INITIAL ELECTRICAL ASSESSMENT REPORT (EAR)

INITIAL ELECTRICAL ASSESSMENT REPORT (EAR) Factory Assessor: 5th floor, Ehasan Tower, 227/B, Hafez Nagar, Bakalia, Chittagong. Uttaron 22 Jul 2014 The Alliance for Bangladesh Worker Safety Page 1/19

Factory 22 Jul 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 2/19

22 Jul 2014 GENERAL INFORMATION General Information Factory Country: Province: City: Bangladesh Chittagong Chittagong Zip Code: Audit Duration: Re-Audit: Draft Report Date : Final Report Date : 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) : Number of Occupants : 1 Days Re-Audit After 0 Months 22-Jul-2014 31-Aug-2014 N/A One Rented Six storied 16,864 sft per floor. 1,01,184 sft total area. 1997 2003/2004 One 150 sft 300 persons. The Alliance for Bangladesh Worker Safety Page 3/19

22 Jul 2014 Provide brief description of the electrical system for each building.: Physical location of Substation? : What equipment/loads does the UPS serve? : Factory. Date of Inspection: 22th July, 2014. Brief #No. of Main Building: 1 (6th stories), #No of Ancillary Building: 1(Generator room, Shed) #Generator Brand and Rating: DG-97KVA Generator brand is Cummins. #Connection Type: PDB Pole Mounted Substation (11kv/.44kv) incoming and self-power Source (Generator) are connected to Change over Switch (C.O.S). #No of MDB/DB: MDB-1, DB- 01,SDB-4. #Emergency Power: Instant power supply (IPS) is connected for emergency load (emergency light, exit signage, fire alarm). There is no sub-station in this factory. Emergency light, fire exit light, etc. The Alliance for Bangladesh Worker Safety Page 4/19

22 Jul 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? No as-built drawing was found on the site. Proper Working or as built electrical drawings of main distribution circuit and floor levels circuits connecting electrical loads (machines/lights/ cooling system etc.) should be available at site. With the help of proper electrical drawings, any addition/deduction/isolation of loads can be done easily and any table-top decision can be made centrally taking consideration of safety, integrity and good productivity. Proper drawing is an engineering tool, and every system must have it. Visual Assessment: No as-built drawing was found on the site. Have a qualified electrical engineer develop an as-built single line diagram detailing key components and capacity of the electrical system. 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 that operate and maintain the electrical system received no electrical safety training and no documents were found at site in this connection. Training is needed for the related workers who deal with electrical equipment for the safety of his/her life as well as the life of the total workers working in the factory." Document Review: NFPA 70E Develop and implement an electrical safety program. Include key topics such as lock out tag out procedures, personal protective equipment requirements, etc. Reference NFPA 70e for example program requirements. The Alliance for Bangladesh Worker Safety Page 5/19

22 Jul 2014 Reference NFPA 70e for example Is a periodical Insulation Resistance Measurement Program established and recorded? Periodical insulation resistance test (IR test) shall have to be carried out for all electrical equipments with Meggar 0.5 KV or 1 KV (according to the voltage rating of equipment). Visual Assessment: No such program schedule is recorded on periodical insulation resistance test is evident in this site. 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, switch gears 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 10.13.4 Insulation Tests and 10.13.8 Electrical Inspections Are thermographic scans of electrical equipment completed at least every three years? Thermographic scans of electrical equipment need to be completed at least every three years to ensure the proper maintenance of the electrical equipment. Such programs has been witnessed in this factory. Visual Assessment: There was no thermographic scan report found. 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 10.13.8 Electrical Inspections Are periodic safety inspections of the electrical system components completed and documented? The Alliance for Bangladesh Worker Safety Page 6/19

22 Jul 2014 Planned Periodical safety inspection of all electrical equipment shall be carried out in order to ensure proper operation of the installation and record of the same should be maintained. Visual Assessment: No records found on periodic safety inspections of the electrical system components 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 10.13 Inspection and Testing and Part 13 Section 13.6 Housekeeping Electrical System Conditions All equipment is efficiently earthed and properly connected to the required number of earth electrodes. In general all parts of equipment and installation other than live parts shall be earth potential, thus ensuring that persons coming in contact with these parts shall also be at earth potential at all times. Location: All DBs. Visual Assessment: All equipment is not efficiently earthed. Provide earthing of equipment at required locations and connect to required number of electrodes. Refer to the BNBC for required number of electrodes. Alliance Standard Part 10 Section 10.13.7.1 Inspection of Substation Installations. Indications of overheating, overloading, or signs of burning were not observed. Indications of overheating, overloading, or signs of burning were observed inside of the Main MCCB Breaker, C.O.S-01, MDB-01, SDB/Finishing, DB/Boiler, SDB-01/Sewing, SDB-02/Sewing, Fuse/Cut-out Switch. Photograph: Indications of overheating, overloading, or signs of burning. The Alliance for Bangladesh Worker Safety Page 7/19

