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INITIAL ELECTRICAL ASSESSMENT REPORT (EAR) Factory Address: 687, Al-Haj Nurl Amin Sowdagar Lane CDA, R/A, Road No 20, South Agrabad Chittagong Chittagong Bangladesh 03 Apr 2014 The Alliance for Bangladesh Worker Safety Page 1/23

03 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: www.bangladeshworkersafety.org. The Alliance for Bangladesh Worker Safety Page 2/23

03 Apr 2014 GENERAL INFORMATION General Information Factory Address: Country: Province: City: 687, Al-Haj Nurl Amin Sowdagar Lane CDA, R/A, Road No 20, South Agrabad Chittagong Chittagong Bangladesh Bangladesh Chittagong Chittagong Zip Code: 4100 Audit Duration: Re-Audit: 2 Days 16 Hours Re-Audit After 0 Months Draft Report Date : 13th April. 2014 Final Report Date : 06 June 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 Three buildings in the complex. Rented Building#1=6storied Building#2=4storied Building#3=5storied Building#1=36200 sft Building#2=7000 sft Building#3=36000 sft Building#1=2010-to till now, Building#2=1991-1992,Building#3=1989 No sign of renovation or addition was noticed. No ancillary structures was found in the complex. N/A, The Alliance for Bangladesh Worker Safety Page 3/23

03 Apr 2014 Number of Occupants : Workers=750 persons Officials (Admin and others)= 50 persons. The Alliance for Bangladesh Worker Safety Page 4/23

03 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: 3 No updated as-built drawing was found on the site. Document Review: No documentation available. Have a qualified electrical engineer develop as-built electrical drawings providing detailing key components of the electrical system according to Alliance Standard Part 10 Section 10.3.7 Alliance Standard Part 10 Section 10.3.7 Electrical System Maintenance Have workers that operate and maintain the electrical system received electrical safety training? Is training documentation on site? Workers got electrical safety training but documents concerning the training were not found during assessment. Document Review: no document found regarding this., Worker Interviews: workers got training. Develop and implement an electrical safety program. Include key tops such as lock out tag out procedures, personal protective equipment requirements, etc. Reference NFPA 70e for example program requirements. 26 Jul 2014 Reference NFPA 70e for example Is a periodical Insulation Resistance Measurement Program established and recorded? The Alliance for Bangladesh Worker Safety Page 5/23

03 Apr 2014 Non-Compliance Level: 3 Periodical Insulation Resistance Measurement Program was not established and recorded. Document Review: seen all documents. 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. (Reference: Alliance Standard Part 10 Section 10.13.4 Insulation Tests and 10.13.8 Electrical Inspections) Alliance Standard Part 10 Section 10.13.4 Insulation Tests and 10.13.8 Electrical Inspections Are records concerning the testing and inspection of the electrical systems maintained on site and up to date? Non-Compliance Level: 3 No records found regarding the testing and inspection of the electrical systems. Document Review: view all documents Develop an electrical maintenance program that includes inspections and testing of the electrical systems. Reference NFPA 70 for example program requirements.(reference: Alliance Standards Part 10 Section 10.13.8 Electrical Inspections) Alliance Standards Part 10 Section 10.13.8 Electrical Inspections Are thermographic scans of electrical equipment completed at least every three years? Non-Compliance Level: 3 Thermographic scans of the electrical equipment have not been completed. Document Review: No Documentation Available. The Alliance for Bangladesh Worker Safety Page 6/23

03 Apr 2014 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. (Reference: Alliance Standards Part 10 Section 10.13.8 Electrical Inspections) Alliance Standards Part 10 Section 10.13.8 Electrical Inspections Are periodic safety inspections of the electrical system components completed and documented? Non-Compliance Level: 3 No records found on periodic safety inspections of the electrical system components. Document Review: No Documentation 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. (Reference: Alliance Standard Part 10 Building Services Section 10.13) Alliance Standard Part 10 Section 10.13 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? Document not found during assessment Document Review: No Documentation Available Inspect electrical switchgear and panel boards on an annual basis to ensure that the equipment is in good working condition.((reference: Alliance Standards Part 10 Section 10.13.8 Electrical Inspections) 27 Jul 2014 Alliance Standards Part 10 Section 10.13.8 Electrical Inspections Electrical System Conditions The Alliance for Bangladesh Worker Safety Page 7/23

