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INITIAL ELECTRICAL SAFETY ASSESSMENT - EXPANSION Yunusco (BD) Ltd(Formerly Shore To Shore Textiles Ltd.) Plot# 224-233, Adamjee EPZ, Shiddirgonj, Narayangonj Siddirgonj The Alliance for Bangladesh Worker Safety Page 1/22

03 Nov 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 2/22

GENERAL INFORMATION General Information Country: Province: City: Bangladesh Dhaka Siddirgonj Zip Code: 1431 Audit Duration: Re-Audit: 1 Days Re-Audit After 0 Months Draft Report Date : 08.11.2016 Final Report Date : 15.11.2016 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 Renovation/Addition : Ancillary Structures in Complex : Approximate Ancillary Structures Area (SF) : N/A There are 10 buildings in the complex, 4 main and 6 ancillary buildings. 3 Main and 4 ancillary buildings were assessed previously. This assessment includes: 1) Canteen Building; 2) Boiler Shed; 3) Fire Pump Shed. Owned Canteen Building: 2-stories Canteen Building: 31,875 SF 2015-2016 December, 2015 1) Boiler Shed; 2) Fire Pump Shed. Total area: 462 SF. 1) Boiler Shed: 210 SF; 2) Fire Pump Shed: 252 SF. The Alliance for Bangladesh Worker Safety Page 3/22

Number of Occupants : 800 Provide brief description of the electrical system for each building.: Physical location of Substation? : What equipment/loads does the UPS serve? : One 1000 KVA (stand-by) Transformer is installed for powering the facility. One emergency Diesel Generator (500 KVA) is installed for powering the facility on emergency basis & another emergency Diesel Generator (32 KVA) is installed for Fire-Fighting Purpose. Power is distributed through Six Main Distribution Board (MDB), Nine Distribution Board (DB), Seven Sub-Distribution Board (SDB) & Three Sub-Sub Distribution Board. Two Power Factor Improvement (PFI) panels are installed for improvement of the power quality. Sub-station located at ground floor of Ancillary Building-01. Fire alarm, Internet, Emergency light, CCTV, PABX & PA systems. The Alliance for Bangladesh Worker Safety Page 4/22

ASSESSMENT FINDINGS Expansion Details Are as-built drawings available for new electrical safety features of the building? As-built single line diagram is not available for the expansion part of the factory. Document Review: The electrical single line diagram is not found for the expansion part of the factory. Prepare as-built electrical single line drawings providing detailing key components of the electrical system, and sent to Alliance for approval later install an electrical system according to the approval drawing. Alliance Standard reference 8.20 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 single line diagram was not available for the expansion part of the factory. Document Review: The electrical single line diagram was not found for the expansion part of the factory. Prepare as-built electrical single line drawings detailing key components of the electrical system, and send to the Alliance for approval. Once approved, install the electrical system according to the approval drawing. Alliance Standard Part 10 Section 10.3.7 Electrical System Maintenance Is a periodical Insulation Resistance Measurement Program established and The Alliance for Bangladesh Worker Safety Page 5/22

recorded? architectural work and electrical works are in progress. Visual Assessment: Electrical works for extension part is in progress. Develop an Insulation Resistance Measurement according to the 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? architectural work and electrical works are in progress. Visual Assessment: Thermographic scans, reports for the extension part of the factory were not found. 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. Alliance Standards Part 10 Section 10.13.8 Electrical Inspections Are periodic safety inspections of the electrical system components completed and documented? architectural work and electrical works are in progress. Visual Assessment: Electrical system installation for expansion areas is in progress. The Alliance for Bangladesh Worker Safety Page 6/22

Provide 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 after installing electrical systems. Alliance Standard Part 10 Section 10.13 Inspection and Testing and Part 13 Section 13.6 Housekeeping Electrical System Conditions Are overhead service connections achieved with covered conductors? architectural work and electrical works are in progress. Ensure overhead service conductors are covered with an approved material if required according to the standard. Alliance Standards Part 10 Section 10.3.10 Service Entry Underground service cables are laid in conformity with the requirements of concealed wiring. architectural work and electrical work are in progress. Ensure underground service cables if required for electrical distribution in the premises 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 The Alliance for Bangladesh Worker Safety Page 7/22

