Chinese hot tub not listed

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why not just contact the AHJ and ask their thoughts on having a NRTL certify the tub?

In my jurisdiction we allow those NRTL's that are listed on OSHA's website.
www.Osha.gov click on the letter "N" in the " A to Z search index" and search for Nationally Recognized Testing Lab

Better then being stuck with a couple thousand dollar ugly lawn decoration

So how would OSHA be involved in a household appliance installation? The same is true for the NRTL listing. That is an OSHA requirement, not an NFPA.

It is probable that the product HAS some sort of labeling and meets requirements established by some non-US entity. The requirements of that listing may even be higher than ANSI rules. The Supplier and Manufacturer should have at least some generic information on those and in turn that information may be used by the AHJ to declare the equipment acceptable.

If the AHJ is intransigent and unwilling to work with the poor Owner, the Owner may choose to investigate the safety of the product himself and determine if the risk is acceptable, then just have a receptacle installed as the premanent wiring and install the tub as a pluggable unit.
 

Jraef

Moderator, OTD
Staff member
Location
San Francisco Bay Area, CA, USA
Occupation
Electrical Engineer
The CEC does not require electrical equipment to be listed. 110.2 of the CEC says "Equipment shall be approvable if it is listed, labeled or certified....."

In the commentary of the hand book after 110.3(B) it states: "This section does not, in itself, require listing or labeling."

After 110.2 it states: "Approval of equipment is the responsibility of the electrical inspection authority, and many such "approvals" are based on tests and listing of testing laboratories.
OK, I bow to your experience in this, thanks for the insight. Every time it has come up on a job for me, I was quoted that line out of 110.2 and told this is where the CEC added NRTL listing to the basic requirements of the NEC. So effectively, my experience is that no inspector I have ever worked with has allowed that loophole, or even mentioned it exists. In other words it appears from the wording that they can make a judgment call on an unlisted piece of equipment, but I have yet to run into one that has exercised or even acknowledged that option.

I also seriously doubt any AHJ who values his position (and the safety of his charges) will take on the personal approval of a non-listed hot tub made in China...
 

cowboyjwc

Moderator
Staff member
Location
Simi Valley, CA
OK, I bow to your experience in this, thanks for the insight. Every time it has come up on a job for me, I was quoted that line out of 110.2 and told this is where the CEC added NRTL listing to the basic requirements of the NEC. So effectively, my experience is that no inspector I have ever worked with has allowed that loophole, or even mentioned it exists. In other words it appears from the wording that they can make a judgment call on an unlisted piece of equipment, but I have yet to run into one that has exercised or even acknowledged that option.

I also seriously doubt any AHJ who values his position (and the safety of his charges) will take on the personal approval of a non-listed hot tub made in China...

I have no doubt that what you say is true and I agree that nobody would approve a non-listed hot tube, but if an inspector had the knowledge and the desire he could inspect the hot tub and "approve" it per 110.3(A).

I just don't like when people get hung up on "this is what it says" when that's not really what it says or someone told them that's what it said.
 

Volta

Senior Member
Location
Columbus, Ohio
...
If the AHJ is intransigent and unwilling to work with the poor Owner, the Owner may choose to investigate the safety of the product himself and determine if the risk is acceptable, then just have a receptacle installed as the premanent wiring and install the tub as a pluggable unit.

The owner(s) may be unlucky, but not poor, they just spent 8,000 on a hot tub!

The unlisted tub cannot be connected with flexible methods 680.42(A), only rigid methods are allowed for unlisted tubs ;).
 

hurk27

Senior Member
Well this again is one of those subjects I just can't stay quiet on:grin:

I have never found in the NEC where a hot tub, or any other appliance or other piece of end use electrical equipment is part of a electrical installation?
sure we have rules on how they are to be connected if there, but I don't think they are part of the electrical installation, that stops at the outlet box of that circuit.
let me ask this:
Does the NEC cover the wiring inside a hot tub?
If not how can it also require it to be listed?
I think only the codes of the manufactures can cover this.

If we look at 110.2:

110.2 Approval.
The conductors and equipment required or permitted by this Code shall be acceptable only if approved.

I know there are other requirements for appliances that are more of a manufacture code like AMA and others who make codes that manufactures have to follow that will require a appliance to have a NTRL listing, but I will always believe the intent of 110.2 to be only the electrical circuits and equipment, such as panels, raceways, outlet box's and any other equipment we install to supply the end appliance, How could we ever cover the listing of all the things that a home owner could plug in, or connect to our outlet box's?

I believe 110.2 stops at our outlet box's, let the code writers of the manufactures control the requirements of appliances
 
I agree it doesn't have to be listed by UL but the AHJ has the say on whether it wants to approve or not.

The plumbing code on the other hand is very specific fixtures being listed. The tub is a fixture, not an appliance.
UPC and Iapmo are two listing agencys for plumbing fixtures. I've seen a couple VERY expensive tubs, one made of Japanese hardwood, turn into expensive deck ornaments.
 

iwire

Moderator
Staff member
Location
Massachusetts
Well this again is one of those subjects I just can't stay quiet on

I won't either. :grin:

I have never found in the NEC where a hot tub, or any other appliance or other piece of end use electrical equipment is part of a electrical installation?

