INITIAL ELECTRICAL ASSESSMENT REPORT (EAR)

INITIAL ELECTRICAL ASSESSMENT REPORT (EAR) Factory Name: Tetlabo, Rupgonj, Narayangonj Rupgonj Dhaka Bangladesh 27 May 2014 The Alliance for Bangladesh Worker Safety Page 1/22

27 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 2/22

27 May 2014 GENERAL INFORMATION General Information Factory Name: Country: Province: City: Bangladesh Dhaka Rupgonj Zip Code: 1464 Audit Duration: Re-Audit: 2 Days Re-Audit After 0 Months Draft Report Date : 05-31-2014 Final Report Date : 06-29-2014 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) : N/A There are 13 buildings in the factory premises out of which five are main production buildings and eight are ancillary buildings. The buildings are named as: 1) Three story RCC Accessories Building, 2) Single story prefabricated Processing shed, 3) Three story pre-fabricated chemical godown shed, 4) Two story pre-fabricated Weaving Shed Unit-2, 5) Two story RCC utility building with pre-fabricated shed at roof unit-1, 6)Three story RCC office building, 7) Two story pre-fabricated utility shed unit-2, 8) Three story RCC staff quarter, 9) Single story Medical Center, Child Care and pump room pre-fabricated shed, 10) Single story pre-fabricated grey & yarn Shed, 11) Two story pre-fabricated weaving shed unit-1, 12) Two story pre-fabricated warping shed, 13) Two story pre-fabricated towel shed. Owned Information provided below as per following format: est occupied floor level [Height up to roof], Stories above grade, Stories below grade, Occupied levels. 1) Accessories Building: 45.92 ft [68.88 ft], 3, 0, 3. 2) Processing shed: 1 ft [14.76 ft], 1, 0, 1. 3) Chemical Godown shed: 45.92 ft [68.88 ft], 3, 0, 3. 4) Weaving Shed Unit-2: 14.76 ft [29.52 ft], 2, 0, 2. 5) Utility building Unit-1: 22.96 ft [32.80 ft], 3, 0, 3. 6) Office building: 45.92 ft [32.80 ft], 3, 0, 3. 7) Utility shed unit-2: 14.76 ft [29.52 ft], 2, 0, 2. 8) Staff quarter: 18.04 ft [36.08 ft], 3, 0, 3. 9) Medical Center shed: 1 ft [10.0 ft], 1, 0, 1. 10) Yarn Shed: 1 ft [14.76 ft], 1, 0, 1. 11) Weaving shed unit-1: 14.76 ft [29.52 ft], 2, 0, 2. 12) Warping shed: 14.76 ft [29.52 ft], 2, 0, 2. 13) Towel shed with basement: 11.48 ft [22.96 ft], 2, 1, 3. Total area of buildings in the factory premises: 1080054.00 SF. Building wise breakdown as follows: 1) Three story RCC Accessories Building: 43980.00 SF, 2) Single story pre-fabricated Processing shed: 81000.00 SF, 3) Three story pre-fabricated Chemical Godown shed: 24600.00 SF, 4) Two story pre-fabricated Weaving The Alliance for Bangladesh Worker Safety Page 3/22

