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INITIAL ELECTRICAL SAFETY ASSESSMENT - EXPANSION Assessor: Nalzani, Chandana Joydebpur, Gazipur Joydebpur, Gazipur Dhaka Emkay Enterprises The Alliance for Worker Safety Page 1/13

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 2/13

GENERAL INFORMATION General Information Country: Province: City: Dhaka Joydebpur, Gazipur Zip Code: 1702 Audit Duration: Re-Audit: 1 Days 0 Hours Re-Audit After 0 Months Draft Report Date : 31 October 2015 Final Report Date : 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) : To be filled out by the Alliance QA representative No There is one main building. Owned 4 stories Total: 20,000 SF(G.F to 3rd: 5,000 SF each). 2013-14 None None N/A Number of Occupants : Total Occupants: 96. (GF: 3, 1st: 3, 2nd: Vacant, 3rd: 90) The Alliance for Worker Safety Page 3/13

Provide brief description of the electrical system for each building.: Physical location of Substation? : What equipment/loads does the UPS serve? : A 400 KVA transformer is connected to REB powers the facility of Odesa Fashions Ltd. Three generators of 500 kva, 350 kva and 150 kva have been provided as standby power source. Power is distributed through two LT Panels, one Main Distribution Board, one Distribution Board and one Sub Distribution Board. Separate from main building. Emergency lights, Exit signage and P.A. System. The Alliance for Worker Safety Page 4/13

ASSESSMENT FINDINGS Expansion Details Are as-built drawings available for new electrical safety features of the building? Non-Compliance Level: 3 Single line diagram and electrical layout are available but earthing layout was not found. And some information (i.e. bus bar capacity, wattage of load of a particular circuit) is required in Single line diagram. Document Review: Documents are not available. Have a qualified electrical engineer update the as-built single line diagram, layout earthing diagram detailing key components, and capacity of the electrical system. 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? Non-Compliance Level: 3 Single line diagram and electrical layout are available but earthing layout was not found. Some information (i.e., bus bar capacity, wattage of load of a particular circuit) is required on Single line diagram but has not been provided. Document Review: Documents are not available. Have a qualified electrical engineer update the as-built single line diagram and layout earthing diagram, detailing key components and the 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 The Alliance for Worker Safety Page 5/13

electrical safety training? Is training documentation on site? Non-Compliance Level: 3 Workers that operate and maintain the electrical system have not received any electrical safety training. Document Review: Documents are not available. Develop and implement an electrical safety program. Include key topics such as lock-out/tag-out procedures, personal protective equipment requirements, etc. Keep records of completed electrical training available on site. Reference NFPA 70e for example Are thermographic scans of electrical equipment completed at least every three years? Non-Compliance Level: 3 No records of previous thermographic scan were found. Document Review: Documents are not available. Complete thermographic scans at least on a three year cycle. Thermographic scans should be completed in accordance with the Standard for Infrared Inspection of Electrical Systems & Rotating Equipment and NFPA 70B or a comparable standard. 19 Nov 2015 Alliance Standards Part 10 Section 10.13.8 Electrical Inspections Is a periodical Insulation Resistance Measurement Program established and recorded? Periodic Insulation Resistance Measurement Program has not been established. Document Review: Documents are not available Develop an Insulation Resistance Measurement Program that ensures deterioration of insulation resistance will be identified quickly. Testing should be in compliance with Inter National Electrical Testing Association (NETA). All The Alliance for Worker Safety Page 6/13

transformers, switchgears etc. shall be subject to an insulation resistance measurement test to ground after installation but before any wiring is connected. Insulation tests shall be made between open contacts of circuit breakers, switches etc. and between each phase and earth. Alliance Standard Part 10 Section 10.13.4 Insulation Tests and 10.13.8 Electrical Inspections Transformers do not contain harmful substances such as PCBs. No document found to verify that the transformer does not contain harmful substances such as PCBs. Document Review: Documents were not available. Consult with manufacturer to determine if transformer contains harmful substances. If harmful substances are found, consider replacing transformers to reduce health hazards. 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 and documented. Document Review: Documents are not available. 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. 19 Nov 2015 Alliance Standard Part 10 Section 10.13 Inspection and Testing and Part 13 Section 13.6 Housekeeping Electrical System Conditions Indications of overheating, overloading, or signs of burning were not observed. The Alliance for Worker Safety Page 7/13

