INITIAL ELECTRICAL ASSESSMENT REPORT (EAR) Factory 81, Kalmessar, "Jalal Shopping Complex" Board Bazar, Gazipur. 20 May 2014 The Alliance for Bangladesh Worker Safety Page 1/21
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 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 2/21
20 May 2014 GENERAL INFORMATION General Information Factory Country: Province: City: Bangladesh Dhaka Gazipur Zip Code: 1704 Audit Duration: Re-Audit: 2 Days Re-Audit After 0 Months Draft Report Date : 29 May 2014 Final Report Date : 11 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 Mixed Building(One) of the Factory(Basement+6-story RCC Building) A.5th, 4th & 3rd floors used by Fashion store Ltd. B.Basement, 2nd & 1st floors used by Atoshi Fashion Ltd. C.Ground floor used to market place. Rented Basement + 6 stories. 91,280 sft. Basement + 3 stories were constructed in 2004-2006. Remaining 3 stories were constructed in 2007. Undocumented vertical extension above 6th floor in between grid 6 and 7 has been noticed contracted in 2007. Generator and Boiler house is a single storied Sloped metallic roof structure supported by brick wall. 991 sft The Alliance for Bangladesh Worker Safety Page 3/21
20 May 2014 Number of Occupants : Provide brief description of the electrical system for each building.: Physical location of Substation? : What equipment/loads does the UPS serve? : Worker = 775 persons. Officials = 109 persons. Yes Outside of the main building. IPS Serves computer and lights. The Alliance for Bangladesh Worker Safety Page 4/21
20 May 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? As-built electrical drawings indicating information such as panel and circuit locations throughout the building(s)were not available for review. Document Review: No Documentation Available. Have a qualified electrical engineer develop an as-built single line diagram detailing key components and capacity of the electrical system. 31 Jul 2014 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? Factory reports that training is conducted, however, no documented electrical safety training for the maintenance staff is available for review. Worker Interviews: Discussed with electrical responsible personnel. 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? The Alliance for Bangladesh Worker Safety Page 5/21
20 May 2014 Periodical Insulation Resistance Measurement Program was not established and recorded. Document Review: Documents were not available at 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, 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 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 equipments were not done. Document Review: There were no records or documents of thermographic scans available at the site. 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. 31 Jul 2014 Alliance Standards Part 10 Section 10.13.8 Electrical Inspections A transformer oil analysis is routinely completed on main service transformers. Low A transformer oil analysis is not routinely completed on main service transformers. Document Review: No Documentation Available Should be Completed an oil analysis on applicable transformers at appropriate intervals based on voltage and power. 20 Jul 2014 The Alliance for Bangladesh Worker Safety Page 6/21
20 May 2014 Alliance Standard Part 10 Section 10.13.8 Electrical Inspections Electrical System Conditions Combustible materials are not stored within the substation room. Combustible materials (Wooden Table and Paper) are stored within the substation room. Also Substation room ceiling is made by combustible material. Photograph: Combustible materials found in substation room. Remove all combustible materials from the substation room. 30 Jun 2014 Not Applicable No circuits are drawn for loads without the incorporation of a overcurrent protection device (circuit breaker). Circuits are drawn without overcurrent protection device. Indicator lamp connected with out protective device of MDB-3rd fl and MDB-5th fl. Photograph: circuits are drawn for loads without the incorporation of circuit breaker All circuits should be drawn for loads with the incorporation of a over current protection device (circuit breaker)according to Alliance Standards Part 10 Section 10.9 Protection of Circuits 25 Aug 2014 Alliance Standards Part 10 Section 10.9 Protection of Circuits Is electrical wiring/cables sized according to capacity of circuit breakers (No higher rated circuit breakers with lower rated wiring)? er rated MCCB/MCB is used to protect the lower rated cable in MDB/DBs The Alliance for Bangladesh Worker Safety Page 7/21