27 May 2014 Shed Unit-2: 232321.00 SF, 5) Two story RCC utility building with pre-fabricated shed at roof unit-1: 15942.00 SF, 6) Three story RCC office building: 30813.00 SF, 7) Two story pre-fabricated utility shed unit-2: 32640.00 SF, 8) Three story RCC staff quarter: 45000.00 SF, 9) Single story Medical Center, Child Care and pump room pre-fabricated shed: 2175.00 SF, 10) Single story pre-fabricated grey & yarn Shed: 72546.00 SF, 11) Two story pre-fabricated weaving shed unit-1: 172000.00 SF, 12) Two story pre-fabricated warping shed: 83928.00 SF, 13) Two story pre-fabricated towel shed with basement: 243109.00 SF. Date of Building Construction : Date of Last Building Renovation/Addition : Ancillary Structures in Complex : Approximate Ancillary Structures Area (SF) : Number of Occupants : Provide brief description of the electrical system for each building.: Physical location of Substation? : What equipment/loads does the UPS serve? : Factory personnel informed the date of construction as follows: 1) Accessories Building: Started in 2006 and finished in 2008, 2) Processing shed: Started in 2005 and finished in 2006, 3) Chemical godown shed: Started in 2007 and finished in 2008, 4) Weaving Shed Unit-2: Finished in 2007, 5) Utility building unit-1: Started in 2005 and finished in 2007, 6) Office building: Started in 2006 and finished in 2007, 7) Utility shed unit-2: Started in 2007 and finished in 2009, 8) Staff quarter: Started in 2007 and finished in 2008, 9) Medical Center shed: Started in 2011 and finished in 2012, 10) Grey & yarn Shed: Started in 2011 and finished in 2012, 11) Weaving shed unit-1: Started in 2005 and finished in 2007, 12) Warping shed: Started in 2006 and finished in 2007, 13) Towel shed with basement: Started in 2009 and finished in 2012. No record for date of building renovation or addition was found from factory personnel. 1) Three story RCC Accessories Building, 2) Three story pre-fabricated Chemical Godown shed, 3) Two story RCC utility building with pre-fabricated shed at roof unit-1, 4) Three story RCC office building, 5) Two story pre-fabricated utility shed unit-2, 6) Three story RCC staff quarter, 7) Single story Medical Center, Child Care and pump room pre-fabricated shed, 8) Single story pre-fabricated grey & yarn Shed. 1) Three story RCC Accessories Building: 43980.00 SF (Ground floor: 14660.00 SF, 1st Floor: 14660.00 SF, 2nd Floor: 14660.00 SF), 2) Three story pre-fabricated Chemical Godown shed: 24600.00 SF (Ground floor: 8200.00 SF, 1st Floor: 8200.00 SF, 2nd floor: 8200.00 SF), 3) Two story RCC utility building with prefabricated shed at roof unit-1: 15942.00 SF (Ground floor: 6721.00 SF, 1st floor: 6721.00 SF, 2nd floor area: 2500.00 SF), 4) Three story RCC office building: 30813.00 SF (Ground floor: 10271.00 SF, 1st floor: 10271.00 SF, 2nd floor: 10271.00 SF), 5) Two story pre-fabricated utility shed unit-2: 32640.00 SF (Ground floor: 16320.00 SF, 1st floor: 16320.00 SF), 6) Three story RCC staff quarter: 45000.00 SF (Ground floor: 15000.00 SF, 1st Floor: 15000.00 SF, 2nd floor: 15000.00 SF), 7) Single story Medical Center, Child Care and pump room pre-fabricated shed: 2175.00 SF, 8) Single story pre-fabricated grey & yarn Shed: 72546.00 SF. Total number of occupants: 4883. 1) Three Story RCC Accessories Building: 45, 2) Single story pre-fabricated Processing shed: 920, 3) Three story pre-fabricated chemical godown shed: 25, 4) Two story pre-fabricated Weaving Shed Unit-2: 1230, 5) Two story RCC utility building with pre-fabricated shed at roof unit-1: 14, 6) Three story storied RCC office building: 135, 7) Two story storied pre-fabricated utility shed unit-2: 7, 8) Three story RCC staff quarter: 79, 9) Single story Medical Center, Child Care and pump room pre-fabricated shed: 16, 10) Single story pre-fabricated grey & yarn Shed: 320, 11) Two story pre-fabricated weaving shed unit-1: 1320, 12) Two story pre-fabricated warping shed: 225, 13) Two story pre-fabricated towel shed with basement: 547. 33 KV REB feed to a 1500 KVA 33 KV / 0.415 KV Oil type Transformer, Gas Generator 1125 KVA-5, Gas Generator 1175 KVA-1, Gas Generator 1752 KVA-1, Gas Generator 1770 KVA-1, Gas Generator 1330 KVA-3 and Gas Generator 1295 KVA-2 connected with 3-phase 4-wire electrical distribution system and Distribution boards. Substations are located in Utility Building-1, Utility Building-2, Utility Building-3, Ground Floor. Emergency Light, exit signage and fire alarm system. The Alliance for Bangladesh Worker Safety Page 4/22

