INITIAL ELECTRICAL ASSESSMENT REPORT (EAR) Factory C-13, South Badda, Gulshan-1, Badda, Dhaka Dhaka Dhaka 22 May 2014 The Alliance for Worker Safety Page 1/21
22 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 2/21
22 May 2014 GENERAL INFORMATION General Information Factory Country: Province: City: Dhaka Dhaka Zip Code: 1212 Audit Duration: Re-Audit: 1 Days Re-Audit After 0 Months Draft Report Date : 05.24.2014 Final Report Date : 05.27.2014 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 2 Nos: 01 No-Main Building; 01-Substation Room; Rented Main Building- 5 Storied; Substation Room- 1 Storied; 20450 No information N/A 1 No - Substation Room. 150 Number of Occupants : 450 The Alliance for Worker Safety Page 3/21
22 May 2014 Provide brief description of the electrical system for each building.: Physical location of Substation? : What equipment/loads does the UPS serve? : Transformer 200KVA (DESCO) and Diesel Generator 181KVA. COS-1 No, LT Panel-1 No, DB- 3 Nos & SDB- 6 Nos. Substation located on ground floor of main building. Computer, Printer. The Alliance for Worker Safety Page 4/21
22 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? Proper Working or as built electrical diagram of main distribution circuit and floor levels circuits connecting electrical loads (machines/lights/cooling system etc.) are not available at site. Document Review: No as-built electrical drawing was found. Have a qualified electrical engineer develop an as-built single line diagram detailing key components and capacity of the electrical system. Alliance Standard Part 10 Section 10.3.7 Electrical System Maintenance Have workers that operate and maintain the electrical system received electrical safety training? Is training documentation on site? Workers that operate and maintain the electrical system have not received electrical safety training. Worker Interviews: No electrical safety training. Develop and implement an electrical safety program. Include key topes such as lock out tag out procedures, personal protective equipment requirements, etc. Reference NFPA 70e for example program requirements. Reference NFPA 70e for example Is a periodical Insulation Resistance Measurement Program established and recorded? The Alliance for Worker Safety Page 5/21
22 May 2014 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). 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. No testing document found to verify that transformers do not contain harmful substances such as PCBs. Document Review: No documentation found regarding this issues., Worker Interviews: Factory personnel are not concerned about this issue. Consider replacing transformers with harmful substances to reduce health hazards. The Alliance for Worker Safety Page 6/21
22 May 2014 Not Applicable Are periodic safety inspections of the electrical system components completed and documented? No periodic safety inspections of the electrical system components are 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 A transformer oil analysis is routinely completed on main service transformers. Low Transformer oil analysis is not completed on main service transformers. Document Review: Transformer oil analysis is not 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 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 rating but physically separated from the remainder of the building (about 1 meter distance). Photograph: No fire rating for substation room. The Alliance for Worker Safety Page 7/21
22 May 2014 Provide adequate fire rating/ protection for substation room. Alliance Standard Part 3 Section 3.4.2.1.4 Are all switchboards and/or distribution boards metal enclosed with a dead front construction? Distribution boards are metal enclosed but no dead front construction. Location: All distribution boards except SDB/4th Floor. Photograph: Distribution boards are metal enclosed Ensure distribution boards are metal enclosed with a dead front construction. 05 Jul 2014 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 loads without the incorporation of an overcurrent protection device (circuit breaker). Location: DB/Stair/Ground Floor; DB- 1/Ground Floor; SDB/1st Floor; SDB/2nd Floor; SDB/3rd Floor; Photograph: Circuits are drawn for loads without the incorporation of an overcurrent protection device. Ensure overcurrent protection device (circuit breaker) for each and every loads. Alliance Standards Part 10 Section 10.9 Protection of Circuits The Alliance for Worker Safety Page 8/21
