INITIAL ELECTRICAL ASSESSMENT REPORT (EAR)

INITIAL ELECTRICAL ASSESSMENT REPORT (EAR) Factory Name: 4 YOU CLOTHING LTD 367/1 Senpara Parbata, Mirpur-10, Dhaka Dhaka Dhaka Bangladesh 27 May 2014 The Alliance for Bangladesh Worker Safety Page 1/18

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 2/18

27 May 2014 GENERAL INFORMATION General Information Factory Name: Country: Province: City: 4 YOU CLOTHING LTD Bangladesh Dhaka Dhaka Zip Code: 1216 Audit Duration: Re-Audit: 1 Days Re-Audit After 0 Months Draft Report Date : 05-28-2014 Final Report Date : 06-23-2014 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 one building on the factory premises. The building is named as: 1) Ten story RCC Main Production Building. Owned 1) Ten story RCC Main Production Building: Building height (est occupied floor level): 28.05 m or 92.00 ft [Height up to roof: 31.10 m or 102.00 ft], Stories above grade: 10, Stories below grade: 0, Occupied levels: 10. Total area: 78342.5 SF. 1) Ten story RCC main production building: 78342.5 SF (Ground floor: 7834.25 SF, 1st floor: 7834.25 SF, 2nd floor: 7834.25 SF, 3rd floor: 7834.25 SF, 4th floor: 7834.25 SF, 5th floor: 7834.25 SF, 6th floor: 7834.25 SF, 7th floor: 7834.25 SF, 8th floor: 7834.25 SF, 9th floor: 7834.25 SF). Factory personnel informed the date of construction as follows: 1) Ten story RCC Main Production Building: Started in December-1995 but no record of a finish date. Factory personnel informed the date of last building renovation as follows: 1) Ten story RCC Main Production Building: Renovation work is on going. There is no ancillary structure on factory premises. There is no ancillary structure on factory premises. The Alliance for Bangladesh Worker Safety Page 3/18

27 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? : Total number of occupants: 1640. 1) Ten story RCC Main Production Building: 1640 (Ground floor: 60, 1st floor: 210, 2nd floor: 212, 3rd floor: 230, 4th floor: 80, 5th floor: 235, 6th floor: 90, 7th floor: 218, 8th floor: 225, 9th floor: 80). Source: DESCO: Transformer-1 (1000 KVA), Generator-3, (650 KVA, 110 KVA, 200 KVA), Change Over Switch(COS)-4, Low Tension (LT) Panel-1, Main Distribution Board (MDB)-2, Distribution Board (DB)-10, Sub Distribution Board (SDB)-5. Substation located in Ground Floor of the building. IPS serves fire alarm, emergency lighting and exit signage. The Alliance for Bangladesh Worker Safety Page 4/18

27 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? There are no proper working or as-built electrical diagrams of the main distribution circuit or floor level circuits connecting electrical loads (machines/lights/cooling system, etc.) available on site. Document Review: No as-built electrical drawings. 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 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 electrical switchgear and panel boards are not inspected on an annual basis. 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? The Alliance for Bangladesh Worker Safety Page 5/18

27 May 2014 Thermographic scans of electrical equipment are not properly 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 NFPA 70B or a comparable standard. Alliance Standards Part 10 Section 10.13.8 Electrical Inspections Transformers do not contain harmful substances such as PCBs. No testing results found to ensure that transformers do not contain harmful substances. Document Review: No testing results found to ensure that transformers do not contain harmful substances. Consult with your transformer manufacturing company, and ensure transformers do not contain any harmful substances by having tests run and reviewing the results. Not Applicable A transformer oil analysis is routinely completed on main service transformers. Low No documentation on transformer oil analysis was found. Document Review: A transformer oil analysis report was not found. 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 The Alliance for Bangladesh Worker Safety Page 6/18

27 May 2014 Underground service cables are laid in conformity with the requirements of concealed wiring. Underground service cables are not laid in conformity with the requirements for concealed wiring. Location: Substation Room, Ground Floor. 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 as per BNBC 2.5.7.2. 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 does not have fire rating protection and is not physically separated from the remainder of the building. Photograph: Substation room does not have fire rating protection and is not physically separated. Provide adequate fire rating protection for substation room, and make it separate from rest of the building. Alliance Standard Part 3 Section 3.4.2.1.4 No circuits are drawn for loads without the incorporation of a overcurrent protection device (circuit breaker). Circuits are drawn for loads without the incorporation of an overcurrent protection device (circuit breaker). Location: DB-1/8th Floor, DB-1/3rd Floor, DB-1/1st Floor, DB-1/2nd Floor, DB-1/6th Floor, DB-1/4th Floor, DB-1/5th Floor, DB-1/7th Floor, DB-1/9th Floor, SDB-2/Ground Floor, SDB-4/Hydrant Room. The Alliance for Bangladesh Worker Safety Page 7/18

