2023 NATIONAL ELECTRIC CODE - Section 210.8(F)

[mbednarik]

That substantiation was shot down by the standards council for lacking technical merit that installation had no EGC.

A wire type EGC requirement would have yielded the same protection IMO without the fight.

 

[don_resqcapt19]

That substantiation was shot down by the standards council for lacking technical merit that installation had no EGC.

If that was the case, the section would have not made it into the NEC. Nothing about the substantiation was ever shot down in the code process.
The only thing that is causing issues is the disconnect between the NEC and the product standards, as the product standards do not have leakage current limits for hardwired equipment. In addition there is an issue with the GFCI response to high frequency leakage current below 5 mA that is resulting from the use of VFDs and other types of power conversion equipment. There were proposals for the Standards Technical Panel for UL 943 to look at the high frequency issue, but they were shot down at ballot. There is work in progress to bring something back to that STP to address the issue.

 

[don_resqcapt19]

At the disconnect that is supposed to be there.

I don't agree...the outlet is at the load end of the branch circuit conductors, and the conductors between the disconnect and the equipment are branch circuit conductors. In my opinion, the outlet for this type of equipment is the terminal block in the equipment.
However, as long as we can agree that there is an outlet that supplies this equipment, it doesn't really make any difference where we say it is....the outlet can have its GFCI protection on the line side of the outlet/

 

[ActionDave]

I don't agree...the outlet is at the load end of the branch circuit conductors, and the conductors between the disconnect and the equipment are branch circuit conductors. In my opinion, the outlet for this type of equipment is the terminal block in the equipment.
However, as long as we can agree that there is an outlet that supplies this equipment, it doesn't really make any difference where we say it is....the outlet can have its GFCI protection on the line side of the outlet/

I was making a bit of a joke. I agree with you about the definition of an outlet. What I don't agree with is this rush to GFCI everything. I would be in favor of GFPE level protection on anything outside. Why do those in charge in the industry decide on the most extreme level of ground fault protection instead of something that would be workable and make things safer?

 

[don_resqcapt19]

I was making a bit of a joke. I agree with you about the definition of an outlet. What I don't agree with is this rush to GFCI everything. I would be in favor of GFPE level protection on anything outside. Why do those in charge in the industry decide on the most extreme level of ground fault protection instead of something that would be workable and make things safer?

Because our GFPE does not provide people protection as there is no trip time in the product standards. They could go to the Special Purpose GFCIs that show up in Article 680 for the 2023, that have a 20 mA trip, but those are all stand alone devices at this time...no breaker or receptacle type.

The 30mA RCDs used in Europe have a very short maximum trip time can can protect people. Not sure what that very short trip time would do with potential nusiance tripping.

 

[ActionDave]

I still see it as over the top. Unless there is something I don't understand we could have safer electrical installs right now. When you say there is no trip time in the standard what does that mean? That a 30mA ground fault can sit for an hour? A second and half? It's not like the outdoor A/C unit is doing double time as a baby crib or a front porch rocking chair. There is a difference between a piece of A/C equipment sitting outside that develops a fault and trips on a GFPE and circuit powering an outdoor receptacle that has a high likelihood of being used for a power tool held in someone's hands that needs GFCI.

Please understand that I am not being antagonistic with you, I am trying to see if there is something I am missing.

 

[don_resqcapt19]

I still see it as over the top. Unless there is something I don't understand we could have safer electrical installs right now. When you say there is no trip time in the standard what does that mean? That a 30mA ground fault can sit for an hour? A second and half? It's not like the outdoor A/C unit is doing double time as a baby crib or a front porch rocking chair. There is a difference between a piece of A/C equipment sitting outside that develops a fault and trips on a GFPE and circuit powering an outdoor receptacle that has a high likelihood of being used for a power tool held in someone's hands that needs GFCI.

Please understand that I am not being antagonistic with you, I am trying to see if there is something I am missing.

It can trip at whatever time the manufacturer decides to want it too.
It is not a people protective device.

Not saying that these need people protection, but since the code requires people protection, a GFPE is not suitable.
The only devices that do that are GFCIs and SPGFCIs.

 

[Bill Snyder]

You haven't said anything that changes the fact that the NEC definition of outlet includes hardwired equipment.

Outlet. A point on the wiring system at which current is taken to supply utilization equipment.

How can the utilization equipment be the outlet that supplies itself?