03 Apr 2014 Light fixtures without protective covers are not installed in storage areas or in any area where the Inspector of the Factories Rules (1.5.3.5) Part 53 disallows these fixtures. Non-Compliance Level: 3 Light fixtures without protective covers are installed in the finished goods storage area as well as at the quality control table. Visual Assessment: Lighting Fixtures Without protective Covers Observed Install Light fixtures with protective covers in all storage areas. (Ref:Alliance Standards Part 10 Section 10.15 Naked Lights) Alliance Standards Part 10 Section 10.15 Naked Lights Are earthing connections provided at electrical equipment? Non-Compliance Level: 3 Earthing connections are not provided appropriately at electrical equipments. Visual Assessment: Common earthing used and no Panel door ECC Need to provide earthing connection at electrical equipments. (Ref: Alliance Standard Part 10 Section 10.7.9 and 10.10 Earthing.) Alliance Standard Part 10 Section 10.7.9 and 10.10 Earthing. Underground service cables are laid in conformity with the requirements of concealed wiring. Underground service cables are not laid in conformity with the requirements of concealed wiring. Visual Assessment: They are working on it. Underground service cables to be laid in conformity with the requirements of concealed wiring. (ref: Alliance Standards Part 10 Section 10.3.10 ) The Alliance for Bangladesh Worker Safety Page 8/23

03 Apr 2014 Alliance Standards Part 10 Section 10.3.10 Service Entry All equipment is efficiently earthed and properly connected to the required number of earth electrodes. Neutral and Earthing is Shorted in most of the boards. Also required number of earth electrodes are not connected. Visual Assessment: Neutral and Earthing found Shorted in most of the distribution boards. Provide earthing of equipment at required locations and connect to required number of electrodes. Refer to the BNBC for required number of electrodes. (Reference: Alliance Standard Part 10 Section 10.13.7.1 Inspection of Substation Installations.) 27 Jul 2014 Alliance Standard Part 10 Section 10.13.7.1 Inspection of Substation Installations. Is a readily accessible single point of disconnect provided for each main electrical service feed? A readily accessible single point of disconnect installed at unreachable height. Photograph: A readily accessible single point of disconnect installed at unreachable height. Main incomer of the panel should be operable to disconnect and must be installed at reachable height, should be maximum 6 feet height. Violation of this rule refers to section 520.53 (C) NFPA70-2011. 27 Jul 2014 BNBC 2.7.5 Main Switch and Switchboards Do switchboards and/or distribution boards have a minimum clearance of 1 m (39 in) in front? Some switchboards do not have minimum clearance of 1 m in front. The Alliance for Bangladesh Worker Safety Page 9/23

03 Apr 2014 Visual Assessment: not enough space infront of some switchboards. Provide a minimum clearance of 1 m (39 in) in front of all switchboards and/or distribution boards (Reference: Alliance Standards Part 10 Section 10.7) 29 Jun 2014 Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Are all switchboards and/or distribution boards metal enclosed with a dead front construction? Some switchboards and/or distribution boards are not metal enclosed with a dead front construction. Visual Assessment: Busbar panel abd change over switch are not metal enclosed. Survey all switchboards and distribution boards and ensure all panel boards are in a metal enclosure and provided with dead front construction. In addition, ensure all switchboards and distribution boards are properly sealed to prevent the entrance of dust, debris, vermin, etc. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Is electrical wiring/cables sized according to capacity of circuit breakers (No higher rated circuit breakers with lower rated wiring)? er rated circuit breakers were found with lower rated cable at several distribution panel. Visual Assessment: MCCB connected with 2.5 rm bya cable. Survey all distribution boards for higher rated circuit breakers and have a qualified electrical engineer determine the appropriate size of MCCB that should be used based on the current carrying capacity of the wiring. (Ref:Alliance Standard Part 10 Section 10.3.1 Electrical Connections.) Alliance Standard Part 10 Section 10.3.1 Electrical Connections. The Alliance for Bangladesh Worker Safety Page 10/23

