Use of a BF GFCI used as a dishwasher disconnect.

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enigma-2

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northern Indiana
Using 2005 NEC.
RE:

422.30 General. A means shall be provided to disconnect each appliance from all ungrounded conductors in accordance with the following sections of Part III.

A disconnecting means is defined as: "A device, or group of devices, or other means by which the conductors of a circuit can be disconnected from their source of supply."

I was asked to permit the use of a BF GFCI to be used as a disconnecting means for a dishwasher. I won't get into the discussion as to why, the electrician wanted to use it and I have to rule on it.

On the surface it seems to be fine, push the "test" button and the ungrounded conductor is disconnected from its supply. But I still have reservations; perhaps unfounded.

1. I do not see where a GFCI was designed or listed for this use. 110.3-(A)(1) & (B).

2. GFCI's are known to fail (which is why they have the test button and require a monthly test.) Of course switches and circuit breakers can fail as well, but they have a established track record of success; not so clear with GFCI's. If a GFCI fails, it may not deenergize the circuit. Or it can fail and possibly refuse to re-energize the circuit.

3. The definition of a GFCI reads: "A device intended for the protection of personnel that functions to deenergize a circuit or portion thereof within an established period of time when a current to ground exceeds the values established for a Class A device." While it doesn't include its use as a disconnecting means, a GFCI does seem to fit within the borders of the definition.

4. Cannot be manually operated without power. Although not related, Section 225.38 reads "Disconnect Construction. Disconnecting means shall meet the requirements of 225.38(A) through (D).
(A) Manually or Power Operable. The disconnecting means shall consist of either (1) a manually operable switch or a circuit breaker equipped with a handle or other suitable operating means or (2) a power-operable switch or circuit breaker, provided the switch or circuit breaker can be opened by hand in the event of a power failure."
A GFCI is not manually operable. And they don't work when the power if off. Now this section doesn't apply to 422.30, but I was looking at it for guidance.

5. (D) Indicating. The building or structure disconnecting means shall plainly indicate whether it is in the open or closed position. Here's one area where the blank-face GFCI fails. There is no clear indicating of "on" and "off". It does state "test" and "reset" but I don't feel that it's "plainly indicating" which state it's in (without taking a very close look to see if the button is raised.

6. Is a GFCI switch rated?

7. Is a GFCI motor rated?

Perhaps I'm being too anal on this, but I seem to have lingering doubts as to it's merit. Based strictly on economics, it would seem clear that the use of a switch is not only cheaper but better for this use. Does anyone have anything they would care to add?
 

MasterTheNEC

CEO and President of Electrical Code Academy, Inc.
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Well in order to save a lot of "INK" let me just say a GFCI Receptacle is not an OCPD nor a disconnection means. Not withstanding that I don't agree with your statement #2 (they are very reliable actually). And yes, Anal is a good word for what you are expressing:sick:

And I mean that with all due respect...honestly.
 

GoldDigger

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This has been discussed in earlier threads, and to me the serious safety concerns include the lack of a positive position indicator.
If the circuit is de-energized and you push the test button you will read zero voltage on the output. But if someone re-energizes the circuit upstream you will get zapped. It cannot be used as a safety disconnect!
 

enigma-2

Member
Location
northern Indiana
... let me just say a GFCI Receptacle is not an OCPD nor a disconnection means.
I believe you meant to say "blank face GFCI".

Do you have any further code references to substantiate your opinion other than "let me just say....". Now, please understand, I strongly lean toward agreeing with you, but I have always used the code to reinforce my stand on things (legality and all that), and there just seems to be so much gray area on this.
 

enigma-2

Member
Location
northern Indiana
This has been discussed in earlier threads, and to me the serious safety concerns include the lack of a positive position indicator.
If the circuit is de-energized and you push the test button you will read zero voltage on the output. But if someone re-energizes the circuit upstream you will get zapped. It cannot be used as a safety disconnect!

You confused me in your response. If you trip the "trip" button, that opens the circuit at that point, which will be located adjacent the dishwasher. (Probably in the cabinet next to the dishwasher.) Why would not the circuit remain energized all the way back to the OCPD? As I see it, the circuit continuous to remain energized and no one need do anything to re-energize "upstream".

What did I miss?
 

GoldDigger

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You confused me in your response. If you trip the "trip" button, that opens the circuit at that point, which will be located adjacent the dishwasher. (Probably in the cabinet next to the dishwasher.) Why would not the circuit remain energized all the way back to the OCPD? As I see it, the circuit continuous to remain energized and no one need do anything to re-energize "upstream".

What did I miss?
What I saying is that if you start out with the breaker tripped, then pushing the test button all you want will not open the GFCI. And if someone then decides to reset the breaker you are not protected by an in-sight disconnect.
 

enigma-2

Member
Location
northern Indiana
What I saying is that if you start out with the breaker tripped, then pushing the test button all you want will not open the GFCI. And if someone then decides to reset the breaker you are not protected by an in-sight disconnect.
I believe you misunderstood. The BF GFCI was to be located adjacent the diswasher. I don't believe it would have any bearing as to what anyone did back at the breaker.

But nevetheless, can you think of any code section I may be overlooking concerning my objection to using a bf gfci as an appliance disconnect?
 

GoldDigger

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I think that you are repeatedly missing my point.
The GFCI cannot be a disconnect because it cannot be opened when the power feeding it is off.
It does not matter how that may have come about; it is possible.
I can push the test button on the GFCI and not have it open.
That can also happen if the GFCI is defective and there will be no visible evidence of that.
Compare this to the situation with a snap switch marked ON and OFF.
If the power to the circuit is off somewhere upstream and I flip the switch to the off position, I know that whatever else happens upstream there will be no power downstream of the switch.
 
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enigma-2

Member
Location
northern Indiana
I think that you are repeatedly missing my point.
The GFCI cannot be a disconnect because it cannot be opened when the power feeding it is off.
It does not matter how that may have come about; it is possible.
I can push the test button on the GFCI and not have it open.
That can also happen if the GFCI is defective and there will be no visible evidence of that.
Compare this to the situation with a snap switch marked ON and OFF.
If the power to the circuit is off somewhere upstream and I flip the switch to the off position, I know that whatever else happens upstream there will be no power downstream of the switch.

Thanks, GoldDigger, I see your point. And a good point it is. An electrician could get seriously injured under those condtions.

How do you see this being documented with the code, that is, how would you write it up as a non-conformance? (422.30 does not extend far enough to bring it in).
 

GoldDigger

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Thanks, GoldDigger, I see your point. And a good point it is. An electrician could get seriously injured under those condtions.

How do you see this being documented with the code, that is, how would you write it up as a non-conformance? (422.30 does not extend far enough to bring it in).
Simple enough for me:
422.30 says that whatever is used as the disconnecting means must be chosen from those listed in the rest of Section III. That will be through 422.35.

Can you find a GFCI (DF or other) in that list?

If you try to go with the general "switch" provision, you fail to meet the mandate of 422.35 for a position indicator. And it does not qualify under 422.34 either, since it is not part of the appliance, in addition to not having a marked OFF position. 422.33 does not apply, and there is no 422.32 in the 2011 code. 422.31 only allows switches or circuit breakers. A GFCI is neither of those. I rest your case. :angel:

We often generalize that under the NEC, if something is not prohibited it is permitted. But there are places like this where there is a list of options, and if it is not permitted it is prohibited.
 
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fmtjfw

Senior Member
Is deenergize the same as disconnect?

Is deenergize the same as disconnect?

Does the test button say "OFF" Must a disconnect say "ON" and "OFF"?

100 Disconnecting Means. A device, or group of devices, or other means by which the conductors of a circuit can be disconnected from their source of supply.

100 Ground-Fault Circuit Interrupter (GFCI). A device intended for the protection of personnel that functions to deenergize a circuit or portion thereof within an established period of time when a current to ground exceeds the values established for a Class A device.

100 Ground-Fault Protection of Equipment. A system intended to provide protection of equipment from damaging line-to-ground fault currents by operating to cause a disconnecting means to open all ungrounded conductors of the faulted circuit.
 

al hildenbrand

Senior Member
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Minnesota
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5. (D) Indicating. The building or structure disconnecting means shall plainly indicate whether it is in the open or closed position. Here's one area where the blank-face GFCI fails. There is no clear indicating of "on" and "off". It does state "test" and "reset" but I don't feel that it's "plainly indicating" which state it's in (without taking a very close look to see if the button is raised.

6. Is a GFCI switch rated?

7. Is a GFCI motor rated?
From the UL White Book - Guide Information for Electrical Equipment:
GROUND-FAULT CIRCUIT INTERRUPTERS (KCXS)
The ??TEST?? and ??RESET?? buttons on the GFCIs are only intended to check for the proper functioning of the GFCI. They are not intended to be used as ??ON/OFF?? controls of motors or other loads unless the buttons are specifically marked ??ON?? and ??OFF.?? Products with ??ON?? and ??OFF?? markings have been additionally Listed under Motor Controllers, Mechanically-operated and Solid-state (NMFT).
 

GoldDigger

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And to follow up on that Al, I am quite certain I have seen dead front GFCI's that say "ON" and "OFF".
But is that just a different way of identifying the test and reset buttons, or is there a clearly visible way of telling which button is pushed?
And if so, would it still qualify as a switch? Especially if pushing the OFF button with power removed does not trip the disconnect?
And if it would trip the disconnect with power removed, it would not serve as the mandatory TEST button, would it?
There is also ample precedent that the absence of an ON indicator light (if there is one) cannot be taken as an indication that the disconnect is really open (in a LOTO situation under OSHA, for example).
 

GoldDigger

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I dunno. Obviously the UL has come to a conclusion; seems to say manufactures can't just use the ON and OFF labels Willy Nilly.
A valid point, and if the particular DF GFCI is indeed listed for use as a motor controller, does that motor controller qualify under 422.31 as a disconnect? Not sure, especially since a motor controller will often have the ability to be remotely operated.
Now show me a DF GFCI with position indication as well as ON and OFF buttons, and I will still have my doubts. I am not sure that without also having TEST and RESET button labels it will qualify as a GFCI. Or can those button functions be unmarked as long as the instructions tell you which is which?
 
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ActionDave

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A valid point, and if the particular DF GFCI is indeed listed for use as a motor controller, does that motor controller qualify under 422.31 as a disconnect? Not sure, especially since a motor controller will often have the ability to be remotely operated.
Now show me a DF GFCI with position indication as well as ON and OFF buttons, and I will still have my doubts. I am not sure that without also having TEST and RESET button labels it will qualify as a GFCI. Or can those button functions be unmarked as long as the instructions tell you which is which?
I dunno again, but you have me sold; Dead Front GFCI for GFCI protection only.

That is all I have ever used them for anyway, but I am pretty sure I have seen them labelled ON, OFF.
 

kwired

Electron manager
Location
NE Nebraska
Simple enough for me:
422.30 says that whatever is used as the disconnecting means must be chosen from those listed in the rest of Section III. That will be through 422.35.

Can you find a GFCI (DF or other) in that list?
I did not look at the list, but would hope a GFCI circuit breaker would qualify as a disconnecting means.
 
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