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need UL for new patent grounding electrode- technology is not 8 ft long (standards)

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    #46
    Originally posted by don_resqcapt19 View Post
    I don't see how anything that UL or any other listing agency can "get around" a legally adopted code rule. 90.7 is clearly talking about the factory installed parts of the listed equipment and does not permit a listing to change or "get around" a code rule as far as the non-factory installed wiring for the listed product.
    My point is that the 'internal factory wiring' of UL Listed items are not required to meet the same NEC requirements as those of similar field wired items.
    If you decide to assemble your own industrial control panel are your internal conductors and protective devices subject to the NEC branch circuit requirements? If you purchase a UL 508A panel are its internal conductors and protective devices subject to the NEC branch circuit requirements?

    UL508A has provisions for 'modifying the available short circuit current within a portion of a circuit in the panel due to current limiting devices' (i.e. a Listed circuit breaker which is marked "current limiting"), while the NEC generally requires the use of tested 'series combinations' of devices.
    Just because you can, doesn't mean you should.

    Comment


      #47
      UL is not the only NRTL. NEC generally only says "listed" meaning by any NRTL. I seem to remember a couple instances where someone on this forum specifically mentions UL.

      UL also tests more than just electrical equipment. They can and will test almost anything imaginable. When something is listed all that means is it meets the standards set for that particular item. I have heard cases where place wants to use something and someone informs them - it must be UL listed. When I hear about that story my first question is "listed for what?" Just listed means nothing if you are not using it according to the listing, yet people see the UL logo on something and say "it is UL listed - it should be safe". SAFE FOR WHAT?

      Something like the ground rod in this discussion would have relatively simple standards to meet, unless you are wanting new listing for a new application then new standards would have to be established for that application. In the case of the ground rod in this discussion the idea is to test that the new design can dissipate same amount of energy as other devices that meet current standards.

      I know of other cases where an item was more complex and when submitted for testing the party submitting only requests certain tests be done. This may not mean the item is bad or they are covering something up, it is simply puting limits on what it is listed for. If you don't ask them to test how well it stands up to rain then you likely do not get a rainproof listing even though it may appear that it would stand up pretty well to rain.
      I live for today, I'm just a day behind.

      Comment


        #48
        Originally posted by kwired View Post
        I know of other cases where an item was more complex and when submitted for testing the party submitting only requests certain tests be done. This may not mean the item is bad or they are covering something up, it is simply puting limits on what it is listed for.
        Many, if not most, 'industrial' HMI touchscreens are UL Listed as office technology equipment, yet they are ubiquitous in environments that would require a Type 12 enclosure.
        Just because you can, doesn't mean you should.

        Comment


          #49
          We're getting into the twilight zone, here, 'parsing' UL, debatining the meaning of 'is.' It's beginning to sound like a Clinton family reunion- and we're way off track.

          The point is that the OP believes he has a good grounding method, even though the NEC does not currently allow it. He believes his method is so unique that it has a patent. He also believes that UL acceptance is all he needs for his device to meet NEC requirements.

          I explained that he needs to have the code changed before UL will list his device. It should have been evident that I meant 'listed for use as a grounding electrode,' as opposed to, say, listed for use as a paperweight. Misrepresentation of a listing or misues of something are separate topics, and not relevant to this discussion.

          I gave examples of how others have persuaded the various code panels to change the code to allow for their products. I showed how the code change came before the UL evaluation.

          As for a UL listing 'trumping' the NEC, were that true such a listing would overrule any law. Apart from the political aspect (who elected UL to play king?), such a position would delight the makers of Romex, who would welcome the opportunity to sell their products in Chicago. If a listing made something acceptable no matter the law, there would be no such thing as 'local ammendments.' Thus, this position is illogical.

          Comment


            #50
            Originally posted by renosteinke View Post
            We're getting into the twilight zone, here, 'parsing' UL, debatining the meaning of 'is.' It's beginning to sound like a Clinton family reunion- and we're way off track.