22 May 2014 No multi looping of wiring/cables observed at circuit breakers within switchboards and/or distribution boards. Multi looping of wiring/cables observed at circuit breakers within distribution boards. Location: DB/Stair; SDB/1st Floor; SDB/3rd Floor; SDB/4th Floor; Photograph: Multi looping of cables at circuit breakers. Remove multi looping of wiring/cables at circuit breakers within distribution boards. Alliance Standard Part 10 Section 10.3 Electrical Wiring and Cabling Indications of overheating, overloading, or signs of burning were not observed. Non-Compliance Level: 1 Indications of burning were observed. Location: 4th Floor/Iron Table; Photograph: Indications of burning were observed. Find out the cause of burning and take proper action. 24 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)? Non-Compliance Level: 1 Electrical cables are not sized according to capacity of circuit breakers. Location: SDB/Boiler; SDB-1/Boiler; Photograph: Electrical cables are not sized accordingly. Consult with a qualified Electrical Engineer and ensure electrical wiring/cables are sized according to capacity of circuit breakers. The Alliance for Worker Safety Page 9/21
22 May 2014 Alliance Standard Part 10 Section 10.3.1 Electrical Connections. Power and telecommunication or antenna cables are led in separately. Power and telecommunication or antenna cables are not led in separately. Location: 1st Floor/Stair Case; Photograph: Power and telecommunication cables are not separated. Led telecommunication or antenna 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 The substation room is clean and free from dirt, lint, water, oil, and debris. Substation room is not clean and free from dirt/ lint/ debris. Photograph: Substation room is not clean. Remove all dirt, debris, lint and improperly stored materials from the substation room. 24 May 2014 Alliance Standard Part 13 Section 13.6.2 The substation room has adequate ventilation. The substation room has no adequate 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. 05 Jul 2014 The Alliance for Worker Safety Page 10/21
22 May 2014 Alliance Standard Part 10 Section 10.13.7.1 Inspection of Substation Installations. The substation room has adequate illumination levels. The substation room is not illuminated properly. Location: Substation Room Photograph: Improper illumination in substation room. Provide additional light fixtures to increase illumination levels provided in the BNBC. 05 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)? Internal components of distribution boards are not properly concealed. Location: COS/Generator Room; DB/Geerator Room; DB/Stair/Ground Floor; DB-1/Ground Floor; SDB/1st Floor;SDB/2nd Floor; SDB/3rd Floor; SDB/4th Floor; Photograph: Internal components are not properly concealed. Provide covers or blanks to conceal all live internal components of distribution boards. 21 Jun 2014 Alliance Standard Part 10 Section 10.3.9 Sub-Distribution Boards Do switchboards and/or distribution boards have clear identification markings? Distribution boards have no clear identification markings. Location: All distribution boards Photograph: Distribution boards have no clear identification As per BNBC section 2.11.5.4 ensure clear and permanent identification The Alliance for Worker Safety Page 11/21
22 May 2014 marks are painted in all distribution boards, switchboards, sub main boards and switches. 21 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 have no capacity information labels. Location: All distribution boards Photograph: Distribution boards have no capacity information labels. Provide capacity information labels (Maximum current rating, no of circuit breakers etc.) for distribution boards. 05 Jul 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 free of dust and debris? Distribution boards are not clean. Location: All Distribution Boards. Photograph: Distribution boards are not clean. Ensure distribution boards free of dirt and debris. 21 Jun 2014 Alliance Standard Part 10 Section 10.3.9.1 Enclosures 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 The Alliance for Worker Safety Page 12/21
