Nirapon was launched following the sunset of the Alliance for Bangladesh Worker Safety which ceased operations as originally planned, five years from its launch. The Alliance was focused primarily on assessing and remediating building, electrical, and fire safety readiness with the 654 RMG factories manufacturing for the 29 member brands. There were other activities such as safety training in factories and giving workers a voice through the implementation of a Help Line and introduction of worker safety committees. The priority though was to address basic safety in each facility.
At the time that the Alliance ceased operations, 428 of the factories closed all material items in their corrective action plans. The remaining factories were comprised of a number that was shared with the Accord (and working thru the Accord process) and others that had started late with the Alliance and had not yet closed all open items in their CAPs. With factories CAP closed, the emphasis shifted from the remediation of physical plants to management systems and making sure the investments in safety were being maintained. Nirapon was launched with this objective in mind.
One of the constants with the Alliance and Nirapon has been ELEVATE and Paul Rigby. ELEVATE built and managed the local Alliance operations in Bangladesh and is playing a similar role for Nirapon. Paul joined the Alliance as its Chief Safety Officer in its 3rd year, was an advisor for Nirapon 1.0, and is now the CEO and Chief Safety Officer of Nirapon 2.0.
We sat down with Paul to get his impressions about the evolution of BEFS in Bangladesh, where we are now, and thoughts on positive next steps for Nirapon and the industry
1. How has building, electrical, and safety evolved in Bangladesh?
Building Electrical and Fire Safety (BEFS) has continued to improve throughout Bangladesh following the work of the Alliance and the Accord, which alongside other government, NGO, and private business-sponsored projects to create safer buildings, reduce the likelihood of collapse and prevent electrical fires and electrocutions. The final part is putting in systems that if fires did start, they would be contained in their origin and workers would have a protected means of escape from the building. However, there is still some way to go. Engineering knowledge still needs to improve in Bangladesh. Whilst many engineers can cite regulation, the intent of regulations is not always fully understood and people will seek “exemptions” to regulations. A classic example of this is chemical storage.
If we consider the hierarchy of control for risk management, BEFS work belongs to the category of engineering controls. That is to say that we have placed engineering safety solutions into a building to help to reduce risk. It must be understood that BEFS work is only a part of safety work. Think about a new car parked in a garage. The car is safe, it has all the latest engineering technology.
If the vehicle isn’t maintained and serviced, then will it stay safe? If the driver is reckless or breaks the laws when driving, can we still say that the vehicle is safe? Let’s explore this hierarchy throughout this discussion.
2. What is the condition of factories now?
The first challenge is that factories believed that CAP closure was the finish line. In fact, so did many others within and outside of the industry. Everyone appeared to see CAP closure as the safety solution. In truth, it is one part of the solution. It is more accurate to say that a CAP closure takes a factory to a starting line of safety. If we look again at the hierarchy of control for risk management, this comes a little more into focus.
The first thing with engineering is that a system or a building needs to be maintained. Even a building will get old. Electrical systems, machinery, fire alarms, etc. all require maintenance if they are to continue to work. Since CAP closure, factories have not maintained these systems and so we are now working with factories to improve that situation, but also to develop their thinking in safety management further.
The people working in the factory need to be trained and competent to do their job. Managing a factory is complex and so it requires complex and well thought out solutions to manage safety in an industrial environment effectively.
Preventative maintenance is required. This is cost-effective and not only good for safety but good for business too.
3. What hazards are in our factories and how are we supporting and educating managers to manage these hazards to mitigate risk?
First, we need to define hazard and risk.
Boilers, electrical systems, chemicals, raw materials, and finished products, and many other things are hazards. They can all cause harm in each set of circumstances, so how do we control and reduce the potential of these hazards to cause harm. Where would we start with that? Well, how about looking at the production processes of the factory, seeing why we need these hazards in our workplace and start looking from there. The view being that safety is integral to what we do, it is not a separate subject. How do we do this? Through a structured approach, applying the hierarchy of control for risk management to all work processes in a factory. We would refer to this as a “Safety Management System”.
Now we are starting to take a more holistic view than what has traditionally been taken. The problem has been that we looked at hazards when there was an accident (reacted). In risk assessment terms this was a cause for concern as the focus moved away from other hazards as it was believed that these were not a problem (there were no reported incidents). Chemicals are always a hazard, so is electricity, so are boilers, they will never cease being hazards, so we must maintain a proactive and preventative thought process.
