Code Compliant Cable Tray?

[roger]

I realize this forum (like everything online) is burdened by argumentative behavior and apologize both forward and backward for any responsibility I might bear for that in this particular thread. The thread has veered radically off course and to no real end. The *only* opinion that matters on whether radical field modification is acceptable belongs to the AHJ (or Court if there's a liability action). Opinions are like ... elbows ... and most of us have a couple. But arguing about whether this is a violation - unless one party is an AHJ and the other party is trying to convince him - is utterly pointless and a complete waste of time.

In the spirit of trying to reduce the argument level, instead of arguing I will now try to stop and instead just reply with direct quotes from AHJ's. I'll start with this one because it's one of my favorites and comes from the great State of Colorado:
ANY listed or classified product which has been altered from the original manufactured condition is unacceptable to the Colorado State Electrical Board. Listed fittings must be used for changes in direction or elevation per the 2008 NEC 392.5E. The contractor's analogy to conduit does not work either as conduit or tubing are vastly different from cable tray. For all that the pictured field bend is ingenious, it is also a violation in that the product no longer has any listing (classification) and would be unacceptable as such.
--J. Grant Hammett
Supervisor Electrical Inspector
Colorado Department of
Regulatory Agencies

What manufacturers tray was the installer using?

Now you may or may not agree with Mr. Hammett, but the *smart* money would be on doing things his way.

No, the smart money would be to show J Hammet any instructions that the manufacturer included with their product.

As pointed out before, if field modifying / altering a product negates it's listing as a blanket statement, we could never pull a knock out in an emclosure.

Roger

 

[mivey]

Are you saying: it is possible that a field evaluation by UL could result in a 'non-violation finding'?

It is possible. But let's use your money to find out. :grin:

 

[roger]

It is possible. But let's use your money to find out. :grin:

I know of an NRTL in NC that is a lot more reasonable than UL, for a small fee I'll help you get intouch with them. :grin:


Roger

 

[CAM]

Classified vs Listed -

Classified vs Listed -

According to the AHJ in Detroit, only Listed products have instructions attached or evaluated. Classified products do not and therefore it is up to the AHJ whether or not to accept field modifications.

I'm happy to give you the City of Detroit's requirements in regard to approval of electrical equipment /materials.

First, I need to clarify terms to be used. "Classified" is a term used for components evaluated by a third-party tester (such as UL) to be installed as part of a more complex, OEM product.

This differs from the term "listed" which means that a product has been evaluated as a whole,including all its "classified" component parts. The product would then carry the "listed" label, recognizable to most people by the "UL"
For example, a "classified" relay might be installed into a machine, and then the machine would be evaluated as a complete product...and would then be "Listed".

In regard to (cable tray), I would require that the product carry a "listed" label. All questions of proper installation would then be answered by the MANUFACTURER'S Installation instructions which are part of the listing.
Phil Clark
Chief Electrical Inspector
City of Detroit

I do know that UL has not required submission of installation instructions for cable tray on recent packages (requesting product for evaluation only). Perhaps this clarifies why and puts an end to the question.

What this leads to, however, is the point that the NEC does not distinguish between Listed and Classified. Listed and labeled are conflated within the Code and since Classified products are labeled we have this confusion. People here think the instructions included with Classified products describing radical field modifications are part of the UL package when they are not.

 

[CAM]

No, the smart money would be to show J Hammet any instructions that the manufacturer included with their product.

Roger

Have you submitted much to UL? Interested in seeing what they actually ask for? Perhaps seeing the itemized list will relieve you of the misapprehension you suffer that these instructions to field modify are seen, evaluated, and included with the Classified label from UL.

UL looks at the product (for tray anyway). UL evaluates the product as an Equipment Grounding Conductor. UL does not have anything to do with field modification unless they are called out by an AHJ to examine modified product in the field. Otherwise the assumption is that the product remains as the manufacturer shipped it.

There are UL Instructions and they are marked as UL Instructions. Cable Tray does not come with UL Instructions

http://ulstandardsinfonet.ul.com/generalinformation/stylemanual/style-manual-body.htm

 

[jim dungar]

So, it appears the chief electical inspector in Detroit might not allow any cable tray to be installed in his jurisdiction as UL does not have a listing for cable tray. But in reality he is saying the tray must be installed per manufacturer's instructions as required by 110.3

What is Mr. Hammett's ruling if the tray is installed as support only and not as an EGC? Or has he interpreted the code phase "permitted" to mean required?

 

[roger]

According to the AHJ in Detroit, only Listed products have instructions attached or evaluated. Classified products do not and therefore it is up to the AHJ whether or not to accept field modifications.



I do know that UL has not required submission of installation instructions for cable tray on recent packages (requesting product for evaluation only). Perhaps this clarifies why and puts an end to the question.

What this leads to, however, is the point that the NEC does not distinguish between Listed and Classified. Listed and labeled are conflated within the Code and since Classified products are labeled we have this confusion. People here think the instructions included with Classified products describing radical field modifications are part of the UL package when they are not.

Nobody has been talking about "Classified"?

The AHJ in Detroit is correct, it would behoove you to listen to what he is saying, you won't listen to us when we have pointed out the same thing.

Anyways, all I can say since you do not have motivation to try to change things following proper chanels and your poll shows many in the trade do not see a concern and even see it as being legal (as I do) if in compliance with NEC 110.3(B) I can't help you, but I will say good luck.

You wanna talk about ground up or ground down now?

Roger

 

[CAM]

Nobody has been talking about "Classified"?

Roger

Um... ALL cable tray is Classified. It is never anything else. So what is it you have been talking about???

