INITIAL ELECTRICAL ASSESSMENT REPORT (EAR)

INITIAL ELECTRICAL ASSESSMENT REPORT (EAR) Assessor: Karardi, Shibpur, Narsingdi Narsingdi Dhaka Bangladesh Emkay Enterprises The Alliance for Bangladesh Worker Safety Page 1/15

10 Apr 2016 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 2/15

GENERAL INFORMATION General Information Country: Province: City: Bangladesh Dhaka Narsingdi Zip Code: Audit Duration: Re-Audit: 1 Days 0 Hours Re-Audit After 0 Months Draft Report Date : 17 April 2016 Final Report Date : 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) : To be filled out by the Alliance QA representative N/A There are twenty buildings, nine main buildings and eleven ancillary buildings. 14 buildings have been audited under Alliance ID 9330. 6 buildings are covered under this audit. 1. Main Shed (Woven); 2. Extension of Woven & Dyeing Building; 3. TWDL Warehouse; 4. Chemical Godown; 5. Finished Godown; 6. Workshop. Owned 1. Main Shed (Woven): 1-story with mezzanine. 1. Main shed (Woven): 51,000 SF. 1. Main Shed (Woven): 2010; 2. Extension of Woven & Dyeing Building: 2015; 3. All other buildings: 2013-14. None There are 5 ancillary buildings part of this audit. Total Area: 38,507 SF. 1. Extension of Woven & Dyeing Building: 13,342 SF (GF: 6,671 SF, 1st: 6,671 SF); 2. TWDL Warehouse: 6,097 SF; 3. Chemical Godown: 10,738 SF (GF: 5,369 SF, 1st: 5,369 SF); 4. Finished The Alliance for Bangladesh Worker Safety Page 3/15

Godown: 4,165; 5. Workshop: 4,165 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? : Total Occupants: 411. 1. Main shed (Woven): 300 (100 @ 3 shifts), 2. Extension of Woven & Dyeing Building: 69 (23 @ 3 shifts); 3. TWDL Warehouse: 15 (5 @ 3 shifts); 4. Chemical Godown: 4 (2 @ 2 shifts); 5. Finished Godown: 18 (6 @ 3 shifts); 6. Workshop: 5. There are thirteen generators (11 pcs; 1.03 MW each, 1 pc; 500 KW, 1 pc; 300 KW) for Powering the whole facility. 1 no. 2 pcs PFI panel (1pc; 1000KVAR, 1pc; 800 KVAR), 2 pcs LT panel, 15 PCs. DB. 2 pcs SDB is occupied for distributing power to loads of the facility. Sub Station is separated from main building. Emergency Light, Emergency Exit. The Alliance for Bangladesh Worker Safety Page 4/15

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 were available for review but several points need to be updated. Such as, phase indication is needed for each panel. Document Review: Documents were not available. Have a qualified electrical engineer develop as-built drawings detailing key components and capacity of the electrical system in accordance with Alliance requirements. 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? Documents regarding electrical safety training program have not been developed. Document Review: Documents were not available. 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 Are thermographic scans of electrical equipment completed at least every three years? The Alliance for Bangladesh Worker Safety Page 5/15

No records of previous thermographic scan were found. Document Review: Documents were not available. Complete thermographic scans on a minimum 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. 25 May 2016 Alliance Standards Part 10 Section 10.13.8 Electrical Inspections Are periodic safety inspections of the electrical system components completed and documented? Records regarding safety inspection of the electrical system components was not found. Document Review: Documents were not available. Establish a periodic inspection program to ensure the electrical systems are free from damage, debris, dirt, lint, etc. Maintain records regarding the inspections and follow up actions. Alliance Standard Part 10 Section 10.13 Inspection and Testing and Part 13 Section 13.6 Housekeeping Is a periodical Insulation Resistance Measurement Program established and recorded? Insulation Resistance Measurement Program and records have not been established or kept. Document Review: Documents were not available. 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, e The Alliance for Bangladesh Worker Safety Page 6/15