And I have never found anything that say the NEC stops at the outlet.

IMO 90.2(A) says the NEC applies to electrical equipment. I see no definition of 'installed' that limits the NEC to the outlet.

Also I see is a fair number of requirements that specifically address issues past the outlet. :)
 

ZCBee

Member
Location
Reno, NV
What is the purpose of NFPA 79 then?

Well this again is one of those subjects I just can't stay quiet on:grin:

I have never found in the NEC where a hot tub, or any other appliance or other piece of end use electrical equipment is part of a electrical installation?
sure we have rules on how they are to be connected if there, but I don't think they are part of the electrical installation, that stops at the outlet box of that circuit.
let me ask this:
Does the NEC cover the wiring inside a hot tub?
If not how can it also require it to be listed?
I think only the codes of the manufactures can cover this.

If we look at 110.2:



I know there are other requirements for appliances that are more of a manufacture code like AMA and others who make codes that manufactures have to follow that will require a appliance to have a NTRL listing, but I will always believe the intent of 110.2 to be only the electrical circuits and equipment, such as panels, raceways, outlet box's and any other equipment we install to supply the end appliance, How could we ever cover the listing of all the things that a home owner could plug in, or connect to our outlet box's?

I believe 110.2 stops at our outlet box's, let the code writers of the manufactures control the requirements of appliances
 

hurk27

Senior Member
I won't either. :grin:



And I have never found anything that say the NEC stops at the outlet.

IMO 90.2(A) says the NEC applies to electrical equipment. I see no definition of 'installed' that limits the NEC to the outlet.

Also I see is a fair number of requirements that specifically address issues past the outlet. :)

I agree that the codes has specifics on how we must hook up a hot tub beyond an outlet, but it doesn't tell us how the hot tub has to be wired internally, it tells us how a electric dryer must be connected, but don't tell us how the motor in it must be wired, so I would guess these hook up are past the outlet box.;)

But to address 90.2, and 110.2
Is a appliance an "electrical equipment" or are they "utilization equipment"
Should they be treated in the same sense of a breaker panel?
If what your saying is true where do we draw the line, I can think of many appliances that might be hooked up when the house is inspected that most inspectors would not even have a clue on how to make a judgment as to its worthiness.

This same idea can be extended to mobile homes, A local inspector can only inspect the service and hook up of a trailer, the inside is beyond their responsibility, what if the trailer is older then the June 1986 HUD code rules, doesn't matter they can not inspect inside of a trailer, it was manufactured, a new trailer will have the HUD inspection tag but the older one wont, and a local inspector can not require that the older trailer get one.

Sure I believe a inspector should have a say on how a appliance gets wired, the NEC gives them that, but to say grandma's 1940 sewing machine can't be used because back then manufactures were not required to get it NTRL listed to me is beyond the scope of a local inspector.
 

hurk27

Senior Member
Ok since this thread was about a hot tub, I looked in my 2002 NEC (the only one I have on this computer) just to see what 680 say's, to see if there is a requirment for a hot tub to be listed?

the only article I can find is 680.42 (2002)

(A) Flexible Connections. Listed packaged spa or hot tub equipment assemblies or self-contained spas or hot tubs utilizing a factory-installed or assembled control panel or panelboard shall be permitted to use flexible connections as covered in 680.42(A)(1) and (A)(2):

Wow "factory installed" seems to say something here but so does the little word "OR"

No where do I see a requirment for a hot tub to be listed?
 

Volta

Senior Member
Location
Columbus, Ohio
Ok since this thread was about a hot tub, I looked in my 2002 NEC (the only one I have on this computer) just to see what 680 say's, to see if there is a requirment for a hot tub to be listed?

the only article I can find is 680.42 (2002)



Wow "factory installed" seems to say something here but so does the little word "OR"

No where do I see a requirment for a hot tub to be listed?

That is my take on it, only needs to be listed if we install a flexible method, otherwise, no. Similar text in 2008.

With factory installed or factory assembled I think they are allowing the sections to be shipped separately, and put together on site, but don't want any 'homemade' control panels.
 

hurk27

Senior Member
That is my take on it, only needs to be listed if we install a flexible method, otherwise, no. Similar text in 2008.

With factory installed or factory assembled I think they are allowing the sections to be shipped separately, and put together on site, but don't want any 'homemade' control panels.

It doesn't even need to be listed to use a flexible cord if is has "a factory-installed or assembled control panel or panel board"

you have to put the "OR" between the listed requirement and the rest.

Here is another view, if end use appliances are "electrical equipment" then why the extra wording "including pump motors" in 680.43D)(2) for bonding.
To me this is saying pump motors are not "electrical equipment"

I agree the NEC is vague on the definition, but to many places in it like this one point to a whole different meaning as to what "electric equipment" is, and what "utilization equipment" is but you will find both wording in the NEC

and from what I can understand is, a motor is in fact "utilization equipment" from this artical:
455.21 Start-Up.
Power to the utilization equipment shall not be supplied until the rotary-phase converter has been started.

