EQUIVALENT INITIAL ELECTRICAL SAFETY ASSESSMENT Factory Sharoj Tower, Plot No, M-4/2, Section-14, Mirpur, Dhaka Dhaka Dhaka 20 May 2014 The Alliance for Worker Safety Page 1/18
20 May 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 Worker Safety (Alliance) and conducted by a third-party Qualified Assessment Firm (QAF). The assessment was conducted against the Alliance for Worker Safety Assessment Protocols (APs) and Fire Safety and Structural Integrity Standard, which is harmonized with the factory assessment guidelines developed by University of Engineering and Technology (BUET) for the National Tripartite Plan of Action (NTPA). The goal of the Alliance process is to provide clear and practical technical requirements by which i 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 Worker Safety Page 2/18
20 May 2014 GENERAL INFORMATION General Information Factory Country: Province: City: Dhaka Dhaka Zip Code: 1216 Audit Duration: Re-Audit: 1 Days Re-Audit After 0 Months Draft Report Date : 05-21-2014 Final Report Date : 06-22-2014 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 There is only One building in the factory premises which is main building. The building named as: 1) Thirteen story RCC Main Building. Owned 1) Thirteen story RCC Main Building. Building height (est occupied floor level): 36.58 m or 120.00 ft [Height up to roof: 39.63 m or 130 ft] Stories above grade: 13, Stories below grade: 0, Occupied levels: 13. Total area of all buildings in the factory premises: 81900 sft. 1) Thirteen story RCC Main Building: 81900 sft (Ground floor to 12th floor: 6300 sft each). Factory personnel informed the date of construction as follows: 1.Thirteen story RCC Main Building.: Finished in 2006. No record for date of renovation or addition was found from factory personnel. There is no ancillary structure in the factory premises. There is no ancillary structure in the factory premises. The Alliance for Worker Safety Page 3/18
20 May 2014 Number of Occupants : Total number of occupants: 1385. 1. Thirteen story RCC Main Building: 1385. (Groundfloor: 30, 1st floor: 50, 2nd floor: 30, 3rd floor: 200, 4th floor: 85, 5th floor: 190, 6th floor: 200, 7th floor: 35, 8thfloor: 210, 9th floor: 215, 10th floor: 75, 11th floor: 10, 12th floor: 55). Provide brief description of the electrical system for each building.: Physical location of Substation? : What equipment/loads does the UPS serve? : Source: DESCO, Transformer (500 KVA)-1 No., and 3 Nos. of Generator (350 KVA DG-1, 250 KVA DG-2, 512 KVA GG.), 3 Nos. of COS, 1 No. of LT Panel, 1 No. of PFI, MDB-1 No., DB-11 Nos., SDB-2 Nos. Substation Room located in Ground Floor. Computer, Printer, fire alarm, emergency lighting, exit signage The Alliance for Worker Safety Page 4/18
20 May 2014 ASSESSMENT FINDINGS 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 have not received electrical safety training. Document Review: No electrical safety training., Worker Interviews, Document Review: No electrical safety training., Worker Interviews 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 Is a periodical Insulation Resistance Measurement Program established and recorded? No periodical Insulation Resistance Measurement Program established. Document Review: No periodical Insulation Resistance Measurement Program. 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 et Alliance Standard Part 10 Section 10.13.4 Insulation Tests and 10.13.8 Electrical Inspections 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? The Alliance for Worker Safety Page 5/18
20 May 2014 The electrical switchgear and panel boards are not inspected on an annual basis to ensure that the equipment is installed in accordance with the listed ratings. Document Review: No annual inspection record for electrical switchgear and panel boards. Inspect electrical switchgear and panel boards on an annual basis to ensure that the equipment is in good working condition. Alliance Standards Part 10 Section 10.13.8 Electrical Inspections Are thermographic scans of electrical equipment completed at least every three years? Thermographic scans of electrical equipment are not completed. Document Review: No thermographic scans for electrical equipment. 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 Transformers do not contain harmful substances such as PCBs. A transformer oil report was found, but there is no information about the existence of harmful substances such as PCBs. Document Review: No information found about the existence of the harmful substances such as PCBs. in transformer s oil report. Consider replacing transformers that contain harmful substances to reduce health hazards. The Alliance for Worker Safety Page 6/18