22 May 2014 board was designed, rated, and listed. Location: All the distribution boards. Photograph: Distribution boards are not provided with physical means Ensure 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 following NFPA 70 section 408.54. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Are electrical wiring/cables properly identified? Electrical cables are not properly identified. Location: All the distribution boards Photograph: Electrical cables are not properly identified Ensure the means of identification is obtained by separate color coding, marking tape, tagging, or other approved means. Electricity Rules 1937 Rule 51 and 56 Each circuit is provided with a dedicated neutral. Each circuit is not provided with a dedicated neutral. Location: SDB/1st Floor; SDB/2nd Floor; SDB/3rd Floor; SDB/4th Floor; Photograph: Each circuit is not provided with a dedicated neutral. Provide dedicated neutral for each circuit. Alliance Standards Part 10 Section 10.3 Electrical Wiring and Cabling The Alliance for Worker Safety Page 13/21
22 May 2014 Electrical wiring and conduit is properly supported. Electrical wiring and conduit is not properly supported. Location: COS/GF/Generator Room; Photograph: Inadequate cable support. Provide adequate supports for electrical wiring and conduit. 05 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/Stair; DB-1/Ground Floor; SDB/1st Floor; SDB/2nd Floor; SDB/3rd Floor; Photograph: No cable socket. Provide cable sockets for stranded conductors having a nominal crosssectional area 6mm2 or greater. 05 Jul 2014 Alliance Standards Part 10 Section 10.3.8.3 Cable Ends Lighting fixtures are supported from the structure and seismic bracing is installed as required. Lighting fixtures are not supported properly. Location: Finishing Section, Ground Floor; Sewing Section, 2nd Floor; Photograph: Lighting fixtures are not supported properly. Ensure Lighting fixtures are supported from the structure and seismic bracing is installed as required. The Alliance for Worker Safety Page 14/21
22 May 2014 21 Jun 2014 Alliance Standards Part 10 Section 10.3.6 Lighting Fittings Electrical connections at equipment, fixtures, etc are properly secured. Electrical connections at equipment, fixtures, etc. are not properly secured. Location: Throughout Sewing Section, 4th Floor; Photograph: Electrical connections are not secured. Ensure electrical connections at equipment, fixtures, etc. are properly secured. 05 Jul 2014 Alliance Standards Part 10 Section 10.3.1 Electrical Connections Cable joints are through porcelain/pvc connectors with PIB tape wound around joint. Non-Compliance Level: 1 Improper cable joints were found. Location: SDB/1st F/Sewing; Photograph: Improper cable joint. Ensure cable joints through porcelain/pvc connectors with PIB tape wound around joint. Alliance Standards Part 10 Section 10.3.8.4 Cable Joints Is all electrical wiring/cable properly terminated at its point of termination (No un-terminated wires, lugs are provided at terminals, etc)? Non-Compliance Level: 1 Electrical cables is not properly terminated. Location: SDB/1st Floor; SDB/3rd Floor; Photograph: Un-terminated wires. Ensure all electrical cables properly terminated at its point of termination. The Alliance for Worker Safety Page 15/21
22 May 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? Non-Compliance Level: 1 Other electrical devices (circuit breakers) are not provided with covers. Location: Under stair case Photograph: Circuit breakers without cover. Provide adequate covers for other electrical devices. 21 Jun 2014 Alliance Standard Part 10 Section 10.3.5 and 13.6.2 Mechanical guards are provided for electrical equipment and wiring where necessary. Non-Compliance Level: 1 No mechanical guards are provided for electrical wiring where necessary. Location: DB/Stair; COS/GF/Generator Room; Photograph: No mechanical guards. Provide mechanical guards for electrical wiring where necessary. 21 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 Are electrical insulation mats provided in front of substation, switchboards and/or distribution boards? Low Electrical insulation mats are not provided in front of substation and distribution boards. Location: All distribution boards The Alliance for Worker Safety Page 16/21
22 May 2014 Photograph: No mats provided in front of substation, distribution boards. Provide electrical insulation mats in front of distribution boards. 21 Jun 2014 Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation. Required equipment and safety signage is posted within the room. Low No equipment and safety signage found in the room. Location: Substation Room; Generator Room; Photograph: No equipment and safety signage found in the room. Provide equipment and safety signage is posted within the room. 21 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 Electricity Rules of 1937 Rule 46 Phase separators are provided between terminals on circuit breakers. Low Phase separators are not provided between terminals on circuit breakers. Location: LT/Ground Floor; DB/Ground Floor; DB-1/Ground Floor; SDB/1st Floor; SDB/2nd Floor; SDB/3rd Floor, SDB/4th Floor Photograph: Phase separators are not provided between terminals on circuit breakers. Install phase separators between terminal connections at the noted locations. Alliance Standard Part 10 Section 10.3.1 Electrical Connections The Alliance for Worker Safety Page 17/21