Nirapon, with ELEVATE, it’s on the ground monitoring partner, and BRAC its training partner, educates, supports, and reinforces safety management with owners and managers to provide them with this perception of hazards. The Nirapon approach is broadly speaking the following…
Safety Management Training for Managers. This provides managers with the knowledge to start to formulate risk management strategies for their workplace.
The 90 – Day Management Guidance and Reporting Process (90 Day Report). This provides factory managers with a framework safety management system. This helps them to see a more holistic view of safety with a structure to support them to put safe systems of work in place. The factory then submits a report with supporting evidence of the work that has been carried out to make the factory safer. We then review this work and feedback to the factories on areas of improvement.
The Safety Support Visit (SSV). This is an on-site visit that QA’s the quality of the 90 – Day Reports. It also provides an opportunity for further education for the managers by referring them back to the safety management training. We examine and report on all aspects of their work, what they have done well, as well as areas where improvements can be made. We also seek to share areas of best practice across all our factories. This helps to develop the philosophy of continuous improvement across the industry. We are not there yet. What we are seeing on our SSVs right now is that managers are focused on the technical, the maintenance processes and they need to improve. The gap is in people management. We will see a manager’s office with shelves of policies and procedures all lined up on the shelf. Then we ask the question, how do you communicate these policies and procedures to the workforce? The disconnect between managers and workers is still there and that is slowly being changed.
The SSV also supports factory managers to develop preventative maintenance programs for all the systems and engineering solutions within the factory. This includes the use of competent trained engineers, not a compliance manager submitting checklists for work in which they are not suitably qualified.
4. What are the keys to successfully managing this work?
By being proactive and taking an all hazards, all risks approach, utilizing a framework of a safety management system coupled with the hierarchy of controls for risk management. With that in place to then examine all areas of work that are applicable to a particular workplace. To facilitate this Nirapon has produced the 90-Day Management Guidance and Reporting Process (the 90-Day Report). This document provides factory managers with a framework to apply to their factory to start to look at how they can control hazards and then reduce the risk.
The 90-day report and the safety support visit provide a framework and give direction to factory owners and managers, but unless we provide training and support then this framework for a safety management system will not be recognized, understood, or used correctly. This reporting process is followed up every 18-months with a safety support visit (not an audit) of the factory.
Factories will seek the status quo of the “Brand requirement”, which is not the route to success. We need a program of education and support in place. At Nirapon we have formed a partnership with BRAC to deliver training to managers, safety management system for managers (SMS); coupled with this Nirapon in partnership with BRAC have provided safety training to factory-based trainers, who in turn facilitate workplace training to all factory workers in basic safety training as well as training in how to respond in an emergency – which is to evacuate. We refer to this model as the train the trainers’ model (TtT).
A readily available asset to support safety is security guards, so we provide safety training to that group too, again using the train the trainer model. Finally, we provide a safety committee to managers and selected workers. This latter group should work cooperatively to develop and update policies and procedures in factories seeking a process of continuous improvement. This is achieved through the ongoing reduction of risk by updating and making improvements to work policies and procedures. This latter group links into the SMS training for managers and brings safety into the mainstream as part of the business and production processes, rather than seeing safety as a separate issue. We will walk through an example of that shortly.
Working collaboratively with the factories when reviewing the 90-day reports, Nirapon provides feedback on those reports to support factories in how they can improve their safety management performance to maintain their workplace, keep their workers trained, and develop safe processes and procedures for all work in the factory.
We also have a Helpline (The Amader Kotha Helpline), this service, described as an anonymous grievance process, is in fact far more than that. It is probably best described as a barometer for safety in the Bangladesh RMG industry as well as a quality assurance (QA) agency for Nirapon work. What we are trying to change here is a deeply embedded mindset, that safety is a Brand requirement and in general, safety gets in the way of production.
We will talk about the helpline in a bit more detail but first, we should discuss an illustration of this mindset and then apply the risk control measures we discussed earlier. We will use chemical usage in the factory production process as an example of this mindset.
A. Current thinking in factories.
Hydrogen Peroxide (H2O2) is used widely in the RMG sector as a cleaning and bleaching agent. In pure form (undiluted) it decomposes explosively and is used as rocket fuel. For this reason, this substance requires a certificate to authorize storage under the Explosives Act 1884.
In Bangladesh National Building Code (BNBC) there are prescribed limits on storage of such substances, these are generally ignored with the Explosives Act certificate being seen as an exemption. As far as a factory manager is concerned, there is nothing else “in writing” so that is the end of the matter.