20 May 2014 Not Applicable Are periodic safety inspections of the electrical system components completed and documented? Periodic safety inspections of the electrical system components are not completed. Document Review: No periodic safety inspections of the electrical system. 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 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. Photograph: Improper wiring of underground service cables. Ensure underground cables for electrical distribution on the premises/garden/compound of the building are encased in GI or PVC pipes and laid in earth trenches of sufficient depth. Alliance Standards Part 10 Section 10.3.10 Service Entry The substation room has the required fire rating/protection and is physically separated from the remainder of the building. The substation room has no required fire protection (door and window are not fire rated), but is physically separated from the remainder of the building. The Alliance for Worker Safety Page 7/18
20 May 2014 Location: substation room Photograph: No fire protection for substation room Consult with an expert fire protection engineer and make sure the substation room is fire rated/protected as per Alliance Standard. Alliance Standard Part 3 Section 3.4.2.1.4 No multi looping of wiring/cables observed at circuit breakers within switchboards and/or distribution boards. Non-Compliance Level: 2 Bunching of cables connected at circuit breakers within the distribution boards. Location: DB-12/1, 12th floor; DB-10/1, 10th floor; DB-9/1, 9th floor; DB-6/1, 6th floor; DB-4/1, 4th floor; DB-3/1, 3rd floor. Photograph: Bunch of cables at circuit breakers. Remove bunching of cables at circuit breakers within distribution boards. Alliance Standard Part 10 Section 10.3 Electrical Wiring and Cabling 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: 2 Light fixtures without protective covers are installed. Location: Store Room, 11th Floor Photograph: Naked light fixtures installed in storage areas. Ensure light fixtures without protective covers are not installed in storage areas or in any area where the Inspector of the Factories Rules disallows these fixtures. Alliance Standards Part 10 Section 10.15 Naked Lights The Alliance for Worker Safety Page 8/18
20 May 2014 Do switchboards and/or distribution boards have a minimum clearance of 1 m (39 in) in front? Non-Compliance Level: 1 Distribution boards are not provided with adequate clearance. Location: DB- 7/1, 7th Floor; DB-2/1, 2nd Floor. Photograph: Inadequate clearance in front of distribution boards. Provide clearance of at least 1 m (39 in) in front of switchboards and distribution boards. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Are switchboards and/or distribution boards installed in compliant locations? Non-Compliance Level: 1 Distribution boards are not installed in compliant locations. Location: DB-1/1 1st floor, Admin Room Photograph: Distribution boards installed in improper location. Install switchboards and/or distribution boards in compliant locations so that operation is not hampered due to limited access. Alliance Standard Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Power and telecommunication or antenna cables are led in separately. Power and telecommunication or antenna cables are not led in separately. Photograph: Power and telecommunication cables are not separated. Lead telecommunication or antenna cables separately to the main point of service. Power and telecommunications cables must have separate entrance. The Alliance for Worker Safety Page 9/18
20 May 2014 Alliance Standards Part 10 Section 10.3.10 Service Entry The substation room has adequate ventilation. The substation room has inadequate ventilation. Photograph: Inadequate ventilation in substation room. Provide means of ventilation for the substation room. Consult a qualified electrical engineer to determine the required ventilation rates based on the installed equipment. Alliance Standard Part 10 Section 10.13.7.1 Inspection of Substation Installations. Are all internal components of switchboards and/or distribution boards properly concealed (No missing circuit breaker or knockout covers)? Internal components of distribution boards are not properly concealed. Location: BOX-Boiler/14th Floor/LIFT, SDB-11/1, 11th floor; DB-10/1, 10th floor; DB-8/1, 8th floor; DB-7/1, 7th floor; DB-6/1, 6th floor; DB-5/1, 5th floor; DB-4/1, 4th floor; DB-3/1, 3rd floor; DB-2/1, 2nd floor; SDB-Boiler room/ground floor; SDB-Embroidery room/ground floor, SDB- Substation/Ground floor. Photograph: Internal components are not properly concealed. Provide covers or blanks to conceal all live internal components of switchboards and/or distribution boards. Alliance Standard Part 10 Section 10.3.9 Sub-Distribution Boards The Alliance for Worker Safety Page 10/18
