INITIAL ELECTRICAL ASSESSMENT REPORT (EAR) Factory Plot No. 60&61, Sector-3, KEPZ, North Patenga, Chittagong Chittagong 11 Feb 2015 The Alliance for Bangladesh Worker Safety Page 1/17
11 Feb 2015 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 2/17
11 Feb 2015 GENERAL INFORMATION General Information Factory Country: Province: City: Bangladesh Chittagong Chittagong Zip Code: 4204 Audit Duration: Re-Audit: 1 Days Re-Audit After 0 Months Draft Report Date : 15/02/2015 Final Report Date : 26/02/2015 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) : N/A There are eight buildings in the factory premises out of which one is main production building and seven are ancillary buildings. The buildings are named as: 1) Six story main production building, 2) Single story security building, 3) Single story compressor building, 4) Single story compressor and sub-station building, 5) Single story pump shed, 6) Single story hardware materials shed, 7) Single story Dining shed, 8) Single story Wastage shed. Owned 1) Six story main production building: Building height (est occupied floor level): 19.5 m or 64 ft [Height up to roof: 22.85 m or 75 ft], Stories above grade: 6, Stories below grade: 0, Occupied levels: 6, 2) Single story security building: Building height (est occupied floor level): 15 cm or 0.5 ft above grade [Height up to roof: 3.05m or 10 ft], Stories above grade: 1, Stories below grade: 0, Occupied levels: 1. 3) Single story compressor building: Building height (est occupied floor level): 15 cm or 0.5 ft above grade [Height up to roof: 3.05m or 10 ft], Stories above grade: 1, Stories below grade: 0, Occupied levels: 1. 4) Single story compressor and sub-station building: Building height (est occupied floor level): 15 cm or 0.5 ft above grade [Height up to roof: 3.05m or 10 ft], Stories above grade: 1, Stories below grade: 0, Occupied levels: 1. 5) Single story pump shed: Building height (est occupied floor level): 15 cm or 0.5 ft above grade [Height up to roof: 2.74 m or 9 ft], Stories above grade: 1, Stories below grade: 0, Occupied levels: 1. 6) Single story hardware materials shed: Building height (est occupied floor level): 15 cm or 0.5 ft above grade [Height up to roof: 2.74 m or 9 ft], Stories above grade: 1, Stories below grade: 0, Occupied levels: 1. 7) Single story Dining shed: Building height (est occupied floor level): 15 cm or 0.5 ft above grade [Height up to roof: 3.05 m or 10 ft], Stories above grade: 1, Stories below grade: 0, Occupied levels: 1. 8) Single story Wastage shed: Building height (est occupied floor level): 15 cm or 0.5 ft above grade [Height up to roof: 3.05 m or 10 ft], Stories above grade: 1, Stories below grade: 0, Occupied levels: 1. The Alliance for Bangladesh Worker Safety Page 3/17
11 Feb 2015 Approximate Building Area (SF) : Date of Building Construction : Date of Last Building 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? : Total area of all buildings in the factory premises: 176223.00 SF. Building wise breakdown as follows: 1) Six story main production building: 171858.00 SF (Ground floor: 28643 SF, 1st floor: 28643 SF, 2nd floor: 28643 SF, 3rd floor: 28643 SF, 4th floor: 28643 SF, 5th floor: 28643 SF). 2) Single story security building: 218 SF, 3) Single story compressor building: 136 SF, 4) Single story compressor and sub-station building: 482 SF, 5) Single story pump shed: 197 SF, 6) Single story hardware materials shed: 400 SF, 7) Single story Dining shed: 2215 SF, 8) Single story Wastage shed: 717 SF. Factory personnel informed the date of construction as follows: 1) Six story main production building: Started in November-2010 and finished in September-2014, 2) Single story security building: Started in March-2014 and finished in April-2014, 3) Single story compressor building: Started in January-2015 and finished in February-2015, 4) Single story compressor and sub-station building: Started in November-2013 and finished in December-2013, 5) Single story pump shed: Started in February-2015 and on going, 6) Single story hardware materials shed: Started in January-2014 and finished in February-2014, 7) Single story Dining shed: Started in April-2014 and finished in May-2014, 8) Single story Wastage shed: Started in June-2014 and finished in July-2014. Renovations and additions were completed as follows: 1) Six story main production building: Roof is under construction for dining shed, 2) Single story pump shed: Construction started in February-2015 and is on going. 1) Single story security building, 2) Single story compressor building, 3) Single story compressor and substation building, 4) Single story pump shed, 5) Single story hardware materials shed, 6) Single story Dining shed, 7) Single story Wastage shed. 1) Single story security building: 218 SF, 2) Single story compressor building: 136 SF, 3) Single story compressor and sub-station building: 482 SF, 4) Single story pump shed: 197 SF, 5) Single story hardware materials shed: 400 SF, 6) Single story Dining shed: 2215 SF, 7) Single story Wastage shed: 717 SF. Total number of occupants: 1256. 