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EQUIVALENT INITIAL ELECTRICAL SAFETY ASSESSMENT Factory South Panishail, Kashimpur, Joydebpur, Gazipur Joydebpur, Gazipur 04 May 2014 The Alliance for Bangladesh Worker Safety Page 1/17

Factory 04 May 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 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

04 May 2014 GENERAL INFORMATION General Information Factory Country: Province: City: Bangladesh Dhaka Joydebpur, Gazipur Zip Code: 1349 Audit Duration: Re-Audit: 1 Days Re-Audit After 0 Months Draft Report Date : 05-07-2014 Final Report Date : 06-19-2014 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 N/A There are 5 buildings on the premises: two are main production buildings and are ancillary buildings. The buildings are named as: 1) Four story RCC main production building, 2) Single story knitting production shed, 3) Single story generator Shed-1, 4) Single story generator Shed-2, 5) Single story Prayer Shed. Rented Information provided below as per following format: est occupied floor level [Height up to roof], Stories above grade, Stories below grade, Occupied levels. 1) Four story RCC main production building: 9.65 m or 31.67 ft [12.7 m or 41.67 ft], 4, 0, 4. 2) Single story knitting production shed: 0.15 m or 0.5 ft above grade [4.25 m or 13.94 ft], 1, 0, 1. 3) Single story generator Shed-1: 0.15 m or 0.5 ft above grade [4.25 m or 13.94 ft], 1, 0, 1. 4) Single story generator Shed-2: 0.15 m or 0.5 ft above grade [3.05 m or 10 ft], 1, 0, 1. 5) Single story Prayer Shed: 0.15 m or 0.5 ft above grade [3.05 m or 10 ft], 1, 0, 1. Total area of buildings in the factory premises: 97355.32 SF. Building wise breakdown as follows: 1) Four story RCC main production building: 75997.32 SF (Ground floor: 18999.33 SF, 1st floor: 18999.33 SF, 2nd floor: 18999.33 SF, 3rd floor: 18999.33 SF), 2) Single story knitting production shed: 20013.00 SF, 3) Single story generator Shed-1: 315.00 SF, 4) Single story generator Shed-2: 450.00 SF, 5) Single story Prayer Shed: 580.00 SF. Factory personnel informed the date of construction as follows: 1) Four story RCC main production building: Construction completed in 2012. No record of date of construction for rest of the buildings were found. No record for date of renovations or additions were found from factory personnel. The Alliance for Bangladesh Worker Safety Page 3/17

04 May 2014 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? : 1) Single story generator Shed-1, 2) Single story generator Shed-2, 3) Single story Prayer Shed. 1) Single story generator Shed-1: 315.00 SF, 2) Single story generator Shed-2: 450.00 SF, 3) Single story Prayer Shed: 580.00 SF. Total number of occupants: 1000 1) Four story RCC main production building: 937 (Ground floor: 116, 1st floor: 198, 2nd floor: 475, 3rd floor: 148), 2) Single story knitting production shed: 60, 3) Single story generator Shed-1: 1, 4) Single story generator Shed-2: 1, 5) Single story Prayer Shed: 1. Source: REB Transformer (500KVA) 1, Generator (1000 KVA) 1; Generator (232KVA) 1; Generator (140KVA) 1; HT Panel 1; LT Panel 1; PFI Panel 1; DB-11; SDB 10. Located in the ground floor main building near main entrance. Computer The Alliance for Bangladesh Worker Safety Page 4/17

04 May 2014 ASSESSMENT FINDINGS Electrical System Maintenance Is a periodical Insulation Resistance Measurement Program established and recorded? No periodical Insulation Resistance Measurement Program established. Document Review: No periodical Insulation Resistance Measurement Program. 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, e Alliance Standard Part 10 Section 10.13.4 Insulation Tests and 10.13.8 Electrical Inspections Is the electrical switchgear and panel boards inspected on an annual basis to ensure that the equipment is installed in accordance with the listed ratings? The electrical switchgear and panel boards are not inspected on an annual basis to ensure that the equipment is installed in accordance with the listed ratings. Document Review: No annual testing and inspection records of the electrical systems. Develop an electrical maintenance program that includes inspections and testing of the electrical systems. Reference NFPA 70 for example program requirements. Alliance Standards Part 10 Section 10.13.8 Electrical Inspections Are thermographic scans of electrical equipment completed at least every three years? The Alliance for Bangladesh Worker Safety Page 5/17

04 May 2014 Thermographic scans of electrical equipment has not been done. Document Review: No thermographic scans for electrical equipment. 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 evidence (certificate) was found that can confirm that the transformer does not contain any harmful substances. Document Review: No evidence was found. Consult with a transformer manufacturing company to ensure that the transformer does not contain any harmful substances. Not Applicable Are periodic safety inspections of the electrical system components completed and documented? No periodic safety inspections of the electrical system components have been done. Document Review: No periodic safety inspections of the electrical system. 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 Bangladesh Worker Safety Page 6/17

