Anybody want to discuss that LCDI thing on window A/C cords?

hbiss

EC, Westchester, New York NEC: 2014
Location
Hawthorne, New York NEC: 2014
Occupation
EC
Don't normally get involved with window A/Cs but my mini-split crapped out in one room and I borrowed a window A/C until I can replace it. So, I put it in the window, plug in the cord with that thing on the end as a plug and nothing happens. I notice that there are buttons on the side of it like a GFCI and I push one then the other and the A/C powers on. 😠 I understand that it is supposed to detect leakage current from a hot to ground short in the line cord if it's damaged. I would like to know what idiocy mandated a device like that.

-Hal
 

hbiss

EC, Westchester, New York NEC: 2014
Location
Hawthorne, New York NEC: 2014
Occupation
EC
The same one that requires them on hair-dryer plugs.
Actually, it isn't. For a hair dryer it's a GFCI. No argument that hair dryers get dropped into sinks and bathtubs full of water. If it's not plugged into a GFCI receptacle this acts as a backup.

The ones on A/Cs are completely different. It's supposed to detect cut or damaged cords. The cord itself incorporates an overall conductive braid over the three conductors. If the cord is damaged such that the hot faults to the braid a solenoid and contacts disconnect power. The system provides no personal safety such as would be if powered from a GFCI circuit or receptacle. Only low-tech removal of power should there be cord damage.

So, the question is why and who would they go to such an extreme just for window A/Cs? Were there multiple deaths associated with damaged cords? What about when someone uses an extension cord to power the AC? What about every other cord connected device in the universe?

Just sounds like another boondoggle to me...

-Hal
 

suemarkp

Senior Member
Location
Kent, WA
Occupation
Retired Engineer
440.65 covers cords on AC units. It says they must have a factory provided LCDI, AFCI, or HDCI on the end of the cord. Not sure what the substantiation was other than these are heavy, taken out yearly and stored, and maybe the cord easily gets crunched. Seems to go back to at least 2005, maybe older.

Some other details here:
 

ramsy

Roger Ruhle dba NoFixNoPay
Location
LA basin, CA
Occupation
Service Electrician 2020 NEC
440.65 covers cords on AC units. It says they must have a factory provided LCDI, AFCI, or HDCI on the end of the cord. Not sure what the substantiation..
Is substantiation required in code proposals or NRTL standards?
 

letgomywago

Senior Member
Location
Washington state and Oregon coast
Occupation
residential electrician
So I've seen melted outlets and cord ends on windows ACs more than should happen. I think this may have been an attempt to limit that or other hazards from these. Remember they're the goto for hotels and so they might need to be redundant in their safety
 

letgomywago

Senior Member
Location
Washington state and Oregon coast
Occupation
residential electrician
Also complaining that something like a gfci trips is kind of silly. We all make fun of the people who have to hire someone to push a button. So as an electrician we shouldn't complain on this silly one. It's not like it's a device that ends up buried behind stuff.
 
So I've seen melted outlets and cord ends on windows ACs more than should happen. I think this may have been an attempt to limit that or other hazards from these. Remember they're the goto for hotels and so they might need to be redundant in their safety
But this device is not intended to nor does it protect against overloads or cord and or outlet damage
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
Is substantiation required in code proposals or NRTL standards?
Yes. It is required for both, and based on participation in some Standards Technical Committees, I think it is more difficult to make a change in a listing standard than in the NEC.
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
This actually appeared for the first time in the 2002 code. It did not pass at the Report on Proposals stage. but did at the Report on Comments stage. Below is the proposal.
Proposal 11- 104 - (440-65 (New) ): sense leakage currents flowing between or from the conductors of the cord set and interrupt the circuit. If leakage current is allowed to continue

Note: It was the action of the Technical Correlating Committee that this Proposal be reported as "Reject" because less than two thirds of the members eligible to vote have voted in the affirmative.

SUBMITTER:
Edward A. Schiff, Technology Research Corp.

RECOMMENDATION: 440-65. Cord Sets with Leakage Current Detection and Interruption Protection

(a) Definition: Cord Sets with Leakage Current Detection and Interruption (LCDI) - a cord set intended to flowing from the conductors, risk of ignition of the surrounding combustible materials and risk of serious injury from electrical shock may result.

