INITIAL ELECTRICAL ASSESSMENT REPORT (EAR) Factory SFB 2 Adamjee EPZ, Siddergonj, Narayangonj, Siddhirgonj Dhaka 22 Feb 2017 The Alliance for Worker Safety Page 1/18
Factory 22 Feb 2017 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
22 Feb 2017 GENERAL INFORMATION General Information Factory Country: Province: City: Dhaka Siddhirgonj Zip Code: 1431 Audit Duration: Re-Audit: 2 Days Re-Audit After 0 Months Draft Report Date : 22 February 2017 Final Report Date : 02 March 2017 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 There are 5 buildings / sheds in the complex. Out of 5 buildings/sheds, 2 are production buildings and 3 are ancillary buildings/sheds. Name of production buildings are: 1) 4-storied R.C. Main Production Building. 2) 1- storied woven Shed. Owned 1) 4-storied R.C. Main Production Building: 4 story above grade. 2) 1-storied woven Shed: 1 story above grade. 1) 4-storied R.C. Main Production Building about 97,500 sft 2) 1-storied woven Shed: 4,500 sft. 1) 4-storied R.C. Main Production Building: 2007-2009. 2) 1-storied woven Shed: 2013. No sign of renovation and addition has been noticed. 3 Nos. 1) 1-storied utility shed (Sub-station and Generator room). 2) 1-storied outdoor shed-1 (ETP, Chemical warehouse and Electrical room). 3) 1-storied outdoor shed-2 (BEPZA-LT panel room). 1) 1-storied utility shed (Sub-station and Generator room): about 2,094 sft. 2) 1-storied outdoor shed-1 (ETP, Chemical warehouse and Electrical room): about 755 sft. 3) 1-storied outdoor shed-2 (BEPZA-LT panel room): The Alliance for Worker Safety Page 3/18
22 Feb 2017 350sft. 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 = 514 Persons. Service Line: BEPZA. FDB: 08 nos. MTS: 06 nos. LV: 03 nos. DB: 01 nos. A/C, DB: 04 nos. A/C W: 03 nos. SSDB: 10 nos. LDB: 26 nos. AVR: 04 nos. SDB: 19 nos. HT Panel (630A VCB): 2 nos. COS: 04 nos (400A), 01 nos (800A), 01 nos (630A). Transformer: 5nos (250KVA: 04 nos & 1250KVA: 01 nos). PFI: 05 nos (750KVAR: 01 nos, 150KVAR: 04 nos). LT Panel: 01 nos. Generator: 03 nos (350KVA: 01 nos, 313KVA: 01 nos, 650KVA: 01 nos. Lift: 01 nos. Fuel Tank Capacity: 200 Ltr. Outside of production building. Emergency Exit light The Alliance for Worker Safety Page 4/18
22 Feb 2017 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 do not reflect actual installation. Document Review: Documents do not match with actual installation. 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 Is a periodical Insulation Resistance Measurement Program established and recorded? Insulation Resistance Measurement test program is not established or recorded. Document Review: No IR test program was recorded. 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 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 Are thermographic scans of electrical equipment completed at least every three years? The Alliance for Worker Safety Page 5/18
22 Feb 2017 Thermographic scans of electrical equipment is not completed at least every three years. Document Review: Thermographic scan report was not found. 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 documentation was provided during inspection. Document Review: No document was found. Consider replacing 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 documented. Document Review: No documentation was found. 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. The Alliance for Worker Safety Page 6/18
22 Feb 2017 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 No testing documentation was provided during inspection. Document Review: No document was found. 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 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 these fixtures. Light fixtures without protective covers are installed in storage areas. Photograph: Light fixtures without protective covers in storage areas. "Remove light fixtures without protective covers from storage areas or any area where the Inspector of the Factories Rules (1.5.3.5) Part 53 disallows these fixtures." 31 Mar 2017 Alliance Standards Part 10 Section 10.15 Naked Lights Do switchboards and/or distribution boards have a minimum clearance of 1 m (39 in) in front? Switchboards and/or distribution boards do not have a minimum clearance of 1 m (39 in) in front. Location: DB/offset. Photograph: No minimum clearance. The Alliance for Worker Safety Page 7/18
22 Feb 2017 Provide minimum clearance of 1 m (39 in) in front of all panel boards in accordance with the Alliance requirement. 15 Apr 2017 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? All switchboards and/or distribution boards are not metal enclosed with a dead front construction. Location: LV-01. Photograph: No dead front constructed metal. Provide switchboards and/or distribution boards with metal enclosed dead front construction. 15 Apr 2017 Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Are switchboards and/or distribution boards installed in compliant locations? Distribution boards are not installed in compliant locations. Location: DB/offset. Photograph: DB is not in a compliant locations. Relocate distribution boards to suitable locations for operation and maintenance. Alliance Standard Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear The Alliance for Worker Safety Page 8/18