03 Apr 2014 No multi looping of wiring/cables observed at circuit breakers within switchboards and/or distribution boards. Multiple wires connected at a single point and looping of wiring was found at circuit breakers in the distribution boards on every floor. Photograph: Main incoming terminal of MDB has multiple cable connections. Multiple cables should enter in one point either on Bus Bar or MCB, MCCBs. Remove all instances of multiple wire connections and looping of wiring in all distribution boards. (Ref:Alliance Standard Part 10 Section 10.3 Electrical Wiring and Cabling) Alliance Standard Part 10 Section 10.3 Electrical Wiring and Cabling All metal in the building is connected to the building earthing/grounding system such as metal rebar in concrete, metal frame of building, or metal water pipe. All metal in the building was not connected to the earthing system. For instance, Cable channel and cable trays were not connected to the earthing system. Visual Assessment: Earthing Connection Not Provided Survey all areas of the building for metal components that are not connected to the earthing system. Connect all metal in the building to the building's earthing/grounding system by approved means. (Ref:Alliance Standard Part 10 Section 10.10 Earthing) Alliance Standard Part 10 Section 10.10 Earthing Are switchboards and/or distribution boards installed in compliant locations? Non-Compliance Level: 1 1st floor MDB and 2nd floor MDB are not installed in complaint locations. Visual Assessment: 1st floor MDB and 2nd floor MDB are found installed in non complaint locations. The Alliance for Bangladesh Worker Safety Page 11/23

03 Apr 2014 Install all the switchboards and/or distribution boards in compliant locations 02 Aug 2014 Alliance Standard Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Indications of overheating, overloading, or signs of burning were not observed. Non-Compliance Level: 1 Indications of overheating was observed on change over switch. Visual Assessment: Change over switch Have a qualified electrical engineer determine the cause of overheating, overloading, or signs of burning and take proper action. (Ref:Alliance Standard Part 10 Section 10.3.5) 15 Jun 2014 Alliance Standard Part 10 Section 10.3.5 Wiring systems are selected and erected so that no damage is caused by the ingress of water. Non-Compliance Level: 1 Motor was found beside wet condition, it can increase the possibility of damage caused by the ingress of the water. Visual Assessment: Motor was placed near wet condition. Electrical connections to electrical equipment installed in wet locations, should be properly secured and sealed to prevent the ingress of water. (Ref:Alliance Standards Part 10 Section 10.3.4.3 ) 12 Jul 2014 Alliance Standards Part 10 Section 10.3.4.3 Presence of Water The Alliance for Bangladesh Worker Safety Page 12/23

03 Apr 2014 Do switchboards and/or distribution boards have capacity information labels? Non-Compliance Level: 3 Switchboards and/or distribution boards don't have capacity information labels. Visual Assessment: No Capacity Labels Observed Capacity labels helps to understand the maximum number of overcurrent protection devices which can be accommodate within the distribution boards. Provide capacity information labels and circuit directories for all switchboards and distribution boards. 19 Jul 2014 Alliance Standard Part 10 Section 10.7 Main Switch, Switchboards And Metal Clad Switchgear and 10.13.7 Inspection of the Installation Are all internal components of switchboards and/or distribution boards properly concealed (No missing circuit breaker or knockout covers)? Change over switch, 1st Floor MDB-1, 1st Floor MDB-2, PFI, 2nd Floor MDB are not properly concealed. Visual Assessment: Visual assessment. Provide covers or blanks to conceal all live internal components of switchboards and/or distribution boards. (Ref:Alliance Standard Part 10 Section 10.3.9 Sub-Distribution Boards) 29 Jun 2014 Alliance Standard Part 10 Section 10.3.9 Sub-Distribution Boards The Alliance for Bangladesh Worker Safety Page 13/23