            The point is that the OP believes he has a good grounding method, even though the NEC does not currently allow it. He believes his method is so unique that it has a patent. He also believes that UL acceptance is all he needs for his device to meet NEC requirements.

            I explained that he needs to have the code changed before UL will list his device. It should have been evident that I meant 'listed for use as a grounding electrode,' as opposed to, say, listed for use as a paperweight. Misrepresentation of a listing or misues of something are separate topics, and not relevant to this discussion.

            I gave examples of how others have persuaded the various code panels to change the code to allow for their products. I showed how the code change came before the UL evaluation.

            As for a UL listing 'trumping' the NEC, were that true such a listing would overrule any law. Apart from the political aspect (who elected UL to play king?), such a position would delight the makers of Romex, who would welcome the opportunity to sell their products in Chicago. If a listing made something acceptable no matter the law, there would be no such thing as 'local ammendments.' Thus, this position is illogical.
            Given that in this particular case the code seems to allow for other types of electrodes as long as they are listed, i don't see much of an issue if UL chose to list his device as a GE. It would not be trumping the NEC, but actually abiding by it.

            I am not real sure just what benefit there would be to such a device. "Better" grounding means is not exactly something that is high on the list of most people, given that what exists is far more than adequate.
            Bob

            Comment


              #51
              Originally posted by renosteinke View Post
              As for a UL listing 'trumping' the NEC, were that true such a listing would overrule any law.
              I don't believe that position was fully opined.

              90.7, 110.2, and 110.3 clearly say that, only with the permission of the AHJ, listed or labeled equipment may be installed without additional inspection, except to check for 'field modifications'. The definitions of listed and labeled refer to standards or specific performance/installation.
              Just because you can, doesn't mean you should.

              Comment


                #52
                Originally posted by renosteinke View Post
                ...The point is that the OP believes he has a good grounding method, even though the NEC does not currently allow it. He believes his method is so unique that it has a patent. He also believes that UL acceptance is all he needs for his device to meet NEC requirements. ...
                The OP is correct. If he gets his product listed as a grounding electrode, he is good to go and users of that listed grounding electrode would be in compliance with the code rule.
                The change to permit the use of "other listed electrodes" was made with products like this in mind.
                Don, Illinois
                (All code citations are 2017 unless otherwise noted)

                Comment


                  #53
                  Originally posted by petersonra View Post
                  Given that in this particular case the code seems to allow for other types of electrodes as long as they are listed, i don't see much of an issue if UL chose to list his device as a GE. It would not be trumping the NEC, but actually abiding by it.

                  I am not real sure just what benefit there would be to such a device. "Better" grounding means is not exactly something that is high on the list of most people, given that what exists is far more than adequate.
                  I'm inclined to agree with both points. According to the OP's second post, Intertek (still uses the ETL mark) has already declined to certify the product apparently for lack of an appropriate standard. For all practical puproses UL is the "Standards King" for this product line and getting them to develop a product standard for a currenly non-existent market is unlikely. CMP5 will only refer to 250.52(A)(6) and your Catch 22 will be in place.

                  Sadly, there is no significant need for a better grounding electrode for general safety purposes; "conventional" electrodes are adequate and bonding is far more important anyway.
                  "Bob"
                  Robert B. Alexander, P.E.
                  Answers based on 2017 NEC unless otherwise noted.

                  Comment


                    #54
                    Yea, I guess I have to conced the point.

                    250.52(A)(6) simply states that "other listed grounding electrodes shall be permitted."

                    IMO, that's really bad code. I'd love to know what they were thinking about when they wrote that line; is it 'code words' for some existing, special-application product? I don't know.

                    It does leave UL, and everyone else, completely in the dark as to what might be an acceptable electrode. It's rather hard to have a test if you don't have a goal to meet.

                    It would be worthwhile forthe OP - since he has a product to submit for evaluation - to write UL and ask the direct question:

                    "What are your criteria for evaluating a grounding electrode as permitted by 250.52(A)(6)?" That should at least get him a person to contact- and, likely, a list of various UL standards to consult.