All equipment is efficiently earthed and properly connected to the required number of earth electrodes. architectural work and electrical work are in progress. Provide proper earthing for all electrical equipment and connect to the required number of electrodes after installing electrical systems. Alliance Standard Part 10 Section 10.13.7.1 Inspection of Substation Installations. Is a readily accessible single point of disconnect provided for each main electrical service feed? The power connection for the factory expansion will be taken from the transformers which have been previously assessed by the Alliance. Provide a readily accessible single point of disconnect for each main electrical service feed for expansion part of the factory. BNBC 2.7.5 Main Switch and Switchboards Do switchboards and/or distribution boards have a minimum clearance of 1 m (39 in) in front? Electrical systems installation for expansion parts of the factory is in progress. Provide minimum clearance of 1 m (39 in) in front of all panel boards in accordance with the Alliance requirement. The Alliance for Bangladesh Worker Safety Page 8/22

Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Are all switchboards and/or distribution boards metal enclosed with a dead front construction? architectural work and electrical work are in progress. Ensure switchboards and distribution boards are metal enclosed with a dead front construction. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Are switchboards and/or distribution boards installed in compliant locations? The switchboards and distribution boards have not been installed for the expansion part of the factory. Ensure distribution boards are installed in compliant locations. Alliance Standard Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Switchboards and/or panelboards are not installed above gas stoves or sinks or within 2.5m of any washing unit in washing rooms or laundries. The construction work for new extension areas has already completed, architectural work and electrical work are in progress. The Alliance for Bangladesh Worker Safety Page 9/22

Ensure switchboards and panelboards are not installed above gas stoves or sinks or within 2.5m of any washing unit in washing rooms or laundries. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear No circuits are drawn for loads without the incorporation of a overcurrent protection device (circuit breaker). architectural work and electrical work are in progress. Ensure circuits are drawn for loads with the incorporation of an over-current protection device. Alliance Standards Part 10 Section 10.9 Protection of Circuits Indications of overheating, overloading, or signs of burning were not observed. architectural work and electrical work are in progress. After complete electrical system installation then observe overheating, overloading, or signs of burning if available and take proper action. 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)? The Alliance for Bangladesh Worker Safety Page 10/22

architectural work and electrical work are in progress. Ensure electrical cables are sized according to capacity of circuit breakers in the installation of electrical systems. 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. architectural work and electrical work are in progress. Ensure multi looping of cables at circuit breaker terminals is not installed within switchboards and distribution boards. Alliance Standard Part 10 Section 10.3 Electrical Wiring and Cabling 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. architectural work and electrical work are in progress. Ensure all metal in the building is connected to the building earthing system such as metal rebar in concrete, metal frame of building, or metal water pipe. Alliance Standard Part 10 Section 10.10 Earthing Light fixtures without protective covers are not installed in storage areas or in any area where the Inspector of the Factories Rules (1.5.3.5) Part 53 disallows The Alliance for Bangladesh Worker Safety Page 11/22

these fixtures. Light fixture with protective covers are not installed in storage areas since electrical system installation is in progress. Ensure light fixtures with protective covers are installed for storage areas in the extension part of the factory according to the standard. Alliance Standards Part 10 Section 10.15 Naked Lights Wiring systems are selected and erected so that no damage is caused by the ingress of water. architectural work and electrical work are in progress. The completed wiring system shall comply with the IP degree of protection relevant to the particular location. Alliance Standards Part 10 Section 10.3.4.3 Presence of Water Power and telecommunication or antenna cables are led in separately. architectural work and electrical works are in progress. Photograph: Electrical works are in progress. Lead telecommunication or antenna cables separately to the main point of service. Power and telecommunications cables must have separate entrance. The Alliance for Bangladesh Worker Safety Page 12/22

