yesterlectric
Senior Member
- Location
- PA
- Occupation
- Electrician
Wondered how to add this request. This would be a public comment on something requesting a change to the whole article’s strategy. It is also apparently a request to revert on a change that was made due to the NEC style manual, which may not be able to be changed. Generally in a public comment you submit a changed text. In this case, I am not sure I could submit an entire draft changed article, and the amount of potential substantiation is immense. Also, I am wondering what committee this would even go to.
If you go to the proposed article 100 right now, I think you will agree it is a mess
Hope this doesn't sound too much like a rant but there’s a lot that could be said about the current draft of the article. I’m hoping some others agree with me though on that the current definitions proposal seems problematic and needs to be changed.
In the event the NFPA won’t make changes, I hope they will at least provide an ease-of-use function, such as underlining all specially defined words throughout the NEC.
Lastly, this is my first time reading a draft, so perhaps the things I am concerned about are normally encountered at this stage?
Comment:
Committee Input No. 8495-NFPA 70-2021 [ Article 100 [Excluding any Sub-Sections] ]
Recommendation:
1. Divide article 100 into 3 parts:
Part I: General 1KV and less
Part II: General over 1KV
Part III: Article specific definitions
2. In addition, a definition at the beginning of an article, or the same definition reworded such that it describes what is considered that equipment, condition, or occupancy should exist.
3. There should be a differentiation between definitions and a statement that something should be considered as something else. An example is in article 230. It used to be that 230.6 allowed conductors to be considered as outside under certain circumstances. Now, the proposed article 100 has a definition of “Outside” that is specific to article 230 despite this term appearing repeatedly throughout the code.
Substantiation:
The current draft would be hard for users of the NEC to use. We have definitions that are repeated multiple times because they may apply generally, apply to a given set of articles under one committee’s jurisdiction, or may apply to only 1 article. We have in some instances parenthesis being used to describe an application of a definition, to abbreviate in others, and in others to differentiate between last, first and first, last format. We have terms like “MV” that many won’d know. This will make it difficult for the user of the code.
Electrical installers frequently need to review special articles, or general articles in detail. When installers are in training they review definitions, and then proceed with other training that reviews the same definitions repeatedly as they learn on other NEC articles. Similarly, definitions applicable to general work are repeatedly used as electricians do that work. As a result, these are more likely to be retained. For those definitions only applicable to one article, or those applicable to special installations, it would be advisable for someone to review the definitions that are special to that article when reviewing the article. When all the definitions are alphabetically placed, this process would require skipping through or reviewing the entire article 100, while hopefully keeping the relevant definitions memorized.
The move by NFPA seems to be largely due to the fact that all its other standards have all definitions in 1 place. The NEC may be more uniue than other standards, more broadly used, or applying to a more broad array of subject matter (Note: I am not sure this is true and would like input from this forum)
Secondly, while we want all the definitions in one place, having a scope statement that includes what the committee that wrote the article believes to be within the jurisdiction of that article would be beneficial. The code should make a differentiation between “when this condition occurs, it shall be considered to be this condition” and “this word means this.” (Note: here, I am still working to find good examples of problematic cases where there was a definition applicable to an article, that they took out and moved to general).
Numerous examples of potential for confusion exist and are below:
Heating Equipment and Heating System – very similar words and in some cases generic terms, but each applicable to a different and specific article.
Cable Joint, Type MV and Cable Termination, Type MV. Specific terms applicable to the medium voltage article (311 in 2020). Problem here is not everyone, even electricians, know MV means medium voltage. And of that, medium voltage is not even defined in the NEC. Outside of the NEC, some think it is up to 35KV and others up to 50KV. Additionally, the definition of Cable Joint, Type MV doesn’t even say it is for medium voltage cable, likely because it wouldn't need to when it was in article 311. Some readers may not know where it applies, and may be lead to think it could be something in chapter 8 – another thing many electricians are less familiar with.
Maximum Voltage is a definition applicable only to article 694, but the term maximum voltage appears elsewhere in the code.
Nominal Voltage, Voltage, Nominal (general), and Voltage, Nominal (article 712) – Nominal Voltage is applicable to articles falling under the jurisdiction of CMP 13, while Voltage, Nominal applies generally. NEC when specifying a requirement will always use the format Nominal Voltage, however.