03 Apr 2014 Are all switchboards and/or distribution boards properly grounded (earthed)? In this factory grounding of MDB 1 & 2-ground floor, MDB-1st floor, MDB-2nd floor, PFI were not properly done. Visual Assessment: MDB 1 & 2-ground floor, MDB-1st floor, MDB-2nd floor, PFI grounding were not properly done. Provide proper grounding(earthing) connection for all switchboards and/or distribution boards. (Ref: Alliance Standard Part 10 Section 10.10.2 Circuit and System Earthing) 27 Jul 2014 Alliance Standard Part 10 Section 10.10.2 Circuit and System Earthing Do switchboards and/or distribution boards have clear identification markings? MDB-1 & 2 of ground floor,1st floor MDB, 2nd floor MDB, PFI do not have identification marking. Visual Assessment: Identification marking not found on MDB-1 & 2 of ground floor,1st floor MDB, 2nd floor MDB, PFI Clear identification/marking must be available at LT, MDB and DB MCB/MCCB. Clear and permanent identification marks are required to be painted in all distribution boards, switchboards, sub main boards and switches as necessary. (Ref: BNBC Part 8 Section 2.11.5.4) 29 Jun 2014 Alliance Standard Part 10 Section 10.7 BNBC Part 8 Section 2.11.5.4 Are switchboards and/or distribution boards provided with physical means to prevent the installation of more over current devices than that number for which the panel board was designed, rated, and listed. The Alliance for Bangladesh Worker Safety Page 14/23

03 Apr 2014 Some Panel boards were not design to prevent installation of more over current devices. Visual Assessment: Ground floor MDB-1 & MDB-2, 1st floor MDB, 2nd floor MDB etc Prevent the installation of more over current devices than that number for which the panel board was designed, rated, and listed. (Ref: Alliance Standards Part 10 Section 10.7) Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Each circuit is provided with a dedicated neutral. Circuits in several distribution boards are not provided with a dedicated neutral for each load. Visual Assessment: Visual assessment Provide dedicated neutral for each circuit. The use of common neutral for more than one circuit should not be allowed in the standard. (Ref:Alliance Standards Part 10 Section 10.3 ) Alliance Standards Part 10 Section 10.3 Electrical Wiring and Cabling Are electrical wiring/cables properly identified? Electrical wiring/cables are not properly identified throughout the factory. Photograph: Electrical wiring/cables are not properly identified. All Phase conductors, Neutral and Earth should follow the color code in accordance with Bangladesh Electricity Rules 1937 Rule 51 and 56 Bangladesh Electricity Rules 1937 Rule 51 and 56 The Alliance for Bangladesh Worker Safety Page 15/23

03 Apr 2014 Electrical wiring and conduit is properly supported. Electrical wiring should be well and properly supported to avoid sudden falling down. There is no support for service cables wiring in this factory. Photograph: Conduits are not properly supported for service cables. Survey all wiring to identify areas where the wiring/cables are not properly supported. Provide proper conduit for electrical wiring. (Ref:Alliance Standard Part 10 Section 10.3.2, 10.3.4.3, and 10.3.5) Alliance Standard Part 10 Section 10.3.2, 10.3.4.3, and 10.3.5 Stranded conductors having a nominal cross-sectional area 6mm2 or greater are provided with cable sockets. Conductors below 6 mm2 without cable sockets, all strands at the exposed ends are soldered together or are crimped using suitable sleeve or ferrules. In MDB/DB/SDBs some cables has not been attached using splicing joint at their busbar with using cable lugs. Visual Assessment: Cable lugs not used to terminate the cables in MCCB for some of the distribution boards. Need to reconnect with proper size of cable sockets. (Alliance Standards Part 10 Section 10.3.8.3) 02 Aug 2014 Alliance Standards Part 10 Section 10.3.8.3 Cable Ends Electrical connections at equipment, fixtures, etc are properly secured. Electrical connections to equipment were not securely connected. Visual Assessment: Conceal conduit cables were found without covers at roof ceiling, Also extra cable were drawn from main breaker point. Survey all equipment to ensure the electrical connection is secure and guarded to prevent damage. If flexible metallic hose is used for wiring to The Alliance for Bangladesh Worker Safety Page 16/23

