Proceedings, Safety in The Garment Industry, Five Years After Rana Plaza on

April 30, 2018

ON THE GUIDELINES FOR ELECTRICAL SAFETY AUDITS IN

RMG INDUSTRY OF BANGLADESH

Mohammed Imamul Hassan Bhuiyan1, Shuvro Prokash Majumder1, Yeasir Arafat1, S.M.
Mahbubur Rahman1 and Md. Zahurul Islam1

ABSTRACT

An aftermath of the catastrophic incidence of fire in Tazreen Fashions in 2012 and building
collapse at Rana Plaza in 2013 is the introduction of a number of international and national
initiatives in order to ameliorate the fire, electrical, and structural safety scenarios in the Ready-
Made Garment (RMG) industry of Bangladesh. These initiatives include international
organizations such as the ACCORD on Fire and Building Safety in Bangladesh and the
ALLIANCE for Bangladesh Workers Safety, and the National Initiative under the National
Tripartite Plan of Action (NTPA) on Fire Safety and Structural Integrity. Ensuring electrical safety
is essential not only to prevent electrical shocks or accidents and subsequent injuries and deaths, but
also to reduce the number of fire incidents by a great extent. According to the Fire Service and Civil
Defense Authority (FSCDA) of Bangladesh, the majority (about 75%) of the past events of fire
accidents in the RMG factories in Bangladesh originated from electrical issues, e.g., loose
connections, electrical arcing, flashing of static charges, and short-circuits. In order to ensure and
enhance electrical safety in the existing RMG factories and thereby to improve the overall fire
safety measures, the organizations mentioned above developed their own guidelines to perform
electrical safety audits and remediation of identified electrical problems in the RMG industry.
These guidelines are mostly based on the Bangladesh National Building Code (BNBC) 2006. In
some contexts, they have also incorporated relevant internationally renowned standards, such as the
National Fire Protection Association (NFPA) 70 or NFPA 70E. This paper aims to review these
guidelines to identify their dissimilarities, limitations, overemphasized issues and scope of
improvement. This is necessary to suggest suitable changes for the harmonization and improvement
of these guidelines, facilitating remediation, and enhancing electrical safety management in the
RMG industry, while also to take into account the upcoming BNBC. This is important to sustain
the process of inspection and remediation as in near future the activities of all the three initiatives
will presumably be carried out under a single and independent entity.

1. Introduction

The Ready-made Garment (RMG) industry has long been the main driving force of the export economy of
Bangladesh accounting for about 81% of its overall export. It is also one of the largest employers in the
country, engaging 4 million workers in 4,482 factories (BGMEA, 2018). Over the years, occasional fire
incidents have been a major plight of the industry (ILO, 2017, Wadud et.al. 2014, Hossain 2016). In
November 2012, a devastating fire occurred in Tazreen Fashions; 129 lives perished while 200 people got
severely injured. This was followed by the catastrophic building collapse at Rana Plaza in April 2013,
causing more than 1100 deaths and similar number of injuries (Solidarity, 2017). Although the industry
had been suffering from fire and other accidents before and had a poor safety record since its nascent, these
two major incidents drew the attention of the world, national and international stakeholders. As these
catastrophes occurred mostly due to non-compliance regarding fire, electrical and structural issues on one
hand and lack of supervision and control by the enforcing agencies on the other (ILO, 2017). A number of
international and national initiatives were taken to ameliorate the fire, electrical and structural problems in
the RMG industry. These include ACCORD on Fire and Building Safety in Bangladesh, the ALLIANCE
for Bangladesh Workers Safety, and the National Initiative under the National Tripartite Plan of Action

1
Department of Electrical and Electronic Engineering, Bangladesh University of Engineering and
Technology, Dhaka-1025,Bangladesh
E-mail of Corresponding Author: imamul@eee.buet.ac.bd
 On the Guidelines for Electrical Safety Audits in
RMG Industry of Bangladesh