27 May 2014 The Alliance for Bangladesh Worker Safety Page 5/22

27 May 2014 ASSESSMENT FINDINGS Electrical System Maintenance Is a periodical Insulation Resistance Measurement Program established and recorded? No periodical Insulation Resistance Measurement Program has been 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 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 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. The Alliance for Bangladesh Worker Safety Page 6/22

27 May 2014 No documents were found to review, so it cannot be verified if the transformer does not contain harmful substances such as PCBs. Document Review: Oil test report (containing information of harmful substances such as PCBs) was not found. Consider replacing transformer with harmful substances to reduce health hazards. Not Applicable A transformer oil analysis is routinely completed on main service transformers. Low Transformer oil analysis is not routinely completed on main service transformer. Document Review: Transformer oil analysis is not routinely completed. Complete an oil analysis on applicable transformers at appropriate intervals based on voltage and power. Alliance Standard Part 10 Section 10.13.8 Electrical Inspections Electrical System Conditions Are all switchboards and/or distribution boards metal enclosed with a dead front construction? Distribution boards are metal enclosed but don't have dead front construction. Location: All distribution boards. Photograph: Metal enclosure with no dead front construction. Ensure distribution boards are metal enclosed with a dead front construction. 28 Jun 2014 The Alliance for Bangladesh Worker Safety Page 7/22

27 May 2014 Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Wet type transformers are not leaking and have appropriate levels. Non-Compliance Level: 2 Main incoming transformer is not leaking but the instrument transformer (415 V/575 V) used to supply weaving machine is leaking. Oil level is appropriate. Location: Weaving-1, Ground Floor. Photograph: Transformer is leaking. Ensure that wet type transformer is not leaking and have appropriate oil levels. Alliance Standards Part 10 Section 10.5 Substation Do switchboards and/or distribution boards have a minimum clearance of 1 m (39 in) in front? Distribution boards are not provided with adequate clearance. Location: MDB- Warping-4-GF-Weaving-2, BOX-ETP-2-ETP-2nd Floor, BOX-ETP-1-ETP-2nd Floor, MDB-Towel (Sizing/Warping)-GF-Towel Building, SDB-Towel (Mending)-GF-Towel Building, DB-Towel-Dyeing (LDB-1)-GF-Towel Building, MDB-Towel Dyeing-Electrician Room-GF-Towel Building, MDB-Ingraving Processing-GF-Processing Section, DB-PI (Light)-GF-Processing. Photograph: Inadequate clearance in front of distribution boards. Provide clearance of at least 1 m (39 in) in front of distribution boards. 28 Jun 2014 Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear The Alliance for Bangladesh Worker Safety Page 8/22

