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2-65 Log #1274 NEC-P02 Final Action: Hold
(210.12)
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Submitter: James W. Carpenter, International Association of Electrical
Inspectors
Comment on Proposal No: 2-153
Recommendation: We support the panel’s action for rejection of this proposal.
Substantiation: AFCI technology was first introduced in the early 1990s and has been included in the code development process in the 1999, 2002, 2005, and 2008 editions. AFCI requirements have been a progressive process, as well as substantiated over the past four NEC Code cycles.
Accordingly, this Code Panel has gradually expanded the AFCI protection
requirements over numerous code cycles with the intent to increase electrical safety in the home, but do so on a gradual basis. However, the expansion of AFCI requirements didn’t come without extensive deliberation by the panel, based on sound technical substantiation and data.
The following past ROPs & ROCs below clearly establish the Panel’s long
history and technical discussions, which has resulted in an equitable code that ensures a minimum level of safety.
NFPA 70 1999 Proposals 2-128, 2-129, 2-130
NFPA 70 1999 Comments 2-56, 2-65, 2-66, 2-67, 2-68, 2-69, 2-70, 2-85
NFPA 70 2002 Proposals 2-102, 2-103, 2-106, 2-110, 2-112, 2-113, 2 115, 2-116
NFPA 70 2002 Comments 2-71, 2-78, 2-79, 2-80, 2-81, 2-82
NFPA 70 2005 Proposals 2-123, 2-133, 2-134, 2-142, 2-146, 2-149, 2 150, 2-134a, 2-161, 2-167
NFPA 70 2005 Comments 2-87a, 2-93, 2-105, 2-108, 2-110
NFPA 70 2008 Proposals 2-142, 2-126
NFPA 70 2008 Comments 2-95, 2-129, 2-137
As stated by CMP 2 Members F. Coluccio, R. LaRocca and J. Pauley, acceptance of this proposal would remove AFCI protection for parallel arcing faults from the first portion of the branch circuit, which is in direct conflict to past panel actions to increase safety. Rejecting this proposal will ensure the level of safety for these branch circuits are not reduced.
The submitter’s substantiation lacks merit as the Standard for AFCIs, UL 1699, doesn’t consider as a component, the proximity to an arcing source.
Regarding costs associated with metal raceways or cables, the submitter has not provided any cost analysis or data to demonstrate what is too cost prohibitive. In addition, CMP 2’s panel statement from the 2002 ROP (2-106) further supports this concept:
“AFCIs Listed to UL 1699 are available, and the standard addresses efficacy, unwanted (nuisance) operation and operation inhibition. Cost should not be an issue for the panel to resolve. The panel reviewed a large amount of data, heard presentations on various positions on AFCIs, and received public comment on the topic. Upon that review, the panel arrived at the requirements in the 1999 NEC and continues to support that established position.”
With respect to the state adoption, states throughout the U.S. continue to recognize and adopt the important safety provisions included in the 2008 NEC, despite the opposition from some industry groups. The panel needs to rise above the political battlefield and continue to move forward with what is in the best interest of safety for citizens.
In the panel statement ROP 2-166, the Code-Making Panel stresses that “AFCI protection is for protection from fire ignition for branch circuits.” Consequently, with this statement and others in the past... the entire branch circuit shall be protected.”
In the panel statement from ROP 2-155: “AFCI devices are widely available in the market and the panel notes that the cost has already come down since the introduction of AFCIs into the 1999 NEC.” Therefore, cost should not be considered.
With regards to the substantiation that “wiring insulation has dramatically improved in the past 50 years.” This is a consideration that should be addressed from the original proposal in 1999 and reviewed as to the comparison of Consumer Product Safety Commission fundamental data as to eliminate the AFCI requirement completely based on the introduction of 90 degree C insulation.
As indicated with this substantiation, the crisis with home structure fire civilian death, it appears that “Cord and Plugs” cord-and-attachment-plug connection accounts for the significant share in 2002-2005 concerning this issue. If it is the cords of appliances and equipment that are of apprehension, then AFCI and/or leakage-current detector-interrupter protection may need to be applied to the product standard as with NEC section 440.64 and addressed by Code-Making Panels 17 and 18.
Should we disregard the past panel action concerning AFCI outlets many other consequences will occur. This will challenge the wisdom that the electrical industry’s leaders have credible knowledge. We have discussed, assessed, informed, and legislated the concept of the entire branch circuit being protected as referenced from zone 1 Consumer Product Safety Commission study, where 36% of residential electrical fires occur. This change will provide the information for state and local jurisdictions to amend this entire section from the National Electrical Code.