2023 Definitions Public Comment

Merry Christmas

Josh111

Senior Member
Location
USA
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.
 

Josh111

Senior Member
Location
USA
Reposted due to one clarification in red below.

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. A heading for each article followed by its associated 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't 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 unique 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.
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
That will be rejected because it is general and does not provide specific new language and because it appears to introduce material that was not introduced in a Public Input.

The formatting of how the text looks and doing things like underlining words is not something that the code making panels can change. Not sure if there is a way to make that type of change.

The parts you want is not something the NFPA wants. The CMP 1 was directed to eliminate the parts and put all definitions in alphabetic order.

I am not finding a definition of "outside" in Article 100 of the First Draft Report.
 

Josh111

Senior Member
Location
USA
Yeah I wondered about the whole thing with introducing new material. However every single one of those definitions that got moved in a certain way you could be considered new material because it’s relocated material. I think what they’re doing is creating a mess. And they should realize that while it’s currently not conceivable for a jurisdiction in the US to adopt somethings else, jurisdictions voluntarily adopt the NEC. If it over time becomes cumbersome and other standards are thought to be better, they could adopt something else. It’s unthinkable now but it could be a while from now. Or other countries that are more likely to make a decision on NEC versus other standards could become less likely to adopt it.
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
Yeah I wondered about the whole thing with introducing new material. However every single one of those definitions that got moved in a certain way you could be considered new material because it’s relocated material. I think what they’re doing is creating a mess. And they should realize that while it’s currently not conceivable for a jurisdiction in the US to adopt somethings else, jurisdictions voluntarily adopt the NEC. If it over time becomes cumbersome and other standards are thought to be better, they could adopt something else. It’s unthinkable now but it could be a while from now. Or other countries that are more likely to make a decision on NEC versus other standards could become less likely to adopt it.
The moving is not new material. Even the moving of sections from one article to another, of the renumbering of an article is not new material.

There are definitions that were changed, and the changes are new material. Some of those changes were from PI and others were a result of panel FRs. The panels themselves can introduce new material at the first stage, but no one, not even a CMP, can add new material at the second stage.

With the current system, a PI that was resolved (rejected) can be brought back in the comment stage, but that is not new material because it was submitted in the public input stage.
 

pv_n00b

Senior Member
Location
CA, USA
I'm not sure what the best way to address this is. The NEC Style Manual does not affect the technical content of the NEC just the presentation. There is another change in the Style Manual that is causing sections to be rewritten in mass to use more of a list format, not changing content just how it is displayed. I'm not even sure how the Style Manual is changed or by who.
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
I'm not sure what the best way to address this is. The NEC Style Manual does not affect the technical content of the NEC just the presentation. There is another change in the Style Manual that is causing sections to be rewritten in mass to use more of a list format, not changing content just how it is displayed. I'm not even sure how the Style Manual is changed or by who.
The style manual is an NFPA document and I believe it is under the purview of the Standards Council. I believe there was a task group assigned to rewrite the style manual.

There are a lot of changes in the FR that were driven by the Style Manual. One of those is that you can't reference a complete article in a rule. It has to be a part of an article or a specific section. However, it appears you can reference a complete article if the reference is in a table and not a section.

There was a lot of work on subject terms, but some does not make any sense, such as changing may to might.

On big emphasis was on the use of the words "where" and "if". Where is to be used only for a physical location. If is to be used for a condition or a choice.

I like the change to list format over long run on sentences.
 

Josh111

Senior Member
Location
USA
Yes I guess to me the whole definitions article is a big change this year and while I can’t say I have prevailing knowledge on it, it doesn’t make a lot of sense to me that there would be no way to submit a comment opposing that change and do so in a way that will allow it to be considered. I hope some of the examples I produced in bold letters above will cause a number of people to agree that even if my suggestion isn’t taken, something needs to be done because it is a mess right now.

Maybe we should add a definition for “not objectionable current” (250.6) or maybe we need a definition of “grounding electrode, permitted” that would basically take everything in 250.52 and reduce it to a definition style format and put it in article 100. Or maybe we need a definition for “properly installed grounding electrode” that takes everything from 250.53. To me, that’s basically what they’re doing with the definition of inside and outside from article 230. For that matter we could just take the entire NEC and place it in a definition in article 100 called “safe electrical installations.”
 

Josh111

Senior Member
Location
USA
I think they should change to a five-year development cycle. For instance with the NESC, you have 18 months after publication to submit a public comment and then something like six months to comment on the first draft. It means that there’s a lot more input.

The three-year development cycle where you have to submit a public input within nine months of publication is problematic. Even a number of the states that are pretty good with ensuring compliance with the electrical codes delay their adoption by up to a year. If they would give 18 months for public input due to a five-year development cycle that would allow it, probably 1/2 to 3/4 of the states will have adopted the new code by the end of the public input period and as a result many professionals will have had experience with the new revisions and whatever it is that they feel could be revised. It would be that much more perspective from trade related professionals.

Right now it’s largely only the trade organizations and a few very interested people in a lot of cases that are reviewing the new code and making public inputs.
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
The electrical industry moves too fast for a 5 year cycle to keep up with product changes.

One other issue is the fact that definitions cannot have requirements. That has always been the case, but it was looked at closely this cycle.
Some of the things they took out because they said they were requirements, I thought were descriptive.

There was also a needed consolidation of definitions as there were a number of cases where the same term was defined differently in the various articles. A lot of work was done to come up with a definition that worked for all. However, in some cases, that was not possible and we have a number of defined terms that only apply to a specific article.
 

Josh111

Senior Member
Location
USA
The electrical industry moves too fast for a 5 year cycle to keep up with product changes.

One other issue is the fact that definitions cannot have requirements. That has always been the case, but it was looked at closely this cycle.
Some of the things they took out because they said they were requirements, I thought were descriptive.

There was also a needed consolidation of definitions as there were a number of cases where the same term was defined differently in the various articles. A lot of work was done to come up with a definition that worked for all. However, in some cases, that was not possible and we have a number of defined terms that only apply to a specific article.
OK but if I wait for something to be what I believe would be improved is there really no way I could request do it? It seems to me that they made a change in the first draft when they moved all these definitions over. So it seems like there would’ve been some way to comment in opposition to such a move. Does it have to be a comment to whatever committee writes the NEC style manual? I saw the article 100 committee’s statement on their decision on this. They basically didn’t say whether they agreed or disagreed with it but said it was just not in their jurisdiction to make the decision. Who makes the decision?
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
OK but if I wait for something to be what I believe would be improved is there really no way I could request do it? It seems to me that they made a change in the first draft when they moved all these definitions over. So it seems like there would’ve been some way to comment in opposition to such a move. Does it have to be a comment to whatever committee writes the NEC style manual? I saw the article 100 committee’s statement on their decision on this. They basically didn’t say whether they agreed or disagreed with it but said it was just not in their jurisdiction to make the decision. Who makes the decision?
It is my understanding that came from the Standards Council and have no idea of that is subject to change by the public. It is not something technical that falls under the purview of the code making panels. Maybe someone at the NFPA could tell you if you call them.
 

Josh111

Senior Member
Location
USA
They seem to be hard against even helping someone knw how to make a comment. Who knows. Maybe we will see a book on a guide to the definitions come out, written by someone on the committee who had a part in the decision to mucky up the definitions section!!
 
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