Alliance Standards Part 10 Section 10.3.10 Service Entry Are all internal components of switchboards and/or distribution boards properly concealed (No missing circuit breaker or knockout covers)? Electrical systems installation for expansion parts of the factory is in progress. Visual Assessment: Electrical systems installation is in progress. Provide covers or blanks to conceal all live internal components of switchboards and distribution boards. Alliance Standard Part 10 Section 10.3.9 Sub-Distribution Boards Are all switchboards and/or distribution boards properly grounded (earthed)? Electrical systems installation for expansion parts of the factory is in progress. Ensure all switchboards and distribution boards are properly grounded according to the standard. Alliance Standard Part 10 Section 10.10.2 Circuit and System Earthing Do switchboards and/or distribution boards have clear identification markings? Electrical systems installation for expansion parts of the factory is in progress. Visual Assessment: Electrical installation works are going on. Ensure switchboards and distribution boards have clear identification markings after complete electrical works. Alliance Standard Part 10 Section 10.7 BNBC Part 8 Section 2.11.5.4 The Alliance for Bangladesh Worker Safety Page 13/22

Do switchboards and/or distribution boards have capacity information labels? Electrical systems installation for expansion parts of the factory is in progress. Visual Assessment: Electrical installation works are going on. Ensure distribution boards have 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-combustible material. 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? The switchboards and distribution boards has not installed in the extension part of the factory. Visual Assessment: Electrical installation works are going on. Ensure distribution boards are free of dust and debris after installation. 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. Electrical systems installation for extension areas are going on. Ensure switchboards and distribution boards are 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. The Alliance for Bangladesh Worker Safety Page 14/22

Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Each circuit is provided with a dedicated neutral. The construction has completed, electrical works are going on. Ensure dedicated neutral is provided for each circuit in the installation of electrical systems. Alliance Standards Part 10 Section 10.3 Electrical Wiring and Cabling Are lighting and receptacle (socket) circuits segregated? The construction work has completed, electrical works are going on. Ensure lighting and receptacle (socket) circuits keep segregated in the installation of electrical systems. Alliance Standard Part 10 Section 10.3.7.2 Are electrical wiring/cables properly identified? The electrical systems installation for extension parts of the factory are going on. Ensure electrical cables are properly identified in the installation of electrical systems. The Alliance for Bangladesh Worker Safety Page 15/22

Bangladesh Electricity Rules 1937 Rule 51 and 56 Electrical wiring and conduit is properly supported. The construction work for new extension areas has already completed, architectural work and electrical work are going on. Ensure electrical wiring and conduit is properly supported after the installation of electrical systems. 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. The construction work for new extension areas has already completed, architectural work and electrical work are going on. Provide 6mm2 strand conductor or greater for cable sockets in floor areas and expose the ends of all strand conductors below the 6mm2 shell be soldered in the installation of electrical systems. Alliance Standards Part 10 Section 10.3.8.3 Cable Ends Cable joints are through porcelain/pvc connectors with PIB tape wound around joint. The construction work for new extension areas has already completed, and electrical works are going on. The Alliance for Bangladesh Worker Safety Page 16/22

Cable joints are to be done through porcelain/pvc connectors with PIB tape wound around before placing the cable in the box. Alliance Standards Part 10 Section 10.3.8.4 Cable Joints Lighting fixtures are supported from the structure and seismic bracing is installed as required. Lighting fixtures are not installed due to the construction work for new extension areas has already completed, and electrical works are going on. Lighting fittings shall be supported by suitable pipe/conduits, brackets fabricated from structural steel, steel chains or similar materials depending upon the type and weight of the fittings. Alliance Standards Part 10 Section 10.3.6 Lighting Fittings Electrical connections at equipment, fixtures, etc are properly secured. Electrical systems are not installed due to the construction work is in progress, and architectural work is in progress. Visual Assessment: Electrical systems installation are in progress. Ensure electrical connections at equipment, fixtures, etc are properly secured. Alliance Standards Part 10 Section 10.3.1 Electrical Connections Is all electrical wiring/cable properly terminated at its point of termination (No un-terminated wires, lugs are provided at terminals, etc)? The Alliance for Bangladesh Worker Safety Page 17/22