22 Jul 2014 Wiring system components including cables and wiring accessories shall be installed or handled only at temperatures within the standard limits. Alliance Standard Part 10 Section 10.3.5 Is electrical wiring/cables sized according to capacity of circuit breakers (No higher rated circuit breakers with lower rated wiring)? Protective devices shall be provided to break any overload current flowing in the circuit conductors before such a current could cause a temperature rise detrimental to insulation, joints, terminations or surroundings of the conductors. Location: All DBs. Visual Assessment: er rated circuit breakers with lower rated wiring. Consult with a qualified Electrical Engineer and ensure electrical cables are sized according to capacity of circuit breakers. Alliance Standard Part 10 Section 10.3.1 Electrical Connections. No multi looping of wiring/cables observed at circuit breakers within switchboards and/or distribution boards. Multiple cables entering in one point prevent tightening of the bolt and causes the electrical sparks due to loose connection. Multiple and looping are found at circuit breakers in the distribution boxes at every panel. Photograph: Multiple and looping cabels. Need to separate the multiple cables either using proper size of circuit breakers or connecting separately on bus bars as per requirements. Alliance Standard Part 10 Section 10.3 Electrical Wiring and Cabling The Alliance for Bangladesh Worker Safety Page 8/19

22 Jul 2014 Are switchboards and/or distribution boards installed in compliant locations? Non-Compliance Level: 2 In damp or wet locations, surface-type enclosures within the scope of this article shall be placed or equipped so as to prevent moisture or water from entering and accumulating within the cabinet or cut-out box, and shall be mounted so there is at least 6-mm (1 4-in.) airspace between the enclosure and the wall or other supporting surface. Enclosures installed in wet locations shall be weatherproof. For enclosures in wet locations, raceways or cables entering above the level of un insulated live parts shall use fittings listed for wet locations. Exception: Non-metallic enclosures shall be permitted to be installed without the airspace on a concrete, masonry, tile, or similar surface. DBs (BBT Controls) must installed at reachable height, should be maximum 6 feet height. Location: Main Incomer(MCCB) of this factory Photograph: All switchboards and/or distribution boards are not installed in compliant location Need to install switchboards and/or distribution boards in compliant location as example installation in an accessible height, in a safe distance from damp and wet locations, far from window or door from where water may come etc. Alliance Standard Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Is a readily accessible single point of disconnect provided for each main electrical service feed? Main incomer of the panel should be operable to disconnect and must be installed at reachable height, should be maximum 6 feet height. Location: Main Incomer(MCCB) of this factory. Photograph: A readily accessible single point of disconnect is not provided for each main electrical service feed. Need to have a readily accessible single point of disconnect for each main electrical service feed. BNBC 2.7.5 Main Switch and Switchboards The Alliance for Bangladesh Worker Safety Page 9/19

22 Jul 2014 Are all switchboards and/or distribution boards properly grounded (earthed)? Panel board cabinets and panel board frames, if of metal, shall be in physical contact with each other and shall be grounded. Where the panel board is used with non-metallic raceway or cable or where separate grounding conductors are provided, a terminal bar for the grounding conductors shall be secured inside the cabinet. The terminal bar shall be bonded to the cabinet and panel board frame, if of metal; otherwise it shall be connected to the grounding conductor that is run with the conductors feeding the panel board. Location: All DBs. Photograph: All switchboards and/or distribution boards are not properly grounded (earthed) Provide grounding (earthing) for distribution boards. Alliance Standard Part 10 Section 10.10.2 Circuit and System Earthing Do switchboards and/or distribution boards have clear identification markings? All distribution boards shall be marked ""Lighting"" or ""Power"", as the case may be, 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. Location: All DBs. Photograph: Distribution boards have no clear identification markings. 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. Alliance Standard Part 10 Section 10.7 BNBC Part 8 Section 2.11.5.4 Do switchboards and/or distribution boards have capacity information labels? The Alliance for Bangladesh Worker Safety Page 10/19