22 May 2014 Are meters and other electrical devices (Ammeter, Voltmeter, PFI Auto Controller, etc) installed on the main electrical equipment operational? Low Non-Compliance Level: 1 Meters and other electrical devices (Ammeter) installed on the main electrical equipment are not operational. Location: LT/GF/Substation; Photograph: Meters and other electrical devices (Ammeter) are not operational. Ensure meters and other electrical devices installed on the main electrical equipment are operational. 05 Jul 2014 Alliance Standard 10.13.7 Inspection of the Installation 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 not physically separated from the remainder of the building. Photograph: Generator room is not rated/separated. Ensure the generator room properly rated and physically separated from the remainder of the building. 05 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 are not properly identified. Photograph: No identification of emergency DBs/CKTs Ensure proper identification of emergency power switchboards, distribution The Alliance for Worker Safety Page 18/21
22 May 2014 boards, and circuits. 21 Jun 2014 NFPA 70 Chapter 7 Article 700.10 Wiring, Emergency System Are life safety loads (fire alarm, fire pump, elevators, emergency lighting, exit signage, etc) connecting to the emergency power system? Life safety loads (fire alarm, fire pump, elevators, emergency lighting, exit signage, etc) are not connected to the emergency power system. Visual Assessment: No emergency power for life safety loads. Provide emergency power connection for life safety loads (fire alarm, emergency lighting, exit signage, etc.). 20 Jul 2014 Alliance Standard Part 10 Section 10.8 Standby Power Is the generator room clean and free of dirt, debris, and improperly stored materials? Generator room is not clean. Photograph: Generator room is not clean. Ensure the generator room clean and free of dirt, debris, and improperly stored materials. 24 May 2014 Alliance Standards Part 10 Section 10.8.4 Generator Room Are cable trenches properly covered? Cable trays are not covered properly. Lint, dirt etc are present in the cable tray. Location: Throughout Finishing Section, Ground floor Photograph: Cable tray without cover The Alliance for Worker Safety Page 19/21
22 May 2014 Provide adequate cover on cable tray to ensure that cable trays are lint/dirt/vermin proof. 21 Jun 2014 Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation Is the generator frame earthing (grounding) provided at two separate points? Generator frame earthing (grounding) is not provided at two separate points. Single point earthing provided at generator frame. Photograph: Inadequate generator frame earthing. Provide two separate points earthing (grounding) provided for generator. 05 Jul 2014 Alliance Standard 10.8.2.2 Are inspection, maintenance, and testing procedures of the emergency generator being completed and documented? Low Inspection, maintenance, and testing procedures of the emergency generator are not being completed. Document Review: Inspection/ maintenance/ testing procedures of the emergency generator are not completed Ensure inspection, maintenance, and testing procedures of the emergency generator being completed and documented. NFPA 110 Chapter 8 Are inspection, maintenance, and testing procedures of the UPS being completed and documented? Low The Alliance for Worker Safety Page 20/21
22 May 2014 Inspection, maintenance, and testing procedures of the UPS are not completed. Document Review: No documentation on UPS testing and maintenance. Ensure inspection, maintenance, and testing procedures of the UPS are not completed and documented. Alliance Standard Part 13 Section 13.11 NFPA 111 Chapter 8 NFPA 70B Chapter 28 Lightning Protection System Is a lightning protection system installed on the building? No lightning protection system installed on the building. Photograph: No lightning protection system Install lightning protection system on the building. 16 Aug 2014 Alliance Standards Part 10 Section 10.11 Lightning Protection. Calculate Risk Index to determine if required. The Alliance for Worker Safety Page 21/21