EQUIVALENT INITIAL ELECTRICAL SAFETY ASSESSMENT Factory Assessor: 33/1, Darail, Shataish Tongi, Gazipur Tongi, Gazipur Dhaka Emkay Enterprises 26 Feb 2014 The Alliance for Worker Safety Page 1/12
26 Feb 2014 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 2/12
26 Feb 2014 GENERAL INFORMATION General Information Factory Country: Province: City: Dhaka Tongi, Gazipur Zip Code: 1710 Audit Duration: Re-Audit: Draft Report Date : Final Report Date : 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) : 01 Days Re-Audit After 0 Months 7-July-2014 Update once final report is complete (after all comments incorporated). N/A There are 4 buildings: (1 Main Building and 3 Ancillary Structures). Owned Main Building : One story pre fabricated building. Total area of the main building is 4,900 SF. 2008-2011 No There are 3 ancillary buildings: Building 1: one story rc building, Building -2: one story brick structure, Building- 3: one story brick structure. Building 1:1,335 SF, Building -2: 654 SF, Building- 3: 397 SF. Number of Occupants : Total occupancy of the factory is 58 (main building: 44, ancillary-1: 12, ancillary-2: 01, ancillary-3: 01). Provide brief description of the electrical system for each building.: Physical location of Substation? : What equipment/loads does the UPS serve? : Service connection of 415 V from DESCO powers the facility of. Sanctioned Load from DESCO is 35 KW. One generator of 34KW has been provided as backup generator. Power is distributed through 1 Main Distribution Board and 2 Distribution Boards. The factory does not have a substation. Emergency lights and exit signs. The Alliance for Worker Safety Page 3/12
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26 Feb 2014 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? High A Single Line Diagram(SLD) is available but as-built electrical layout drawings were not found. Document Review: Relevant documents not available. Have an Electrical Engineer prepare as-built electrical drawings of all electrical installations according to existing electrical system. 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? High Documents regarding electrical safety training of workers were not found. Document Review: Documents not available. Develop and implement an electrical safety training program. Include key topics such as lock out tag out procedures, personal protective equipment requirements, etc. Keep records of completed training on site. Reference NFPA 70e for example Are thermographic scans of electrical equipment completed at least every three years? Records concerning previous thermographic scans were not provided. Document Review: Documents 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 NFPA70B or a comparable standard. The Alliance for Worker Safety Page 5/12
26 Feb 2014 Alliance Standards Part 10 Section 10.13.8 Electrical Inspections Are periodic safety inspections of the electrical system components completed and documented? Records regarding periodic safety inspections of the electrical system components were not provided. Document Review: Documents 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. Alliance Standard Part 10 Section 10.13 Inspection and Testing and Part 13 Section 13.6 Housekeeping Is a periodical Insulation Resistance Measurement Program established and recorded? Non-Compliance Level: 2 Documents regarding periodical insulation resistance measurement program were not found. Document Review: Documents not available. 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 Electrical System Conditions 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. High Non-Compliance Level: 2 Continuity of earth connection found for metallic parts related to electrical system but dedicated earthing connection was not found. Visual Assessment: Visual inspection during audit. Provide eathing connection to all exposed-conductive parts (metal) related to/in close proximity to electrical equipment/installation and utility service such as metallic water/gas/steam pipes etc. such that all the metals remain at a substantially same potential of building earthing system. The Alliance for Worker Safety Page 6/12
26 Feb 2014 Alliance Standard Part 10 Section 10.10 Earthing Do switchboards and/or distribution boards have a minimum clearance of 1 m (39 in) in front? High Non-Compliance Level: 1 DB-1.2 does not have required clearance due to a table being placed in front of it. Photograph: DB-1.2. Remove the table in front of the distribution board so there is a minimum of 1 m clearance in front of it. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Indications of overheating, overloading, or signs of burning were not observed. High Non-Compliance Level: 1 During thermographic scan, some hotspots were observed at multiple locations. Hotspots were found at cable termination points inside MDB-1, DB- 1.2, cable for curing machine inside MDB-1 and at circuit breakers inside MDB-1, DB-1.2. Visual Assessment: Inspected with thermal imager. Keep the load balanced across all three phases and avoid overloading. Terminate all cables at circuit breakers tightly using lugs of proper size(punched by proper lug puncher and crimping tool). Arrange thermographic inspections periodically to identify hotspots. 02 Oct 2014 Alliance Standard Part 10 Section 10.3.5 Are all internal components of switchboards and/or distribution boards properly concealed (No missing circuit breaker or knockout covers)? Cable entry hole was found open in all of the distribution boards. For example, DB-1.2 had its cable entry hole open. This issue is present in all 3 distribution boards. Photograph: DB-1.2. Provide covers or blanks to conceal all live internal components of switchboards and/or distribution boards. The Alliance for Worker Safety Page 7/12