Mohammed Imamul Hassan Bhuiyan1, Shuvro Prokash Majumder1,

Yeasir Arafat1, S.M. Mahbubur Rahman1 and Md. Zahurul Islam1

(NTPA) on Fire Safety and Structural Integrity. The ACCORD and ALLIANCE are the platforms formed
by groups of mainly European and USA-based clothing brands, respectively. On the other hand, the NTPA
involves the Government of Bangladesh and stakeholders from RMG factories and labor organizations
(ILO, 2017).
Among the three major issues, the electrical ones cause electrical shocks and accidents in the factories
which can result in injuries leading to prolonged disability on occasions and fatalities. At the same time, it
is also a major cause of fire and explosion worldwide (Daéid, 2004). As for the RMG industry in
Bangladesh, electrical safety issues are responsible for most of the fires, about 75% according to the Fire
Service and Civil Defense Authority (FSCDA) of Bangladesh. Many of these fires occur due to loose
connections, arcing and flashover and short circuits (Sundaram et.al., 2016 and Haque et.al., 2017). It is
interesting to note that unlike the well-circulated electrical short-circuit, the main reasons for electrical
fires are loose connections and in-line arcing (Babrauskas, 2008). In terms its ability to cause fire, short-
circuits rank below in-line arcing followed by miscellaneous events such as misuse of appliances, use of
extension cords, lightning protection etc. It is of utmost importance that electrical problems are minimized
in the RMG industry as it will reduce not only electrical accidents, but also electrical fires. The ACCORD,
ALLIANCE and NTPA have developed their own guidelines to identify electrical issues in the garment
factories, build the required corrective action plans and mobilize and supervise remediation. The
Guidelines are mostly based on the Bangladesh National Building Code (BNBC) 2006 and in some
respects, well-known international standards such as the NFPA 70 and NFPA 70E. Using the Guidelines,
the ACCORD and ALLIANCE have made a considerable progress in indentifying and remediating
electrical problems. Under ACCORD as of January 2018, 65,266 electrical items have been found of which
more than 85% have been rectified (ACCORD, 2018). As of 2017, more than 600 factories have been
inspected under ALLIANCE wherein about 90% of the electrical errors are remediated (ALLIANCE,
2017). Under the umbrella of NTPA, 1549 factories have been inspected for identifying electrical issues
with only a few factories being remediated. Note that the ALLIANCE and ACCORD will leave the field
soon and presumably the process will continue under an independent body afterwards (ALLIANCE, 2017).
It is necessary to review the Guidelines to identify their limitations and scope of possible improvement so
that the process of inspection and remediation becomes harmonized, stronger and more sustainable. The
present paper aims at finding the dissimilarities, limitations and overemphasized issues among the existing
guidelines and suggests necessary assimilations and changes to harmonize and improve while taking into
account the upcoming BNBC. The latter is important since electrical safety inspections beyond ALLIANCE
and ACCORD should conform to the upcoming version of BNBC (based on BNBC 2015 draft).

2. Comparison of the Guidelines of ACCORD, ALLIANCE and NTPA

In this Section, the Guidelines mentioned above have been compared. During the comparison, the
Guidelines of ACCORD and ALIANCE are compared together against that of NTPA because the first two
are almost similar. We will refer to the former as A-A and the latter as NTPA in subsequent discussions.
The comparison reveals three different types of issues: (i) Requirements in NTPA but not in A-A (Table 1),
(ii) Requirements in A-A but not in NTPA (Table 2), (iii) Requirements in A-A and NTPA that are
different (Table 3). Note that the electrical items in Tables 1 and 2 have similar requirements in most part
and only the additional requirements as in NTPA or A-A are shown. If the additional requirement
improves electrical safety considerably, it is termed as a major issue otherwise will be termed as moderate
or minor issues. Similarly, if the differences in Table 3 reduce risk of electrical accidents and fires
significantly, it is denoted as a major issue and moderate or minor otherwise. For the various electrical
safety items, comments are also provided on the corresponding requirements regarding their affect on
reducing electrical and fire hazards. The draft version of the upcoming BNBC, referred to as BNBC 2015,
is also considered in the comments. It is seen from the tables that in most of the cases the differences or
additional requirements do not significantly increase the risk of electrical accidents and/or fire, and hence
are considered as moderate/minor issues. On the other hand, there are several major issues meaning that
the absence of corresponding additional requirements (for example the requirements for the Inspection and
Testing item in A-A) can reduce the risk of electrical accidents and fire, and hence must be included in
NTPA. However, the lone major issue in Table 1 is considerably substantiated in A-A by the requirement of
 Proceedings, Safety in The Garment Industry, Five Years After Rana Plaza on
April 30, 2018

Layout and Installation Drawings. As for the moderate issues, the harmonization of the corresponding
additional requirements for the guidelines will bolster their capacity to identify electrical problems and
facilitate remediation to reduce electrical accidents and electrical fire. For the minor issues, the guidelines
can be kept as it is since the differences are expected to affect the risk of electrical accidents and fire
insignificantly. It is also observed that the comments as well as the overall requirements of the various
guidelines are, in general, conform to the BNBC 2015. BNBC recommends the use of a spare circuit-
breaker for Electrical Connections, not found in either NTPA or A-A, and hence can incorporated in them.
The requirements of A-A for the Conductors is also provided in BNBC 2015 and thus should be included
in NTPA.