 

[Bill Snyder]

If that was the case, the section would have not made it into the NEC. Nothing about the substantiation was ever shot down in the code process.
The only thing that is causing issues is the disconnect between the NEC and the product standards, as the product standards do not have leakage current limits for hardwired equipment. In addition there is an issue with the GFCI response to high frequency leakage current below 5 mA that is resulting from the use of VFDs and other types of power conversion equipment. There were proposals for the Standards Technical Panel for UL 943 to look at the high frequency issue, but they were shot down at ballot. There is work in progress to bring something back to that STP to address the issue.

I agree but if GFPE was used where the equipment clears the fault prior to human contact we would have no argument.

 

[Bill Snyder]

It can trip at whatever time the manufacturer decides to want it too.
It is not a people protective device.

Not saying that these need people protection, but since the code requires people protection, a GFPE is not suitable.
The only devices that do that are GFCIs and SPGFCIs.

SPGFCI was not on the table or 7 states would not have deleted this reference

 

[kwired]

It can trip at whatever time the manufacturer decides to want it too.
It is not a people protective device.

Not saying that these need people protection, but since the code requires people protection, a GFPE is not suitable.
The only devices that do that are GFCIs and SPGFCIs.

But the mentality has become lets people protect everything, but at same time can't just change the wording to "everything" so lets just add an item or two every new code cycle until we get there.

Other than swimming pool equipment there should be no real need for GFCI protection on something hard wired, the EGC should be sufficient enough. The EGC is much more vulnerable to being interrupted with cord and plug connections and has long been a driving force in GFCI requirements until more recent editions of NEC where the driving force seems to be more "because we can".

GFPE would still be pretty effective for people protection of hard wired equipment.

 

[don_resqcapt19]

SPGFCI was not on the table or 7 states would not have deleted this reference

It was not proposed for the purposes of 210.8(F). The only place it appears in the 2023 code is in Article 680. Would not be surprised if we see SPGFCI in other locations for the 2026 code.

 

[Bill Snyder]

The same place it is for every other hard wired piece of equipment...the point where the branch circuit conductors connect to the equipment.

Why would CMP-2 have to clarify 210.8(D) that say like a dryer requires GFCI protection weather hard wired or cord and plug connected they all connect to an outlet anyway?

 

[Bill Snyder]

I don't agree...the outlet is at the load end of the branch circuit conductors, and the conductors between the disconnect and the equipment are branch circuit conductors. In my opinion, the outlet for this type of equipment is the terminal block in the equipment.
However, as long as we can agree that there is an outlet that supplies this equipment, it doesn't really make any difference where we say it is....the outlet can have its GFCI protection on the line side of the outlet/

Pick a number

 

[Bill Snyder]

Or at the point that the branch circuit wiring connects to the utilization equipment.

The confusion doesn't end there

 

[don_resqcapt19]

Pick a number

I don't need to pick a number...the outlet will have GFCI protection as long as it is in the supply circuit as some point before the branch circuit conductors connect to the AC. If the main breaker in that panel was a GFCI breaker, it would provide the protection required in 210.8(F).

 

[Bill Snyder]

I don't need to pick a number...the outlet will have GFCI protection as long as it is in the supply circuit as some point before the branch circuit conductors connect to the AC. If the main breaker in that panel was a GFCI breaker, it would provide the protection required in 210.8(F).

Not required here in Colorado because 210.8(E) and 210.8(F) have been deleted. If that was the intent of CMP-2 why wasn't the compatibility of EVSE investigated? CMP-2 says it's under the control of CMP-12 why wasn't compatibility investigated for other hardwired equipment? Because they are not outlets.

 

[roger]

So you're basing your whole argument on Colorado, not the NEC?

 

[don_resqcapt19]

Not required here in Colorado because 210.8(E) and 210.8(F) have been deleted. If that was the intent of CMP-2 why wasn't the compatibility of EVSE investigated? CMP-2 says it's under the control of CMP-12 why wasn't compatibility investigated for other hardwired equipment? Because they are not outlets.

Outlets has ZERO to do with the lack of investigation for GFCI compatibility. This is much like the issue that resulted in 404.2(C)...a fight between the NEC and the standards writing organizatons.

 

[kwired]

Why would CMP-2 have to clarify 210.8(D) that say like a dryer requires GFCI protection weather hard wired or cord and plug connected they all connect to an outlet anyway?

NEC doesn't require GFCI protection on a dryer. Some changes in 2020 however do require the receptacle, when used, to be protected if in locations mentioned in 210.8(A) or (B). Then (F) would require protection even if hardwired if it should happen to be located outdoors.

The items (D) covers are items that have previously required GFCI protection but were never specifically mentioned in 210.8. The details are still in 422 but 210.8 points us to them.