(b) All single phase cord and plug connected room air conditioners shall be provided with factory installed cord leakage current detection and interruption protection. The LCDI shall utilize air break contacts and be an integral part of the attachment plug or located in the supply cord within 12 in. (305 mm) of the attachment plug.
SUBSTANTIATION: Electrical cords and plugs are responsible for 7400 fires (attended by the fire service) per year which result in 108 deaths, 539 civilian injuries and $121 million in direct property damage per year in US homes according to The US Home Product Report, 1991-1995

(Appliances and Equipment) published by the NFPA in 1998. The majority of the cord and plug fires were caused by short circuits or ground faults (54.3%). Other electrical failure (23%) and overloads (9.4%) accounted for most of the balance. Following the leadership of the Consumer Products Safety Commission, the electronics Industry Association, AHAM, NEMA, and Underwriters Laboratory, industry has made a significant effort on the development of technologies for improving the safety of electrical products.

The flexible cords on room air conditioners are subjected to excessive abuse during its product life. The power supply cord can be damaged in a number of ways. The cord can be pinched or crimped during installation or storage. The shear mass of the product can permanently damage the cord. Once installed the cord is often within harms way by being pinched by furniture, chewed by a pet or infant or kicked.

This abuse will result in series (broken conductors), parallel (degraded insulation), and/or ground faults in the cord. These conditions will lead to combustion of the cord and/or surrounding material. Examples of recent serious room air conditioner cord fires are contained in table 1 that I have provided. Room and portable air conditioners account for 1,400 fires (attended by the fire service) per year and result in 10 deaths per year, on average according to the NFPA.

Considering that these products are primarily used seasonally in the North East, this would equate to approximately 10 fires per day attended by the fire service (not to mention, all the fires which are controlled without calling 911). In addition, cord damage presents a significant risk of serious injury from shock or death by electrocution. There have also been many incidents of electric shock and even electrocution involving air conditioners. In 1997, an 18-year-old girl was electrocuted in Maryland because a damaged cord was touching the metal frame of her hotel room door. In July of 1999, a seven year old boy in Sabetha, Kansas died from electrocution when he came in contact with a dehumidifier cord on a wet kitchen counter top. Devices which meet this standard sense ground faults, thus providing protection from serious injury from shock or electrocution.

Many precedents exist for incorporating cord LCDI protection for room air conditioners into the code. The safety of service cords has long been viewed as part of the branch circuit wiring by the code for years. Examples include Section 422-49 GFCIs on high pressure spray washers, Section 422-41, Cord and Plug connected appliances subject to immersion (hair dryers), Table 400-4 defining lamp, heater, iron, range, dryer and vacuum cleaner cords, and Article 422 defines a multitude of flexible cord and plug-connected appliance requirements.

A serious safety problem continues to exist. Proven UL recognized / CSA certified cord sets are available from multiple manufacturers which provide this protection at an economical cost. The elimination of these needless deaths is immeasurable and the savings in property losses, injuries, insurance claims, and law suits will be dramatic. Note: Supporting material is available for review at NFPA Headquarters.

PANEL ACTION: Accept in Principle in Part.

Add a new definition to 440-2 as follows:

“Leakage Current Detection and Interruption (LCDI) Protection.
A device provided in a power supply cord or cord set that senses leakage current flowing between or from the cord conductors and interrupts the circuit at a predetermined level of leakage current.”

Add a new 440-65 as follows:

“Leakage Current Detection and Interruption (LCDI). Single-phase cord- and plug-connected room air conditioners shall be provided with factory-installed LCDI protection. The LCDI protection shall be an integral part of the attachment plug or be located in the power supply cord within 300 mm (12 in) of the attachment plug.”

PANEL STATEMENT: The changes are to (1) comply with the NEC Style Manual; (2) include power supply cords; (3) delete the proposed requirement that air break contacts be provided, as being too restrictive and not substantiated.

NUMBER OF PANEL MEMBERS ELIGIBLE TO VOTE: 15

VOTE ON PANEL ACTION:

AFFIRMATIVE: 7

NEGATIVE: 8

EXPLANATION OF NEGATIVE:

BUNCH: There is conflicting data as to actual cause of cited incidents of cord related failures. Although this CDI might lead to a product improvement, it should be regulated through the recognized testing labs and standards, not in the NEC.

COX: Devices, such as proposed, would offer protection of all available portable cord connected devices if they were installed on the branch circuits rather than on individual pieces of equipment. Article 210-12 already provides for similar devices on branch circuits for bedrooms.

HAMER: This should be handled in the product standards, not the National Electrical Code.

RASMUSSEN: The proposal should be rejected. The concept of utilizing advancements in technology to enhance the safety of appliances should be encouraged. However, the submitter's substantiation does not provide clear evidence that the incidents of cord fires cited relate to damage to the room air conditioner supply cord. The involvement of inappropriate extension cords appear to be a factor. For instance, in the Oct. 1998 El Dorado, AR incident, one of the few examples where some detail is given, it states, “The spliced cord was run under a rug across the room, when it overheated and arced.” Before requiring such major change to existing room air conditioner requirements, the submitter is encouraged to provide well documented and verifiable examples of specific incidents where the product improvement being recommended would have prevented the unwanted incident from occurring.