Alliance Standard Part 10 Section 10.13.4 Insulation Tests and 10.13.8 Electrical Inspections Electrical System Conditions Are all switchboards and/or distribution boards metal enclosed with a dead front construction? Perforated back-cover has been installed for LT Switchgear-2 in Generator control room. Photograph: Back cover with holes in LT-Panel-02 in Sub Station room. Provide switchboards and/or distribution boards with metal enclosed dead front construction. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Indications of overheating, overloading, or signs of burning were not observed. During thermographic scan, some hotspots were observed at multiple locations. Refer to Thermographic Survey Report for detailed information. Visual Assessment: Inspected with thermal imager. Determine the cause of overheating, overloading, or signs of burning and take proper action. Suggested plan for specific issues have been incorporated in the Thermographic Survey Report. Alliance Standard Part 10 Section 10.3.5 No multi looping of wiring/cables observed at circuit breakers within switchboards and/or distribution boards. Multiple-termination into a terminal of circuit breaker was observed in some The Alliance for Bangladesh Worker Safety Page 7/15

panels of the factory. For example, in DB-1/SINGEING/GF/B-12 multiple connections are taken from single port of circuit breaker. Photograph: Multiple connections into DB-1/SINGEING/GF/B-12. Remove multi looping of wiring/cables at circuit breakers within switchboards and/or distribution boards. Make separate connection from bus bar for individual circuits. 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: 1 Electrical equipment is not efficiently earthed and properly connected to the required number of earth electrodes. For an example: In DB-04 earthings were not efficiently connected and required number of earth electrodes was not available. Photograph: Electrical equipment is not connected to the required number of earth electrodes. Provide efficient earthing for all equipment at required locations and properly connect using the required number of earth electrodes. Refer to the BNBC for required number of electrodes. 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: 1 All metal components have not been connected to building earthing system. Visual Assessment: Visually inspected during audit. Connect all metal in the building to the building earthing system such as metal rebar in concrete, metal frame of building, or metal water pipe. The Alliance for Bangladesh Worker Safety Page 8/15

Alliance Standard Part 10 Section 10.10 Earthing Are all switchboards and/or distribution boards properly grounded (earthed)? Under sized grounding cables were found in panels. For example, in DB-04, one 1.5 sq mm cable has been provided as earthing connection where main phase cable is 6.0 sq mm. Photograph: Earthing cable size not proper. Provide earthing cable for this panel according to the size of the main service cable (phase cable) and provide earthing connection at all required location (panel, equipment etc.) as per Alliance standard; Part 10; Section 10.10.2; Circuit and System Ear Alliance Standard Part 10 Section 10.10.2 Circuit and System Earthing Do switchboards and/or distribution boards have capacity information labels? Capacity information labels are not maintained properly for all panels. For example: In DB-07/PUMP/GF/B-12 no capacity information was available but the label was found. Photograph: Capacity information labels ware not maintained properly. Provide capacity information labels (Maximum current rating, number of circuit breakers, rated capacity of circuit breaker, etc.) for Switchboards and/or distribution boards. Display panel schedule on panel door (inner side) printed on a sheet made of non 25 May 2016 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? Dust was found inside distribution boards. For example: In DB- 13/INSPECTION/GF/B-10 dust was found. The Alliance for Bangladesh Worker Safety Page 9/15

Photograph: Dust found inside DB-13/INSPECTION/GF/B-10. Disconnect the panel from the electrical service and clean interior components of all dust and debris. Seal all openings within the enclosure to prevent dust and debris from entering. Alliance Standard Part 10 Section 10.3.9.1 Enclosures Are all internal components of switchboards and/or distribution boards properly concealed (No missing circuit breaker or knockout covers)? Bottom plate of all panels in sub-station room were not installed to conceal live component of panel. Photograph: Base plate not provided in LT Panel in Sub Station room. Provide cable gland according to the respective cable size for cable entry and exit so that the cables are not stressed on the sharp edges of the hole of panels. Provide covers or blanks to conceal all live internal components of switchboards and/or distr Alliance Standard Part 10 Section 10.3.9 Sub-Distribution Boards 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. Capacity information labels have not been found in order to determine how many circuit breakers the panels were designed for. Some distribution boards have space in DIN-rail channel to install additional over-current devices. For example, DB-13/INSPECTION/GF/B-10, Ground Floor in had space in DIN-rail channel for additional circuit breakers. Photograph: DB-13/INSPECTION/GF/B-10, Ground Floor in had space in DINrail channel for additional circuit breakers. For switchboards and/or distribution boards, provide the 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. Verify the existi The Alliance for Bangladesh Worker Safety Page 10/15

Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Are electrical wiring/cables properly identified? Cables have not been provided with identification. Also, color code has not been maintained at MCB terminals in some panel boards. For example, cables in DB-02/BLEACHING/GF/B-12, Ground Floor did not have identification. Photograph: Cables are not identified in DB-02/BLEACHING/GF/B-12. Provide identification of wires/cables by separate color coding, marking tape, tagging, or other approved means. Bangladesh Electricity Rules 1937 Rule 51 and 56 Electrical wiring and conduit is properly supported. Electrical wiring was not properly supported. For example: in DB- 7/PUMP/GF/B-12, the incoming and outgoing cables were not properly supported with required supporting materials. Photograph: Picture Provide adequate supports for electrical wiring and conduit. 25 May 2016 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. Cables connected to DB-03/WASHING/GF/B-12 without cable shoe were observed in Ground Floor. The Alliance for Bangladesh Worker Safety Page 11/15

