Replacing 2 wire receptacles with AFCIs

[GoldDigger]

And I wonder how long it will be before someone introduces a dual function receptacle device? Or will there just not be enough room in a single gang box for one?

 

[Smart $]

And I wonder how long it will be before someone introduces a dual function receptacle device? Or will there just not be enough room in a single gang box for one?

If they can fit dual function into a single breaker space, I fail to see why they can't put the electronics into a duplex which fits in a single gang box. How many years was it between GFCI breaker and receptacle???

 

[jxofaltrds]

Third choice...

Dual Function breaker and standard receptacle.

Main reason I did not mention your option is because I assumed an old panel where that may not be possible.

Again proves that the answers we give are on limited facts/knowledge.

 

[tom baker]

Perhaps a code proposal is in order.

 

[Smart $]

Perhaps a code proposal is in order.

Have at it. Got about two months left... to get it in for 2017.

 

[codeunderstanding]

Since we are directed to "elsewhere in the NEC" I believe that includes the Exception to 2014 210.12(B). If the conductors are at all short (and in many cases in the older installs they are) the existing conductors invite the installation of pigtails. Adding conductor less that six foot in length invokes the exception to 210.12(B), and no AFCI protection is needed whether the old two wire nongrounding type receptacle is replaced with a GFCI receptacle, or a similar new nongrounding type receptacle.

Have you been using this exception on device replacements? I was at a code class and asked the instructor about it. He said it is fine up to article 210.12B. Then in 406.4D4 it says you need them. That is his interpretation. Those to articles seem to contradict them selves.

 

[al hildenbrand]

Code understanding, this is the heart of the issue, IMHO. 406.4D4 doesn't, on it's own, require AFCI, no way, no how. 406.4D4 ONLY refers us to " elsewhere in the NEC."

Therefore all of 210.12 applies as it fits the situation, including on replacements.
Tapatalk

 

[jxofaltrds]

Code understanding, this is the heart of the issue, IMHO. 406.4D4 doesn't, on it's own, require AFCI, no way, no how. 406.4D4 ONLY refers us to " elsewhere in the NEC."

Therefore all of 210.12 applies as it fits the situation, including on replacements.
Tapatalk

Bingo!

 

[fmtjfw]

From the 2011 NEC 406.12:

You are misreading the exception. It refers to 2 prong receptacles without a grounding hole, not a 3 prong receptacle with a grounding hole but not connected to a EGC. All AFCI and GFCI receptacles I have ever seen include a grounding hole and thus do not fall under the no-TR exception.

 

[jxofaltrds]

 

[al hildenbrand]

You are misreading the exception. It refers to 2 prong receptacles without a grounding hole, not a 3 prong receptacle with a grounding hole but not connected to a EGC. All AFCI and GFCI receptacles I have ever seen include a grounding hole and thus do not fall under the no-TR exception.

Respectfully, you are mis-reading me. I understand the exception to the TR requirement that is offered for non-grounding type receptacles. My point, my meaning, is as stated in Post #16 .

 

[al hildenbrand]

All AFCI and GFCI receptacles I have ever seen include a grounding hole and thus do not fall under the no-TR exception.

Set the idea of TR that I introduced to the side. Just look at 406.4(D)(4). 406.4(D)(4) does not, all by itself, require AFCI, it only tells us to go "elsewhere in this Code".

"Elsewhere in this Code" for AFCI requirements is 210.12.

The Exception to 210.12(B), new in 2014, ONLY says that the "conductors" need to be extended less that six feet. That means if I add <6' conductors in replacing a panel, or in replacing a receptacle device, the adding of <6' conductors is the only condition needed for AFCI to NOT be required.

TR, non-grounding type, grounding type, GFCI, OBC AFCI, grounded wiring method, ungrounded wiring method . . . all are covered by the 2014 NEC 210.12(B) Exception when less than six feet of conductor are added.

Today, IMHO, if I replace a bad duplex 15 or 20 Amp 125 Volt receptacle device, grounding or non-grounding type, and I choose to ADD 6 inch pigtails on the existing conductors, then 2014 NEC 210.12(B) Exception applies, and "no AFCI is required."

 

[fmtjfw]

Respectfully, you are mis-reading me. I understand the exception to the TR requirement that is offered for non-grounding type receptacles. My point, my meaning, is as stated in Post #16 .

Sorry, I missed that.

 

[fmtjfw]

Today, IMHO, if I replace a bad duplex 15 or 20 Amp 125 Volt receptacle device, grounding or non-grounding type, and I choose to ADD 6 inch pigtails on the existing conductors, then 2014 NEC 210.12(B) Exception applies, and "no AFCI is required."

However I totally disagree with the idea that adding conductor within a box triggers 210.12(B) Exception. The exception allowing an extension of 6 feet of conductors makes it plain to me that the intent is that the extension is not in the box. You can code lawyer your interpretation, but it stretches the bounds of credulity. I hope you assertion is a rhetorical device and nothing that you would actually implement or allow.