27 May 2014 Photograph: No protection device. Ensure overcurrent protection device (circuit breaker) for each and every load. 09 Jul 2014 Alliance Standards Part 10 Section 10.9 Protection of Circuits 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. There is metal in the building that is not connected to the building earthing system. Location: Water pipe (GI), cable ladder throughout the building. Visual Assessment: Not all metal in the building is connected to the building earthing. Connect all metal in the building to the building earthing/grounding system, such as metal rebar in concrete, metal frame of building, or metal water pipe. Alliance Standard Part 10 Section 10.10 Earthing Shielding or additional insulation is provided for wiring exposed to external heat sources. Non-Compliance Level: 2 Additional insulation is not provided for wiring that is exposed to external heat sources. Location: Boiler Room, Ground Floor. Photograph: Inadequate insulation for the wiring. Provide shielding and/or additional insulation for wiring exposed to external heat sources. 09 Jul 2014 Alliance Standards Part 10 Section 10.3.4.2 External heat sources. The Alliance for Bangladesh Worker Safety Page 8/18

27 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 do not have adequate clearance. Location: DB-1/6th Floor, DB -1/8th Floor, DB -1/9th Floor. Photograph: Inadequate clearance in front of distribution boards. Provide clearance of at least 1m (39in.) in front of distribution boards. 25 Jun 2014 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 cables and telecommunication or antenna cables are not led in separately. Location: All cable trays where power cables and telecommunication or antenna cables are routed together. Photograph: Power and telecommunication cables are not separated. Lead telecommunication or antenna cables separately to the main point of service. Power and telecommunication cables must have a separate entrance. Alliance Standards Part 10 Section 10.3.10 Service Entry Do switchboards and/or distribution boards have capacity information labels? No capacity information labels are provided for any of the distribution boards. Location: All distribution boards. Photograph: No capacity information labels provided on distribution boards. Provide capacity information labels (maximum current rating, number of circuit breakers, etc.) for switchboards and/or distribution boards. 09 Jul 2014 The Alliance for Bangladesh Worker Safety Page 9/18

27 May 2014 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. Distribution boards are not provided with a 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 distribution boards are provided with a physical means to prevent the installation of more over current devices than that number for which the panel board was designed, rated, and listed following NFPA 70 Section 408.54. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Cable joints are through porcelain/pvc connectors with PIB tape wound around joint. Improper cable joints. Location: All distribution boards. Photograph: Improper cable joints. Ensure cable joints are through porcelain/pvc connectors with PIB tape wound around the joints. Alliance Standards Part 10 Section 10.3.8.4 Cable Joints The substation room has adequate illumination levels. Non-Compliance Level: 2 The substation room has inadequate illumination levels. The Alliance for Bangladesh Worker Safety Page 10/18

27 May 2014 Photograph: Improper illumination in transformer room. Provide additional light fixtures to increase illumination levels as provided for in the BNBC. 09 Jul 2014 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)? Non-Compliance Level: 2 Internal components of distribution boards are not properly concealed. Location: DB-1/8th Floor, MDB-2/Substation room, LT Panel/Substation room, DB-1/1st Floor, DB-1/2nd Floor, DB-1/6th Floor. Photograph: Internal components are not properly concealed. Provide covers or blanks to conceal all live internal components of distribution boards. 25 Jun 2014 Alliance Standard Part 10 Section 10.3.9 Sub-Distribution Boards 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: All distribution boards (except LT panel and all MDBs). Photograph: No cable sockets. Provide cable sockets for stranded conductors with a nominal cross-sectional area of 6 mm2 or greater and conductors below 6 mm2 without cable sockets, all strands at the exposed ends are to be soldered together or are crimped using suitable sleeve or ferrules. 09 Jul 2014 Alliance Standards Part 10 Section 10.3.8.3 Cable Ends The Alliance for Bangladesh Worker Safety Page 11/18

27 May 2014 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: 2 Electrical cables are not properly terminated. Location: DB-1/4th Floor, DB-1- Finishing/6th Floor, Sewing Machine/7th Floor, Sewing Machine/8th Floor. Photograph: Un-terminated wires. Ensure all electrical wiring/cables are properly terminated at their point of termination. Alliance Standards Part 10 Section 10.3.9.2 Wiring of Sub-distribution Boards Are lighting and receptacle (socket) circuits segregated? Non-Compliance Level: 1 Lighting and sockets are not separated. Location: Technical Room/7th Floor. Photograph: Lighting and sockets are not separated. Separate lighting and socket circuits at the noted locations. Have a qualified electrician separate the lighting and sockets into separate circuits. Alliance Standard Part 10 Section 10.3.7.2 A wire/cable shaft is provided for the whole building. Wiring and cables are arranged in shaft for ease of inspection and maintenance. Non-Compliance Level: 1 A shaft for BBT system is available in the floor but a shaft for cable is not provided for the whole building. Photograph: Cable shaft is not found. Provide cable shaft for the whole building for ease of inspection and maintenance. 15 Sep 2014 The Alliance for Bangladesh Worker Safety Page 12/18