20 May 2014 and many SDBs in all floors of the factory. Photograph: Location: 5th floor MDB 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.have a qualified electrical engineer size the circuit breaker according to the demand of the circuits. 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 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. 06 Aug 2014 Alliance Standard Part 10 Section 10.3 Electrical Wiring and Cabling All equipment is efficiently earthed and properly connected to the required number of earth electrodes. Non-Compliance Level: 2 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. The neutral and body of almost all SDBs/DBs are not efficiently earthed in all floor of the factory. Photograph: Equipment is not properly connected to the required number of earth electrodes. Provide earthing of equipment at required locations and connect to required number of electrodes. Refer to the BNBG for required number of electrodes. 31 Jul 2014 The Alliance for Bangladesh Worker Safety Page 8/21
20 May 2014 Alliance Standard Part 10 Section 10.13.7.1 Inspection of Substation Installations. 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. Non-Compliance Level: 2 There is no building earthing and also no grounding system in the factory. As a result there is no question to found any metals connected to the earthing system. (Cable tray, Cable channel earthing is not Properly done) Visual Assessment: Earthing Connection Not Provided Connect all metal in the building to the building's earthing/grounding system by approved means. 31 Aug 2014 Alliance Standard Part 10 Section 10.10 Earthing 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 in the finished goods storage area as well as at the quality control table. Photograph: Light fixtures without protective covers found in the finished goods storage area. Install Light fixtures with protective covers in all storage areas. 20 Jul 2014 Alliance Standards Part 10 Section 10.15 Naked Lights Are all switchboards and/or distribution boards metal enclosed with a dead front construction? Non-Compliance Level: 1 Some distribution boards has opening which is not dead front construction and not found any barrier in front of the panelboard The Alliance for Bangladesh Worker Safety Page 9/21
20 May 2014 Photograph: Not enclosed with a dead front construction Ensure distribution boards are metal enclosed with a dead front construction Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear The substation room is clean and free from dirt, lint, water, oil, and debris. Substation room is not clean properly. Photograph: Substation room is not clean. Remove all dirt, debris, lint, water, oil, and improperly stored materials from the substation room. 30 Jun 2014 Alliance Standard Part 13 Section 13.6.2 The substation room has adequate ventilation. It does not appear that the substation room has sufficient ventilation to dissipate heat losses from electrical equipment. 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. The Alliance for Bangladesh Worker Safety Page 10/21
20 May 2014 The substation room has adequate illumination levels. There is no adequate illumination levels in the substation room. Photograph: Inadequate lightening in substation room Provide additional light fixtures to increase illumination levels provided in the BNBC. 20 Jul 2014 Alliance Standard Part 10 Section 10.13.7.1 Inspection of Substation Installations. Transformers are properly grounded (earthed). Transformers are not properly grounded(earthed) Visual Assessment: Visually noted this scenario Transformers should be properly grounded(earthed) 20 Jul 2014 Alliance Standards Part 10 Section 10.5 Substation Are all switchboards and/or distribution boards properly grounded (earthed)? The body of allmost all SDBs/DBs are not efficiently earthed in all floors of the factory. Photograph: Switch boards are not properly earthed All switchboards and/or distribution boards including doors need to be properly grounded (earthed). Alliance Standard Part 10 Section 10.10.2 Circuit and System Earthing The Alliance for Bangladesh Worker Safety Page 11/21
20 May 2014 Do switchboards and/or distribution boards have capacity information labels? Capacity labels are not provided on switchboards and distribution boards. Photograph: Capacity information labels not found in any panel board of the facility. Capacity labels helps to understand the maximum number of protective devices that can be accommodated and what is the capacity of the boxes. Capacity information labels need to be provided for all MDB/DB/SDBs. 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: No dedicated neutral for each circuit Need to draw dedicated neutral for each single phase load according to Alliance Standards Part 10 Section 10.3 Electrical Wiring and Cabling Alliance Standards Part 10 Section 10.3 Electrical Wiring and Cabling 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. Cable socket is not provided for all stranded conductors having nominal crosssectional area 6mm2 or greater. Photograph: Cable socket is not provided. Need to provide cable socket for every connection according to Alliance Standards Part 10 Section 10.3.8.3 Cable Ends The Alliance for Bangladesh Worker Safety Page 12/21