26 Feb 2014 Alliance Standard Part 10 Section 10.3.9 Sub-Distribution Boards Are all switchboards and/or distribution boards properly grounded (earthed)? None of the distribution boards doors have been earthed. Photograph: MDB-1. Provide earth connection for doors of metallic distribution board using green cable or braid so that the metallic door of the panel remains at zero potential all the time. Alliance Standard Part 10 Section 10.10.2 Circuit and System Earthing Do switchboards and/or distribution boards have clear identification markings? None of the electrical panels have clear identification markings. Photograph: COS. Provide permanent identification marking mentioning name of panels or write the panel name on a durable material sheet posted on panels door. 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? None of the distribution boards have been provided with capacity information labels. Photograph: DB-1.2. Provide a capacity information label which contains the current carrying capacity and size of main cable, rated capacity of circuit breaker and the busbar (with dimension). Display panel schedules posted on panels door (inner side). 21 Aug 2014 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 8/12
26 Feb 2014 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. Capacity information labels have not been found in order to determine how many circuit breakers, the panels were designed for. Some distribution boards have space in DIN-rail channel to install additional over-current devices. This issue is present in all three distribution boards. Photograph: DB-1.2. 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. Also, provide 1 spare circuit breaker for every 5 circuit breakers inside the distribution board. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Each circuit is provided with a dedicated neutral. Circuits having common neutral were found in all distribution boards. Photograph: MDB. Provide an individual neutral connection, same as respective phase cable-size for each circuit. Alliance Standards Part 10 Section 10.3 Electrical Wiring and Cabling Are electrical wiring/cables properly identified? None of the cables have been provided with identification. Visual Assessment: Visually inspected during audit. Provide identification/tagging mentioning the equipment/machines 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 colorcode 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). Electricity Rules 1937 Rule 51 and 56 The Alliance for Worker Safety Page 9/12
26 Feb 2014 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 busbar without lugs were found. For example, cables without lugs were found inside MDB. Photograph: MDB. Cables must be terminated to MCCB/ busbar using lugs according to respective cable size. Use appropriate crimping tool or lug puncher (hydraulic preferably) for punching the lugs/cable sockets. Alliance Standards Part 10 Section 10.3.8.3 Cable Ends Are electrical insulation mats provided in front of substation, switchboards and/or distribution boards? Low Electrical panels have not been provided with insulation mats. This issue persists in all distribution boards. Photograph: DESCO Meter board. Provide electrical insulation mats in front of distribution boards. Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation. Phase separators are provided between terminals on circuit breakers. Low Non-Compliance Level: 1 MCCB without phase separators were found inside DB-1.1. Photograph: DB-1.1. Install phase separators between terminal connections. Verify phase separators are installed at all remaining locations. 21 Aug 2014 Alliance Standard Part 10 Section 10.3.1 Electrical Connections Emergency Power System Are emergency power switchboards, distribution boards, and circuits properly identified? High The Alliance for Worker Safety Page 10/12
26 Feb 2014 No identification has been provided for emergency power switchboards and distribution boards. 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. 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. NFPA 70 Chapter 7 Article 700.10 Wiring, Emergency System Is the generator frame earthing (grounding) provided at two separate points? No earthing was found for the generator. Visual Assessment: Visually inspected during audit. Install two distinct earth connections of minimum 35 sqmm for generator frame earthing. 21 Aug 2014 Alliance Standard 10.8.2.2 Is the generator room appropriately sized in order to properly access the generator to perform routine maintenance activities? Measurement of generator room is 13.69 sq m for 42.5KVA diesel generator, required room for a generator of this size is 24 sq m. Visual Assessment: Visually inspected during audit. Keep proper (minimum 1 meter) clearance around the generator while constructing the generator room wall for ease of maintenance work. 02 Oct 2014 Alliance Standard Part 10 Section 10.8.4 Generator Room Are inspection, maintenance, and testing procedures of the emergency generator being completed and documented? Low Documents regarding generator inspection and maintenance were not found. Visual Assessment: Visually inspected during audit. The Alliance for Worker Safety Page 11/12
26 Feb 2014 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) other requirements. NFPA 110 Chapter 8 Are inspection, maintenance, and testing procedures of the UPS being completed and documented? Low Documents regarding IPS testing and maintenance were not found. Document Review: Documents not available. 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 Is the appropriate type and number of firefighting equipment installed inside the generator room? Low Non-Compliance Level: 2 Only a smoke detector was present. No firefighting equipment was provided inside the generator room. Visual Assessment: Visually inspected during audit. Provide firefighting equipment (preferably ABC type) inside generator room. Is the appropriate type and number of firefighting equipment installed inside the generator room? The Alliance for Worker Safety Page 12/12