1) Six story main production building: 1250 (Ground floor: 100, 1st floor: 280, 2nd floor: 280, 3rd floor: 280, 4th floor: 280, 5th floor: 30); 2) Single story security building: 4; 3) Single story compressor building: 0; 4) Single story compressor and sub-station building: 1; 5) Single story pump shed: 0; 6) Single story hardware materials shed: 1; 7) Single story Dining shed: 0 (Capacity-210); 8) Single story Wastage shed: 0. One source of Bangladesh Export Processing Zone Association BEPZA) fed into via 1 No. Tension (HT) Panel to 1 No. 750KVA Oil Type Service Transformer. Electrical power is distributed via 1 No. Low Tension (LT) Panel, 1 No. 415KVAR Power Factor Improvement (PFI) Panel, 6 Nos. Main Distribution Board (MDB) and 12 Nos. Sub Distribution Boards (SDB). Total Captive Power capacity of 28KVA is achieved by 1 No. 28KVA Diesel Generator. The substation is located in the single story compressor and substation building. Instant Power Supply (IPS) provides power to elevator, fire alarm, emergency lighting and exit signage. The Alliance for Bangladesh Worker Safety Page 4/17
11 Feb 2015 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? Proper as-built single line diagram (SLD) was available on site but electrical layout drawing was not found. Photograph: Electrical Layout diagram is not available. Have a qualified electrical engineer develop an as-built electrical layout diagram detailing the locations of panels and wiring connections throughout the building(s). 08 Apr 2015 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? Workers that operate and maintain the electrical system have not received electrical safety training. Worker Interviews: Workers that operate and maintain the electrical system have not received electrical safety training. 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 training available on site. Reference NFPA 70e for example Is a periodical Insulation Resistance Measurement Program established and recorded? The Alliance for Bangladesh Worker Safety Page 5/17
11 Feb 2015 Periodical Insulation Resistance Measurement Program has not been established. Worker Interviews: Periodical Insulation Resistance Measurement Program has not been established. 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 (IETA). 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? Thermographic scans of electrical equipment have not been conducted. Worker Interviews: Thermographic scans of electrical equipment have not been conducted. 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 test result or manufacturer's specification was found to ensure that the transformer is free from harmful substances such as PCBs. Document Review: No test result or manufacturer's specification found. Contact with transformer manufacturer regarding PCB containment report and The Alliance for Bangladesh Worker Safety Page 6/17
11 Feb 2015 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 have not been completed. Document Review: Periodic safety inspections of the electrical system components have not been completed. 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. 08 Apr 2015 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 routinely completed on main service transformers. Document Review: Any document regarding transformer oil analysis was not found during audit. 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 All equipment is efficiently earthed and properly connected to the required number of earth electrodes. The Alliance for Bangladesh Worker Safety Page 7/17
11 Feb 2015 Door earthing is not provided and an earthing connection is not provided in motor. Location: HT & LT panel, fire pump. Visual Assessment: All electrical equipment is not efficiently earthed. The earth electrodes are not properly identified. Provide earthing of equipment at required locations and connect to required number of electrodes. 08 Apr 2015 Alliance Standard Part 10 Section 10.13.7.1 Inspection of Substation Installations. The substation room has the required fire rating/protection and is physically separated from the remainder of the building. Non-Compliance Level: 2 The substation room does not have required fire rating and is physically separated by less than 3m from the main production building. Photograph: The substation room is separated but not fire rated. Consult with an expert engineer to provide adequate fire rating for the substation room. Alliance Standard Part 3 Section 3.4.2.1.4 Indications of overheating, overloading, or signs of burning were not observed. Signs of burning were not found but indications of overheating were observed at some locations during thermography. Locations: 1) Compressor Control Unit, Compressor Room (67.9 C); 2) MDB-01, 1st Floor, Sewing Area (99.2 C). Note: Detail therm The Alliance for Bangladesh Worker Safety Page 8/17