04 May 2014 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 completed. Worker Interviews: Transformer oil analysis is not completed. Complete an oil analysis on the applicable transformers at the appropriate intervals based on the voltage and power. Alliance Standard Part 10 Section 10.13.8 Electrical Inspections Electrical System Conditions The substation room has the required fire rating/protection and is physically separated from the remainder of the building. The door of the substation room is not fire rated. Photograph: No fire rating. Provide adequate fire protection for the substation room and make it separate from rest of the building. Alliance Standard Part 3 Section 3.4.2.1.4 Are all switchboards and/or distribution boards metal enclosed with a dead front construction? Non-Compliance Level: 2 All distribution boards are metal enclosed, but do not have dead front construction with the exception of four distribution boards. Location: All distribution boards (Except LT-Panel, Substation Room; DB-1, Knitting Section; DB-2, Knitting Section; DB-3, Knitting Section). Photograph: Some distribution boards are metal enclosed, but do not have dead front construction. The Alliance for Bangladesh Worker Safety Page 7/17

04 May 2014 Ensure distribution boards are metal enclosed with a dead front construction. 17 Jun 2014 Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear 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. Non-Compliance Level: 2 Not all metal in the building is connected to the building earthing system. Unconnected metal includes a cable ladder. Location: Substation room; Generator room-1; Generator room-2; Prayer room. Photograph: Not all of the metal in the building is connected to the building's earthing system. Connect all metal in the building to the building's earthing and grounding system. This should include metal such as the rebar in the concrete, the metal frame of the building, and the metal water pipes. Alliance Standard Part 10 Section 10.10 Earthing Indications of overheating, overloading, or signs of burning were not observed. Non-Compliance Level: 1 Indications of overheating (89 C) were observed. Location: LT-Panel, Substation Room. Photograph: Indications of overheating were observed. Find out the cause of the overheating and take proper action and consider replacement of conductors and equipment. 07 May 2014 Alliance Standard Part 10 Section 10.3.5 The Alliance for Bangladesh Worker Safety Page 8/17

04 May 2014 Is electrical wiring/cables sized according to capacity of circuit breakers (No higher rated circuit breakers with lower rated wiring)? Non-Compliance Level: 1 The electrical cables are not sized according to the capacity of the circuit breakers. er rated circuit breakers with lower rated wiring are present. Location: DB, 3rd Floor. Photograph: er rated circuit breakers with lower rated wiring. Consult with a qualified electrical engineer and ensure the electrical wiring and cables are sized according to the capacity of the circuit breakers. 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. Non-Compliance Level: 1 Multi looping of cables was observed at the circuit breakers within the distribution boards. Location: DB, 3RD Floor; DB-4, 2nd floor. Photograph: Multi looping of cables at the circuit breakers. Remove the multi looping of cables at the circuit breakers within the distribution boards. Alliance Standard Part 10 Section 10.3 Electrical Wiring and Cabling The substation room has adequate ventilation. The substation room does not have adequate ventilation. Photograph: Inadequate ventilation in the substation room. Provide a means of ventilation for the substation room. Consult a qualified electrical engineer to determine the required ventilation rates based on the installed equipment. 17 Jun 2014 The Alliance for Bangladesh Worker Safety Page 9/17

04 May 2014 Alliance Standard Part 10 Section 10.13.7.1 Inspection of Substation Installations. Do switchboards and/or distribution boards have clear identification markings? Distribution boards do not have clear identification markings. Location: All distribution boards. Photograph: No clear identification markings. Ensure clear and permanent identification marks are painted on all distribution boards, switchboards, sub main boards, and switches. 17 Jun 2014 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 do not have capacity information labels. Location: All distribution boards. Photograph: No DB capacity information labels. Provide capacity information labels (Maximum current rating, number of circuit breakers, etc.) for switchboards and/or distribution boards. 17 Jun 2014 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. Switchboards and 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. Location: All distribution boards. The Alliance for Bangladesh Worker Safety Page 10/17

04 May 2014 Photograph: No means to prevent the installation of more over current devices. Ensure switchboards and/or 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 following NFPA 70 section 408.54. Alliance Standards Part 10 Section 10.7 Main Switch, Switchboards and Metal Clad Switchgear Each circuit is provided with a dedicated neutral. Each circuit is not provided with a dedicated neutral. Location: All Distribution boards. Photograph: No dedicated neutral. Provide a dedicated neutral for each circuit. Alliance Standards Part 10 Section 10.3 Electrical Wiring and Cabling Are electrical wiring/cables properly identified? Electrical cables are not properly identified. Location: All distribution boards. Photograph: Electrical cables are not identified. Ensure that cables are identified by separate color coding, marking tape, tagging, or any other approved means. Bangladesh Electricity Rules 1937 Rule 51 and 56 The Alliance for Bangladesh Worker Safety Page 11/17

