EQUIVALENT INITIAL ELECTRICAL SAFETY ASSESSMENT

EQUIVALENT INITIAL ELECTRICAL SAFETY ASSESSMENT Hatimara Road, Barenda, Kashimpur, Gazipur, Gazipur Dhaka The Alliance for Worker Safety Page 1/18

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 2/18

GENERAL INFORMATION General Information Country: Province: City: Dhaka Gazipur Zip Code: 1346 Audit Duration: Re-Audit: 1 Days Re-Audit After 0 Months Draft Report Date : 05-19-2014 Final Report Date : 06-19-2014 Are all action items from previous assessment complete? : Buildings in Complex : Is the building(s) owned or rented by the?: Number of Building Levels (Stories) : Approximate Building Area (SF) : Date of Building Construction : Date of Last Building N/A There are 5 buildings in the factory premises. Out of which is four are production buildings and one is ancillary building. The buildings are named as: 1) Six story RCC building, 2) Four story RCC building (proposed ten story), 3) Six story RCC Utility building, 4) Four story RCC ETP building, 5) Single story Prefab shade. Owned 1) Six story RCC building: Building levels: 6, 2) Four story RCC building: Building levels: 4, 3) Six story RCC Utility building: Building levels: 6, 4) Four story RCC ETP building: Building levels: 4, 5) Single story Prefab shade building: Building levels: 1. 1) Six story RCC building: 113025 sft (Ground floor: 22405 sft, 1st floor: 20405 sft, 2nd floor: 20405 sft, 3rd floor: 20405 sft, 4th floor: 20405 sft, 5th floor: 9000 sft), 2) Four story RCC building: 47941 sft (Ground floor: 11423 sft, 1st floor: 11793 sft, 2nd floor: 12145 sft, 3rd floor: 12580 sft), 3) Six story RCC Utility building: 21000 sft (Ground floor: 3500 sft, 1st floor: 3500 sft, 2nd floor: 3500 sft, 3rd floor: 3500 sft, 4th floor: 3500 sft, 5th floor: 3500 sft), 4) Four story RCC ETP building: Total area: 2280 sft (Ground floor: 570 sft, 1st floor: 570 sft, 2nd floor: 570 sft, 3rd floor: 570 sft), 5) Single story Prefab shade building: 11379 sft. personnel informed the date of construction as follows: 1) Six story RCC building: Started in 2003 and finished in 2010, 2) Four story RCC building (proposed ten story): Started in 2012 and finished in 2013 (Upto 3rd story), 3)Six story RCC Utility building: Started in 2005 and finished in 2007, 4) Single story prefab shed: Finished in 2007. No record of date of last building renovation/addition was found from factory personnel. The Alliance for Worker Safety Page 3/18

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? : 1) Four story RCC ETP building. 1) Four story RCC ETP building: Total area: 2280 sft (Ground floor: 570 sft, 1st floor: 570 sft, 2nd floor: 570 sft, 3rd floor: 570 sft). Total number of occupants: 1837. 1) Six story RCC building: 1446 (Ground floor: 76, 1st floor: 320, 2nd floor: 280, 3rd floor: 355, 4th floor: 330, 5th floor: 85), 2) Four story RCC building: 86 (Ground floor: 39, 1st floor: 0, 2nd floor: 47, 3rd floor: 0), 3) Six story RCC Utility building: 145 (Ground floor: 2, 1st floor: 1, 2nd floor: 103, 3rd floor: 25, 4th floor: 12, 5th floor: 2), 4) Four story RCC ETP building: 2, 5) Single story prefab shed: 158. 1No Transformer (630 KVA) and 2 Nos Gas Generator (505 KVA, 725 KVA). Source REB, 1 No COS, 1 No HT Panel, 1 No LT Panels, MDB- 09 Nos, DB-13 Nos, SDB- 07 Nos. Substation located at Ground Floor of main building. Computer,Printer, emergency light. The Alliance for Worker Safety Page 4/18

ASSESSMENT FINDINGS 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 to ensure that the equipment is installed in accordance with the listed ratings. Document Review: No annual inspection record for electrical switchgear or 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? Thermographic scans of electrical equipment are not completed. Document Review: No thermographic scans of the 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 Worker Safety Page 5/18