27 May 2014 Switchboards and/or panelboards are not installed above gas stoves or sinks or within 2.5m of any washing unit in washing rooms or laundries. Switchboards are installed near sinks. Location: General Store-1st Floor- Chemical godown building, Yarn & Fabrics mending. Photograph: Switchboard installed in an improper location. Ensure switchboards and panel boards are not installed above gas stoves or sinks or within 2.5m of any washing unit in washing rooms or laundries. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear No circuits are drawn for loads without the incorporation of a overcurrent protection device (circuit breaker). Circuits are drawn for panel indicators without the incorporation of an over current protection device (circuit breaker). Location: DB-Lighting-2-GF- Weaving-2, DB-Fan-2 (Ist Floor)-Towel Building, MDB-Towel Stitching-1st Floor-Towel Building, DB-Towel (Stitching) (LDB-1)-1st Floor-Towel Building, MDB-WTP-Thermoboiler Room. Photograph: No protection device. Ensure over an current protection device (circuit breaker) is installed for each and every load. 12 Jul 2014 Alliance Standards Part 10 Section 10.9 Protection of Circuits Indications of overheating, overloading, or signs of burning were not observed. Indications of overheating were observed. Location: LT PANEL 2.1 (lower)- GF-Utility-3 (72.9 C), LT PANEL 2.1 (upper)-gf-utility-3 (76.2 C), MDB-5/3.1- GF-Utility-3 (77.4 C), MDB-Boiler-1-Boiler Room-1-Utility-1 (91.3 C), MDB- GF(8)-GF-Compressor Room-Utility-3 (109.7 C), MDB-GF (6) LEFT-GF-Utility- 2-Pump room-1 (78.2 C), Box-Emergency light-gf Weaving-1 (92.5 C), MDB- Sizing (left) GF-Weaving-2-X-former room (79.8 C). The Alliance for Bangladesh Worker Safety Page 9/22

27 May 2014 Photograph: Indications of overheating were observed. Find out the cause of overheating and take proper action. 31 May 2014 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)? Electrical wiring and cables are not sized according to capacity of circuit breakers. Location: DB-GF-4-Weaving-1, DB-10 (GF)-Weaving-1, DB-14-GF- Weaving-1, DB -16-GF-Weaving-1, MDB-Stitching-2-1st Floor-Stitching-2, DB- Lighting-1-1st Floor-Stitching-2, MDB-Ingraving Processing-GF-Processing Section. Photograph: er rated circuit breakers with lower rated wiring. Consult with a qualified Electrical Engineer and ensure electrical wiring and 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. Multi looping of cables are observed at circuit breakers & busbar within switchboards and distribution boards. Location: DB-Loom-7-GF-Weaving-2, DB-Loom-4-GF-Weaving-2, DB-Loom-3-GF-Weaving-2, DB-Loom-1-GF- Weaving-2, DB-1st-3-Finishing Folder-1st Floor-Stitching-1, BOX-5-1st Floor- Stitching-1, BOX-ETP-3-ETP-2nd Floor, DB Towel Engraving, DB Towel Sewing M/C-2, DB Towel Sewing M/C-1-Towel Building. Photograph: Multi looping of cables at circuit breakers and busbar. Remove multi looping of cables at circuit breakers & busbar within switchboards and distribution boards. Alliance Standard Part 10 Section 10.3 Electrical Wiring and Cabling The Alliance for Bangladesh Worker Safety Page 10/22

27 May 2014 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. Cable tray and MS stair in the building are not connected to the building earthing system. Location: Cable Tray-Thermoboiler Room, Generator Room- Utility-1, MS Stair (Beside Fire control room). Worker Interviews: Cable tray and MS stair in the building are not connected to the building earthing system. Connect Cable trays and MS stairs to the building earthing system. 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. Light fixtures without protective covers are installed in storage areas. Location: Accessories Store-GF-Weaving-1, Finished Goods Store-1st Floor-Weaving-1. Photograph: Naked light fixtures are 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 (1.5.3.5) Part 53 disallows these fixtures. 31 May 2014 Alliance Standards Part 10 Section 10.15 Naked Lights Wiring systems are selected and erected so that no damage is caused by the ingress of water. Wiring systems are not selected and erected considering the effect of damage caused by ingress of water. Location: Near ETP drain-1st Floor-ETP Building, Roof Top-Foreign Staff Quarter. The Alliance for Bangladesh Worker Safety Page 11/22