03 Apr 2014 motors and other equipment, ensure the wiring is enclosed the full length and secured properly. (Ref:Alliance Standards Part 10 Section 10.3.1 Electrical Connections) 26 Jul 2014 Alliance Standards Part 10 Section 10.3.1 Electrical Connections Is all electrical wiring/cable properly terminated at its point of termination (No un-terminated wires, lugs are provided at terminals, etc)? Cable lugs were missing in some cable termination points of main distribution boards. Visual Assessment: Missing cable lugs Survey all electrical wiring to identify wiring that is not terminated or has not been terminated properly. Remove all abandoned wiring and ensure all wiring is terminated at its intended point of connection in a compliant manner. ( Ref:Alliance Standards Part 10 Section 10.3.9.2 ) 26 Jul 2014 Alliance Standards Part 10 Section 10.3.9.2 Wiring of Sub-distribution Boards Mechanical guards are provided for electrical equipment and wiring where necessary. Rotating parts of electrical equipment and wirings are not provided with mechanical guard. Visual Assessment: Over head transmission line are not provided with mechanical guards. Provide mechanical guard for Main breaker and Overhead transmission line. (Ref:Alliance Standard Part 10 Section 10.3 Electrical Wiring and Cabling) 12 Jul 2014 Alliance Standard Part 10 Section 10.3 Electrical Wiring and Cabling, 10.6.5 Cables, and 10.7 Main Switch, Switchboards And Metal Clad Switchgear The Alliance for Bangladesh Worker Safety Page 17/23

03 Apr 2014 Are switchboards and/or distribution boards free of dust and debris? Non-Compliance Level: 1 Dust found on MDB-2 of ground floor. Visual Assessment: Dust found on MDB-2 of ground floor. All panel boards should be kept clean and free. Have a qualified individual clean the interior components of distribution panel. (Ref:Alliance Standard Part 10 Section 10.3.9.1 Enclosures) 14 Jun 2014 Alliance Standard Part 10 Section 10.3.9.1 Enclosures Cable joints are through porcelain/pvc connectors with PIB tape wound around joint. Non-Compliance Level: 1 Improper cable joints found with the cable. Photograph: Cable joint found without PVC connectors. Need to joint cable through porcelain/pvc connectors with PIB tape. (Ref:Alliance Standards Part 10 Section 10.3.8.4 Cable Joints) Alliance Standards Part 10 Section 10.3.8.4 Cable Joints Are electrical insulation mats provided in front of substation, switchboards and/or distribution boards? Low Electrical graded rubber mats were not found in front of any switch boards, distribution boards. Visual Assessment: Electrical Insulation mats were not found infront of some switch boards. Provide electrical insulation mats in front of all switchboards and distribution boards. (Ref:Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation). 30 Jun 2014 The Alliance for Bangladesh Worker Safety Page 18/23

03 Apr 2014 Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation. Phase separators are provided between terminals on circuit breakers. Low Phase separators were not provided at most of the MCCB within the distribution boards on each floor. Visual Assessment: No Phase Separators Observed. Survey all distribution boards and install phase separators between terminal connections at the missing locations found during the survey. Phase separators are need between terminals of circuit breakers to prevent arcing and short circuiting between phases. (Ref:Alliance Standard Part 10 Section 10.3.1 Electrical Connections) Alliance Standard Part 10 Section 10.3.1 Electrical Connections An instruction board for first aid and artificial respiration is located in the generator room and substation room. Low Non-Compliance Level: 1 No instruction board for first aid and artificial respiration was found in the generator room. Visual Assessment: Instruction board not found Provide instruction board for first aid and artificial respiration located in substation room and generator room. Instruction board should be displayed for restoration of persons suffering from electrical shock and artificial respiration in case of electric shock at any place in the factory. 04 Jul 2014 A sign detailing electrical shock first aid procedures should be installed in these rooms. Emergency Power System The Alliance for Bangladesh Worker Safety Page 19/23