20 May 2014 27 Aug 2014 Alliance Standards Part 10 Section 10.3.8.3 Cable Ends Is all electrical wiring/cable properly terminated at its point of termination (No un-terminated wires, lugs are provided at terminals, etc)? Electrical wiring/cable found not properly terminated at its point of termination.found at 3rd floor, 4th floor and 5th floor MDB. Photograph: Electrical wiring/cable is not properly terminated. Need to connect each point of wire connection from busbar and need to proper cable lug and remove common neutral and earthing. 23 Jul 2014 Alliance Standards Part 10 Section 10.3.9.2 Wiring of Sub-distribution Boards Are junction boxes and other electrical devices provided with covers? Junction box is not sealed.it is found at 6th floor Photograph: Found not sealed junction box. Need to seal every junction box. 27 Aug 2014 Alliance Standard Part 10 Section 10.3.5 and 13.6.2 Mechanical guards are provided for electrical equipment and wiring where necessary. Connection for sockets found hanging and insecured at Generator room.also found at HT cable, Change over, some connection of 3rd floor, 4th floor and 5th floor. Photograph: Mechanical guard not provided The Alliance for Bangladesh Worker Safety Page 13/21
20 May 2014 Mechanical guards need to be provided instead of flexible cable or cords as fixed wiring unless contained in an enclosure and cable tray affording mechanical support. 27 Aug 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 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. Non-Compliance Level: 2 Boxes do not have any correct design to understand for how many devices can be installed. Visual Assessment: Visually we noted this NC. Physical means to prevent the installation of more over current devices then that for which the equipment was designed need to be installed based on the calculation of panel capacity. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Electrical wiring and conduit is properly supported. Non-Compliance Level: 2 No support for service cables wiring. Photograph: Electrical wiring and conduit is not properly supported Electrical wiring should be properly supported to avoid sudden falling down. Provide adequate support or mechanical guard for all electrical wiring and conduit. 27 Aug 2014 Alliance Standard Part 10 Section 10.3.2, 10.3.4.3, and 10.3.5 The Alliance for Bangladesh Worker Safety Page 14/21
20 May 2014 Electrical connections at equipment, fixtures, etc are properly secured. Non-Compliance Level: 2 Connection for sockets found hanging and insecured at Generator room, Store room No ECC at panel door, cable tray is not earthing, combustable material found infront of 4th floor panel box. Photograph: No ECC at panel door, cable tray is not earthing,also combustable material found. If flexible metallic hose is used for wiring to motors and other equipment, the wiring should be enclosed to the full lengths, and the hose should be secured properly by approved. 27 Aug 2014 Alliance Standards Part 10 Section 10.3.1 Electrical Connections Are there additional areas of non-compliance to report? Non-Compliance Level: 2 We found inappropriate number of Earthing Pit and Damp condition of Substation room. Earthing connection is disconnected from Exhaust fan of the 3rd, 4th and 5th fl. Transformer silica is turned brown color and IPS stand on combustible material. Photograph: Damp condition in substation room and earthing connection disconnected from exhaust fan found. Combustable material should be removed immediately and transformer need to be changed.and should be kept the building free from dampness. 28 Jul 2014 Not Applicable The Alliance for Bangladesh Worker Safety Page 15/21
20 May 2014 Are all internal components of switchboards and/or distribution boards properly concealed (No missing circuit breaker or knockout covers)? Non-Compliance Level: 1 There are some MDB/DB/SDBs found at all floors without circuit breakers or knockout covers. All change over switch, MDB-GF, Boiler room breaker were not properly concealed. Photograph: All change over switch, MDB-GF, Boiler room breaker 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 Do switchboards and/or distribution boards have clear identification markings? Non-Compliance Level: 1 Clear identification/marking was not available at DB-Generator/GF floor of the factory. Photograph: Distribution boards have no 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. Clear identification marking must be available at LT, MDB and DB MCB/MCCB as per BNBC 2006 of section: 2.11.5.4 Alliance Standard Part 10 Section 10.7 BNBC Part 8 Section 2.11.5.4 Are electrical wiring/cables properly identified? Non-Compliance Level: 1 Electrical wiring/cables are not properly identified.(at all MDB, DB and SDB) Photograph: Not properly identified Electrical wiring/cables need to be provided with proper color code for all the The Alliance for Bangladesh Worker Safety Page 16/21