27 May 2014 Photograph: May damage due to ingress of water. Ensure wiring systems are selected and erected so that no damage is caused by the ingress of water. 12 Jul 2014 Alliance Standards Part 10 Section 10.3.4.3 Presence of Water Do switchboards and/or distribution boards have clear identification markings? Distribution boards do not have 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. 28 Jun 2014 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 do not have capacity information labels. Location: All distribution boards. Photograph: No DB capacity information labels. Provide capacity information labels (Maximum current rating, no of circuit breakers etc.) for distribution boards. 12 Jul 2014 Alliance Standard Part 10 Section 10.7 Main Switch, Switchboards And Metal Clad Switchgear and 10.13.7 Inspection of the Installation The Alliance for Bangladesh Worker Safety Page 12/22

27 May 2014 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. Distribution boards are not 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. Location: All distribution boards. Photograph: No means to prevent the installation of more over current devices. Ensure proper rating for distribution boards and provide physical means to prevent the installation of more over current devices than that number for which the panel board is rated. Alliance Standards 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 cables are not led in separately. Location: IT department-2nd Floor, Marketing-1st Floor, Finance department-ground Floor, Office building. Photograph: Power and telecommunication cables are not separated. Lead telecommunication cables separately to the main point of service. Power and telecommunications cables must have separate entrance. Alliance Standards Part 10 Section 10.3.10 Service Entry Are all internal components of switchboards and/or distribution boards properly concealed (No missing circuit breaker or knockout covers)? Internal components of switchboards are not properly concealed. Location: Switchboard-1st Floor-Utility-1 Building. Photograph: Internal components are not properly concealed. The Alliance for Bangladesh Worker Safety Page 13/22

27 May 2014 Provide covers or blanks to conceal all live internal components of switchboards and distribution boards. 28 Jun 2014 Alliance Standard Part 10 Section 10.3.9 Sub-Distribution Boards Are all switchboards and/or distribution boards properly grounded (earthed)? Distribution boards are not grounded. Location: DB-GF-5-Weaving-1, MDB- Warping-4-GF-Weaving-2, BOX-EL-GF-Weaving-2. Photograph: No grounding of distribution boards. Provide grounding for switchboards and distribution boards as per BNBC section 2.8.1. Alliance Standard Part 10 Section 10.10.2 Circuit and System Earthing Are switchboards and/or distribution boards free of dust and debris? Distribution boards are not clean. Location: SDB-GF (5.1)-Weaving-1, SDB-GF (5.2)-Weaving-1, DB-Overhead-1-AC Plant-GF-Weaving-2, DB-Overhead-2- AC Plant-GF-Weaving-2, BOX-ETP-3-ETP-2nd Floor, BOX-ETP-2-ETP-2nd Floor, BOX-ETP-1-ETP-2nd Floor, MDB-ETP-ETP-2nd Floor. Photograph: Dirt found in distribution boards. Ensure distribution boards free of dirt and debris. 28 Jun 2014 Alliance Standard Part 10 Section 10.3.9.1 Enclosures The Alliance for Bangladesh Worker Safety Page 14/22

