INITIAL ELECTRICAL ASSESSMENT REPORT (EAR)

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1 INITIAL ELECTRICAL ASSESSMENT REPORT (EAR) Factory Name: Maks Fashion Ltd 1 Kapashgola Road Chawkbazar Chittagong Chittagong Bangladesh 19 Apr 2014 The Alliance for Bangladesh Worker Safety Page 1/15

2 19 Apr 2014 Introduction to the Report The following report contains a site profile and summary of non-conformities identified during an onsite assessment commissioned by the Alliance for Bangladesh Worker Safety (Alliance) and conducted by a third-party Qualified Assessment Firm (QAF). The assessment was conducted against the Alliance for Bangladesh Worker Safety Assessment Protocols (APs) and Fire Safety and Structural Integrity Standard, which is harmonized with the factory assessment guidelines developed by Bangladesh University of Engineering and Technology (BUET) for the Bangladesh National Tripartite Plan of Action (NTPA). The goal of the Alliance process is to provide clear and practical technical requirements by which Bangladeshi Ready Made Garment (RMG) Factories producing for Alliance members may be consistently and fairly evaluated for fire, structural, and electrical safety in a non-duplicative manner. Each assessment will prompt action plans that will be used by RMG factories to systematically and sustainably improve safety conditions for garment workers. Beyond tracking and reporting on action steps taken in a transparent manner, the Alliance organization and its members will seek to further support factory improvements through technical assistance, training, implementation support for functional Worker Committees, and in some cases financial assistance and wage support for workers if factories are closed for remediation. The contents of the report do not constitute a guarantee of compliance with the applicable laws, the Alliance Standard or the absolute or continued safety against fire, electrical and/or structural integrity issues that may lead to injury or loss of life. The report is designed to provide a non-exhaustive summary of risk issues, based on a limited sampling and duration of time onsite by the named QAF. Neither the QAF nor the Alliance can certify or guarantee the quality, outcome, or effectiveness of actions taken in response to the report. For more information and report feedback please go to: The Alliance for Bangladesh Worker Safety Page 2/15

3 19 Apr 2014 GENERAL INFORMATION General Information Factory Name: Country: Province: City: Maks Fashion Ltd Bangladesh Chittagong Chittagong Zip Code: 4203 Audit Duration: Re-Audit: 1 Days Re-Audit After 0 Months Draft Report Date : June 8, 2014 Final Report Date : June 8, 2014 Are all action items from previous assessment complete? : Buildings in Complex : Is the building(s) owned or rented by the Factory?: Number of Building Levels (Stories) : Approximate Building Area (SF) : Date of Building Construction : Date of Last Building Renovation/Addition : Ancillary Structures in Complex : Approximate Ancillary Structures Area (SF) : N/A 1- Main Building Rented 6 story + tin shed (7th story) 37,800 sft Construction started in 1974 and partially completed in floor extension is completed at None NA Number of Occupants : 433 The Alliance for Bangladesh Worker Safety Page 3/15

4 19 Apr 2014 The Alliance for Bangladesh Worker Safety Page 4/15

5 19 Apr 2014 ASSESSMENT FINDINGS Electrical System Information Are as-built electrical drawings indicating information such as panel and circuit locations throughout the building(s) available for review? Non-Compliance Level: 2 The factory management provided equipment/electrical layout drawing, however, one-line diagrams were not available. Additionally, no grounding (earthing) drawings or power distribution schedules were available. Document Review: One-line diagrams were not available for review. No grounding (earthing) drawings or power distribution schedules were available for review Have a qualified electrical engineer develop an as-built single line diagram detailing key components and capacity of the electrical system. Additionally, grounding layout drawings should be developed and made available. Alliance Standard Part 10 Section Electrical System Maintenance Have workers that operate and maintain the electrical system received electrical safety training? Is training documentation on site? No documented electrical safety training for the maintenance staff was available for review. Document Review: No documented electrical safety training for the maintenance staff was available for review. Develop an electrical safety training program for all workers that may be exposed to electrical safety hazards. Training program should be in line with NFPA 70E: STANDARD FOR ELECTRICAL SAFETY IN THE WORKPLACE or equivalent standard. Agenda, materials, and attendance should be documented and kept on file for review. Reference NFPA 70e for example The Alliance for Bangladesh Worker Safety Page 5/15