No evidence (certificate) found to confirm that transformer does not contain any harmful substances. Document Review: No evidence found. Consult with transformer manufacturing company to ensure that the transformer does not contain any harmful substances. Consider replacing the transformers with harmful substances to reduce health hazards. Not Applicable Are periodic safety inspections of the electrical system components completed and documented? Periodic safety inspections of the electrical system components are not 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. and 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 Alliance for Worker Safety Page 6/18

Underground service cables are laid in conformity with the requirements of concealed wiring. Underground service cables are not laid in conformity with the requirements of concealed wiring. Location: Transformer room-ground Floor Photograph: Improper wiring of underground service cables. Ensure underground cables for electrical distribution in the premises/garden/compound of the building are encased in GI or PVC pipes and laid in earth trenches of sufficient depth. Alliance Standards Part 10 Section 10.3.10 Service Entry Combustible materials are not stored within the substation room. Underground service cables are not laid in conformity with the requirements of concealed wiring. Location: Transformer room-ground Floor Photograph: Improper wiring of underground service cables. Ensure underground cables for electrical distribution in the premises/garden/compound of the building are encased in GI or PVC pipes and laid in earth trenches of sufficient depth. Not Applicable Are all switchboards and/or distribution boards metal enclosed with a dead front construction? Distribution boards are metal enclosed but not with dead front construction. Location: All Distribution Boards. Photograph: Distribution boards without dead front construction. Ensure switchboards and/or distribution boards are metal enclosed with a dead front construction. The Alliance for Worker Safety Page 7/18

Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear All equipment is efficiently earthed and properly connected to the required number of earth electrodes. Non-Compliance Level: 2 Electrical equipment is not efficiently earthed and/or properly connected to the required number of earth electrodes. Visual Assessment: Inadequate equipment earthing. Provide earthing of equipment at required locations and connect to required number of electrodes. Refer to the BNBG for required number of electrodes. Alliance Standard Part 10 Section 10.13.7.1 Inspection of Substation Installations. Do switchboards and/or distribution boards have a minimum clearance of 1 m (39 in) in front? Non-Compliance Level: 2 Switchboards and distribution boards are not provided with adequate clearance. Locations: DB-4 Ground Floor, Building-1; SDB Sample Section 4th Floor, SDB Sewing 3rd Floor Building-3, SDB-1 Printing Ground Building-1. Photograph: Inadequate clearance in front of distribution boards. Provide clearance of at least 1m (39 in.) in front of switchboards and/or distribution boards. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear The Alliance for Worker Safety Page 8/18

No circuits are drawn for loads without the incorporation of a overcurrent protection device (circuit breaker). Non-Compliance Level: 2 Circuits are not drawn for loads with the incorporation of an over current protection device (circuit breaker). Location: DB-1 Ground Floor Bldg-1, DB-2-2 Bldg-1, DB-1-1 Lab Room Bldg-3, DB-3 Ground Floor Bldg-1, MDB-3- Ground Floor Bldg-4, SDB 5th Floor Bldg-3. Photograph: No protection device. Ensure over current protection device (circuit breaker) for each and every load. Alliance Standards Part 10 Section 10.9 Protection of Circuits Indications of overheating, overloading, or signs of burning were not observed. Non-Compliance Level: 2 Indications of overheating were observed. Locations: DB-2-1 2nd Floor Building-1, DB-2-1 2nd Floor Building-2, DB-4-1 4th Floor Building-1, LT-2 (bottom of left) Generator Room, LT-2 (right) Generator Room, SDB-1st Floor Building-3, SDB-2-4 2nd Floor Building-1. Photograph: Indications of overheating. Find out the cause of overheating and consider replacement of conductors and equipment. Alliance Standard Part 10 Section 10.3.5 Are switchboards and/or distribution boards installed in compliant locations? Non-Compliance Level: 1 Distribution boards are not installed in compliant locations (access bared/limited). Location: DB-1-1 Lab Room Building-3, MDB-2-1 Building-2. Photograph: Distribution boards installed in improper locations. Install switchboards and/or distribution boards in compliant locations so that operation is not hampered due to limited access. The Alliance for Worker Safety Page 9/18