The construction work for new extension areas has already completed, architectural work and electrical work are going on. Visual Assessment: Electrical systems installation for the extension part of the factory are in progress. Ensure all electrical cables properly terminates at its point of termination in the installation of electrical systems. Alliance Standards Part 10 Section 10.3.9.2 Wiring of Sub-distribution Boards Are junction boxes and other electrical devices provided with covers? Electrical systems installation for the extension parts of the factory are going on. Provide adequate covers for junction boxes and other electrical devices if required in the installation of electrical systems. Alliance Standard Part 10 Section 10.3.5 and 13.6.2 Mechanical guards are provided for electrical equipment and wiring where necessary. Electrical systems installation for the extension part of the factory are going on. Provide mechanical guards for electrical equipment where required. 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 18/22

Are electrical insulation mats provided in front of substation, switchboards and/or distribution boards? Low architectural work and electrical works are in progress. Photograph: Electrical works are in progress. Provide electrical graded rubber insulation mats, specified for 650 V- protection, of required size (accommodating at least two person or dependent on the panel's width) in accordance with Alliance Standards. Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation. Required equipment and safety signage is posted within the room. Low Required equipment and safety signage is not posted. Provide required safety signage in switchgear, unit substations, transformers, pull boxes, connection boxes, and other similar associated equipment. Signage shall be marked with appropriate caution signs. Entrance to room and other guarded locations that contain exposed live parts shall be marked with conspicuous warning signs forbidding unqualified persons to enter. 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 meters and other electrical devices (Ammeter, Voltmeter, PFI Auto Controller, etc) installed on the main electrical equipment operational? Low Electrical systems installation for expansion parts of the factory is in progress. Photograph: Electrical works for extension areas is in progress. Ensure meters and other electrical devices are installed on the main electrical equipment and are operational. The Alliance for Bangladesh Worker Safety Page 19/22

Alliance Standard 10.13.7 Inspection of the Installation Phase separators are provided between terminals on circuit breakers. Low The construction work for new extension areas has already completed, and electrical works are going on. Ensure phase separators are provided between terminals on circuit breakers. Alliance Standard Part 10 Section 10.3.1 Electrical Connections Signage indicating the prohibition of light fixtures without protective covers is installed at required locations. Low Signage indication in not provided at required location due to the construction work has already completed, architectural work and electrical work are going on. Visual Assessment: Electrical systems installation are in progress. Install signs posted in Bengali and English, indicating the prohibition at all entrances to storage and other required areas. Alliance Standards Part 10 Section 10.15 Naked Lights Emergency Power System Are cable trenches properly covered? architectural work and electrical work are in progress. The Alliance for Bangladesh Worker Safety Page 20/22

Ensure cable trenches are provided with adequate covers for the cable trench with non flammable materials. Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation Are emergency power switchboards, distribution boards, and circuits properly identified? Emergency equipment is not installed since the electrical system installation is in progress. Ensure proper identification of emergency power switchboards, distribution boards, and circuits, according to Alliance requirement after installation of electrical systems. NFPA 70 Chapter 7 Article 700.10 Wiring, Emergency System Is an uninterruptable power supply (UPS) provided? The UPS or IPS system is not provided since the electrical system installation is in progress. Need to provide uninterrupted power supply (UPS) or instant power supply (IPS) for running emergency equipment. Not Applicable Are life safety loads (fire alarm, fire pump, elevators, emergency lighting, exit signage, etc) connecting to the emergency power system? The Alliance for Bangladesh Worker Safety Page 21/22

Life safety loads are not connecting to the emergency power system since electrical system installation is in progress. Need to provide emergency power connection for life safety loads (fire alarm, fire pump, elevators, emergency lighting, exit signage, etc). Alliance Standard Part 10 Section 10.8 Standby Power Are inspection, maintenance, and testing procedures of the UPS being completed and documented? Low Inspection, maintenance, and testing procedures of the UPS or IPS are not found due to electrical systems installation are going on. Provide an inspection testing, and maintenance program for the UPS or IPS system 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 The Alliance for Bangladesh Worker Safety Page 22/22