6 19 Apr 2014 Is a periodical Insulation Resistance Measurement Program established and recorded? No Insulation resistance measurement program is established per Alliance Standard Part 10 Section Insulation Tests and Electrical Inspections. Document Review: No Insulation resistance measurement program available Develop an Insulation Resistance Measurement Program that ensures deterioration of insulation resistance will be identified quickly. Testing should be in compliance with International Electrical Testing Association (NETA). All transformers, switchgears etc. shall be subject to an insulation resistance measurement test to ground after installation but before any wiring is connected. Insulation tests shall be made between open contacts of circuit breakers, switches etc. and between each phase and earth. Alliance Standard Part 10 Section Insulation Tests and Electrical Inspections Are records concerning the testing and inspection of the electrical systems maintained on site and up to date? No records concerning the testing and inspection of the electrical systems were maintained on site. Document Review: No records concerning the testing and inspection of the electrical systems were available Develop an electrical maintenance program that includes inspections and testing of the electrical systems. Reference NFPA 70 for example program requirements. Alliance Standards Part 10 Section Electrical Inspections Are thermographic scans of electrical equipment completed at least every three years? The Alliance for Bangladesh Worker Safety Page 6/15

7 19 Apr 2014 No thermographic scanning is conducted. Worker Interviews: Management confirms no thermographic scanning is conducted Thermographic scanning should be part of the electrical maintenance program. Complete thermographic scans at least on a three year cycle. Thermographic scans should be completed in accordance with the Standard for Infrared Inspection of Electrical Systems & Rotating Equipment and NFPA70B or a comparable standard. Alliance Standards Part 10 Section Electrical Inspections Are periodic safety inspections of the electrical system components completed and documented? Non-Compliance Level: 2 The in-house Engineer reportedly inspected periodically but no documentation could be provided. Document Review: No documented periodic inspection available. "Establish a periodic inspection program to ensure the electrical systems are free from damage, debris, dirt, lint, etc. Maintain records concerning inspections and follow up actions. Alliance Standard Part 10 Section Inspection and Testing and Part 13 Section 13.6 Housekeeping Is the electrical switchgear and panel boards inspected on an annual basis to ensure that the equipment is installed in accordance with the listed ratings? Non-Compliance Level: 2 The factory management team informed us they did inspect on annual basis but could not provide inspection records. Document Review: No inspection records available. Develop an electrical maintenance program that includes regular and fully documents inspections and testing of the electrical systems. Electrical switchgear and panel boards should be inspected on an annual basis to ensure that the equipment is installed in accordance with the listed ratings The Alliance for Bangladesh Worker Safety Page 7/15

8 19 Apr 2014 Alliance Standards Part 10 Section Electrical Inspections Electrical System Conditions Are all switchboards and/or distribution boards metal enclosed with a dead front construction? Non-Compliance Level: 1 Generator circuit breaker was not enclosed in a metal box with dead front construction. Photograph: Photo of unprotected breaker Enclose generator circuit breaker in approved metal enclosure with dead front construction. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear No circuits are drawn for loads without the incorporation of a overcurrent protection device (circuit breaker). Non-Compliance Level: 1 There was no ground fault protection on Generator as per IEEE. Visual Assessment: No ground fault protection observed on Generator Install isolation monitoring devices on generator system to identify earth faults and to take remedial actions before there is an power cuts. Generators must be provided with protective relays which, in case of a fault, quickly initiate a disconnection of the machine from the system and, if necessary, initiate a complete shut down of the machine. Alliance Standards Part 10 Section 10.9 Protection of Circuits Do switchboards and/or distribution boards have clear identification markings? There was no permanent identification found on any switchboards and/or The Alliance for Bangladesh Worker Safety Page 8/15