                    Comment


                      #55
                      Originally posted by renosteinke View Post

                      It does leave UL, and everyone else, completely in the dark as to what might be an acceptable electrode. It's rather hard to have a test if you don't have a goal to meet.

                      Wondering what a 'listed electrode' may be and what standards it would be listed to, I found this:

                      UL & cUL Listed to UL467 and CSA C22.2 No.41 respectively
                      http://www.erico.com/products/ChemRod.asp

                      Here are is the table of contents of UL 467

                      http://ulstandardsinfonet.ul.com/toc...=s&fn=0467.toc

                      'Chemical electrodes' are not discussed in the NEC, therefore a listing would be required to use them.

                      So, the truth is that UL will, and has, listed grounding electrodes that do not fit into the standard categories. If UL will not list the device, it's not because they don't have standards, or don't list electrodes. More likely the device does not meet the standards or was not submitted properly.
                      Cheers and Stay Safe,

                      Marky the Sparky

                      Comment


                        #56
                        Originally posted by renosteinke View Post
                        ...250.52(A)(6) simply states that "other listed grounding electrodes shall be permitted."

                        IMO, that's really bad code. I'd love to know what they were thinking about when they wrote that line; is it 'code words' for some existing, special-application product? I don't know.
                        ...
                        The purpose was so that the list of permitted electrodes does not have to be changed everytime a new type of device is listed as a grounding electrode. As I recall the proposal was to specifically permit listed "chemical" electrodes and the CMP changed the wording to "other listed electrodes".
                        Don, Illinois
                        (All code citations are 2017 unless otherwise noted)

                        Comment


                          #57
                          Originally posted by K8MHZ View Post
                          Wondering what a 'listed electrode' may be and what standards it would be listed to, I found this:



                          http://www.erico.com/products/ChemRod.asp

                          Here are is the table of contents of UL 467

                          http://ulstandardsinfonet.ul.com/toc...=s&fn=0467.toc

                          'Chemical electrodes' are not discussed in the NEC, therefore a listing would be required to use them.

                          So, the truth is that UL will, and has, listed grounding electrodes that do not fit into the standard categories. If UL will not list the device, it's not because they don't have standards, or don't list electrodes. More likely the device does not meet the standards or was not submitted properly.
                          I note from the Erico link the minimum length is 10'. "Chemical" may have had nothing to do with it, UL may have just evaluated it as a conventional rod.
                          "Bob"
                          Robert B. Alexander, P.E.
                          Answers based on 2017 NEC unless otherwise noted.

                          Comment


                            #58
                            Originally posted by renosteinke View Post
                            Yea, I guess I have to conced the point.

                            250.52(A)(6) simply states that "other listed grounding electrodes shall be permitted."

                            IMO, that's really bad code. I'd love to know what they were thinking about when they wrote that line; is it 'code words' for some existing, special-application product? I don't know.

                            It does leave UL, and everyone else, completely in the dark as to what might be an acceptable electrode. It's rather hard to have a test if you don't have a goal to meet.

                            It would be worthwhile forthe OP - since he has a product to submit for evaluation - to write UL and ask the direct question:

                            "What are your criteria for evaluating a grounding electrode as permitted by 250.52(A)(6)?" That should at least get him a person to contact- and, likely, a list of various UL standards to consult.
                            What about 250.52(A)(5)(b) that specifically addresses rods?

                            (b) Rod-type grounding electrodes of stainless steel and copper or zinc coated steel shall be at least 15.87 mm (5/8 in.) in diameter, unless listed.
                            Kind of the same thing. telling you you must meet certain criteria, but if you have something listed then it is acceptable. Listed rods are usually 1/2 inch diameter but an unlisted 1/2 inch rod is a code violation. Someone had to come up with the first 1/2 inch rod and whatever it takes to make it acceptable and get it listed.