Alliance Standard Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear 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 wiring and cables are not sized according to capacity of circuit breakers. Location: DB-1 Dyeing Ground Floor Building-4, DB-2-1 Building-1, SDB Finishing Section 1st Floor Building-3. Photograph: er rated circuit breakers with lower rated wiring. Consult with a qualified electrical engineer and ensure electrical wiring/cables are sized according to the capacity of the circuit breakers. 25 Jul 2014 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. Non-Compliance Level: 1 Multi looping of wiring observed at circuit breakers within switchboards and distribution boards. Locations: MCB Box 4th Floor Building-1, MDB 4th Floor Building-1, MCB Box 1st Floor Building-1; AND Bunches of cables were found in distribution boards. Locations: DB-1-2 Building-1, MCB Box 1st Floor Building-1, MDB-1 Embroidery Ground Floor Building-1, SDB 5th Floor Building-3. Photograph: 1. Multi looping of wiring at circuit breakers. 2. Bunches of cables were found in Distribution Boards. Remove multi looping and bunches of cables at circuit breakers within switchboards and/or distribution boards. Alliance Standard Part 10 Section 10.3 Electrical Wiring and Cabling The Alliance for Worker Safety Page 10/18

The substation room has adequate ventilation. The substation room lacks adequate ventilation. Location: Substation Room- Ground Floor Photograph: Inadequate ventilation in substation room. Provide means of ventilation for the substation room. Consult a qualified electrical engineer to determine the required ventilation rates based on the installed equipment. Alliance Standard Part 10 Section 10.13.7.1 Inspection of Substation Installations. Do switchboards and/or distribution boards have capacity information labels? Switchboards and distribution boards have no capacity information labels. Locations: All Distribution Boards. Photograph: No capacity information labels on distribution boards. Provide capacity information labels (maximum current rating, number of circuit breakers, etc.) for switchboards and/or distribution boards. 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 physical means to prevent the installation of more over current devices than that number for which the panel board was designed, rated, and/or listed. location: All Distribution Boards. Photograph: No means to prevent the installation of more over current devices. The Alliance for Worker Safety Page 11/18

Ensure switchboards and/or 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/or listed. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Each circuit is provided with a dedicated neutral. Not all circuits are provided with a dedicated neutral. Locations: All Distribution Boards. 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/cables are not properly identified. Locations: All Distribution Boards. Photograph: Electrical wiring/cables are not 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 Are switchboards and/or distribution boards free of dust and debris? Non-Compliance Level: 2 Distribution boards are not clean. Locations: DB-1 Ground Floor, Building-3; MCB Box 5th Floor, Building-2; MDB-1 Embroidery-Ground Floor, Building-2; The Alliance for Worker Safety Page 12/18

MDB-2 Dyeing-Ground Floor, Building-4. Photograph: Dirt found in distribution boards. 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 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. Locations: LT-1, MCB Box 1st Floor, Bldg-1; MDB 4th Floor, Bldg-1; MDB Ground Floor, Bldg-1; MDB-1 Embroidery-Ground Floor, Bldg-2; MDB-2-1, Bldg-2; SDB 4th Floor Bldg-3. Photograph: No cable sockets provided. Provide cable sockets for stranded conductors having a nominal crosssectional area of 6mm2 or greater. Alliance Standards Part 10 Section 10.3.8.3 Cable Ends Cable joints are through porcelain/pvc connectors with PIB tape wound around joint. Non-Compliance Level: 2 Improper cable joints were found. Locations: DB-1-1, Lab Room, Bldg-3; DB-1-2 Bldg-1; DB-2-1, Bldg-2; DB-2-1 Bldg-1; DB-4 Ground Floor, Bldg-1; MDB-1 Embroidery-Ground Floor Bldg-2; SDB 5th Floor Bldg-3; SDB-1 Ground Floor, Bldg-1. Photograph: Improper cable joints. Ensure cable joints are through porcelain/pvc connectors with PIB tape wound around joint. The Alliance for Worker Safety Page 13/18