9 19 Apr 2014 distribution boards in the factory. Panel Schedules were not provided on any of the panel boards. Visual Assessment: There was no permanent identification observed on any switchboards and/or distribution boards All distribution boards shall be marked "Lighting" or "Power", as the case may be, provided a unique ID number (e.g. MDB-1) and also be marked with the voltage and number of phases of the supply. Each shall be provided with a circuit list giving diagram of each circuit which it controls and the current rating for the circuit and size of fuse element (panel schedule). 30 Jun 2014 Alliance Standard Part 10 Section 10.7 BNBC Part 8 Section Do switchboards and/or distribution boards have capacity information labels? None of the switchboards and/or distribution boards in the factory have capacity information labels Visual Assessment: Capacity information labels not observed. Label all switchboards and/or distribution boards in the factory with capacity information. The permanent label should identify the maximum voltage present in an item of equipment or within the enclosure. 30 Jun 2014 Alliance Standard Part 10 Section 10.7 Main Switch, Switchboards And Metal Clad Switchgear and Inspection of the Installation A wire/cable shaft is provided for the whole building. Wiring and cables are arranged in shaft for ease of inspection and maintenance. A wire/cable shaft is not provided for the whole building as per BNBC Part 8 Section Cables are transferred through floor systems without protection (rigid conduit), fire stopping materials, or fire rated shaft. Photograph: Photo of cabling run through floor to floor penetrations Install vertical shaft of 200 mm x 400 mm size for every 1500 m2 floor area. Shaft should be installed with free and easy access to the electrical shaft room in each floor must be available for operation, maintenance and emergency shut downs. CWhere a wiring system passes through elements of building construction such as floors, walls, roofs, ceilings, partitions or cavity barriers, The Alliance for Bangladesh Worker Safety Page 9/15

10 19 Apr 2014 the openings remaining after passage of the wiring system shall be sealed according to the degree of fire resistance prescribed for the respective element of building construction before penetration. BNBC Part 8 Section Electrical wiring and conduit is properly supported. Inspectors observed several instances of flexible cabling and conduit in production areas. Photograph: Photo of example of unsupported conduit. All cabling and wiring must be supported and covered for safety. Install cable trays/ladder/risers or rigid conduits to prevent from mechanical stress and physical damages. Flexible conduits as noted must be firmly affixed to the walls. Alliance Standard Part 10 Section , , and Are junction boxes and other electrical devices provided with covers? Non-Compliance Level: 2 Several switch boxes were broken or had missing covers. This was common finding throughout factory. Photograph: Photos of broken or missing switch covers Repair/replace all broken or missing switch covers. Alliance Standard Part 10 Section and The Alliance for Bangladesh Worker Safety Page 10/15

11 19 Apr 2014 Electrical connections at equipment, fixtures, etc are properly secured. Non-Compliance Level: 1 Ceiling fan connections in the canteen (roof area) were not secured and covered. Additionally, wiring for lighting in the canteen was not properly covered and secured. Photograph: Photo of ceiling fan and lighting connections Assure that canopies of all ceiling fans are closed and no wiring or coils are exposed. Electrical connections for lighting should also be properly enclosed and secured. Alliance Standards Part 10 Section Electrical Connections An instruction board for first aid and artificial respiration is located in the generator room and substation room. Low There was no instruction board for first aid and artificial respiration in the generator area. Visual Assessment: No instruction board for first aid and artificial respiration observed in the generator area Install instruction board for first aid and artificial respiration in the generator area. 07 Jul 2014 A sign detailing electrical shock first aid procedures should be installed in these rooms. Signage indicating the prohibition of light fixtures without protective covers is installed at required locations. Low No signage indicating the prohibition of light fixtures without protective covers installed in storage areas as per Alliance Standards Part 10 Section Naked Lights. Visual Assessment: No signage indicating the prohibition of light fixtures without protective covers observed The Alliance for Bangladesh Worker Safety Page 11/15