SCHRAM: The information on fires alleged to have been caused by overheating or faults in room air conditioner power supply cords, which was presented to the panel, is vague as to the details of the actual causes of the fires. It is not clear from this material a that a LCDI in the air conditioner power supply cord or plug would have prevented any of the reported fires. The substantiation for the proposal refers to the “excessive abuse” potential for room air conditioner cords, but the material presented to the panel contains no details to support this contention. Further, no data was presented to the panel to support the statements in the substantiation concerning electric shock incidents that could have been prevented by use of a LCDI in the cord or plug. It is my opinion that the NEC is not the proper place for a product safety requirement, such as mandating the factory installation of a LCDI in room air conditioner power supply cords or plugs. I recognize that 422-41 and 422-49 do include similar requirements, but the circumstances that resulted in these code requirements were quite different than the circumstances in this case, and the need was well supported. I would urge the manufacturers of room air conditioners to thoroughly investigate the need for and efficacy of LCDIs on room air conditioners, and if appropriate, revise UL484 to require their use.

SAPORITA: I must vote negative on the panel action. While I believe that this proposal may reduce the likelihood of cord fires, this is a product standards issue.

THOMAS: The cord set with leakage current detection and interruption seems to be a reasonable safety item but I question placing the requirement in the NEC. This is not part of the premises wiring and is not enforceable by the Authority Having Jurisdiction.

WRIGHT: The proposal should be rejected. NEMA agrees with the submitter's concept. However the proposal is too restrictive.
There are other methods of providing this protection.
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
Here are the comments on the LCDI code change.
Comment 11- 230 - (440-2 and 440-65): Accept

SUBMITTER: William H. King, Jr. , U.S. Consumer Product Safety Commission

COMMENT ON PROPOSAL NO: 11-104

RECOMMENDATION: I support the panel action to "Accept in Principle in Part" with the additions to Section 440-2, and by adding the new Section 440-65. I further support broadening the protection devices permitted to include arc-fault circuit-interrupter protection.

SUBSTANTIATION: Panel 11 is urged to adopt the proposal as amended by the panel and reported in the ROP, and as noted above. While the explanation offered by several panel members for their negative votes has merit, i.e., the matter is a product standard issue, and product standard developers and listing organizations have not responded to this safety issue with upgraded requirements. Therefore, it is appropriate to bring the matter before the broader electrical safety community represented by the NEC Committee.



Each year CPSC identifies fires that specifically mention the power cord attached to an air conditioner as the cause. In a check of incidents reported to the CPSC for 1999, six reports clearly state that the power cord on the air conditioner started the fire. Other reports for room air conditioners mention short circuit conditions associated with the appliance, but lack more specificity. Still other reports cite an extension cord used with a room air conditioner as the cause. While there may be multiple reasons for fires with room air conditioners, the power cord is a specific part in need of improvement.

Window-mount room air conditioners are frequently used as seasonal products, often removed from window locations and stored elsewhere when not in use. Cords used on these products (typically SP-3 type construction) are not designed to withstand mechanical stress conditions encountered as part of the removal and storage process. Of the cost-effective technologies available today, listed arc-fault circuit interrupters and leakage current detection interrupters provide a remedy for numerous causes associated with the power cord as well as some internal appliance faults that increase the risk of fire with cord-connected air conditioners.

PANEL ACTION: Accept.

NUMBER OF PANEL MEMBERS ELIGIBLE TO VOTE: 15

VOTE ON PANEL ACTION:

AFFIRMATIVE: 11

NEGATIVE: 4

EXPLANATION OF NEGATIVE:

BUNCH: I vote negative. The substantiation for this is not well founded. Several incidents have been referenced without any forensic support that the problem was a direct result of what this proposal is addressing. This should be examined by the manufacturers and testing agencies to first verify if these reports are accurate and if so, the product should be regulated through product standards and not the NEC. This is inappropriate and in many cases will not be enforceable by the authority having jurisdiction.



CLOSSON: While the use of cord sets with leakage current detection have merit; the requirement for the construction and performance of products belongs in the end product safety standards, not in the NEC.



COX: While I agree that the LCDI is a means to enhance safety for portable cords for air conditioners, I believe this is an issue for the product standards and should not be mandated by the NEC. If portable cords are the source of some fires as indicated by the data, then it should be the responsibility and desire of the listing agency to change the standard to eliminate the hazard. The listing agency may allow other suitable methods for alleviating the safety hazard.