There are in fact a lot more requirements, that are written, and the certificate is issued with certain expectations – but that is another subject altogether.
B. Hierarchy of controls approach, where we need to get to.
Elimination – Do we need to use H2O2?
Substitution – Is there another substance we can use?
Engineering Controls (BEFS) – We store the chemical in a fire-resistant storage facility. If it is a flammable or high hazard, then we can also install sprinklers. There may also be interceptors in the drainage system to capture any spillage.
Administrative controls – Regulations around segregation and separation of different substance classes are applied. There are signs to indicate the hazard class and that only trained authorized persons to have access to the storage facility. The factory puts in place policy and procedures about how the chemical is handled, mixed, moved, and used at every stage of the use of the chemical in the production process. The chemical is only handled or used by trained personnel. There will also be an emergency and first aid procedures at each stage in case there is an accident. All accidents are investigated to seek to improve the process and prevent reoccurrence. All processes should be followed. There should be a schedule of annual refresher training for those involved with chemical use. Exercises should be carried out to train for emergencies and to test policies and procedures. All lessons learned are being incorporated into policy and procedures.
Personal Protective Equipment (PPE) – The trained people carrying out this work need to be equipped with the right equipment to protect them from any harmful effects from any chemical that they are required to handle or use. This equipment should be tested and maintained regularly.
As I am sure you will agree, the hierarchy of control approach will control the hazard and reduce the risk of injury, spillage, fire, or explosion. This thinking must be applied to all work at the factory so that all hazards are controlled, and risk is reduced in an environment of continuous improvement, and that is the challenge.
The Helpline will usually alert us to a problem or an accident and if we trace back to the cause we can then offer solutions. The Helpline is also able to see risk emerging and as we continue to develop and improve our partnership working, we can start to take a more holistic view of risk and start to predict problems as they emerge. We can then alert our members and perhaps prevent matters from escalating too far.
Ideally, the factory should do this themselves, but until we change that mindset and factory owners and managers recognize their responsibility for providing a safe workplace, we will have to support and develop safety thinking in the industry.
5. What makes Nirapon different?
We take an educational approach that seeks to support the industry to join the dots of safety management. As this understanding develops, the industry will become self-directing and so safer and sustainable.
The ownership of risk rests with the employer, and only the owner of risk can effectively control that risk – not the customer. That means that if a factory is not safe, we can only provide the owner and managers with the education and direction to achieve a safe workplace, we cannot control the risk for them.
When thinking of Nirapon, think about OSHA or HSE, it is about occupational safety, not just engineering safety but the broader spectrum of risk that we have discussed in the hierarchy of control for risk management.
6. Many industry groups and initiatives have been developed to conduct assessments and manage Corrective Action Plans. Tell us why Nirapon is focused on working with CAP Closed factories?
To answer that question, we need to look back to why the Alliance, Accord, and others came to Bangladesh in the first place. When Rana Plaza collapsed it was the third-largest industrial accident in modern history. The focus within Bangladesh following that disaster was the business continuity of the industry, the Brands focus was on the need to improve safety, the obvious start point was making factories (the workplace) safe. In broad terms that is the role of BEFS, ((Nirapon TSV) because they are the systems of a building that need to be improved.
That resulted in buildings being constructed to withstand the structural demands resulting from industrial processes, machinery, and people. With electrical and other utility systems that could facilitate the loads required to service industrial-scale machinery and finally a structure that could mitigate the spread of fire using passive and active measures, provide an alert to fire and a protected means of egress to evacuate the building.
With those things in place, you now have a start line to work from to make a workplace safe. It is people and how they operate that dictates the safety of the workplace. Think again about the reckless driver, not observing the speed limit or other traffic signs, not driving within the limits of their experience or the conditions of the road. The car that they drive is now a hazard, despite all the latest technologies and engineering solutions incorporated into that car, because of the mindset and attitude of the driver. We need to work with the driver, not the car (except to service and maintain it), we need to work with the owner, managers, the workers, and yes maintain the factory to keep the workplace safe.
Nirapon seeks to change mindsets, through a process of education, not enforcement. Think about Covid-19 and the issue of wearing masks or vaccines, to change a mindset you must convince people that what you are trying to achieve is the right course of action. That is the challenge that Nirapon faces, along with the other challenge that a lot of people in factories (and elsewhere) saw and still see CAP closure as the solution.
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