04 May 2014 Are all internal components of switchboards and/or distribution boards properly concealed (No missing circuit breaker or knockout covers)? Non-Compliance Level: 2 The internal components of the distribution boards are not properly concealed. Location:DB-1, packing, 1st floor; DB-1, knitting, 1st floor; DB-2, knitting, 1st floor; DB-3, knitting, 1st floor. Photograph: Internal components are not properly concealed. Provide covers or blanks to conceal all of the live internal components of the switchboards and/or distribution boards. 04 Jun 2014 Alliance Standard Part 10 Section 10.3.9 Sub-Distribution Boards Cable joints are through porcelain/pvc connectors with PIB tape wound around joint. Non-Compliance Level: 2 Cable joints are not through porcelain/pvc connectors with PIB tape wound around the joint. Location: DB-1, Knitting Section, Ground Floor; DB-3, Accessories Section, Ground Floor; DB-4, Accessories Section; SDB-2, HR Office, 1st Floor. Photograph: Improper cable joints were found. Ensure cable joints through porcelain/pvc connectors 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: 2 A bunch of cables are connected to the MCCB and the MCB. Location: DB, Sewing Section, 3rd Floor; DB-4, Accessories Section, Ground Floor; LT Panel, Substation Room, Ground Floor; SDB-2, HR Office, 1st Floor; SDB-3, Knitting Section, Ground Floor. Photograph: A bunch of cables are connected to the MCCB and the MCB. The Alliance for Bangladesh Worker Safety Page 12/17

04 May 2014 Need to remove the bunch of cables from the MCCB and the MCB. Not Applicable Are electrical insulation mats provided in front of substation, switchboards and/or distribution boards? Low Adequate electrical insulation mats are not provided in front of the substation, switchboards, and distribution boards. Location: All switchboards and distribution boards. Photograph: Non-graded insulation mats. Provide electrical insulation mats in front of the substation, switchboards, and 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: 2 Phase separators are not provided between the terminals on the circuit breakers. Location: DB-1, Canteen, 3rd Floor; DB-2, Iron section, 3rd Floor; DB-2, Sample Section, 3rd Floor; DB-3, Sewing Section, 2nd Floor; DB-4, 2nd Floor, Sewing Section. Photograph: No phase separators. Install phase separators between terminal connections at the noted locations. 17 Jun 2014 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 Non-Compliance Level: 2 The Alliance for Bangladesh Worker Safety Page 13/17

04 May 2014 No signage indicating the prohibition of light fixtures without protective covers is installed at the required locations. Location: Store Room, Ground floor. Photograph: No signage indicating the prohibition of the installation of naked light fixtures at the required location. Ensure signage indicating the prohibition of light fixtures without protective covers is installed at the required locations. 04 Jun 2014 Alliance Standards Part 10 Section 10.15 Naked Lights Emergency Power System Is the generator room properly rated and physically separated from the remainder of the building? The generator room is not properly fire rated. Location: Generator room -1, Generator room -2. Photograph: Generator room is not rated. Ensure the generator room is properly rated and physically separated from the remainder of the building. 17 Jun 2014 Alliance Standards Part 10 Section 10.8.4 Generator Room Are cable trenches properly covered? Cable trenches are not covered properly. Location: Generator Room-1. Photograph: Inadequate cable trench covering. Provide adequate cover on the cable trench. 04 Jun 2014 Alliance Standard Part 10 Section 10.13.7 Inspection of the Installation Are emergency power switchboards, distribution boards, and circuits properly The Alliance for Bangladesh Worker Safety Page 14/17

04 May 2014 identified? Emergency power switchboards, distribution boards, and circuits are not properly identified. Worker Interviews: As discussed with the factory's concerned person, no identification of emergency DBs/CKTs. Ensure proper identification of emergency power switchboards, distribution boards, and circuits. 04 Jun 2014 NFPA 70 Chapter 7 Article 700.10 Wiring, Emergency System Is the generator room appropriately sized in order to properly access the generator to perform routine maintenance activities? The size of generator room is not appropriate. Location: Generator Room-1 and Generator Room-2. Photograph: Inadequate generator room size. Ensure that the generator room is sized so that the generator can be properly accessed for routine maintenance activities. 30 Jul 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 Inspection, maintenance, and testing procedures of the emergency generator are not completed. Document Review: Inspection, maintenance, and testing procedures of the emergency generator are not completed and documented. Ensure that inspection, maintenance, and testing procedures of the emergency generator are being completed and documented. The Alliance for Bangladesh Worker Safety Page 15/17

04 May 2014 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 completed. Document Review: No documentation on UPS testing and maintenance is available. Ensure that inspection, maintenance, and testing procedures of the UPS are completed and documented. 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: 1 An appropriate type and number of firefighting equipment is not installed inside the generator room. Location: Generator Room - 2. Photograph: Inadequate firefighting equipment. Install the appropriate type and number of firefighting equipment inside the generator room. 04 Jun 2014 Is the appropriate type and number of firefighting equipment installed inside the generator room? Lightning Protection System The appropriate number of down conductors are installed based on the building size. The Alliance for Bangladesh Worker Safety Page 16/17

04 May 2014 The appropriate number of down conductors are not installed based on the building size. Photograph: Inadequate number of down conductors. Ensure an appropriate number of down conductors are installed based on the building size. 17 Jun 2014 Alliance Standards Part 10 Section 10.11 Lightning Protection The Alliance for Bangladesh Worker Safety Page 17/17