I definitely would not want to be testifying in court, after the fire, that I decided not to install the Code-required AFCI based on that reasoning about the exception.

 

[iwire]

However I totally disagree with the idea that adding conductor within a box triggers 210.12(B) Exception. The exception allowing an extension of 6 feet of conductors makes it plain to me that the intent is that the extension is not in the box. You can code lawyer your interpretation, but it stretches the bounds of credulity. I hope you assertion is a rhetorical device and nothing that you would actually implement or allow.

I definitely would not want to be testifying in court, after the fire, that I decided not to install the Code-required AFCI based on that reasoning about the exception.

So you feel a six inch extension is a dangerous application of the exception but five foot extension is a safe and correct application of the exception.

That makes no sense whatsoever.

 

[al hildenbrand]

However I totally disagree with the idea that adding conductor within a box triggers 210.12(B) Exception.

I am not the only one who can read this in the 2014 National Electrical Code as printed. Do you have a copy of the International Association of Electrical Inspectors (IAEI) Analysis of Changes NEC - 2014? Please refer to the very last sentence at the bottom of page 64:

Analysis of Changes NEC - 2014
210.12(B) Exception
"This will clarify that extending branch circuit conductors within an enclosure for the purposes of replacing a device or utilization equipment or for extending a branch circuit to a panelboard being replaced or upgraded does not require an AFCI protective device to be installed."

I definitely would not want to be testifying in court, after the fire, that I decided not to install the Code-required AFCI based on that reasoning about the exception.

I read and understand that you, in your opinion, disagree with my point of what the 2014 NEC 210.12(B) Exception says. Please show me, with the language of the 2014 Code, how AFCI is "Code-required" when, after extending the branch circuit conductors less than six feet, only the replacing of a receptacle outlet device occurs (no new outlet added).

 

[fmtjfw]

I currently do not have a copy of Analysis of Changes NEC - 2014. I will be picking one up on 12-Nov-2014. I may have taken a shortened version of 2014 Analysis of Changes class when it first came out as part of a three-day symposium. On the 12th I will take the full day course and receive the book as well. I will discuss your interpretation with the CMP member(s) who will be the instructors.

As you know, information, other than direct quotes from the NEC, in the ROP, ROC, Handbook, and Analysis of Changes are commentary, not enforceable nor necessarily definitive.

1. The purpose for AFCI protection is to reduce electrical fires caused by arcing. Unfortunately the incidence of electrical fires is higher in older structures than in newly constructed ones. The focus of AFCI protection is on protecting people rather than property.

"90.1 Purpose.
(A) Practical Safeguarding. The purpose of this Code is the practical safeguarding of persons and property from hazards arising from the use of electricity."[NEC]

The NEC does not require adding AFCI protection of circuits without a triggering event. It uses 210.12(B) maintenance of a circuit or 406.4(D) replacement of receptacles to trigger several safety upgrades (grounding, GFCI, AFCI and TR).

2. It is claimed that the US Constitution prevents a Code designed to become law by adoption to enforce an ex post facto requirement (making some existing thing that was legal in the past now illegal). Actually the US Supreme Court has held otherwise in some instances.

"Article I ?9 clause 3 No Bill of Attainder or ex post facto Law shall be passed."
"Article I ?10 clause 1 No State shall ... pass any Bill of Attainder, ex post facto Law ..."[US Constitution]

See http://en.wikipedia.org/wiki/Ex_post_facto_law#United_States

3. Here we are dealing with interaction of provisions in two NEC articles 210 Branch Circuits and 406 -- Receptacles, Cord Connectors, and Attachment Plugs (Caps). Both articles contain requirements for grounding, GFCI, AFCI, and TR. The interaction of 210.12(B) Exception and 406.4(D)(4) is the question at hand.

"210.12(B) Arc-Fault Circuit Interrupter Protection. Branch Circuit Extensions or Modifications -- Dwelling Units.
....
In any of the areas specified in 210.12(A), where branch-circuit wiring is modified, replaced, or extended, the branch circuit shall be protected by one of the following:
(1) A listed combination-type AFCI located at the origin of the branch circuit
(2) A listed outlet branch-circuit type AFCI located at the first receptacle outlet of the existing branch circuit

Exception: AFCI protection shall not be required where the extension of the existing conductors is not more than 1.8 m (6 ft) and does not include any additional outlets or devices."[NEC]

"406.4(D) General Installation Requirements.
....
(D) Replacements. Replacement of receptacles shall comply with 406.4(D)(1) through (D)(6), as applicable. Arc-fault circuit-interrupter type and ground-fault circuit-interrupter type receptacles shall be installed in a readily accessible location.
....
(4) Arc-Fault Circuit-Interrupter Protection. Where a receptacle outlet is supplied by a branch circuit that requires arc-fault circuit-interrupter protection as specified elsewhere in this Code, a replacement receptacle at this outlet shall be one of the following:
(1) A listed outlet branch-circuit type arc-fault circuit-interrupter receptacle
(2) A receptacle protected by a listed outlet branch-circuit type arc-fault circuit-interrupter type receptacle
(3) A receptacle protected by a listed combination type arc-fault circuit-interrupter type circuit breaker

