documented safety program dedicated to all staff who come into contact with   
chemicals and hazardous materials.
* Duration of Exposure has been identified for hazardous materials, and is actively   
monitored.
* Safety equipment provided:
Yes No Yes No
Proper ventilation   Respirators  
Gloves   Showers  
Aprons   Eye wash  

21
 Blood tests   Medical reviews  
Hazardous Waste Management
Must
Yes No Improve

* Proper methods for neutralizing waste have been identified.   

* Waste is neutralized using proper methods, and in a timely manner.   
How often is hazardous waste removed? ____________________
* Waste is stored in an area segregated from new material.   
* Waste removal is actively monitored by the organization, including:
Yes No Yes No
Analyticals   Volumes  
Bill of lading  

22