Photograph: Cables are connected in DB-03/WASHING/GF/B-12 without cable shoe. Provide proper size and type of cable socket for stranded conductors having a nominal cross-sectional area 6mm2 or greater. For conductors below 6 mm2 without cable sockets, provide soldering for all strands at the exposed ends or crimp the exposed ends u Alliance Standards Part 10 Section 10.3.8.3 Cable Ends Cable joints are through porcelain/pvc connectors with PIB tape wound around joint. Cable joints were made without providing any connectors and only PVC tape wound around. For example, cable joints without connectors were observed in DB-03/WASHING/GF/B-12. Photograph: Cable joints without connectors were observed in DB- 03/WASHING/GF/B-12. Provide cable joints through porcelain/pvc connectors with PIB tape wound around joint before placing the cable in the box. Alliance Standards Part 10 Section 10.3.8.4 Cable Joints Mechanical guards are provided for electrical equipment and wiring where necessary. No mechanical guards are provided for electrical equipment and wiring where necessary. For example: in DB-07/PUMP/GF/B-12 no mechanical guards were found. Photograph: No mechanical guards for DB-07/PUMP/GF/B-12. Provide mechanical guards for electrical equipment where necessary. 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 The Alliance for Bangladesh Worker Safety Page 12/15

Each circuit is provided with a dedicated neutral. Non-Compliance Level: 1 Dedicated neutral is not provided with each circuit and neutral cables did not have any identification. Therefore it cannot be determined whether dedicated neutral connections have been used. For example, neutral cables without identification were found in, DB-06/QAD/GF/B-12. Photograph: Neutral cables without identification were found in DB- 06/QAD/GF/B-12. Provide a dedicated neutral for each circuit following respective phase cable size. Provide identification and marking of neutral cables to each circuit for maintenance. Alliance Standards Part 10 Section 10.3 Electrical Wiring and Cabling Electrical connections at equipment, fixtures, etc are properly secured. Non-Compliance Level: 1 Electrical connections were not properly secured in several panel boards. For example: In DB-03/WASHING/GF/B-12, the incoming neutral cable was damaged. Photograph: Cable was damaged in DB-03/WASHING/GF/B-12. Properly connect and secure cables at equipment, fixtures, etc. in accordance with Alliance standard. 18 May 2016 Alliance Standards Part 10 Section 10.3.1 Electrical Connections Phase separators are provided between terminals on circuit breakers. Low Phase separators into terminal of circuit breaker were not observed in some panels of the factory. For example, in DB-7/PUMP/GF/B-12 phase separators were not provided. Photograph: Phase separators were not found in DB-1/SINGEING/GF/B-12. The Alliance for Bangladesh Worker Safety Page 13/15

Install phase separators between terminal connections. Verify phase separators are installed at all remaining locations. Alliance Standard Part 10 Section 10.3.1 Electrical Connections Emergency Power System Are cable trenches properly covered? Cable trenches are not covered throughout the length of the tray in substation room may cause damaging of service cables. Photograph: Cable trenches are not properly covered. Provide cable ladder/cable trench to accommodate cable. If trench is provided, then provide the cable ladder/cable trench with a cover of non flammable material. Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation Are emergency power switchboards, distribution boards, and circuits properly identified? Non-Compliance Level: 1 Components of the emergency power system do not have proper identification. Photograph: No identification for the IPS system located in the facility. Provide proper identification of all boxes and enclosures (including transfer switches, generators, and power panels) for emergency circuits. Provide permanently markings so they will be readily identified as a component of an emergency circuit or system. 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 14/15

Documentation of inspection and maintenance and testing of UPS was not available on site. Visual Assessment: Visually Inspected during audit. Establish an inspection testing and maintenance program for the Uninterruptable Power Supply (UPS) and associated components. The program must based on the following: (1) Manufacturer's recommendations (2) Manufacturer's instruction manuals (3) M 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? Lightning protection system has not been installed. The calculated risk index for this facility is 43, which is above the marginal risk index of 40. Visual Assessment: Visually inspected during audit. Have a qualified electrical engineer design a lightning protection system according to the BNBC or NFPA requirements. Have a licensed electrician install the designed system. Alliance Standards Part 10 Section 10.11 Lightning Protection. Calculate Risk Index to determine if required. The Alliance for Bangladesh Worker Safety Page 15/15