This requirement becomes effective January 1, 2014."[NEC]

4. The NEC Committee Report on Proposals 2013 contains the following concerning the adoption of the 210.12(B) Exception:

"2-115 Log #536 .... 'Exception: AFCI protection shall not be required where the extension of the existing conductors is not more than 1.8 m (6 ft) and does not include any additional outlets or devices.' ....
Explanation of Negative:
KING, D: This Proposal should be rejected. It is the intent of Section 210.12(B) to provide AFCI protection where circuits that are covered by 210.12(A) are 'modified'. The submitter has not provided any substantiation to allow for an exception for AFCI Protection in the branch circuit modification described in his substantiation. Accepting the proposed exception would greatly dimish the level of safety currently provided by the requirements of 210.12(B).
Explanation of Abstention:
ORLOWSKI, S: See my Explanation of Vote on Proposal 2-92. [National Association of Home Builders -- no support of anything having to do with AFCIs]
Comment in Affirmative:
HILBERT, M: Continue to accept in principle. The issues noted in the substantiation are often topics of discussion at IAEI meetings as well as other educational meetings and do need clarification.
The proposed language as revised by the panel's accept in principal action will go a long way in promoting uniform interpretations. It will clarify that extending branch circuit conductors within an enclosure for the purposes of replacing a device or utilization equipment or for extending a branch circuit to a panelboard being replaced or upgraded does not require an AFCI protective device to be installed.
Six feet was chosen for branch circuit extensions as it should provide a sufficient length for most applications where an existing panel is being relocated out of a clothes closet or to comply with readily accessible requirements, etc."[ROP]

5. I assert that the following is an incorrect reading of the interaction between 210.12(B) Exception and 406.4(D)(4):

"Mike, that's a non-issue with new nongrounding type 15 and 20 A 125 V receptacles. The NEC says clearly they don't have to be Tamper-Resistant.

Read 406.12 Exception (4).

The simplest solution to this 2014 NEC 406.4(D)(4) conundrum is to pigtail the conductors between the branch circuit and the replacement device, IMHO, thereby invoking 2014 NEC 210.12(B) Exception."[Mike Holt's Forum -- NEC -- Replacing 2 wire receptacles with AFCIs -- #11 by al hildebrand]

As I understand it, this asserts that if you extend the conductors (less than 6 feet) you avoid the requirement of 406.4(D)(4).

The event at hand is replacing a 2-wire receptacle, probably because it is broken or failing, or because the owner wants to plug in 3-prong plugs. This triggers the requirements in 406.4(D). Thus the trigger is the REPLACEMENT, which requires an AFCI because of location. Because a ground was apparently not available, replacement with a 3-wire device also requires GFCI protection.

The event is not triggering the extension of conductors as governed by 210.12(B) so it and its exception do not apply.

The requirements of 406.4(D) still apply, even if the installer chooses to extend the conductors.

The intent of the exception to 210.12(B) is not not evade the requirement of 406.4(D)(4), but rather to provide relief from the 210.12(B) requirement for AFCIs when short conductor extensions occur.

Intentionally adding a conductor extension in hopes of triggering the exception to defeat the AFCI requirement is contrary to the intent of the NEC as stated in 90.1(A).

new to 2014

 

[GoldDigger]

As I read the exception, what is stated (although ambiguously) is that as long as you do not extend it more than six feet, including not extending it at all, the exception applies.
That is clearer with the wording "not extended more than" than with the wording "extended not more than". But if the meaning were that the exception only applied when some extension is done, there are many clearer ways to state that.

 

[GoldDigger]

When one code section says "you must do A, no exceptions" and another section says "well, in case B you are not required to do A", then we have a job for the TCC.

 

[al hildenbrand]

The NEC Committee Report on Proposals 2013 contains the following concerning the adoption of the 210.12(B) Exception:

"2-115 Log #536 .... 'Exception: AFCI protection shall not be required where the extension of the existing conductors is not more than 1.8 m (6 ft) and does not include any additional outlets or devices.' ....
. . .
Comment in Affirmative:
HILBERT, M: Continue to accept in principle. The issues noted in the substantiation are often topics of discussion at IAEI meetings as well as other educational meetings and do need clarification.
The proposed language as revised by the panel's accept in principal action will go a long way in promoting uniform interpretations. It will clarify that extending branch circuit conductors within an enclosure for the purposes of replacing a device or utilization equipment or for extending a branch circuit to a panelboard being replaced or upgraded does not require an AFCI protective device to be installed.
Six feet was chosen for branch circuit extensions as it should provide a sufficient length for most applications where an existing panel is being relocated out of a clothes closet or to comply with readily accessible requirements, etc."[ROP]

Well, isn't that interesting. The authors of the Analysis of Changes NEC - 2014 are "QUOTING" the CMP panel member M. Hilbert word for word.

So it seems that even a member of the CMP is saying what I am saying.