27 May 2014 BNBC Part 8 Section 2.5.6.1 Electrical wiring and conduit is properly supported. Non-Compliance Level: 1 Electrical wiring and conduit are not properly supported. Location: Substation Room. Photograph: Inadequate cable support. Provide adequate supports for electrical wiring and conduit. 09 Jul 2014 Alliance Standard Part 10 Section 10.3.2, 10.3.4.3, and 10.3.5 Signage indicating the prohibition of light fixtures without protective covers is installed at required locations. Low No signs to indicate the prohibition of light fixtures without protective covers are installed at the required locations. Location: Storage Area/Ground Floor. Photograph: No signage indicating the prohibition of the installation of light fixtures without protective covers. Ensure signage indicating the prohibition of light fixtures without protective covers is installed at required the locations. 25 Jun 2014 Alliance Standards Part 10 Section 10.15 Naked Lights Required equipment and safety signage is posted within the room. Low Non-Compliance Level: 2 Some equipment has required equipment signage but there is no safety signage in the substation room. Photograph: No safety signage was found. Required safety equipment and safety signage must be posted within the room. The Alliance for Bangladesh Worker Safety Page 13/18

27 May 2014 25 Jun 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 Are electrical insulation mats provided in front of substation, switchboards and/or distribution boards? Low Non-Compliance Level: 1 Electrical insulation mats are not provided in front of distribution boards. Location: DB-1 (4th Floor), SDB-2 (4th Floor), SDB -3 (6th Floor). Photograph: No electrical graded insulation mats provided in front of distribution boards. Provide electrical graded insulation mats in front of distribution boards. 25 Jun 2014 Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation. Phase separators are provided between terminals on circuit breakers. Low Non-Compliance Level: 1 Phase separators are not provided between terminals on circuit breakers. Location: DB-1-Finishing/6th Floor, DB-1/7th Floor, DB-1/8th Floor. Photograph: No phase separators. Install phase separators between terminal connections at the noted locations. 09 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? Generator room is not properly rated and is not physically separated from the The Alliance for Bangladesh Worker Safety Page 14/18

27 May 2014 remainder of the building. Photograph: Generator room is not rated and separated. Ensure the generator room is properly rated and physically separated from the remainder of the building. 09 Jul 2014 Alliance Standards Part 10 Section 10.8.4 Generator Room Are emergency power switchboards, distribution boards, and circuits properly identified? Emergency power distribution boards and circuits are not properly identified. Visual Assessment: No identification of emergency DBs/CKTs. Ensure proper identification of emergency power switchboards, distribution boards, and circuits. 25 Jun 2014 NFPA 70 Chapter 7 Article 700.10 Wiring, Emergency System Are cable trenches properly covered? Non-Compliance Level: 2 Cable trenches are not covered properly. Location: Generator Room, Ground Floor. Photograph: There is no cable trench cover. Provide a cover for cable trenches. 25 Jun 2014 Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation The Alliance for Bangladesh Worker Safety Page 15/18

27 May 2014 Is the generator frame earthing (grounding) provided at two separate points? Generator frame earthing is only provided at single point. Photograph: Inadequate generator frame earthing. Provide two separate points earthing (grounding) for each generator. 21 Jul 2014 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 generator room is not appropriate. Photograph: Inadequate generator room size. Ensure that the generator room is appropriately sized in order to gain proper access to the generator to perform routine maintenance activities. 20 Aug 2014 Alliance Standard Part 10 Section 10.8.4 Generator Room Are inspection, maintenance, and testing procedures of the UPS being completed and documented? Low Non-Compliance Level: 1 Inspection, maintenance and testing procedures of the IPS are performed by the supplier but documentation is not complete. Photograph: Improper documentation found for IPS mantenance. 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. The Alliance for Bangladesh Worker Safety Page 16/18

27 May 2014 18 Aug 2014 Alliance Standard Part 13 Section 13.11 NFPA 111 Chapter 8 NFPA 70B Chapter 28 Lightning Protection System 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. Visual Assessment: The lightning protection ground terminals are not bonded to the building or structure grounding. Consult with an expert electrical engineer to ensure the lightning protection ground terminals are bonded to the building or structure grounding. 09 Jul 2014 Alliance Standards Part 10 Section 10.11 Lightning Protection The air termination network vertical and horizontal conductors are appropriately spaced. Non-Compliance Level: 2 The air termination network vertical and horizontal conductors are appropriately spaced, but as-built electrical drawing (SLD) for the lightning protection system was not available for review. The adequacy and functionality of the system could not be verified/checked. Location: Roof Floor, Main Building. Worker Interviews: Factory personnel said that the air termination networks are appropriately spaced but no drawing was found to review and verify this information. Consult with an expert electrical engineer and ensure your system is secured against lightning. 09 Jul 2014 Alliance Standards Part 10 Section 10.11 Lightning Protection The Alliance for Bangladesh Worker Safety Page 17/18

27 May 2014 The Alliance for Bangladesh Worker Safety Page 18/18