During thermographic scan, some hotspots were observed at multiple locations. Refer to Thermographic Survey Report for detailed information. Visual Assessment: Inspected with thermal imager. Suggested plan for specific issues have been incorporated in the Thermographic Survey Report. 19 Nov 2015 Alliance Standard Part 10 Section 10.3.5 Wet type transformers are not leaking and have appropriate levels. Non-Compliance Level: 1 The wet type transformer is leaking and oil level is not appropriate. Photograph: Transformers were leaked and levels were not appropriate. Contact the transformer servicing company to repair the oil-leak issue and check oil levels. Alliance Standards Part 10 Section 10.5 Substation Are electrical wiring/cables properly identified? Non-Compliance Level: 3 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-01, Ground Floor did not have identification. Photograph: Photograph: Cables are not identified in DB-01. Provide identification/tagging mentioning the equipment/machine name (i.e., Sewing machine line-1 or Lighting line-2) and type of conductor (i.e. L1, L2, L3, N, PE) for every cable at its termination point or maintain the color-code at its termination point (providing colored cable-sleeves) for identification of conductor-type (i.e. Red/Yellow/blue for phase cable, Black for neutral cable, Green for earthing cable). Labeling-cable-tie/Marker-tie can be used for cable identification. The Alliance for Worker Safety Page 8/13

Electricity Rules 1937 Rule 51 and 56 Are all internal components of switchboards and/or distribution boards properly concealed (No missing circuit breaker or knockout covers)? A hole was observed in the back cover of the panel for the incoming and outgoing cables. Photograph: Unused opening inside of SDB-06. Make circular hole at the base/top plate of panels and 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 (of noncombustible material) if any additional gap remains after installing cable glands. 19 Nov 2015 Alliance Standard Part 10 Section 10.3.9 Sub-Distribution Boards Do switchboards and/or distribution boards have capacity information labels? Switchboards and/or distribution boards do not have capacity information labels. Photograph: Capacity information label not provided on MDB. Provide a capacity information label which contains the current carrying capacity and size of main cable, rated capacity of circuit breaker and the bus bar (with dimension). Display panel schedule on panel door (inner side) printed on a sheet made of non combustible material. 03 Dec 2015 Alliance Standard Part 10 Section 10.7 Main Switch, Switchboards And Metal Clad Switchgear and 10.13.7 Inspection of the Installation The Alliance for Worker Safety Page 9/13

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 MCB of DB-01 without cable sockets were found on Ground Floor. Photograph: Cables are connected in DB-01 without cable sockets. Terminate cable with cable sockets of appropriate size. Terminate all the strains removing air gap. 03 Dec 2015 Alliance Standards Part 10 Section 10.3.8.3 Cable Ends Are switchboards and/or distribution boards free of dust and debris? Non-Compliance Level: 1 Dust was observed inside distribution panel SDB-06. Photograph: Dust found inside distribution panel (SDB-06). 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. 03 Dec 2015 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. Non-Compliance Level: 1 Switchboards and/or 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 listed. Photograph: SDB-05 had space in DIN-rail channel for additional circuit breakers. The Alliance for Worker Safety Page 10/13

Calculate and display the information of the capacity & panel-schedule of the distribution boards and then provide a physical means to prevent the installation of additional circuit breakers. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Cable joints are through porcelain/pvc connectors with PIB tape wound around joint. Non-Compliance Level: 1 Cable joints were made without providing any connectors and only PVC tape wound around. For example, cable joints without connectors were observed in DB-01. Photograph: Cable joints were found in DB-01. Provide cable joints with PVC connections with PIB tape wound around the joint. Alliance Standards Part 10 Section 10.3.8.4 Cable Joints Are there additional areas of non-compliance to report? Non-Compliance Level: No. Not Applicable Emergency Power System Are emergency power switchboards, distribution boards, and circuits properly identified? The Alliance for Worker Safety Page 11/13

Components of the emergency power system do not have proper identification. The required marking can be by color code, the words emergency system, or any other method that identifies the box or enclosure as a component of the emergency system. Visual Assessment: Visually inspected during audit. All boxes and enclosures (including transfer switches, generators, and power panels) for emergency circuits shall be permanently marked so they will be readily identified as a component of an emergency circuit or system. 19 Nov 2015 NFPA 70 Chapter 7 Article 700.10 Wiring, Emergency System Is the generator room properly illuminated? Non-Compliance Level: 1 Generator room is not properly illuminated. Photograph: Illumination is not proper in generator room. Provide additional light fixtures to ensure the required illumination described in the standard for proper maintenance and operation of the generator. 03 Dec 2015 Alliance Standards Part 10 Section 10.8.4 Generator Room Lightning Protection System Is a lightning protection system installed on the building? Non-Compliance Level: 3 Lightning protection system for the building has not been installed. The calculated risk index for the facility is 44, where the marginal risk index is 40. Visual Assessment: Visually inspected during audit. Have a qualified electrical engineer design a lightning protection system according to the BNBC requirements. Have a licensed electrician install the designed system. 14 Jan 2016 The Alliance for Worker Safety Page 12/13

Alliance Standards Part 10 Section 10.11 Lightning Protection. Calculate Risk Index to determine if required. The Alliance for Worker Safety Page 13/13