12 19 Apr 2014 Install signage in all storage areas or other areas of combustibles indicating no use of light fixtures without protective covers as per Alliance Standard Signs should conform to ANSI Z535 or equivalent international standard regarding safety signs. 30 Jun 2014 Alliance Standards Part 10 Section Naked Lights Are meters and other electrical devices (Ammeter, Voltmeter, PFI Auto Controller, etc) installed on the main electrical equipment operational? Low Non-Compliance Level: 2 PFI Auto Controller is not working. Photograph: Photo of PFI Auto Controller Repair PFI Auto Controller system. Alliance Standard Inspection of the Installation Emergency Power System Is the generator room clean and free of dirt, debris, and improperly stored materials? The generator area is separated by open metal cage and therefore not protected from influx of dust and debris. Generator area is not free of dirt and debris (area is quite dirty). Area is also used for storage of other materials. Photograph: Photos of generator areas Clean generator room of residual dust and debris. Remove all non-essential materials and any combustible materials from the generator area. A regular cleaning regiment should be scheduled to prevent the build up of dust and debris in the area. Consider designing a separate room for housing of generator to help prevent the influx of dust and debris. Alliance Standards Part 10 Section Generator Room Are emergency power switchboards, distribution boards, and circuits properly The Alliance for Bangladesh Worker Safety Page 12/15

13 19 Apr 2014 identified? Emergency switchboards, distribution boards and circuits are not properly identified as part of emergency power system. Visual Assessment: No emergency power identification was observed. "All boxes and enclosures (including transfer switches, generators, and power panels) for emergency circuits shall be permanently marked so they will be readily identified as a component of an emergency circuit or system. The required marking can be by color code, the words emergency system, or any other method that identifies the box or enclosure as a component of the emergency system." 30 Jun 2014 NFPA 70 Chapter 7 Article Wiring, Emergency System Is the generator room properly rated and physically separated from the remainder of the building? Non-Compliance Level: 2 Generator room is in ground floor in separate area adjacent to factory building. However, as noted elsewhere, the generator area is not separated from path of egress at south side stair discharge. Photograph: Generator Room Provide fire-resistive rated construction barriers between hazard types. Generator sets shall be separated from all other occupancy areas by a minimum 2 hour construction. Consult a qualified fire protection engineer to design the required rated construction barrier. 27 Aug 2014 Alliance Standards Part 10 Section Generator Room Is the generator room appropriately sized in order to properly access the generator to perform routine maintenance activities? Adequate clearance to properly access the generator to perform routine maintenance activities is not available based on layout of generator area. The Alliance for Bangladesh Worker Safety Page 13/15

14 19 Apr 2014 Photograph: Photo of generator area This generator room/area should provide access to the generator for routine maintenance (minimum of 1 meter clearance on all sides). As noted elsewhere, a generator room with appropriate segregation should be created. Alliance Standard Part 10 Section Generator Room Are inspection, maintenance, and testing procedures of the emergency generator being completed and documented? Low No inspection, maintenance and testing are being completed as per standard. Document Review: No document provided to confirm that the inspections and maintenance is taking place. Establish a routine maintenance and testing program for the emergency generator. The program shall be based on all of the following: (1) Manufacturer's recommendations (2) Manufacturer's Instruction manuals (3) Requirements of NFPA 110 Chapter 8 All inspection, maintenance and testing should be documented and records available for review." NFPA 110 Chapter 8 Are inspection, maintenance, and testing procedures of the UPS being completed and documented? Low Non-Compliance Level: 2 The management team provided inspection, maintenance, and testing procedures of the UPS however, no documentations of inspections could be provided. Document Review: No records of testing available for review. "Establish an inspection testing, and maintenance program for the Uninterruptable Power Supply (UPS) and associated components. The program must based on the following: (1) Manufacturer's recommendations (2) Manufacturer's instruction manuals (3) Minimum Requirements of NFPA 111 Chapter 8 (4) Minimum Requirements of NFPA 70B Chapter 28 All inspections, maintenance and testing should be fully documented and available for review. The Alliance for Bangladesh Worker Safety Page 14/15

15 19 Apr 2014 Alliance Standard Part 13 Section NFPA 111 Chapter 8 NFPA 70B Chapter 28 Lightning Protection System Is a lightning protection system installed on the building? No lightning protection is found in the factory building. Per risk assessment lighting protection is required. Uploaded Document: Lighting Risk Assessment Have a qualified electrical engineer design a lightning protection system according to the BNBC requirements. Have a licensed electrician install the designed system. Alliance Standards Part 10 Section Lightning Protection. Calculate Risk Index to determine if required. The Alliance for Bangladesh Worker Safety Page 15/15

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