11 Feb 2015 Photograph: Indications of overheating were observed at some locations during thermography. Find out cause of overheating and take proper action including replacing cables or equipment where necessary. 24 Feb 2015 Alliance Standard Part 10 Section 10.3.5 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. Motor body earthing is not provided for the fire pump motor. Location: Fire pump motor. Photograph: Motor body earthing is not provided for the fire pump motor. 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 according to BNBC Part 8 Section 2.8 Earthing requirement. Alliance Standard Part 10 Section 10.10 Earthing Wiring systems are selected and erected so that no damage is caused by the ingress of water. Panel is located in open space with no protection from ingress of water. Location: Water pump control panel, rear wall of main factory building. Photograph: Possibility of damage due to ingress of water. Ensure wiring systems are selected and erected so that no damage is caused by the ingress of water. 29 Mar 2015 Alliance Standards Part 10 Section 10.3.4.3 Presence of Water The Alliance for Bangladesh Worker Safety Page 9/17
11 Feb 2015 Power and telecommunication or antenna cables are led in separately. Power and telecommunication or antenna cables are not routed separately. Location: 4th Floor, Beside the MDB-01. Photograph: Power and telecommunication cables are not separated. Route telecommunication or antenna cables separately to the main point of service. Power and telecommunications cables must have separate entrance. 08 Apr 2015 Alliance Standards Part 10 Section 10.3.10 Service Entry 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. Proper capacity information labels of distribution boards are not available and therefore "physical means to prevent the installation of more over current devices" is not known. Location: All distribution boards. Photograph: No means to prevent the installation of more over current devices. Ensure proper DB capacity information labels and ensure distribution boards are provided with 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 substation room has adequate ventilation. Non-Compliance Level: 2 Substation room does not have arrangements for cross ventilation. Only one exhaust fan is installed but no supply fan to supply air inside the room or ceiling fans are installed. Photograph: Inadequate ventilation system in substation room. The Alliance for Bangladesh Worker Safety Page 10/17
11 Feb 2015 Provide means of proper cross ventilation for the substation room. Consult a qualified electrical engineer to determine the required ventilation rates based on the installed equipment. 29 Mar 2015 Alliance Standard Part 10 Section 10.13.7.1 Inspection of Substation Installations. The substation room has adequate means of security. Non-Compliance Level: 2 There is no fencing provided around the transformer to avoid anyone from accidentally coming into contact with the transformer. The transformer and panels are located within the same room in close proximity. Photograph: There is no fencing provided around the transformer. Ensure proper fencing is around the transformer to avoid accidents by coming into contact with the transformer. 29 Mar 2015 Alliance Standard Part 10 Section 10.13.7.1 Inspection of Substation Installations. Do switchboards and/or distribution boards have capacity information labels? Non-Compliance Level: 2 Inadequate capacity information labels are provided. Only the maximum current rating is provided but number of circuit breakers in use and the number of circuit breakers that can be installed are not provided. Location: All distribution boards. Photograph: Inadequate DB capacity information labels are provided. Provide adequate capacity information labels (Maximum current rating, no of circuit breakers etc.) for distribution boards. 29 Mar 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 Bangladesh Worker Safety Page 11/17
11 Feb 2015 Are all internal components of switchboards and/or distribution boards properly concealed (No missing circuit breaker or knockout covers)? Internal components of sockets are not properly concealed. Location: Switchboards, Third Floor Preparation B. Photograph: Sockets are not properly concealed. Provide covers to conceal all live internal components of the socket. 03 Apr 2015 Alliance Standard Part 10 Section 10.3.9 Sub-Distribution Boards Electrical wiring and conduit is properly supported. Electrical conduit is not properly supported. Location: Beside the steel frame stair. Photograph: Inadequate cable conduit support. Provide adequate supports for electrical wiring and conduit. 29 Mar 2015 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. Cable sockets are not provided for stranded conductors greater than 6mm2. Location: Low Tension Bushing, Transformer, Substation Room. Photograph: Cable sockets are not provided. Provide cable sockets for stranded conductors having a nominal crosssectional area 6mm2 or greater. The Alliance for Bangladesh Worker Safety Page 12/17