Inside and Outside -- general words used throughout the NEC that have a specific requirement for article 230. What’s more: this didn’t used to be a definition in article 230. It was put as that in certain circumstances conductors could be considered inside or outside the building. It is probably the case that even in article 230, every mention of inside or outside doesn’t fit the definition.
If you go to the proposed article 100 right now, I think you will agree it is a mess
Hope this doesn't sound too much like a rant but there’s a lot that could be said about the current draft of the article. I’m hoping some others agree with me though on that the current definitions proposal seems problematic and needs to be changed.
In the event the NFPA won’t make changes, I hope they will at least provide an ease-of-use function, such as underlining all specially defined words throughout the NEC.
Lastly, this is my first time reading a draft, so perhaps the things I am concerned about are normally encountered at this stage?
Comment:
Committee Input No. 8495-NFPA 70-2021 [ Article 100 [Excluding any Sub-Sections] ]
Recommendation:
1. Divide article 100 into 3 parts:
Part I: General 1KV and less
Part II: General over 1KV
Part III: Article specific definitions
2. In addition, a definition at the beginning of an article, or the same definition reworded such that it describes what is considered that equipment, condition, or occupancy should exist.
3. There should be a differentiation between definitions and a statement that something should be considered as something else. An example is in article 230. It used to be that 230.6 allowed conductors to be considered as outside under certain circumstances. Now, the proposed article 100 has a definition of “Outside” that is specific to article 230 despite this term appearing repeatedly throughout the code.
Substantiation:
The current draft would be hard for users of the NEC to use. We have definitions that are repeated multiple times because they may apply generally, apply to a given set of articles under one committee’s jurisdiction, or may apply to only 1 article. We have in some instances parenthesis being used to describe an application of a definition, to abbreviate in others, and in others to differentiate between last, first and first, last format. We have terms like “MV” that many won’d know. This will make it difficult for the user of the code.
Electrical installers frequently need to review special articles, or general articles in detail. When installers are in training they review definitions, and then proceed with other training that reviews the same definitions repeatedly as they learn on other NEC articles. Similarly, definitions applicable to general work are repeatedly used as electricians do that work. As a result, these are more likely to be retained. For those definitions only applicable to one article, or those applicable to special installations, it would be advisable for someone to review the definitions that are special to that article when reviewing the article. When all the definitions are alphabetically placed, this process would require skipping through or reviewing the entire article 100, while hopefully keeping the relevant definitions memorized.
The move by NFPA seems to be largely due to the fact that all its other standards have all definitions in 1 place. The NEC may be more uniue than other standards, more broadly used, or applying to a more broad array of subject matter (Note: I am not sure this is true and would like input from this forum)
Secondly, while we want all the definitions in one place, having a scope statement that includes what the committee that wrote the article believes to be within the jurisdiction of that article would be beneficial. The code should make a differentiation between “when this condition occurs, it shall be considered to be this condition” and “this word means this.” (Note: here, I am still working to find good examples of problematic cases where there was a definition applicable to an article, that they took out and moved to general).
Numerous examples of potential for confusion exist and are below:
Heating Equipment and Heating System – very similar words and in some cases generic terms, but each applicable to a different and specific article.
Cable Joint, Type MV and Cable Termination, Type MV. Specific terms applicable to the medium voltage article (311 in 2020). Problem here is not everyone, even electricians, know MV means medium voltage. And of that, medium voltage is not even defined in the NEC. Outside of the NEC, some think it is up to 35KV and others up to 50KV. Additionally, the definition of Cable Joint, Type MV doesn’t even say it is for medium voltage cable, likely because it wouldn't need to when it was in article 311. Some readers may not know where it applies, and may be lead to think it could be something in chapter 8 – another thing many electricians are less familiar with.
Maximum Voltage is a definition applicable only to article 694, but the term maximum voltage appears elsewhere in the code.
Nominal Voltage, Voltage, Nominal (general), and Voltage, Nominal (article 712) – Nominal Voltage is applicable to articles falling under the jurisdiction of CMP 13, while Voltage, Nominal applies generally. NEC when specifying a requirement will always use the format Nominal Voltage, however.
Inside and Outside -- general words used throughout the NEC that have a specific requirement for article 230. What’s more: this didn’t used to be a definition in article 230. It was put as that in certain circumstances conductors could be considered inside or outside the building. It is probably the case that even in article 230, every mention of inside or outside doesn’t fit the definition.