27 May 2014 Each circuit is provided with a dedicated neutral. Each circuit is not provided with a dedicated neutral. Location: MDB-GF (5)- Weaving-1, DB-GF (22)-Weaving-1, MDB-GF-1-Weaving-1, DB-GF-1- Weaving-1, MDB-GF-3-Weaving-1, DB-GF-2-Weaving-1, DB-GF-8-Weaving- 1, DB-GF-9-Weaving-1, SDB-GF (3)-Weaving-1, DB-GF-13-Weaving-1, DB - 17-GF-Weaving-1, DB-GF-17-Weaving-1, SDB-GF (5.1)-Weaving-1, SDB-GF (5.2)-Weaving-1, MDB-Loom-Tx-Room-GF-weaving-2, DB-1st-2-Finishing Folder-1st Floor-Stitching-1, SDB-1-1st Floor-Stitching-1, SDB-2-1st Floor- Stitching-1, BOX-1-1st Floor-Stitching-1, DB-Lighting-2-1st Floor-Stitching-2, DB-Lighting-3-1st Floor-Stitching-2, DB-Lighting-4-1st Floor-Stitching-2, DB- Machine-1-1st Floor-Stitching-2, DB-Machine-2-1st Floor-Stitching-2, DB- Machine-3-1st Floor-Stitching-2, DB-5-Quilting-1st Floor-Stitching-2, SDB- Quilting-1st Floor-Stitching-2, DB-Towel (Sizing/Warping)-GF-Towel Building, MDB-Towel (Lighting)-GF-Towel Building, DB-Towel (Lighting-1)-GF-Towel Building, DB-Towel (Lighting-2)-GF-Towel Building, MDB-Towel(Loom-1)-GF- Towel Building, MDB-Towel (Loom-2)-GF-Towel Building, SDB-Towel (Mending)-GF-Towel Building, MDB-Towel-Dyeing-Anglada-GF-Towel Blgd, DB-Towel-Dyeing (LDB-2)-GF-Towel Building, DB-Colour Kitchen (LDB)-GF- Towel Building, MDB-Flat Belt-GF-Towel Building, DB-Flat Belt (LDB-1)-GF- Towel Building, DB-Flat Belt (LDB-2)-GF-Towel Building, DB-Towel (Ingraving)-GF-Towel Building, DB-Towel-Stitching-Office-1st Floor-Towel Building, DB-Fan-2 (Ist Floor)-Towel Building, DB-Towel (Stitching)-M/C-3-1st Floor-Towel Building, DB-Processing Ingraving-1-GF-Processing Section. Photograph: No dedicated neutral. Provide dedicated neutral for each circuit. Alliance Standards Part 10 Section 10.3 Electrical Wiring and Cabling Are electrical wiring/cables properly identified? Electrical wiring and cables are not properly identified. Location: DB-11 (GF)- Weaving-1, SDB-Loom-Ground Floor-Weaving-1, MDB-Sizing-Tx Room-GF- Weaving-2, DB-Office-1st Floor-Stitching-2, DB-Towel (Ingraving)-GF-Towel Building, DB-PI (Light)-GF-Processing, SDB-Fabrics Godown-Ground Floor. Photograph: Electrical wiring and cables are not identified. Ensure the means of identification is obtained by separate color coding, marking tape, tagging or other approved means. The Alliance for Bangladesh Worker Safety Page 15/22

27 May 2014 Bangladesh Electricity Rules 1937 Rule 51 and 56 Electrical wiring and conduit is properly supported. Electrical wiring and conduit is not properly supported. Location: Roof Top- Weaving-1 Building. Photograph: Inadequate cable support. Provide adequate supports for electrical wiring and conduit. 12 Jul 2014 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. Cable sockets are not provided for stranded conductors. Location: DB-Fire Control Room. Photograph: No cable socket used. Provide cable sockets for stranded conductors having a nominal crosssectional area 6 mm2 or greater. For conductors below 6 mm2 without cable sockets, all strands at the exposed ends are soldered together or are crimped using suitable sleeve or ferrules. 12 Jul 2014 Alliance Standards Part 10 Section 10.3.8.3 Cable Ends Cable joints are through porcelain/pvc connectors with PIB tape wound around joint. Improper cable joints were found. Location: Fire Control Room. Photograph: Improper cable joint. The Alliance for Bangladesh Worker Safety Page 16/22

27 May 2014 Ensure cable joints are through porcelain or PVC connectors with PIB tape wound around joint. Alliance Standards Part 10 Section 10.3.8.4 Cable Joints Electrical connections at equipment, fixtures, etc are properly secured. Electrical connections at equipment are not properly secured. Location: Grey & Yarn Godown-Mending Section. Photograph: Electrical connections are not secured. Ensure electrical connections at equipment, fixtures etc. are properly secured. 12 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)? Electrical wire is not properly terminated. Location: DB (Old)-Fire Control Room. Photograph: Un-terminated wire. Ensure all electrical wiring properly terminated at its point of termination. 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. No mechanical guards are provided for electrical equipment where necessary. The Alliance for Bangladesh Worker Safety Page 17/22