20 May 2014 Do switchboards and/or distribution boards have clear identification markings? Distribution boards have no clear identification markings. Location: All distribution boards. Photograph: No clear identification markings. Ensure clear and permanent identification marks are painted in all distribution boards, switchboards, sub main boards, and switches. 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? Distribution boards have no capacity information labels. Location: All Distribution Boards. Photograph: Distribution boards capacity information labels not available. Provide capacity information labels (maximum current rating, number of circuit breakers, etc.) for switchboards and/or distribution boards. Alliance Standard Part 10 Section 10.7 Main Switch, Switchboards And Metal Clad Switchgear and 10.13.7 Inspection of the Installation 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. There is no capacity information available on distribution panel boards, so physical means to prevent the installation of more over current devices is not a consideration right now. When available, the electrical concern should consider the given suggested plan of action. Location: All Distribution Boards. Photograph: Means to prevent the installation of more over current devices due to plug in bus bar. Ensure switchboards and/or distribution boards are provided with physical The Alliance for Worker Safety Page 11/18
20 May 2014 means to prevent the installation of more over current devices than the number for which the panel board was designed, rated, and listed. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear A wire/cable shaft is provided for the whole building. Wiring and cables are arranged in shaft for ease of inspection and maintenance. Cable shaft is not provided for the building. Location: Main Building. Photograph: No cable shaft. Provide wire/ cable shaft for the whole building. Wiring and cables are arranged in shaft for ease of inspection and maintenance. BNBC Part 8 Section 2.5.6.1 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. Non-Compliance Level: 2 Cable sockets are not provided for stranded conductors. Location: SDB-11/1, 11th Floor; DB-10/1, 10th Floor; DB-9/1, 9th Floor; DB-7/1, 7th Floor; DB-5/1, 5th Floor; DB-4/1, 4th Floor; DB-3/1, 3rd Floor; DB-2/1, 2nd Floor; SDB- Embroidery room/ground Floor; MDB-Substation/Ground Floor. Photograph: No cable socket. Provide cable sockets for stranded conductors having a nominal crosssectional area of 6 mm2 or greater. Alliance Standards Part 10 Section 10.3.8.3 Cable Ends The Alliance for Worker Safety Page 12/18
20 May 2014 Cable joints are through porcelain/pvc connectors with PIB tape wound around joint. Non-Compliance Level: 2 Improper cable joints were found. Location: SDB-11/1, 11th Floor; DB-10/1, 10th Floor; DB-9/1, 9th Floor; DB-8/1, 8th Floor; DB-6/1, 6th Floor; DB-5/1, 5th Floor; DB-4/1, 4th Floor; DB-3/1, 3rd Floor; DB-2/1, 2nd Floor; DB-1/1, 1st Floor. Photograph: Improper cable joint. Ensure cable joints are through porcelain/pvc connectors with PIB tape wound around the joint. Alliance Standards Part 10 Section 10.3.8.4 Cable Joints Each circuit is provided with a dedicated neutral. Non-Compliance Level: 1 Each circuit is not provided with a dedicated neutral. Location: DB-4/1, 4th floor; DB-2/1, 2nd floor; DB-1/1, 1st Floor. Photograph: No dedicated neutral. Provide a dedicated neutral for each circuit. Alliance Standards Part 10 Section 10.3 Electrical Wiring and Cabling Electrical wiring and conduit is properly supported. Non-Compliance Level: 1 Electrical wiring and conduit are not properly supported. Location: Substation Room/Ground Floor; Generator-3 Room/Ground Floor. Photograph: Inadequate cable support. Provide adequate supports for electrical wiring and conduit. The Alliance for Worker Safety Page 13/18
20 May 2014 Alliance Standard Part 10 Section 10.3.2, 10.3.4.3, and 10.3.5 Is all electrical wiring/cable properly terminated at its point of termination (No un-terminated wires, lugs are provided at terminals, etc)? Non-Compliance Level: 1 Electrical wiring/cable is not properly terminated. Location: SDB-11/1, 11th Floor; DB-9/1, 9th Floor; DB-6/1, 6th Floor; DB-5/1, 5th Floor. Photograph: Un-terminated wires. Ensure all electrical wiring/cable is properly terminated at its point of termination. Alliance Standards Part 10 Section 10.3.9.2 Wiring of Sub-distribution Boards Required equipment and safety signage is posted within the room. Low Safety signage not posted within the substation room. Photograph: No safety signage found within the substation room. Indoor electrical installations that are accessible to unqualified persons shall be made with metal-enclosed equipment. Switchgear, unit substations, transformers, pull boxes, connection boxes, and other similar associated equipment shall be marked with a Alliance Standard Part 10 Section 10.3.7, Section 10.7.3, and 10.13.7, NFPA 70 Chapter 1 Article 110.21, and Electricity Rules of 1937 Rule 46 Signage indicating the prohibition of light fixtures without protective covers is installed at required locations. Low No signage was found at required locations. Visual Assessment: No such signage was found. The Alliance for Worker Safety Page 14/18