And this definition:

Appliance. Utilization equipment, generally other than industrial, that is normally built in standardized sizes or types and is installed or connected as a unit to perform one or more functions such as clothes washing, air conditioning, food mixing, deep frying, and so forth.

I rest my case lol:grin:
 

Volta

Senior Member
Location
Columbus, Ohio
It doesn't even need to be listed to use a flexible cord if is has "a factory-installed or assembled control panel or panel board"

you have to put the "OR" between the listed requirement and the rest.
After reading that section more carefully, I agree.
Here is another view, if end use appliances are "electrical equipment" then why the extra wording "including pump motors" in 680.43D)(2) for bonding.
To me this is saying pump motors are not "electrical equipment"
Oh, probably to give no wiggle room. I think if they say "including" motors, then by that sentance structure, the book considers motors included as electrical equipment.
I agree the NEC is vague on the definition...I rest my case lol:grin:
:grin:
 

hurk27

Senior Member
After reading that section more carefully, I agree.

Oh, probably to give no wiggle room. I think if they say "including" motors, then by that sentance structure, the book considers motors included as electrical equipment.
:grin:

I disagree with this (in red) because why would they waste text space if it is clear that motors are "electrical equipment" ?

I say they included it because it is "not electrical equipment" it is "utilization equipment"

we install "electrical equipment" to supply "utilization equipment" and I still believe we should only be responsible for the "electrical equipment" we install, not the "utilization equipment" that might be installed other then the hook up to it.;)

The NEC, IBC, does not have any codes to how a "utilization equipment" has to be manufactured or built, there are other codes that the manufacture has to follow to market thier product, and it is these codes that will call for the product "utilization equipment" to be listed by a NTRL, not the NEC, all the NEC tells us is how this "utilization equipment" has to be wired, and how we must install our "electrical equipment"

Ok enough ranting bed time lol:grin:
 

adelle

Member
I'm surprise nobody brought this up yet:

Is this device intended for use on the North American electrical system? Or is it a domestic Chinese unit? China has a different system - probably neutral + ground and a 250v hot leg. At least thats what a lot of Europe has. Beside the slight voltage incompatability, is the internal grounding compatable with American systems? If one side of the line input is grounded internally and you connect that to a standard US 240v split phase supply - well you get the idea.

P.S. I'll bet the pump motors are 50hz!
 
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iwire

Moderator
Staff member
Location
Massachusetts
I agree that the codes has specifics on how we must hook up a hot tub beyond an outlet, but it doesn't tell us how the hot tub has to be wired internally, it tells us how a electric dryer must be connected, but don't tell us how the motor in it must be wired, so I would guess these hook up are past the outlet box.

410.130.(G)

422.41

422.46

422.47

422.49

422.51

440.65

Just a random few examples of the NEC applying to utilization equipment 'beyond the outlet'.:grin:
 

hurk27

Senior Member
410.130.(G)

422.41

422.46

422.47

422.49

422.51

440.65

Just a random few examples of the NEC applying to utilization equipment 'beyond the outlet'.:grin:


Thanks for looking these up, I never thought (last nite) about these codes, and there are others, but I find it hard to see how these codes could be enforced legally when in the eyes of the law no one can tell you that you can not use a older appliance, I would have to say the grandfather clause would block this in a court of law? look at 440.65, what if I have an older window air unit I want to use instead of buying a new one, are we saying it is now made illegal to use it? I don't think that would fly in court. something that was legal when manufactured can not be made illegal.

I agree they are in the NEC, but I think these codes are over stepping what can be enforced, and or putting the inspector into a field that is beyond his scope of expertize.
What next, I can see now, an inspector wanting to return after a home owner has all his appliances installed including his TV, radio, Etc... if he can inspect appliances we are doomed as electricians because we are now responsible for what a home owner plugs in:mad:
If what you say is true?:confused:
 

hurk27

Senior Member
I'm surprise nobody brought this up yet:

Is this device intended for use on the North American electrical system? Or is it a domestic Chinese unit? China has a different system - probably neutral + ground and a 250v hot leg. At least thats what a lot of Europe has. Beside the slight voltage incompatibility, is the internal grounding compatible with American systems? If one side of the line input is grounded internally and you connect that to a standard US 240v split phase supply - well you get the idea.

P.S. I'll bet the pump motors are 50hz!

China has been flooding the American market for a long time, trust me, they know what power standards we use:grin:
 
410.130.(G)

422.41

422.46

422.47

422.49

422.51

440.65

Just a random few examples of the NEC applying to utilization equipment 'beyond the outlet'.:grin:

Does it make sense to have them in the Code when they are unenforceable?

I don't recall ever seeing in any household appliances' manual that would indicate compliance with the provisions of the NEC. They might refer to the Code by saying that it should be installed by a 'qualified electrician' and the installation should meet local codes, but usually have a very loose and haphazard connection to the Code.
 
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