20 May 2014 phase conductors (Red, Yellow, Blue), Neutral (Black) and Earth (Green or yellow/green strip)according to Bangladesh Electricity Rules 1937 Rule 51 and 56 Bangladesh Electricity Rules 1937 Rule 51 and 56 Cable joints are through porcelain/pvc connectors with PIB tape wound around joint. Non-Compliance Level: 1 Improper cable joints found with the cable in cutting section.we found at 3/4 location. Photograph: Improper cable joint found Need to joint cable through porcelain/pvc connectors with PIB tape. 27 Aug 2014 Alliance Standards Part 10 Section 10.3.8.4 Cable Joints Required equipment and safety signage is posted within the room. Low Proper "electric danger/caution" signage is not provided on panel boards in substation room. Visual Assessment: Visually we didn't find the safety signage and required equipment 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 appropriate caution signs. Entrances to rooms and other guarded locations that contain exposed live parts shall be marked with conspicuous warning.as per NFPA 110.21 signage should be permanently affixed, not hand-written,and durable enough to withstand the environment. 20 Jul 2014 Alliance Standard Part 10 Section 10.3.7, Section 10.7.3, and 10.13.7, NFPA 70 Chapter 1 Article 110.21, and Bangladesh Electricity Rules of 1937 Rule 46 The Alliance for Bangladesh Worker Safety Page 17/21
20 May 2014 Phase separators are provided between terminals on circuit breakers. Low Non-Compliance Level: 2 There are some MCCBs in MDBs has no phase separator. Photograph: Phase Separator is not fixed on circuit breakers (found at all panel of the facility.) Need to provide phase separators between terminal connections at the noted locations. 31 Aug 2014 Alliance Standard Part 10 Section 10.3.1 Electrical Connections Signage indicating the prohibition of light fixtures without protective covers is installed at required locations. Low Non-Compliance Level: 2 Signage indicating the prohibition of light fixtures without protective cover is not installed in the required locations. Photograph: No signage found. 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 (1.6.3.7) Part 53 disallows these fixtures. Install signs posted in Bengali and English, indicating this prohibition at all entrances to these areas. 28 Aug 2014 Alliance Standards Part 10 Section 10.15 Naked Lights Emergency Power System Is the generator room properly ventilated The Generator room is not provided with well ventilation system. Photograph: Inadequate Ventilation observed The Generator room should be provided with adequate ventilation system. The Alliance for Bangladesh Worker Safety Page 18/21
20 May 2014 29 Jul 2014 Alliance Standards Part 10 Section 10.8.4 Generator Room Are emergency power switchboards, distribution boards, and circuits properly identified? Emergency power switchboards, distribution boards, and circuits not properly identified in all areas. Visual Assessment: Not properly identified 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. 25 Aug 2014 NFPA 70 Chapter 7 Article 700.10 Wiring, Emergency System Are cable trenches properly covered? Non-Compliance Level: 1 Not properly covered at substation only. Photograph: Cables Supported By Piping. Provide a cable tray or other suitable means approved by a qualified electrical engineer to support all electrical cables throughout the factory. 31 Jul 2014 Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation The Alliance for Bangladesh Worker Safety Page 19/21
20 May 2014 Is the generator frame earthing (grounding) provided at two separate points? The Generator frame is not provided with two separate earthing points. Photograph: Earthing not provided at any of two points for the generator. Should Provide earthing at two separate points. 28 Jul 2014 Alliance Standard 10.8.2.2 Is the generator room properly illuminated? The Generator room is not provided with adequate light. Photograph: Illumination level is not sufficient in the generator room. Should be provided with adequate lighting in the Generator room. 26 Aug 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 Inspection, maintenance, and testing procedures of the generator document were not found. Document Review: No document was reviewed. 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 26 Aug 2014 The Alliance for Bangladesh Worker Safety Page 20/21
20 May 2014 NFPA 110 Chapter 8 Lightning Protection System Is a lightning protection system installed on the building? A lightning protection system is not installed for the building. The Risk Index of this building is about 47. Detail calculation is as follows : A. Use of structure - Big industrial plants, telephone exchanges, office blocks, hotels, blocks of flats (7) + B. Type of Construction - Brick, plain concrete, or masonry with nonmetal roof (4) + C. Contents or Consequential Effects â Industrial and agricultural buildings with specially susceptible contents (5) + D. Degree of Isolation - Structure completely isolated or exceeding at least twice the height of surrounding structures or trees (10) + E. Type of Terrain - Flat terrain at any level (2) + F. Height of Structure - 18â 24 m (8) + G. Lightning Prevalence - Number of thunderstorm days per year : 10-12 (11) = Total 47 Visual Assessment: Visually we noted the items. Have a qualified electrical engineer design a lightning protection system according to the BNBC requirements. Have a licensed electrician install the designed system. 25 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 21/21