20 May 2014 Light fixtures without protective covers (otherwise known as naked lights) shall not be allowed in storage areas or in any area where the Inspector of the Factories Rules disallows these fixtures. Install signs posted in Bengali and English, indicating th Alliance Standards Part 10 Section 10.15 Naked Lights Phase separators are provided between terminals on circuit breakers. Low Non-Compliance Level: 2 Phase separators are not provided between terminals on circuit breakers. Location: SDB-11/1, 11th Floor; SDB-Boiler room/ground Floor. Photograph: Phase separators are not provided. Install phase separators between terminal connections. Verify phase separators are installed at all remaining locations. Alliance Standard Part 10 Section 10.3.1 Electrical Connections Emergency Power System Are cable trenches properly covered? Cable trenches are not covered. Location: Substation room/ Ground Floor. Photograph: Cable trench have no cover. Provide adequate cover on cable trenches. Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation The Alliance for Worker Safety Page 15/18
20 May 2014 Are emergency power switchboards, distribution boards, and circuits properly identified? Emergency power switchboards, distribution boards, and circuits are not properly identified. Location: Near Generator room/ground floor. Photograph: No identification of emergency DBs/CKTs 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 col NFPA 70 Chapter 7 Article 700.10 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 not properly rated but physically separated from the remainder of the building. Location: Generator room/ground Floor. Photograph: Generator room is not rated. Consult with an expert fire protection engineer and make sure the generator room is fire rated as per Alliance Standard. Alliance Standards Part 10 Section 10.8.4 Generator Room Is the generator room properly ventilated Non-Compliance Level: 2 Generator room is not properly ventilated. Location: Generator 1 and Generator 2/Ground Floor. Photograph: Inadequate ventilation. Consult a qualified electrical engineer to determine the required ventilation rates and reconfigure exhaust fans by recommendations of the qualified electrical engineer. The Alliance for Worker Safety Page 16/18
20 May 2014 Alliance Standards Part 10 Section 10.8.4 Generator Room Is the generator frame earthing (grounding) provided at two separate points? Generator frame earthing is not provided at two separate points. Location: Generator room, Ground floor. Photograph: Inadequate generator frame earthing. Provide two separate points of earthing (grounding) for generator. Alliance Standard 10.8.2.2 Is the generator room appropriately sized in order to properly access the generator to perform routine maintenance activities? The size of the generator room is not appropriate. Location: All generator room/ Ground Floor. Photograph: Inadequate generator room size. Ensure an appropriate size for the generator room in order to properly access the generator to perform routine maintenance activities. Alliance Standard Part 10 Section 10.8.4 Generator Room Lightning Protection System Is a lightning protection system installed on the building? Non-Compliance Level: 1 Lightning protection system is installed, but the height of the building pillar's rods are higher than the height of lightning protection. The Alliance for Worker Safety Page 17/18
20 May 2014 Photograph: Lightning protection system available but not proper. 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 lightning protection ground terminals are bonded to the building or structure grounding. The lightning protection ground terminals are not bonded to the building or structure grounding. Worker Interviews: Lightning protection ground terminals are not bonded to Structure grounding. The lightning protection ground terminals should be bonded to the building or structure grounding. Alliance Standards Part 10 Section 10.11 Lightning Protection The Alliance for Worker Safety Page 18/18