11 Feb 2015 29 Mar 2015 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 joint was found. Location: 4th Floor, Beside the MDB-01. Photograph: Improper cable joint was found. Ensure cable joints are through porcelain or PVC connectors with PIB tape wound around joint. 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)? Un-terminated wires were found. Location: 4th Floor, Sewing Line-D. Photograph: Un-terminated wires were found. Ensure all electrical cable is properly terminated at its point of termination. Alliance Standards Part 10 Section 10.3.9.2 Wiring of Sub-distribution Boards Are junction boxes and other electrical devices provided with covers? Junction box is not provided with cover. Location:Ground Floor, Beside the SDB-02. Photograph: No electrical cover. Provide adequate covers for junction boxes and other electrical devices to keep them free from lint & dirt. The Alliance for Bangladesh Worker Safety Page 13/17
11 Feb 2015 15 Mar 2015 Alliance Standard Part 10 Section 10.3.5 and 13.6.2 Required equipment and safety signage is posted within the room. Low Required equipment and safety signage are not posted within the room. Photograph: Equipment and safety signage is not posted. 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. 15 Mar 2015 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 Signage indicating the prohibition of light fixtures without protective covers is installed at required locations. Low No signage indicating the prohibition of light fixtures without protective covers is installed at required locations. Location: Store. Photograph: No signage indicating the prohibition of installation of light fixtures without protective covers. Ensure signage indicating the prohibition of light fixtures without protective covers is posted in Bengali and English at required locations. The Alliance for Bangladesh Worker Safety Page 14/17
11 Feb 2015 15 Mar 2015 Alliance Standards Part 10 Section 10.15 Naked Lights Are electrical insulation mats provided in front of substation, switchboards and/or distribution boards? Low Non graded electrical insulation mat is provided in front of LT Panel. Location: LT panel, Substation Room. Photograph: Non graded Electrical insulation mat is provided. Provide electrically graded insulation mats in front of distribution boards. 15 Mar 2015 Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation. Phase separators are provided between terminals on circuit breakers. Low Phase separators are not provided between terminals on circuit breakers. Location: Water Pump Panel, MDB-01 (4th Floor). Photograph: No phase separators are provided between terminals on circuit breakers. Install phase separators between terminal connections at the noted locations. 29 Mar 2015 Alliance Standard Part 10 Section 10.3.1 Electrical Connections Emergency Power System Are emergency power switchboards, distribution boards, and circuits properly identified? Emergency power switchboards, distribution boards, and circuits are not identified. Location: All emergency switchboards, distribution boards and The Alliance for Bangladesh Worker Safety Page 15/17
11 Feb 2015 circuits. Photograph: Emergency power switchboards, distribution boards, and circuits are not identified. Ensure emergency power switchboards, distribution boards, and circuits are permanently marked so they will be readily identified as a component of an emergency circuit or system. 13 Apr 2015 NFPA 70 Chapter 7 Article 700.10 Wiring, Emergency System Are cable trenches properly covered? Non-Compliance Level: 2 Cable trenches are not covered. Location: Substation Room. Photograph: No cover on cable trenches. Provide adequate cover on cable trench. 15 Mar 2015 Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation Is the generator frame earthing (grounding) provided at two separate points? A small 28kVA generator (which is provided only for fire pump) is not earthed at two separate points. Visual Assessment: Generator is not earthed at two separate points. Provide two separate points earthing for generator. 06 Apr 2015 Alliance Standard 10.8.2.2 Are inspection, maintenance, and testing procedures of the emergency generator being completed and documented? Low The Alliance for Bangladesh Worker Safety Page 16/17
11 Feb 2015 Non-Compliance Level: 2 Inspection, maintenance, and testing procedures of the generator was not found. Worker Interviews: Inspection, maintenance, and testing procedures of the generator was not 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. 26 Apr 2015 NFPA 110 Chapter 8 Lightning Protection System Is a lightning protection system installed on the building? A lightning protection system is not installed on any of the buildings on the premises. Photograph: Lightning protection system is not installed. Consult with qualified electrical engineer to calculate the risk index of the buildings for confirming the necessity of lightning protection system installation and requirements. 10 May 2015 Alliance Standards Part 10 Section 10.11 Lightning Protection. Calculate Risk Index to determine if required. The Alliance for Bangladesh Worker Safety Page 17/17