Table 1. Requirements mentioned in NTPA but not in Accord-Alliance (A-A)

Items Additional Requirements Comments

Electrical Wiring Use of looping wiring, join box and * Useful to reduce risk of overloading and
and Cabling: importantly provision for 20% subsequent electrical fire. BNBC 2015
Electrical spare capacity and a spare circuit in additionally mentions a spare circuit-
Connections branch circuits (Clause 4.4.1) breaker.
*Moderate issue
EQUIPMENT (Clause 4.7.5) *Minor issue
AND
ACCESSORIES:
Energy Meters
Inspection of the Installation in accordance with the *Major issue
Installation: approved drawings; (Clause
Inspection of 4.16.7.1)
Substation
Installations

Table 2. Requirements mentioned in Accord-Alliance (A-A) but not in NTPA

Items Additional Requirements Comments

Electrical Wiring Independent support of lighting fixtures *Reduces risk of electrical fire
and Cabling: from the building structure with seismic *Moderate issue
Lighting Fittings bracing as required (Clause 10.3.6)
Electrical Wiring For existing buildings, maintaining an *Useful for identifying
and Cabling: Layout appropriate Single Line Diagram (SLD) electrical problems.
and Installation reflecting as built conditions (Clause *Moderate issue
Drawings 10.3.7)
Electrical Wiring Identification of Live, Neutral and Earth *Important for electrical safety
and Cabling : through the use of colored insulation or *Moderate issue
Conductor and Cables: colored plastic vinyl tape (Clause 10.3.8.1) *also provided in BNBC 2015
Conductors
Electrical Wiring Legible identification of every circuit with *Important for electrical safety
and Cabling: Sub- its location and specific purpose or use; *Moderate issue
distribution Boards provision for circuit directory on the panel
door (Clause 10.3.9.1)
Electrical Service Vermin and damp-proof components of a *Important for reducing risk of
Shaft and Bus Duct: bus duct and using fire stops in all electric shock and arcing
Bus Duct openings (Clause 10.4.2) *Moderate issue
Electrical Sufficient access and working space of at *Important for electrical safety
Substation: least 1.07 m (3ft 6in) in substations *Moderate issue
Substation Location around the equipment (Clause 10.5.2)
Main Switch, Distance of 1 m (39 in.) in front of the *Important for electrical safety
Switchboards and switchboards and switchgear and *Moderate issue
Metal Clad distribution panels.(Clause 10.7.1 and
 On the Guidelines for Electrical Safety Audits in
RMG Industry of Bangladesh