 

[CAM]

So, it appears the chief electical inspector in Detroit might not allow any cable tray to be installed in his jurisdiction as UL does not have a listing for cable tray. But in reality he is saying the tray must be installed per manufacturer's instructions as required by 110.3

What is Mr. Hammett's ruling if the tray is installed as support only and not as an EGC? Or has he interpreted the code phase "permitted" to mean required?

2005 NEC 392.5(E) which is currently adopted by the State of Florida ? specifically calls for fittings to change direction ? 392.5 (A), (B), (C), (D), (are) also affected by field modifications and would not be acceptable.
Victor Lombardi Acting Electrical Director
Miami-Dade County Building Department

Again, opinions vary, but I have seen a lot of differing reasons why my photos are violations..

 

[iwire]

According to the AHJ in Detroit, only Listed products have instructions attached or evaluated. Classified products do not and therefore it is up to the AHJ whether or not to accept field modifications.

It sure is and that applies to listed and classified equipment.

Straight from the UL General directory top you.

What happens to the Listing if a UL-Listed product is modified in the field?


An authorized use of the UL Mark is the manufacturer’s declaration that the product was originally manufactured in accordance with the applicable requirements when it was shipped from the factory. When a UL-Listed product is modified after it leaves the factory, UL has no way to determine if the product continues to comply with the safety requirements used to certify the product without investigating the modified product. UL can neither indicate that such modifications ‘‘void’’ the UL Mark, nor that the product continues to meet UL’s safety requirements, unless the field modifications have been specifically investigated by UL. It is the responsibility of the Authority Having Jurisdiction (AHJ) to determine the acceptability of the modification or if the modifications are significant enough to require one of UL’s Field Engineering Services staff members to evaluate the modified product. UL can assist the AHJ in making this determination.

Again, opinions vary, but I have seen a lot of differing reasons why my photos are violations..

I see no violations in your photos, it is only your own opinion that there are violations.

 

[CAM]

I see no violations in your photos, it is only your own opinion that there are violations.

Once again, in case you missed it, each quote from an AHJ is in direct response to the same photos. Apparently it is not "only (my) opinion"...

You are correct in advising that UL Classification is voided by their modification of (basket tray). Any change to a product requires a re-testing and re-labeling for the new use or application.
Sydney Lester Manager
Fire Protection/Elevator/Electrical Technical Review
Permit Operations Division
Department of Consumer & Regulatory Affairs
Washington DC

 

[CAM]

It sure is and that applies to listed and classified equipment.

Straight from the UL General directory top you.

Hm. This looks suspiciously like what I have been saying from the start. And nice of you to print the quote from the document I linked. It's clearer that way.

 

[iwire]

Hm. This looks suspiciously like what I have been saying from the start. And nice of you to print the quote from the document I linked. It's clearer that way.

Really, it seems you have selective reading issues. :grin:

Unless I missed something you have been saying your pictures show a violation.

I see two problems with that assessment:

1) 110.3(B) says we must follow the directions, the directions tell us we can cut it and bend it the product.

2) When a listed product is modified it is not automatically a violation, it is up to the AHJ to decide that. Most AHJs are fine with any modifications that are shown in the instructions.

At this point it has become clear you have no interest at all in listening to anyone's opinion but your own so good luck with whatever your agenda is.

 

[iwire]

Once again, in case you missed it, each quote from an AHJ is in direct response to the same photos. Apparently it is not "only (my) opinion"...

One AHJ out 1,000s that means damn little does it not?

Care to show us how the question was presented to that AHJ.

 

[CAM]

2) When a listed product is modified it is not automatically a violation, it is up to the AHJ to decide that. Most AHJs are fine with any modifications that are shown in the instructions.

My opinion is that I wouldn't think you could cut and make your own fittings in the field.
Vince Metallo Code Enforcement Officer III
Baltimore County Electrical Inspection

At this point it has become clear you have no interest at all in listening to anyone's opinion but your own so good luck with whatever your agenda is.

Read my original post and you will see what I am soliciting opinion on and about. You're partly right on listening to opinions - I am interested in listening to opinions on why contractors or engineers think AHJ's haven't enforced the Code - just as my first post said. I am not really interested in what contractors or engineers think does or doesn't violate code since it's not their decision to make.

(T)he City of Houston would not consider a field modification to a basket tray as shown in your attachments. This type of modification affects the structural integrity of the supports and would be deemed as violating the UL listing.
Sheila W. Blake CBO, MBA, LEED AP
Assistant Director
City of Houston Code Enforcement

 

[CAM]

One AHJ out 1,000s that means damn little does it not?

Care to show us how the question was presented to that AHJ.

I guess that depends on whether you work in the jurisdiction doesn't it? It means a lot if you have done what the photos show and the inspector pays attention to it I'd think.

I haven't worked my way up to CT in contacting AHJ's yet. But in NYC, the head of ECRIC assured me that there was zero cut/bent tray in Manhattan. Clearly then the inspectors just haven't paid any attention because it's in a lot of buildings there. So back to my first post - why haven't they been paying attention?

As for the question I posed, again for the umpteenth time, the same photos I posted here and the same verbiage. You want me to copy you when I get around to asking the AHJ's in Connecticut so you can see for yourself the process?

I have my own opinion in answer to my original question, but I am not sharing it just yet.

 

[roger]

Really, it seems you have selective reading issues.:grin:

Now that's an understatement :grin:

At this point it has become clear you have no interest at all in listening to anyone's opinion but your own so good luck with whatever your agenda is.

I have a suspicion we are being trolled .

Roger

 

[augie47]

.......................
I have a suspicion we are being trolled .

Roger

you think :grin:

 

[jumper]

You wanna talk about ground up or ground down now?

Roger

Now, that is too important of an issue to be discussed in this silly thread.

 

[iwire]

I have a suspicion we are being trolled .

It sure seems that way.:roll: