- Location
- Illinois
- Occupation
- retired electrician
I see nothing in 625 that specifically changes the requirement in 210.8(F). The language would have to be more like the language in the PI that is posted in post #58 to override 210.8(F).
EVSE and GFCI PROTECTION
- Thread starter Rjryan
- Start date
brycenesbitt
Senior Member
- Location
- United States
Agreed. But the intent of the PI is super clear. I'm trying to reach out to the submitter of that PI now...
And now that J3400 is reality it's probably also best to consider 277V handling for the same set of issues.
- Location
- Illinois
- Occupation
- retired electrician
It doesn't matter what the submitter has to say about the PI...it only matters what the CMP members have to say about it. If it received at least 50% support at the Jan first draft meeting, it will be balloted and must receive at least 2/3s vote to become a first revision. The first draft report is scheduled to be published on July 10th.
If it received less than 50% support at the meeting, it will not be balloted, but could be brought back for the second draft meeting by someone making a Public Comment on that rejected input .
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mtnelect
HVAC & Electrical Contractor
- Location
- Southern California
- Occupation
- Contractor, C10 & C20 - Semi Retired
NEC is working on that issue now, see attachment.
brycenesbitt
Senior Member
- Location
- United States
From Kevin Cheong's PI
Per our comments in our conference presentation, and its handouts, and in support of TIA Log #1748 and #1749, there is no need for GFCI protection to EV power transfer system equipment as it will already include personnel protection system equipment per UL 2231-1 and 2231-2 which includes the Dalziel Frequency Factor to improve compatibility with such non-linear equipment and reduce nuisance tripping, without compromising safety (muscular tetanization / let-go). There have been no known / confirmed shocks from EV charging, even during firefighting operations, so UL 2231 has been shown to be safe. The UL study referenced in TIA Log #1748 and #1749 acknowledge the current incompatibility of GFCI Class A with UL 101, or by inference UL 2231, despite such equipment being shown to be safe, not only theoretically, but in actual use.
- Location
- Illinois
- Occupation
- retired electrician
Standards Council Decision (Final): D#23-16
Standards Council Agenda Item: SC#23-11-7-d
Date of Decision: 30 November 2023
TIA No. 1748 to NFPA 70®, National Electrical Code®, 2023 Edition
....
The Council has reviewed the entire record concerning this matter and has considered all the arguments put
forth in this appeal. In the view of the Council, this appeal does not present any clear and substantial basis
upon which to overturn the results yielded by the NFPA standards development process. Accordingly, the
Council has voted to deny the appeal. The effect of this action is that NFPA 70, National Electrical Code
will not include the text of TIA No. 1748
- Location
- Illinois
- Occupation
- retired electrician
SC#23-11-8-d Page 1 of 2 D#23-17
Standards Council Decision (Final): D#23-17
Standards Council Agenda Item: SC#23-11-8-d
Date of Decision: 30 November 2023
TIA No. 1749 to NFPA 70®, National Electrical Code®, 2023 Edition
...
The Council has reviewed the entire record concerning this matter and has considered all the arguments put
forth in this appeal. In the view of the Council, this appeal does not present any clear and substantial basis
upon which to overturn the results yielded by the NFPA standards development process. Accordingly, the
Council has voted to deny the appeal. The effect of this action is that NFPA 70, National Electrical Code
will not include the text of TIA No. 1749.
Ahh so they are re-inventing the wheel and it looks like a square wheel so the CMP is not going to buy it.
Whats the difference between a UL 2231 device and a RCD?
I know there are different types of RCD so perhaps I should ask what type of RCD is similar or equivalent to a UL 2231 protection device?
Also why is this just for car chargers?
What about all the other 240V equipment they want to put on GFCI's?
brycenesbitt
Senior Member
- Location
- United States
The argument from Greg Woyczynski, Association of Home Appliance Manufacturers (AHAM) is that such GFCI are not necessary, not cost effective, at odds with energy conserving circuits, and should be exempt as well.
See also the related 277 Volt issues regarding J3400 and the transition from J1772 to J3400 in 89 FR 16081.
LOL What else would they say? I am sure pool equipment manufacturers back in 1968 or whenever GFCI started would say the same thing.
Its pretty standard world wide to have some leakage current detection on all residential outlets.
What I bet Greg and I would agree on is all the Great North American Standards (UL ANSI) were (and still are) some of the first and best standards in the world, but this aint 1924 and North America is not a 'the' market leader anymore.
In 2024 when we (North America) come up with our own new standards (with a 2028 due date) for just north America we are essentially paying a 'tax' to UL and manufacturers to re-invent the wheel, and higher manufacturing costs just mean more materials costs, and more supply chain shortages, just look at the PV industry as an example.
If RCD is safe for ground fault protection across the pond for all the 240V equipment in the UK / EU / Australia it will work here, Eaton alredy makes them:
brycenesbitt
Senior Member
- Location
- United States
Some older background but good analysis on USA electrocutions. There's a remarkable amount of people killing themselves by DIY'ing large appliances while power is on.... which leads to potential solutions like checking if deadman switches on appliance covers are actually working to reduce such deaths.
It's a shame that CPSC investigators are relying on death certificates with no followup questions like that. Often the brand and age of the device is lost by the time the regulators see it, and thus the NEC code comittees.
It's a shame that CPSC investigators are relying on death certificates with no followup questions like that. Often the brand and age of the device is lost by the time the regulators see it, and thus the NEC code comittees.
- Location
- San Francisco Bay Area, CA, USA
- Occupation
- Electrical Engineer
Most do.
brycenesbitt
Senior Member
- Location
- United States
They all do. A core part of the EVSE specification is a level of ground fault protection. The issue is the threshold that's deemed good internationally vs. in the USA.
That said it's possible to make a crappy EVSE that's not listed, pretend it's listed, and sell it on Amazon. Frankly that's the bigger hazard compared to this code centric ideal world discussion here. Sigh.
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brycenesbitt
Senior Member
- Location
- United States
Here is a spreadsheet of electrical incidents including electrocutions reported in 2023.
Reading through this dishwasher and HVAC DIY repair appears to be big themes, which brings up the question of how what solutions to that problem are possible, given the Darwin award limitations.
As for EVSE incidents, not so much
Number of incident found 0 User Selected Criteria:
- Incident Received Year: 2023 , 2022 , 2021 , 2020 , 2019 , 2018 , 2017 , 2016 , 2015 , 2014 , 2013 , 2012 , 2011
- Product Hazard: Electrical, Electrical - Electric shock/Electrocution, Electrical - Water leaking
- Severity: Death , Emergency Department Treatment Received
- Incident Description Contains: EVSE
Though there's never really enough detail to determine what went wrong. For example this brings up nothing but additional questions, most notably was he messing with the wires? DIY? GFCI on the circuit or breaker? Modifications to the product? We just don't know.
20230905-829E7-4363821
Death Certificates TX Incident year 2021
Decedent: 69 yom. incident description: decedent was installing a microwave when electrocuted. incident location: residence. cod: electrocution. Additional icd codes: T754. autopsy? yes. manner of death: accident.
20230905-D6CC6-4363840 Death Certificates TX 2021 decedent: 44 yom. incident description: made contact with ungrounded dryer chassis and adjacent metal gas line. incident location: residence. cod: electrocution. addtl icd codes: t754. autopsy? yes. manner of death: accident.
Reading through this dishwasher and HVAC DIY repair appears to be big themes, which brings up the question of how what solutions to that problem are possible, given the Darwin award limitations.
As for EVSE incidents, not so much
Number of incident found 0 User Selected Criteria:
- Incident Received Year: 2023 , 2022 , 2021 , 2020 , 2019 , 2018 , 2017 , 2016 , 2015 , 2014 , 2013 , 2012 , 2011
- Product Hazard: Electrical, Electrical - Electric shock/Electrocution, Electrical - Water leaking
- Severity: Death , Emergency Department Treatment Received
- Incident Description Contains: EVSE
Though there's never really enough detail to determine what went wrong. For example this brings up nothing but additional questions, most notably was he messing with the wires? DIY? GFCI on the circuit or breaker? Modifications to the product? We just don't know.
20230905-829E7-4363821
Death Certificates TX Incident year 2021
Decedent: 69 yom. incident description: decedent was installing a microwave when electrocuted. incident location: residence. cod: electrocution. Additional icd codes: T754. autopsy? yes. manner of death: accident.
20230905-D6CC6-4363840 Death Certificates TX 2021 decedent: 44 yom. incident description: made contact with ungrounded dryer chassis and adjacent metal gas line. incident location: residence. cod: electrocution. addtl icd codes: t754. autopsy? yes. manner of death: accident.
A straight numbers comparison needs some context. Virtually every home has some kind of HVAC, probably 90% have dishwashers, but maybe 5% have EVSEs.
I do agree that EVSEs are incredibly safe given the nature of their design. It’s just difficult to quantify. Once DIYers start messing with EVSEs in any significant number, we may start to see incidents.
brycenesbitt
Senior Member
- Location
- United States
Found this, don't know what it means yet:
Some of the key changes for the new edition of UL 60335-2-40 include:
Changes in Article 210.8(F), Clause 13 of NFPA 70®, the National Electrical Code®, allow for alternative safety measures due to inoperability with code-required ground fault circuit interrupters (GFCIs). For motor-operated and combined, permanently connected, stationary, class I appliances, which are appliances accessible to the general public, leakage current is replaced with touch current as defined in IEC 60990.
Some of the key changes for the new edition of UL 60335-2-40 include:
Changes in Article 210.8(F), Clause 13 of NFPA 70®, the National Electrical Code®, allow for alternative safety measures due to inoperability with code-required ground fault circuit interrupters (GFCIs). For motor-operated and combined, permanently connected, stationary, class I appliances, which are appliances accessible to the general public, leakage current is replaced with touch current as defined in IEC 60990.
brycenesbitt
Senior Member
- Location
- United States
Absolutely needs to be scaled to exposure.
So far not finding any incidents in order to perform a scaling operation, and much less an EVSE incident that could have been prevented by an upstream GFCI. There might be one somewhere globally, or missed by the CSPC.
The DIY issue is big for EVSE because they are simple enough to install for a DIY'er, and there's an active modding community https://www.openevse.com/ What that community needs is to be taught about torque screwdrivers.
Let me make sure I got all this correct an EVSE is much like a motor controller/starter, it basically turns an outlet (at the end of a cord) on and off.
To sum up an EVSE its basically some type of contactor or solid state relay, controlled by a 2 wire signal buss, that turns on and off a specialty pendant receptacle outlet. It also outputs a 1 khz square wave to communicate the ampacity of the branch circuit to the vehicle?
A Car charger is a device mounted onboard an electric vehicle, senses the incoming voltage, and 1khz square wave, does the AC-DC conversion probably switch mode power supply / charger circuit regulated by the square wave from the EVSE as to not draw more than the branch circuit can offer.
I just cant imagine what about an EVSE would be prone to GFCI nuisance tripping. I can imagine how the charger in the car could be.
To sum up an EVSE its basically some type of contactor or solid state relay, controlled by a 2 wire signal buss, that turns on and off a specialty pendant receptacle outlet. It also outputs a 1 khz square wave to communicate the ampacity of the branch circuit to the vehicle?
A Car charger is a device mounted onboard an electric vehicle, senses the incoming voltage, and 1khz square wave, does the AC-DC conversion probably switch mode power supply / charger circuit regulated by the square wave from the EVSE as to not draw more than the branch circuit can offer.
I just cant imagine what about an EVSE would be prone to GFCI nuisance tripping. I can imagine how the charger in the car could be.
- Location
- Illinois
- Occupation
- retired electrician
There was a public input recommending the following new exception to 210.8(F), but we won't know the status of that until the Frist Draft Report is posted on July 10, 2024. No idea of what "clause 13 of NFPA 70" is intended to mean.
brycenesbitt
Senior Member
- Location
- United States
Correct. The issue is apparently high frequency noise from the AC to DC switching circuitry in the vehicle. The same issue with other modern variable speed DC motor and compressor circuits, thus the HVAC industry exemption in NEC 210.8. The issue appears less at lower currents, more at higher current (though who knows as the NEC exempts circuits past 50A or at 277V). Thus the false trip issue may change depending on what car is plugged in, the starting state of charge, and perhaps the temperature. An 8/12 amp travel cord likely won't have a problem.
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As you summed up the EVSE is a computer controlled relay featuring current sensing, the ability to signal a maximum amperage to the vehicle, and a circuit to ensure the ground is complete back to the panel. If the EVSE itself is to trigger the GFCI it's only going to be prior to energizing when it checks for ground continuity. Beyond that it's the connected vehicle charging electronica and could occur any time of day. The EVSE was designed to be the ground fault detector.
If the EVSE only triggered GFCI when it starts, that's less of a deal, as the driver is likely still nearby, rather than say sleeping. EVSE, unlike most dedicated GFCI automatically retry, and may have the capacity to notify the vehicle owner.