Mohammed Imamul Hassan Bhuiyan1, Shuvro Prokash Majumder1,

Yeasir Arafat1, S.M. Mahbubur Rahman1 and Md. Zahurul Islam1

Items Additional Requirements Comments

Switchgear: Main Clause 10.7.3)
Switch, Switchboards
and location of
distribution boards
Standby Power: At least 1.07 m(3ft 6in) space on all sides *Important for electrical safety
Generator Room of the generator (Clause 10.8.4) *Moderate issue
ILLUMINATION Emergency power or battery backup *Minor issue
OF EXIT SIGNS Lighting for exit signs; verification of the *The requirements on
AND MEANS OF power at least once per year. Battery- inspection and testing are not
ESCAPE: Exit Signs operated signs being tested monthly, and given in BNBC 2015
for a minimum 90 min once per year
(Clause 10.12.1)
ILLUMINATION Emergency power or battery backup *Minor issue
OF EXIT SIGNS Lighting for exit signs; verification of the
AND MEANS OF power at least once per year. Battery-
ESCAPE: Means operated signs being tested monthly, and
of egress for a minimum 30 min once per year
(Clause 10.12.2)
Battery Systems Battery systems installed, tested and *overemphasized requirement
(standby or emergency maintained as per NFPA 111. (Clause as one can follow BNBC
power) 10.12.3) *Minor issue
Generators (standby or Generators installed, tested, and *overemphasized requirement
emergency power) maintained in accordance with NFPA as one can follow BNBC
110.(Clause 10.12.4) *Minor issue
INSPECTION AND Periodic inspection and testing program *Important for reducing
TESTING: Periodic complying the requirements of NFPA 70E electrical fires and electrical
Inspection and Testing (clause 10.13.2.1). For existing accidents.
construction, thermographic inspection of *Major issue
electrical equipment being on a tri-annual
basis and in accordance with ASTME1934
(Clause 10.13.2.2)
INSPECTION AND For existing construction, test made on all
TESTING: Insulation electrical equipment on a 5 year cycle and
Resistance Tests as per Clause 10.13.4.1 (Clause 10.13.4)
INSPECTION AND For existing construction, on a 5 year *Important ensuring electrical
TESTING: Earth cycle and as per Clause 10.13.5.1 (Clause safety.
Resistance Test 10.13.5) *Major issue
Electrical Preserving Records of initial testing and *Minor issue
Inspections subsequent testing onsite (Clause 10.13.8)
Naked lights Not allowed in storage areas or in any area *important for electrical safety
where the Inspector of the Factories Rules and reducing risk of electrical
(1.6.3.7) Part 53 disallows. Posting of fire
signs in Bengali and English, indicating *Major issue
this prohibition at all entrances to these
areas. Mandatory Lighting in storage
areas. (Clause 10.15)
Electrical Safety Development of an Electrical Safety *Moderate issue
Program Program as per NFPA70E for operation
and maintenance personnel (Clause 10.16)
 Proceedings, Safety in The Garment Industry, Five Years After Rana Plaza on
April 30, 2018

Table 4 provides a set of recommendations that should be incorporated in the Guidelines. Mandatory use of
the Cu conductors will drastically reduce the problem of loose connections and overloading. Employing
RCCBs in watery premises is necessary as unbalanced 3-phase supply is common in Bangladesh that can
easily lead to earth leakage currents and any inadvertent operation can cause fatality. On the other hand,
use of AFCI is common in USA and can be introduced in our factories as it would extinguish in-line arcing
and hence suppress incipient electric fire. Provision for accepting new technology for LPS is suggested as
otherwise factory owners could be deprived off possible alternative method with greater efficiency and
reduced cost. The suggestions can also be incorporated in the upcoming BNBC for its improvement and
ensure conformity of the guidelines with the BNBC.

Table 3. Differing Requirements in A-A and NTPA

Items Requirements Comments

Electrical Wiring and A-A: Underground cables through GI or PVC pipes and laid *Minor
Cabling: Wiring in earth trenches of 600 mm (24 in,) (Clause 10.3.2) issue
NTPA: …. trenches of sufficient depth (Clause 4.4.2)
Electrical Wiring and A-A: 900mm (36 in.) distance from external heat (Clause *Minor
Cabling: External 10.3.4.2); NTPA: Sufficiently far (Clause 4.4.4.2) issue
Influences
Main Switch, NTPA: allows open type switchboards only in dry and *Moderate
Switchboards ventilated locations and far away from storage batteries or issue
chemical fumes.(Clause 4.8.1); A-A: Open type switchboards
are not allowed. (Clause 10.7.1)

Table 4. Suggested Recommendations for inclusion in the Guidelines

Items Recommendations Comments

Wiring Use of Cu cable should be mandatory for LV (low BNBC 2015 suggests the use
voltage) application. Use of Aluminum cable of PVC insulated cables with
should be discouraged. Cu conductors. However, it
does not mention the use of
Fire resistant (FR) cables with 3-hours fire rating FR or flame retardant cables
shall be used for emergency communication and although it is important for
power cables. Flame retardant cables should be of inhibiting flame propagation,
LSZH (Low Smoke Zero Halogen) type and used in fire detection and suppression,
confined spaces such as vertical riser and plenum and effective evacuation.
spaces.
Switchgear Residual Current Circuit-Breaker (RCCB) should BNBC 2015 recommends the
be used in all outlets at premises with proximity to use of RCCB in MDBs only.
water, such as kitchen, washrooms, washbasin, However, it is mentioned in
boiler room, washing plant, water treatment plant NFPA 70 E and important for
etc. reducing risk of electrical
shock and electrocution.
Switchgear Arc Fault Circuit Interrupter (AFCI) is Mentioned in NFPA 70 (not
recommended in all MDBs and substations. in BNBC 2006/2015) and will
be useful for suppressing
arcing, thus reducing the risk
of electrical fire.
Lightning Use of newly introduced technology not mentioned New technology may be more
Protection in the BNBC or other standards can be effective. Too much emphasis
System (LPS) accommodated upon scientific on available technology while
evaluation/assessment by established research or rejecting the new one without
testing labs or universities. scientific validation can be
counter-productive.
 On the Guidelines for Electrical Safety Audits in
RMG Industry of Bangladesh