27 May 2014 Location: Motor-Ground Floor-Warping-Utility-2 Building, Motor-In Front of Thermo boiler Room, Motor-Ground Floor-Mending Section-Fabrics & Yarn Store. Photograph: No mechanical guards. Provide mechanical guards for electrical equipment where necessary. 28 Jun 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 Signage indicating the prohibition of light fixtures without protective covers is installed at required locations. Low No signage indicating the prohibition of light fixtures without protective covers is installed at required locations. Location: Accessories Store-GF-Weaving-1, Finished Goods Store-1st Floor-Weaving-1, Garments accessories Store-2nd Floor-Weaving-1, Yarn Godown-Basement-Towel Bldg, Chemical Store- Basement-Towel Bldg, Chemical Sub Store-Dyeing-GF-Towel Bldg, Wastage Godown-Basement-Towel Bldg. Photograph: No signage indicating the prohibition of installation of naked light fixtures. Ensure signage indicating the prohibition of light fixtures without protective covers is installed at required locations. 28 Jun 2014 Alliance Standards Part 10 Section 10.15 Naked Lights Are electrical insulation mats provided in front of substation, switchboards and/or distribution boards? Low Electrical insulation mats are not provided in front of switchboards and distribution boards. Location: DB-GF-21-Weaving-1, MDB-AC Plant-AC Plant- GF-Weaving-2, MDB-Warping-4-GF-Weaving-2, DB-Loom-4-GF-Weaving-2, DB-Lighting-1-GF-Weaving-2, BX-Reed Cleaner-GF-Weaving-2, DB-1/7-1st Floor-Stitching-1, MDB-ETP-2nd Floor. Photograph: No mats are provided in front of switchboards and distribution boards. The Alliance for Bangladesh Worker Safety Page 18/22

27 May 2014 Provide electrical insulation mats in front of switchboards and distribution boards. 28 Jun 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 are not provided between terminals on circuit breakers. Location: MDB-GF (5)-Weaving-1, MDB-GF-1-Weaving-1, DB-GF-1-Weaving- 1, DB-GF-2-Weaving-1, DB-GF-5-Weaving-1, DB-11(GF)-Weaving-1, DB-GF- 13-Weaving-1, SDB-Loom-Ground Floor-Weaving-1, MDB-AC Plant-AC Plant- GF-Weaving-2, DB-Overhead-1-AC Plant-GF-Weaving-2, DB-Overhead-2-AC Plant-GF-Weaving-2, MDB-Warping-4-GF-Weaving-2, MDB-Sizing-Tx Room- GF-Weaving-2, MDB-Workshop-Tx Room-GF-Weaving-2, MDB-Workshop-Tx- Room-GF-Weaving-2, DB-Loom-7-GF-Weaving-2, DB-Loom-6-GF-Weaving-2, DB-Loom-5-GF-Weaving-2, DB-Loom-4-GF-Weaving-2, DB-Loom-3-GF- Weaving-2, DB-Loom-1-GF-Weaving-2, SDB-2-1st Floor-Stitching-1, SDB-3-1st Floor-Stitching-1, MDB-Stitching-2-1st Floor-Stitching-2, DB-Lighting-1-1st Floor-Stitching-2, DB-Lighting-2-1st Floor-Stitching-2, DB-Lighting-4-1st Floor- Stitching-2, DB-Machine-1-1st Floor-Stitching-2, DB-Machine-2-1st Floor- Stitching-2, DB-Machine-3-1st Floor-Stitching-2, DB-Office-1st Floor-Stitching- 2, DB-5-Quilting-1st Floor-Stitching-2, MDB-ETP-ETP-2nd Floor, DB-Chemical Store-Basement-Towel Building, MDB-Towel (Sizing/Warping)-GF-Towel Building, MDB-Towel-Dyeing-Anglada-GF-Towel Bldg, DB-Colour Kitchen (LDB)-GF-Towel Building, DB-Towel (Raising)-GF-Towel Building, MDB-Flat Belt-GF-Towel Building, DB-Towel (Ingraving)-GF-Towel Building, MDB-Towel Stitching-1st Floor-Towel Building, DB-Towel (Stitching) (LDB-1)-1st Floor- Towel Building. Photograph: No phase separator. Install phase separators between terminal connections at the noted locations. 12 Jul 2014 Alliance Standard Part 10 Section 10.3.1 Electrical Connections Emergency Power System Is the generator room properly rated and physically separated from the remainder of the building? The generator room does not have the required fire rating but is physically separated (approximately 4 m gap between two buildings) from the remainder The Alliance for Bangladesh Worker Safety Page 19/22

