Why was Nirapon established?
There is a common misconception that the Alliance for Bangladesh Worker Safety simply ceased operations at the end of 2018 and left Bangladesh. That was not the case. The Alliance handed over to Nirapon to what was the next phase of the program. By the end of 2018 the Alliance had closed the corrective action plan (CAP) on around 450 factories. That success, rather than being the end of the program was in fact the beginning of the next phase. Closing the CAP took the factories to a ‘start line’ of safety.
Beyond the safety engineering solutions achieved during CAP closure, there are three key areas that we need to focus on these being:
That all the people working in the factory interact and work within that building in a safe way. This requires, among other things, for effective policies and procedures along with risk assessments and control measures for all hazards and risks; as well as ongoing training for all people in the factory, and processes for developing policies and working practices that are consultative and open with full worker engagement.
That effective schedules and systems are in place to continuously maintain all the engineering safety solutions at the factory along with all other ancillary equipment necessary to support production at the factory. This will include boilers, generators, electrical equipment, fire alarms, sprinkler systems etc. This maintenance should follow a preventative maintenance process, which prevents equipment failures.
That the technical changes continue to follow the relevant regulations and are complementary to the work that was undertaken during the Alliance. There are often changes to the building, this can be caused by changes to production techniques, growth of the business or change of use to areas of the factory.
How is Nirapon different than other safety organizations?
There are several ways that Nirapon is different. Nirapon works with factories that have closed their CAPs, and so demonstrating their commitment to investing in the engineering safety solutions in their factory. Nirapon works with other partner service providers, the Amader Kotha Helpline, BRAC (training) and ELEVATE (engineering services). This provides Nirapon with a holistic approach to safety.
Nirapon works to provide safety information to Members in a consistent way to allow the Members to work with the factory to leverage the changes required. Nirapon provides appropriate technical and risk management guidance to support the factory in making any changes. In most cases we are talking about managing hazards and risks as opposed to technical engineering work, because the factories are CAP closed.
The approach of Nirapon is educational not enforcement. The factories that are CAP closed need to maintain that standard with their engineered safety solutions and the safety of their electrical systems and the structure of their buildings. We can support those changes and maintain the engineering safety of the factory.
As well as maintenance there is a need to plan and schedule safety activities that are integral to the production processes. This can be, for example, maintenance planning, worker and specialist training, safety inspections of the factory premises and scheduling worker safety committee meetings.
We focus on the solution to the problem and see the problem as a need to educate rather than penalize. In the long term, this should make factories more open to admitting uncertainty and seeking guidance to achieve appropriate safety solutions.
Does Nirapon suspend factories that are not compliant?
We must remember that Nirapon works with CAP-closed factories. It would be unreasonable to suspend a factory that has already invested in the engineering safety of their factory. By the same token, that factory will want to preserve the safety gains they have made and so are very willing to be guided on the management of safety.
The core role of Nirapon is guiding and educating workers, managers, and owners to interact with their CAP-closed factory in a safe and sustainable way. A CAP-closed factory is only safe until we put people into that building. If those people then act unsafely then the factory is still not be safe.
However, don’t misunderstand – if a factory continually fails to engage with Nirapon (such as not responding to information requests or, for example, not taking part in training), then we will work with the relevant member to enforce that issue but only when other options have not provided the required cooperation from the factory.
Does Nirapon only work with CAP-closed factories?
There are some factories that have not yet achieved CAP closure. These are predominantly new factories or a small number of factories that have carried over from the Alliance. These factories are managed by ELEVATE, undergo training with BRAC and subscribe to the Amader Kotha Helpline, which is the process to achieve CAP closure. All this work is under the supervision and oversight of Nirapon. Once CAP-closed, the factory joins the Nirapon Safety Management Program.
Having this system in place allows us to support new factories joining Nirapon as well as supporting safe and sustainable growth in Bangladesh factories.
How do Nirapon members ensure that Bangladesh factories adopt safe practices?