Mohammed Imamul Hassan Bhuiyan1, Shuvro Prokash Majumder1,

Yeasir Arafat1, S.M. Mahbubur Rahman1 and Md. Zahurul Islam1

3. Conclusions

Enhancing electrical safety in the RMG industry is essential to reduce electrical accidents and fires, thereby
saving numerous lives and properties. In this regard, the initiatives of ACCORD, ALLIANCE and NTPA
have contributed, so far, significantly through inspections and remediation in a large number of factories,
performed under their respective Guidelines. A comparative analysis of the Guidelines has been carried out
in the present paper to identify their limitations and areas of improvement. A number of moderate and
minor issues have been identified and a few major issues have been determined. Suggestions have been
provided for assimilations and changes to incorporate these issues in various guidelines and render
improvement. However, the impact of the guidelines on reducing risks of electrical accidents and fire
should be analyzed and compared with related data from stakeholders such as FSCDA and Department of
Inspections for Factories and Establishments (DIFE). Fire risk indices have been developed incorporating
structural and management parameters (Wadud, 2017); however, a risk index reflecting the current level of
electrical safety in the RMG industry is still lacking.

References

BGMEA (2018) “Trade Information”, Online available at http://www.bgmea.com.bd/home/pages/

accessed on April 11, 2018.

ILO (2017) “Towards Improved Fire and Building Safety in Bangladesh”, International Labor
Organization (ILO) Country Office for Bangladesh, Dhaka, Bangladesh.

Hossain, Md. Faruk (2016) “Fire Hazard in Readymade Garment Factories and its Impacts on
Workers in Dhaka Metropolitan Area, Bangladesh”, J. Asiat. Soc. Bangladesh, Sci. 42(1), pp. 77-93.

Wadud, Zia, Yasin, F.H. and Ahmed, Nizam Uddin (2014) “Assessment of Fire Risk in the
Ready-made Garment Industry in Dhaka, Bangladesh”, Fire Technology, 50 (5), pp. 1127-1145.

Solidarity Center (2017) “Bangladesh Garment and Textile Factory Safety Incidents”, Online available at
https://www.solidaritycenter.org/wp-content/uploads/2017/04/ accessed on April 11, 2018.

Daéid, Niamh Nic (2004) “Fire Investigation”, CRC Press, Glasgow, UK.

Sundaram P., Shanmuga, Thangaraj, R. , Raj, Aravind and Jaya Krishna, K (2016) “A Case Study on
Investigation of Fire Accident Analysis in Cotton Mills”, Proc. of 14th International Conference on
Humanizing Work and Work Environment, pp. 236-240.

Haque, F., Marma, Hla-U-May and Chowdhury, A.H. (2017) “Prediction of Burn Incidents Due to
Faulty Installations in RMG Factories in Bangladesh”, Proc. of ECCE, Cox’s bazaar, Bangladesh, pp.
733-737.

Babrauskas, V. (2008) “Research on Electrical Fires: The State of the Art”, Proc. of 9th International
Conference on Fire Safety Science, pp. 3-18.

ACCORD (2018) “Quarterly Aggregate Report on Remediation Progress at RMG Factories Covered by
the Accord”, ACCORD on Fire and building Safety in Bangladesh, Dhaka, Bangladesh, pp.6-11.

ALLIANCE (2017) “Dawn of a New Era in Safety: Accelerating Progress in the Alliance’s Final
Year”, Alliance for Bangladesh Worker Safety, Dhaka, Bangladesh, pp. 4-6.

Wadud, Zia, and Yasin, F.H. (2017) “Fire Safety in the Readymade Garment Sector in Bangladesh:
Structural Inadequacy Versus Management Deficiency”, Fire Technology, 53 (2), pp. 793-814.