22 Jul 2014 "Capacity labels helps to understand the maximum numbers of protective devices can be accommodate and what is the capacity of the boxes is also can be understand from the information label. Means of prevention of installing exceeding the designed number of devices is described in section 408.54, NFPA70-2011. As per NFPA70-2011, a panel board shall be 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. For the purposes of this section, a 2-pole circuit breaker or fusible switch shall be considered for two over current devices; a 3-pole circuit breaker or fusible switch shall be considered for three over current devices. Location: All DBs." Visual Assessment: Switchboards and/or distribution boards have no capacity information labels. Provide capacity information labels (Maximum current rating, no of circuit breakers etc.) for Switchboards and distribution boards. 15 Oct 2014 Alliance Standard Part 10 Section 10.7 Main Switch, Switchboards And Metal Clad Switchgear and 10.13.7 Inspection of the Installation Each circuit is provided with a dedicated neutral. Circuits are not provided with a dedicated neutral for each load. The use of common neutral for more than one circuit shall not allowed in the standard. Photograph: Circuit is not provided with a dedicated neutral for each load. Provide dedicated neutral for circuit. 31 Oct 2014 Alliance Standards Part 10 Section 10.3 Electrical Wiring and Cabling Are electrical wiring/cables properly identified? Electrical wiring/cables are not properly identified. Location: All DBs. Photograph: Electrical wiring/cables are not properly identified. "Need to maintain color code for all cables. For phase conductors use Red, Yellow, Blue, For Neutral conductors use black and For Grounding cable use green dotted yellow." The Alliance for Bangladesh Worker Safety Page 11/19

22 Jul 2014 31 Oct 2014 Bangladesh Electricity Rules 1937 Rule 51 and 56 Cable joints are through porcelain/pvc connectors with PIB tape wound around joint. Cable joint should be done in accordance with the direction described in the standards to avoid loose connections. Location: All SDBs. Photograph: Improper cable joints were found. Need to joint cable through porcelain/pvc connectors with PIB tape wound around joint. 31 Oct 2014 Alliance Standards Part 10 Section 10.3.8.4 Cable Joints Is all electrical wiring/cable properly terminated at its point of termination (No un-terminated wires, lugs are provided at terminals, etc)? Unterminated cables may lead the electrical short circuit. Cables shall be connected to terminals only by soldered or welded lugs, unless the terminal are of such form that it is possible to securely clamp them without cutting away the cable strands. Location: All DBs. Photograph: Cables are connected without lugs Ensure all electrical wiring/cable properly terminated at its point of termination. 31 Oct 2014 Alliance Standards Part 10 Section 10.3.9.2 Wiring of Sub-distribution Boards Electrical connections at equipment, fixtures, etc are properly secured. Non-Compliance Level: 2 Connections between conductors and between conductors and other equipment shall provide durable electrical continuity and adequate mechanical strength and protection. Location: All SDBs. The Alliance for Bangladesh Worker Safety Page 12/19

22 Jul 2014 Photograph: Loose connection found. If flexible metallic hose is used for wiring to motors and other equipment, the wiring is enclosed to the full lengths, and the hose secured properly by approved. 15 Oct 2014 Alliance Standards Part 10 Section 10.3.1 Electrical Connections Electrical wiring and conduit is properly supported. Electrical wiring and conduit is properly supported. Photograph: Inadequate cable support. Provide adequate supports for electrical wiring and conduit. 15 Oct 2014 Alliance Standard Part 10 Section 10.3.2, 10.3.4.3, and 10.3.5 Are junction boxes and other electrical devices provided with covers? Proper junction boxes need to be used wherever joints are in conductors or cross-over of conductors takes place. Junction boxes should have cover to keep free of lint buildup to reduce the potential for ignition. Location: Generator Room. Photograph: Switch board is not properly covered. Provide adequate covers for junction boxes and other electrical devices. 30 Sep 2014 Alliance Standard Part 10 Section 10.3.5 and 13.6.2 The Alliance for Bangladesh Worker Safety Page 13/19