27 May 2014 of the building. Location: Utility-2 Building, Ground Floor. Photograph: No fire rating for generator room. Provide adequate fire rating for generator room. 12 Jul 2014 Alliance Standards Part 10 Section 10.8.4 Generator Room Are cable trenches properly covered? Cable trenches are not covered properly. Location: Cable Trench Utility-2 Building. Photograph: Inadequate cable trench cover Provide adequate cover on cable trench. 28 Jun 2014 Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation Are emergency power switchboards, distribution boards, and circuits properly identified? Emergency power distribution boards are not properly identified. Location: All emergency distribution boards. Photograph: Improper identification of emergency distribution boards. Ensure proper identification of all emergency power distribution boards. It may be color paint or metal sticker permanently affixed with door. 28 Jun 2014 NFPA 70 Chapter 7 Article 700.10 Wiring, Emergency System Are inspection, maintenance, and testing procedures of the UPS being completed and documented? Low The Alliance for Bangladesh Worker Safety Page 20/22

27 May 2014 Inspection, maintenance and testing procedures of the IPS are not being completed. Visual Assessment: Inspection, maintenance and testing procedures of the IPS are not being completed. Establish an inspection testing and maintenance program for the Uninterruptible Power Supply (UPS)and/or Instant Power Supply (IPS) associated components. The program must be based on the following: (1) Manufacturer's recommendations (2) Manufacturer's instruction manuals (3) Minimum Requirements of NFPA 111 Chapter 8 (4) Minimum Requirements of NFPA 70B Chapter 28. Alliance Standard Part 13 Section 13.11 NFPA 111 Chapter 8 NFPA 70B Chapter 28 Are inspection, maintenance, and testing procedures of the emergency generator being completed and documented? Low Inspection, maintenance and testing procedures of the emergency generators are being completed but not documented properly. Photograph: Inspection, maintenance and testing procedures of the emergency generators being completed but not documented properly. Ensure inspection, maintenance, and testing procedures of the emergency generator being completed and properly documented. 25 Jul 2014 NFPA 110 Chapter 8 Lightning Protection System The air termination network vertical and horizontal conductors are appropriately spaced. As built electrical drawing (SLD) for the lightning protection system was not available to review whether the air termination network vertical conductors are appropriately spaced or not. Document Review: No as-built drawing is found. The Alliance for Bangladesh Worker Safety Page 21/22

27 May 2014 Consult with an Expert Electrical Engineer and ensure the system is secured against lightning. 12 Jul 2014 Alliance Standards Part 10 Section 10.11 Lightning Protection The appropriate number of down conductors are installed based on the building size. The as built electrical drawing (SLD) for the lightning protection system was not available to review, so appropriate number of down conductors needed can not be verified. Document Review: No as-built drawing was found. Consult with an Expert Electrical Engineer and ensure your system is secured against lightning. 12 Jul 2014 Alliance Standards Part 10 Section 10.11 Lightning Protection The Alliance for Bangladesh Worker Safety Page 22/22