22 Feb 2017 Is electrical wiring/cables sized according to capacity of circuit breakers (No higher rated circuit breakers with lower rated wiring)? er rated breaker is found with lower rated cable. Location: LV-01. Photograph: er rated breaker with lower rated cable. Consult with a qualified Electrical Engineer and ensure electrical wiring/cables are sized according to capacity of circuit breakers. Provide electrical wiring/cables of proper size according to capacity of circuit breakers. er rated circuit breakers are not allowed with lower rated wiring. 15 May 2017 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. Multi looping of cables was observed at circuit breaker and busbar within switchboards. Location: LDB-W-01. Photograph: Multi looping of cables are observed. Survey all distribution boards to identify all locations of multi looping of cables. 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 Is a readily accessible single point of disconnect provided for each main electrical service feed? Non-Compliance Level: 1 Readily accessible single point of disconnect is not provided for each main electrical service feed. Location: LDB-3E-03 Photograph: No readily accessible single point of disconnect. Provide readily accessible single point of disconnect for each main electrical The Alliance for Worker Safety Page 9/18
22 Feb 2017 service feed. BNBC 2.7.5 Main Switch and Switchboards Wiring systems are selected and erected so that no damage is caused by the ingress of water. Non-Compliance Level: 1 Wiring systems are erected allowing ingress of water. Location: LDB-01-E-04. Photograph: Wiring systems are erected allowing ingress of water. Relocate distribution boards to suitable locations for operation and maintenance. Alliance Standards Part 10 Section 10.3.4.3 Presence of Water 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: All Panel boards. Photograph: Internal components of DB are not properly concealed. Provide covers or blanks to conceal all live internal components of switchboards and/or distribution boards. 31 Mar 2017 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 panel boards. Photograph: No marking in DB. The Alliance for Worker Safety Page 10/18
22 Feb 2017 Provide clear and permanent identification marks on all distribution boards, switchboards, sub main boards and switches and post proper caution/danger signage in all electrical panel boards. 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 panel boards. Photograph: No capacity information labels in DBs. 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-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 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 a physical means to prevent the installation of more over current devices than that number for which the panel board was designed, rated and listed. Location: All panel boards. Photograph: No physical means for DBs. Verify the existing load does not exceed the panel rating. For switch boards 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. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear The Alliance for Worker Safety Page 11/18
22 Feb 2017 Are electrical wiring/cables properly identified? Electrical wiring/cables are not properly identified. Location: All panel boards. Photograph: No identification for Electrical wiring/cable. Provide identification of wires/cables by separate color coding, marking tape, tagging, or other approved means. Electricity Rules 1937 Rule 51 and 56 The substation room has adequate ventilation. The substation room does not have adequate ventilation. Photograph: The substation room does not have adequate ventilation. 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. The substation room has adequate illumination levels. The substation room does not have adequate illumination levels. Photograph: The substation room does not have adequate illumination levels. Provide additional light fixtures to increase illumination levels provided in the BNBC. 15 Apr 2017 Alliance Standard Part 10 Section 10.13.7.1 Inspection of Substation Installations. The Alliance for Worker Safety Page 12/18
22 Feb 2017 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. Stranded conductors having a nominal cross-sectional area 6mm2 or greater are not provided with cable sockets. Location: SDB-01-W-04. Photograph: Cable lugs not used. Provide proper cable lugs for for connecting cable with circuit breaker or busbar. Alliance Standards Part 10 Section 10.3.8.3 Cable Ends Cable joints are through porcelain/pvc connectors with PIB tape wound around joint. Improper cable joints were found. Location: Every floor. Photograph: Improper cable joints. Provide cable joints through porcelain/pvc connectors with PIB tape wound around joint before placing the cable in the box in accordance with Alliance Standard Section 10.3.8.4. 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 are not properly terminated. Location: DB-U-01. Photograph: Electrical cables are not properly terminated. Provide proper termination of all wiring in accordance with the Alliance standard. No un-terminated wires or cables are allowed. The Alliance for Worker Safety Page 13/18