The role of Nirapon through its members is to support the employer (factory owner and managers) to provide a safe workplace. To achieve this, Nirapon developed the Safety Management Program. The components of this program are:
The 90-Day Workbook and Management Guidance. This workbook sets out a comprehensive systems-based approach to safety management at a factory. The workbook is divided into three key areas: safety management, safety maintenance and technical change management. A factory must submit a report every 90-days accompanied by evidence (photos, videos, corroborating documents, not checklists) of work carried out in support of managing and maintaining a safe workplace. Every report is reviewed, and feedback is provided to the factory on the work completed and the evidence submitted in support including suggestions for improvements.
The Safety Support Visit (SSV). This is a quality assurance measure of the 90-Day Workbook. Is what the factory telling us in the 90-Day reports reflected in what we are seeing at the factory? Is the factory demonstrating continuous improvement, learning from the feedback received? The members sourcing from the factory also receive the feedback from the SSV and of course from the 90-Day reports submitted from the workbook to demonstrate the safety work that the factory has carried out in the previous quarter.
BRAC online safety training for workers, security guards and safety committee. This uses the train-the-trainer model. This means that every factory has its own trainers that can deliver a continuous program of safety training to the factory. There is unlimited online support for the factory-based trainers. Additionally, BRAC will visit the factory to assess the performance of the trainers and again to assess that the training has been delivered successfully to the workers. There is also dedicated training for managers in how to manage occupational safety in a factory. By undertaking this training and having the 90-Day workbook as guidance, we can better guide factories to manage safety in their factory as their requirement representing the employer.
Subscription and membership of the Amader Kotha Helpline. The Helpline allows workers to seek assistance outside the factory management chain. The Helpline is available to everyone at participating garment factories. This service can be used if a resolution cannot be reached in the factory management chain or the caller feels that they cannot approach managers. This service also advises us of safety issues in factories and provides a form of real-time monitoring.
Together these components provide a significant level of oversight at Nirapon supplying factories to support owners and managers to manage their responsibility for factory safety.
Why does Nirapon believe that the owner as the employer is responsible for the safety of the factory?
This is a very important point to clarify and explain. It is a legal requirement that the employer is responsible for the safety of the workplace and the workforce. In addition, workers also have a duty of care for their own safety and others around them.
Throughout the 19th and 20th centuries, governments across the industrial and developed world sought to control safety through legislation. Employers looked to government to solve safety in all types of workplaces. That process did not work, as trying to legislate problems away was unsuccessful. In any industry the people that know the industry best of all are those that are in that industry – the workers, managers, employers etc. The best people to resolve issues are those same people. In addition, you cannot implement some of the various control measures, supervise safety procedures, or manage hazards and risk in a workplace unless a physical presence can be maintained.
In the early 1970s occupational safety legislation came into being that placed the emphasis on the employer to provide and maintain a safe workplace.
Since OSHA's establishment in 1971, workplace fatalities have been cut by 60 percent, and occupational injury and illness rates by 40 percent. At the same time, U.S. employment has nearly doubled from 56 million workers at 3.5 million worksites to 105 million workers at nearly 6.9 million sites.
In the UK, the Health and Safety at Work etc Act 1974 was described as "a bold and far-reaching piece of legislation" by HSE's first Director General, John Locke. It certainly marked a departure from the framework of prescribed and detailed regulations which was in place at the time. The Act introduced a new system based on less-prescriptive and more goal-based regulations, supported by guidance and codes of practice. For the first time employers and employees were to be consulted and engaged in the process of designing a modern health and safety system.
Is there a proven system for managing safety effectively?
Nirapon has created a safety management framework for use by factories. The 90-Day workbook, guidance and reporting process. This seeks to break down safety into three key areas.
This is all based upon a system known as the Hierarchy of controls for safety management. This looks at the controls that can be used to manage hazards (something that can cause harm) or risk (the likelihood of harm being caused by the hazard).
The first control measure is elimination. Do we need to do this work or do we need this object that is creating the hazard? As an example, does a factory need to use the chemical Hydrogen Peroxide in the production process? If the answer is no, then it can be removed from the factory.
If the answer is yes, then can it be substituted by a less hazardous material, for example a higher dilution mix?