SAPORITA: I vote negative on the panel action. While protection of air conditioning power cords against arcing fault and overload conditions has great merit, the proposed solution to remedy the problem is a product standards issue and should be addressed therein. The proposed requirements for LCDI and AFCI protection of specific power cords do not belong in the NEC. Also, the inclusion of AFCI protection is new material introduced during the comment stage that has not had adequate public review. Therefore, this material should not be introduced into the 2002

NEC.

COMMENT ON AFFIRMATIVE:

HAMER: See my Affirmative Comment on Comment 11-242.





Comment 11- 231 - (440-2-Leakage Current Detection and Interruption (LCDI) Protection and 440-65 Leakage Current Detection and
Interruption (LCDI) and Arc Fault Circuit Interrupter (AFCI) ):

Accept

Note: The Technical Correlating Committee understands that the final action on this material is contained in Comment 11-242.

SUBMITTER:
Larry F. Miller, National Electrical Manufacturers Association (NEMA)

COMMENT ON PROPOSAL NO: 11-104

RECOMMENDATION: Add a new definition to 440-2 as follows:

Leakage Current Detection and Interruption (LCDI) Protection.

A device provided in a power supply cord or cord set that senses leakage current flowing between or from the cord conductors and
interrupts the circuit at a predetermined level of leakage current.

Add a new 440-65 as follows:

Leakage Current Detection and Interruption (LCDI) and Arc Fault Circuit Interrupter (AFCI).
Single-phase-cord- and plug connected room air conditioners shall be provided with factory installed LCDI or AFCI protection. The LCDI/AFCI protection shall be an integral part of the attachment plug or be located in the power supply cord within 300 mm (12 in). of the attachment plug.

SUBSTANTIATION: NEMA supports the Panel's action of Accept in Principle in Part with the addition of including an option for AFCI protected cord set.

A unnecessary and serious safety hazard continues to exist. An article in the March/April 2000 NFPA journal documented a room air conditioner cord fire in a nursing home. Both the January/February and March/April electrical accidents section of the IAEI News also had articles on air conditioner cord fires.

Room air conditioners are used in existing homes, institutions and elderly housing which do not have requirements for AFCI protection. There are many precedents for incorporation of product and cord safety requirements in the Code. This includes:

Section 422-41 Immersion protection for cord and plug connected appliances

Section 422-45 Stands for cord-and plug-connected appliances

Section 422-46 Flatirons equipped with an identified temperature limiting means

Section 422-49 Factory installed GFCIs for High Pressure Spray Washers

Section 680-40 GFCI protection for cord-and plug-connected spas and hot tubs.



This requirement is functional in nature. It is based on the UL/CSA standards. A serious and preventable safety hazard that results in fires, injuries and deaths every year continues to exist. There are many precedents for this requirement. Economical, proven, and listed products are available that will provide the necessary safety protection.

PANEL ACTION: Accept.

NUMBER OF PANEL MEMBERS ELIGIBLE TO VOTE: 15

VOTE ON PANEL ACTION:

AFFIRMATIVE: 11

NEGATIVE: 4

EXPLANATION OF NEGATIVE:

BUNCH: I vote negative, see my explanation of negative vote on Comment 11-230.

CLOSSON: While the use of cord connected room air conditioners provided with factory installed LCDI or AFCI protection has merit, the requirement for the construction and performance of products belongs in the end product safety standards, not in the NEC.

COX: See my Explanation of Negative on Comment 11-230.

SAPORITA: I vote negative on the panel action. While protection of air conditioning power cords against arcing fault and

overload conditions has great merit, the proposed solution to remedy the problem is a product standards issue and should be

addressed therein. The proposed requirements for LCDI and AFCI protection of specific power cords do not belong in the NEC.
 

gene6

Senior Member
Location
NY
Occupation
Electrician
Interesting I have a AC unit mounted thru my wall and it has one. Its a 240V cord, I never noticed it till now.
Its also interesting to see the CMP's debate the scope of the NEC, seems like it was 11 - 4 that the scope does not end at a receptacle outlet even if the inspectors end there.
 

don_resqcapt19

Moderator
Staff member
Location
Illinois
Occupation
retired electrician
Interesting I have a AC unit mounted thru my wall and it has one. Its a 240V cord, I never noticed it till now.
Its also interesting to see the CMP's debate the scope of the NEC, seems like it was 11 - 4 that the scope does not end at a receptacle outlet even if the inspectors end there.
It is my opinion that things like this and about half of Article 422 is outside the scope of the NEC.
 
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