                            OP's product is possibly no different. If what he has is a rod then it would have been already covered by 250.52(A)(5) once if it gets listed. If it is something other than a rod and does not meet the other made electrode requirements then it will now be covered by 250.52(A)(6) after it gets a listing. Future code editions could end up being changed to specifically mention his product but until then, if it is listed it can be used.

                            edit to add: Do we need something better than grounding electrodes we currently use? Doesn't that really depend on what somebody may discover someday? What we currently use is sufficient for what we know. Someday somebody may find it is not. What is wrong with letting someone try to find out? If they can't prove something they came up with is any better then you can discriminate against it, or maybe say "it gets the job done, but is no better than what we already have and is more / less expensive than this or that method.
                            Last edited by kwired; 06-13-12, 08:12 PM.
                            I live for today, I'm just a day behind.

                            Comment


                              #59
                              I was hoping to avoid getting into the discussion of "what's wrong with whatwe already have?"

                              First off, there's quite a bit of room for discussion as to just what a grounding electrode is supposed to accomplish. That would seem to be a pretty basic question to answer, before we try to say whenther a method is adequate. (Would the little 3/8" x 36" rods used by the data guys suffice?)

                              Do they accomplish anything? The experience of Norway, which does not use grounding electrodes, suggests that our concerns on this matter are excessive. Even here we have documented many perfectly functioning installations where the grounding electrode hasn't been effective -for whatever reason- for decades.

                              Those, I submit, are questions for another thread.

                              Next, it's not really the job of the code panels, the AHJ, or anyone but the consumer ("the market") to decide. Not everyone has the same circumstances, and the means to put the rod in the ground will vary by locale. Driven? What aout the little drill tips some sell, that claim to let you simply spin the rod in?

                              The 'if listed' provisions might seem nice, but we already have data that suggests that listing assumptions are already wrong. That is, we are allowed to list skinny rods if they're made of some 'non-corroding' material like stainless steel .... yet, our research shows that stainless steel corrodes away FASTER than plain, or copper-wrapped, steel.

                              The NEC equates plate elctrodes with ground rods, while field experience shows extremely fast corrosion of plate electrodes. You might as well not bother.

                              Comment


                                #60
                                Originally posted by renosteinke View Post
                                I was hoping to avoid getting into the discussion of "what's wrong with whatwe already have?"

                                First off, there's quite a bit of room for discussion as to just what a grounding electrode is supposed to accomplish. That would seem to be a pretty basic question to answer, before we try to say whenther a method is adequate. (Would the little 3/8" x 36" rods used by the data guys suffice?)

                                Do they accomplish anything? The experience of Norway, which does not use grounding electrodes, suggests that our concerns on this matter are excessive. Even here we have documented many perfectly functioning installations where the grounding electrode hasn't been effective -for whatever reason- for decades.

                                Those, I submit, are questions for another thread.

                                Next, it's not really the job of the code panels, the AHJ, or anyone but the consumer ("the market") to decide. Not everyone has the same circumstances, and the means to put the rod in the ground will vary by locale. Driven? What aout the little drill tips some sell, that claim to let you simply spin the rod in?

                                The 'if listed' provisions might seem nice, but we already have data that suggests that listing assumptions are already wrong. That is, we are allowed to list skinny rods if they're made of some 'non-corroding' material like stainless steel .... yet, our research shows that stainless steel corrodes away FASTER than plain, or copper-wrapped, steel.

                                The NEC equates plate elctrodes with ground rods, while field experience shows extremely fast corrosion of plate electrodes. You might as well not bother.
                                NEC is only asking for the rod to have a resistance of 25 ohms or less. If it is higher than that they say drive one more, but if it still is not 25 or less so what you are likely to not acquire the target value. There are some cases where specifications can go beyond that and specify a particular resistance and will want to continue to add electrodes until the target is reached. That is a case of necessity (to someone) and not just meeting recognized standards.
                                I live for today, I'm just a day behind.

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