22 Feb 2017 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 Junction boxes are not provided with covers. Location: Near of FDB-W-04. Photograph: No cover for the Junction boxes. Provide adequate covers for junction boxes and other electrical devices according to Alliance Standard. 31 Mar 2017 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 Mechanical guards are not provided for electrical equipment and wiring where necessary. Location: In front of SDB-01-W-04. Photograph: No Mechanical guards. Survey all locations to identify missing mechanical guards. Provide mechanical guards for electrical equipment where necessary. 31 Mar 2017 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 Proper electrical insulation mats are not provided in front of substation switchboards and distribution boards. Location: All panel boards. The Alliance for Worker Safety Page 14/18
22 Feb 2017 Photograph: Insulation mats are provided.but not proper sized. Provide electrical insulation mats in front of distribution boards. 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 within the room. Visual Assessment: There is no safety signage in the substation room. "Indoor electrical installations that are accessible to unqualified persons shall be made with metal-enclosed equipment. Switchgear, unit substations, transformers, pull boxes, connection boxes, and other similar associated equipment shall be marked with appropriate caution signs. Entrances to rooms and other guarded locations that contain exposed live parts shall be marked with conspicuous warning signs forbidding unqualified persons to enter. Caution, warning, danger signs or labels should meet the following requirements: (1) The marking shall adequately warn of the hazard using effective words and/or colors and/or symbols. American National Standards Institute ANSI Z535.4-2011, Product Safety Signs and Labels, provides guidelines for suitable font sizes, words, colors, symbols, and location requirements for labels. (2) Shall be permanently affixed to the equipment or wiring method and shall not be hand written. Exception, portions of labels or markings that are variable, or that could be subject to changes, shall be permitted to be hand written and shall be legible. (3) The label shall be of sufficient durability to withstand the environment involved. ANSI Z535.4-2011, Product Safety Signs and Labels, provides guidelines for the design and durability of safety signs and labels for application to electrical equipment" 31 Mar 2017 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: LV-01. Photograph: Phase separators are not provided. The Alliance for Worker Safety Page 15/18
22 Feb 2017 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 Signage indicating the prohibition of light fixtures without protective covers is installed at required locations. Low Signage indicating the prohibition of light fixtures without protective covers is not installed at required locations. Photograph: Signage indicating the prohibition of light fixtures without protective covers is not installed at required locations. "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 (1.6.3.7) Part 53 disallows these fixtures. Install signs posted in Bengali and English, indicating this prohibition at all entrances to these areas." 31 Mar 2017 Alliance Standards Part 10 Section 10.15 Naked Lights Emergency Power System Is the generator room properly ventilated The generator is not room properly ventilated. Photograph: No proper ventilation system. Provide the generator room with significant amount of ventilation and fitted with a number of ceiling fans. Appropriate type and number of firefighting equipment must be installed inside the generator room. 15 Apr 2017 Alliance Standards Part 10 Section 10.8.4 Generator Room The Alliance for Worker Safety Page 16/18
22 Feb 2017 Is the generator frame earthing (grounding) provided at two separate points? Generator frame earthing (grounding) is not provided at two separate points. Photograph: Generator frame earthing. Provide generator frame earthing at two separate points with proper size of conductors and sufficient number of earth electrodes. 15 Apr 2017 Alliance Standard 10.8.2.2 Is the generator room properly illuminated? The generator room is not properly illuminated. Photograph: No proper illumination. Provide proper illumination in generator room. 15 Apr 2017 Alliance Standards Part 10 Section 10.8.4 Generator Room Are inspection, maintenance, and testing procedures of the emergency generator being completed and documented? Low Inspection, maintenance, and testing procedures for the emergency generator are being documented, but not in Accordance with all requirements. Document Review: No proper document was found. "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 (3) Requirements of NFPA 110 Chapter 8" The Alliance for Worker Safety Page 17/18
22 Feb 2017 NFPA 110 Chapter 8 Are inspection, maintenance, and testing procedures of the UPS being completed and documented? Low Inspection, maintenance, and testing procedures of the UPS are not being completed and documented. Document Review: No documentation was found for Inspection, maintenance, and testing of IPS. "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 Is a lightning protection system installed on the building? Lightning protection system is not properly installed on the building. Photograph: Lightning protection system. Have a qualified electrical engineer design a lightning protection system according to the BNBC requirements. Have a licensed electrician install the designed system. 31 May 2017 Alliance Standards Part 10 Section 10.11 Lightning Protection. Calculate Risk Index to determine if required. The Alliance for Worker Safety Page 18/18