22 Jul 2014 Phase separators are provided between terminals on circuit breakers. Low Phase separator is need to provide for the terminals of circuit breakers to prevent arcing and short circuit between phases. Location: All DBs. Photograph: Phase Separator is not fixed on circuit breakers. Install phase separators between terminal connections at the noted locations. 31 Oct 2014 Alliance Standard Part 10 Section 10.3.1 Electrical Connections Are meters and other electrical devices (Ammeter, Voltmeter, PFI Auto Controller, etc) installed on the main electrical equipment operational? Low Non-Compliance Level: 2 Ammeter, Voltmeter are not working in this factory. These meters are the primary source to see the current status of the system. Location: MDB/ 5th FL Photograph: Some of the meters and other electrical devices (Ammeter, Voltmeter, PFI Auto Controller, etc) installed on the main electrical equipment are not operational Ensure meters and other electrical devices installed on the main electrical equipment are operational. 15 Oct 2014 Alliance Standard 10.13.7 Inspection of the Installation Are electrical insulation mats provided in front of substation, switchboards and/or distribution boards? Low Non-Compliance Level: Graded insulation/rubber mat need to provide in front of all switchboards and distribution boxes to prevent electrical shocks during working inside. Location: All DBs. Photograph: Electrical insulation mats are not provided in front of substation, switchboards and/or distribution boards Provide electrical insulation mats in front of distribution boards. The Alliance for Bangladesh Worker Safety Page 14/19

22 Jul 2014 30 Sep 2014 Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation. Emergency Power System Are emergency power switchboards, distribution boards, and circuits properly identified? All emergency power switchboards, distribution boards, and circuits need to be properly identified to easy locate and maintain to get service in need. No identification evident here in all areas. 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. NFPA 70 Chapter 7 Article 700.10 Wiring, Emergency System Is the generator room clean and free of dirt, debris, and improperly stored materials? Generator room should be clean and free of dirt, debris and improperly stored materials to reduce to a minimum the probability of communicating fire to adjacent combustible materials. The room should have significant amount of ventilation and fitted with a number of ceiling fans. Appropriate type and number of firefighting equipment must be installed inside the generator room. Photograph: Generator Room is not clean. Keep the generator room clean and free of all type of dirt, debris, and improperly stored materials. Alliance Standards Part 10 Section 10.8.4 Generator Room The Alliance for Bangladesh Worker Safety Page 15/19

22 Jul 2014 Is the generator room properly ventilated Generator room of this factory is well ventilated. Photograph: The generator room is not properly ventilated Ensure proper ventilation for generator room. Alliance Standards Part 10 Section 10.8.4 Generator Room Is the generator frame earthing (grounding) provided at two separate points? Generator frame earthing (grounding) is not provided at two separate points. Photograph: Generator earthing not provided two points Provide generator frame earthing (grounding) at two separate points. 15 Oct 2014 Alliance Standard 10.8.2.2 Is the generator room properly illuminated? Generator room should be illuminated properly. Photograph: Inadequate illumination. Ensure generator room is properly illuminated (At least 150 lux). 15 Oct 2014 Alliance Standards Part 10 Section 10.8.4 Generator Room The Alliance for Bangladesh Worker Safety Page 16/19

22 Jul 2014 Is the generator room appropriately sized in order to properly access the generator to perform routine maintenance activities? Generator room should be enough in size as per BNBC Table 8.2.9 to perform the routine maintenance works. Photograph: Generator room is not appropriately sized Need to install the generator in an appropriately sized room. 30 Nov 2014 Alliance Standard Part 10 Section 10.8.4 Generator Room Are inspection, maintenance, and testing procedures of the emergency generator being completed and documented? Low Document on inspection, maintenance, and testing procedures of the generator need to be documented. Visual Assessment: Document were not found. "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 " 31 Oct 2014 NFPA 110 Chapter 8 Is the appropriate type and number of firefighting equipment installed inside the generator room? Low Appropriate number of firefighting equipment on the basis of area should be installed at generator room. Photograph: Appropriate number of firefighting equipment were not found. Appropriate number of firefighting equipment need to installed at generator room. The Alliance for Bangladesh Worker Safety Page 17/19

22 Jul 2014 30 Sep 2014 Is the appropriate type and number of firefighting equipment installed inside the generator room? Are inspection, maintenance, and testing procedures of the UPS being completed and documented? Low Inspection, maintenance, and testing procedures of the UPS need to be done and documented Visual Assessment: No record found on inspection, maintenance, and testing procedures of the UPS "The routine maintenance and operational testing program shall be based on all of the following: (1) Manufacturer's recommendations (2) Instruction manuals (3) Minimum requirements of NFPA 110 Chapter 8 (4) The authority having jurisdiction" 31 Oct 2014 Alliance Standard Part 13 Section 13.11 NFPA 111 Chapter 8 NFPA 70B Chapter 28 Lightning Protection System Is a lightning protection system installed on the building? 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. Visual Assessment: This factory has no lightning protection system. 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 10.11 Lightning Protection. Calculate Risk Index to determine if required. The Alliance for Bangladesh Worker Safety Page 18/19

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