Alliance Standards Part 10 Section 10.3.8.4 Cable Joints Transformers are properly grounded (earthed). Non-Compliance Level: 1 Transformer is properly grounded (earthed). Photograph: Adequate grounding of transformer. Alliance Standards Part 10 Section 10.5 Substation Electrical wiring and conduit is properly supported. Non-Compliance Level: 1 Electrical wiring and conduit is not properly supported. Location: Substation Room, Generator Room. Photograph: Inadequate cable support. Provide adequate supports for electrical wiring and conduit. Alliance Standard Part 10 Section 10.3.2, 10.3.4.3, and 10.3.5 Electrical connections at equipment, fixtures, etc are properly secured. Non-Compliance Level: 1 Electrical connections at equipment/fixtures/etc. not properly secured. Location: Dyeing-Ground Floor, Bldg-4; Embroidery-Ground Floor, Bldg-2; Sewing-3rd Floor Bldg-3; and Sewing-3rd Floor Bldg-3. Photograph: Electrical connections are not secured. Ensure electrical connections at equipment, fixtures, etc. are properly secured. The Alliance for Worker Safety Page 14/18

Alliance Standards Part 10 Section 10.3.1 Electrical Connections Mechanical guards are provided for electrical equipment and wiring where necessary. Non-Compliance Level: 1 No mechanical guards are provided for electrical equipment at the necessary locations. Locations: Substation Room, Generator Room. Photograph: No mechanical guards. 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 Signage indicating the prohibition of light fixtures without protective covers is installed at required locations. Low There is no signage at the required locations about the prohibition of light fixtures without protective covers. Visual Assessment: No signage indicating the prohibition of light fixtures without protective covers. Light fixtures without protective covers (otherwise known as naked lights) shall not be allowed in storage areas or in any area where the Inspector of the Factories Rules disallows these fixtures. Install signs posted in Bengali and English, indicating this prohibition at all entrances to these areas. Alliance Standards Part 10 Section 10.15 Naked Lights Phase separators are provided between terminals on circuit breakers. Low Non-Compliance Level: 1 Phase separators are not provided between terminals on circuit breakers. Locations: DB-1 and DB-3 Ground Floor, Bldg-1; LT-1, MDB-2 Dyeing-Ground The Alliance for Worker Safety Page 15/18

Floor Bldg-4; MDB-2-1 Bldg-2; MDB-3 Ground Floor, Bldg-4; SDB 1st Floor Bldg-3; SDB-3rd Floor-Sewing, Bldg-3. Photograph: No phase separators. Install phase separators between terminal connections at the noted locations. Alliance Standard Part 10 Section 10.3.1 Electrical Connections Emergency Power System Are cable trenches properly covered? Non-Compliance Level: 1 Cable trenches are not covered properly. Photograph: Inadequate cable trench cover. Provide adequate cover on cable trench. Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation Are inspection, maintenance, and testing procedures of the emergency generator being completed and documented? Low No. Inspection, maintenance, and testing procedures of the emergency generator are not being completed and documented. Document Review: Inspection, maintenance, and testing procedures for the emergency generator are not completed and documented. Establish a routine maintenance and testing program for the emergency generator. The program shall be based on all of the following: (1) Manufacturer's recommendations (2) Manufacturer's Instruction manuals NFPA 110 Chapter 8 Are inspection, maintenance, and testing procedures of the UPS being The Alliance for Worker Safety Page 16/18

completed and documented? Low Inspection, maintenance, and testing procedures of the UPS are not completed. Document Review: No documentation on UPS testing and maintenance was found. 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) 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 Lightning Protection System The air termination network vertical and horizontal conductors are appropriately spaced. No designs or documents found to verify the air termination network's vertical and horizontal conductors are appropriately spaced. Photograph: Inadequate spacing. Consult with an expert electrical engineer and prepare drawings for lightning protection, including a risk index and make sure your system is secured against lightning. Alliance Standards Part 10 Section 10.11 Lightning Protection The appropriate number of down conductors are installed based on the building size. No drawing or documents found to identify the appropriate number, based on the building's size, of down conductors are installed. The Alliance for Worker Safety Page 17/18

Photograph: Inadequate down conductors installed. Consult with an expert electrical engineer to ensure the appropriate number of down conductors are installed based on the building's size, according to the BNBC. And make sure your building is secured against lightning. Alliance Standards Part 10 Section 10.11 Lightning Protection 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: No lightning protection ground terminals are bonded to the structure grounding. The lightning protection ground terminals should be bonded to the building or structure grounding. Alliance Standards Part 10 Section 10.11 Lightning Protection The Alliance for Worker Safety Page 18/18