The next is engineering controls, that is the design and layout of the factory and all the systems within to keep the people separate from the hazards in the factory. For example, the protected means of egress, fire detection system, fire doors, sprinkler systems, etc. This was the main focus of the Alliance work.
A workplace is required to have established policies and procedures in place so that everyone in the factory knows their job as well as understanding the hazards of other work going on around them. All workers need to have the relevant qualifications and receive regular training to keep those skills and knowledge relevant and up to date. These policies and procedures need to be communicated to the workforce (more training) and should be reviewed and when necessary, updated annually. The workforce should be involved in that process because they have the most knowledge about the work that they do. Whenever there is an accident, all procedures should be examined to seek to improve the procedures and to prevent recurrence. Finally, there should be effective supervision of this work. There is that employer’s responsibility again. This work is referred to as the administrative controls.
Personal Protective Equipment (PPE) is the backstop control. With all the other controls in place, there may still be a need to wear some form of equipment or clothing to provide a higher level of protection.
The employer must be able to demonstrate that they have examined all hazards and risks that are likely to be encountered in the workplace and has then done all that is reasonably practical to mitigate those risks.
All of what has been very briefly described in the hierarchy of controls is the framework of a safety management system. If we can embed this in our factories and get owners, managers, and workers to understand and use these systems, factories in Bangladesh will be safer and will continue to improve in safety management.
What is the participation rate of factories in the Nirapon program?
The factories are in the program have a 99% participation rate – but we cannot get complacent. Factories need to improve in the work that they do, how they plan that work. For example, the thinking on maintenance is that a repair is needed when something stops working. We are teaching the factories to adopt preventative maintenance, in other words service the equipment while it is in good working order to keep it operating as it should be.
This approach is good for safety, but it is also good for business, too. If the electrical systems keep breaking down, this is unsafe. We all know that over 80% of all fires in factories are caused by electrical issues; but electricity is also the life blood of a factory. If the system keeps breaking down how can a factory produce products on time?
Does it reflect poorly on the Brands when the factories continue to have safety issues?
There isn’t a factory in the world that does not have safety issues that require resolution. In Bangladesh, a lot of what we are talking about isn’t known by our factories. The adage “you don’t know what you don’t know” is applicable. The solution is in taking an educational rather than enforcement based approach, providing that the factory is cooperative and is open to and responds to feedback.
We report to the members on all aspects of the safety of their supplying factories. That report is communicated in such a way that provides solutions to those issues without getting the factory to lose focus on areas where they are having success. All reporting is factual and is supported by evidence.
Does Nirapon deal with labor issues, too?
Nirapon works with three Partner Service Providers and is a member-led organization. In the case of any labor issues, these are managed through the Amader Kotha Helpline. All factories in the Nirapon Programs must subscribe to the Helpline and all workers at those factories are issued with a card with the Helpline telephone number.
The Helpline receives a wide range of safety and labor-related calls. In the case of labor issues, the Helpline will work with the factory to gather all available information from both the caller and management (protecting the callers’ identity) when discussing with managers. Wherever possible, workers are encouraged to seek a resolution with managers. However, there may be many reasons why this is not possible and so the Helpline will still provide support including ascertaining any solution generated by factory management. The members are then informed and when required, will work with the factory to resolve an issue.
Where the situation allows, the Helpline will work to seek a resolution, educate managers and the caller to better manage these situations, prevent recurrence and maintain positive industrial relations in the workplace.
So, Nirapon deals with safety management, technical matters, engineering work and labor and worker issues?
The focus of Nirapon is to develop through education an effective and sustainable safety management system in our members' factories. There are many things that can impact this work. Through working with BRAC, ELEVATE, and Amader Kotha Helpline and being a member-led organization, we can get any issues dealt with by the most appropriate and qualified people for any situation we may encounter. In all cases the following activities are member led:
Nirapon (coordinates the work of all Partner Service Providers) – leads on the Safety Management Program: Safety Support Visits and 90-Day Workbook, etc.
BRAC – training factory managers and factory-based trainers (train the trainer model).
ELEVATE – all technical matters and engineering work.
Amader Kotha Helpline – all calls from workers on safety, labor and other matters.