03 Apr 2014 Are emergency power switchboards, distribution boards, and circuits properly identified? Non-Compliance Level: 3 Emergency power switchboards, distribution boards can not be identified. Visual Assessment: No identification evident here in all areas. 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. 19 Jul 2014 NFPA 70 Chapter 7 Article 700.10 Wiring, Emergency System Are cable trenches properly covered? All the cable trenches are not properly covered. Visual Assessment: Some cable trenches are not covered properly Ensure all cable trenches are covered with non inflammable material. (Ref:Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation) 16 Aug 2014 Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation Are life safety loads (fire alarm, fire pump, elevators, emergency lighting, exit signage, etc) connecting to the emergency power system? Emergency lights are connected with battery Visual Assessment: Emergency lights are served by battery. Life safety loads (fire alarm, fire pump, elevators, emergency lighting, exit signage, etc) should be connecting to the emergency power system to ensure an uninterrupted power supply to these equipment. The Alliance for Bangladesh Worker Safety Page 20/23

03 Apr 2014 16 Aug 2014 Alliance Standard Part 10 Section 10.8 Standby Power Is the generator frame earthing (grounding) provided at two separate points? Non-Compliance Level: 1 The generator frames were only provided with one point of connection to the earthing system Visual Assessment: Earthing provided at one point Provide generator frame earthing (grounding) at two separate points for all generators. (Ref:Alliance Standard 10.8.2.2) 12 Jul 2014 Alliance Standard 10.8.2.2 Is the generator room properly illuminated? Non-Compliance Level: 1 The generator room does not have adequate illumination level. Visual Assessment: not properly illuminated. Generator room should be illuminated properly. (Ref:Alliance Standards Part 10 Section 10.8.4 Generator Room) 12 Jul 2014 Alliance Standards Part 10 Section 10.8.4 Generator Room Are inspection, maintenance, and testing procedures of the emergency generator being completed and documented? Low Non-Compliance Level: 3 Inspection, maintenance, and testing procedures for the generators are not being documented. Document Review: No Documentation Available Establish a routine maintenance and testing program for the emergency generator. The program shall be based on all of the following: (1) The Alliance for Bangladesh Worker Safety Page 21/23

03 Apr 2014 Manufacturer's recommendations (2) Manufacturer's Instruction manuals (3) Requirements of NFPA 110 Chapter 8 NFPA 110 Chapter 8 Is the appropriate type and number of firefighting equipment installed inside the generator room? Low Non-Compliance Level: 1 Firefighting equipment installed inside the generator room is not enough. Visual Assessment: Improper number of firefighting equipment found in the generator room. Install appropriate type and number of firefighting equipment inside the generator room. 19 Jul 2014 Is the appropriate type and number of firefighting equipment installed inside the generator room? Lightning Protection System Is a lightning protection system installed on the building? Non-Compliance Level: 3 Lightning protection system is not installed on the building. Visual Assessment: Lightning protection system not installed. According to Alliance Standards Part 10 Section 10.11 Lightning Protection, A building shall have protection against lightning depending on the probability of a stroke and acceptable risk levels. A complete lightning protection system shall consist of air termination network, down conductors and earth termination. 16 Aug 2014 Alliance Standards Part 10 Section 10.11 Lightning Protection. Calculate Risk Index to determine if required. The Alliance for Bangladesh Worker Safety Page 22/23

03 Apr 2014 The Alliance for Bangladesh Worker Safety Page 23/23