differences between AHJs on low voltage mobile equipment

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passin'thru

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1st time poster, so apologies in advance for the long post.

I design mobile equipment, so I've never had to deal with NEC or AHJs previously. One of our more recent pieces of equipment does plug in to recharge the battery system. We actually require 16VDC to be provide to our equipment. The equipment uses a maximum of 2A.

The "building side" is using a 220VAC to 16VDC power supply rated at 30A output with internal overload protection. Each charging location has separate wires with 5A fuses, 6 charging outputs per power supply. Each AHJ has passed this "building side" design and wiring without issue.

Our customer is using our equipment in multiple locations across the country & each location requires this new charging system to be installed. After several dozen successfully installations, we have run into a couple of AHJs who refuse to pass inspections because our equipment that gets plugged in is not UL certified.

I have tried to browse the forum to find where the NEC requires our equipment to be UL certified but am not having much luck. A bit more background, the equipment is brought into the building and plugged in for recharging while not in use. While in use, it is removed from the building and disconnected from any electrical system (runs on battery power). Because of shifts, the equipment spends approx 12 hours plugged in and 12 hours in use.

I am a bit at a loss here because this is my first experience with AHJ and NEC. Our company is taking the stance of getting field UL certifications for the locations were the AHJ refuses to pass the charging systems (can't fight city hall). What I am trying to determine is if this is likely to continue to crop up or be a very rare occurrence (ie: the first score of inspectors either worked off different codes or missed it - or - are there just a few jurisdictions with special rules).

thank you all in advance for you insight and opinions.
pt
 
422.60- Attach a nameplate; solves that issue. But it also sounds like your battery charger doesn't fit the definition of appliance, I'd call it a stretch--

Appliance. Utilization equipment, generally other than industrial, that is normally built in standardized sizes or types and is installed or connected as a unit to perform one or more functions such as clothes washing, air conditioning, food mixing, deep frying, and so forth.
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90.7- Also seems like a stretch to me.

Is this equipment hard-wired or does it plug in? You'll have a much harder time with hard-wired. And if it's plug-in, why do they care? If nothing else, take it away for the inspection then bring it back later.
 
Plug connected and it has a name plate. Pehaps it needs different information. We are being told that they want them to have a UL decal. The cost to do a UL feild certification is in excess of $17k.

The other AHJ says violation 17AE100877 defined by article 100 of the Calif Elec code.
 
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From what these inspectors are saying, no shop-built equipment could be used in the facility.

passin'thru said:
Plug connected and it has a name plate. Pehaps it needs different information. We are being told that they want them to have a UL decal. The cost to do a UL feild certification is in excess of $17k.
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Might be cheaper to have these built in a UL508-certified shop, who will apply a UL sticker. Not sure if your device qualifies for 508, though. (see below....)

Did they explain what NEC/CEC article requires that your device have a UL sticker? Doesn't sound like it's an "appliance" by the definition in Art. 100.

passin'thru said:
The other AHJ says violation 17AE100877 defined by article 100 of the Calif Elec code.
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Not an expert here, but it really sounds like someone is blowing smoke. The 2016 CEC is the 2014 NEC with additions, and there are no changes to Art 100. And, Article 100 doesn't define any "violations" like that (take a look at what's in there). I'd ask for the exact text being cited.

I still think it would be easier to take the device away and bring it back later. Or just buy some UL-listed 120vac to 16vdc power supplies; they're really cheap.
 
Power supplies are UL listed, they are on the building side. We are being told by the general contractor that the AHJ will not pass the construction, stating that the equipment (ours) has to be UL listed to connect to the plugs.

For future euipment builds, this wont be a problem as we can get factory UL certified and pass those costs along. These two AHJ caught us by surprise as about 30 previous AHJ did not require this.

In my quick glance at the paperwork, it didnt seem that our equipment would require UL, but this isn't a situation we have encountered and feild UL approval seemed our only option.
 
passin'thru said:
Power supplies are UL listed, they are on the building side.
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I wonder if those supplies are Class 2? Not that it *should* make a difference, but maybe it would sooth that AHJ.

passin'thru said:
The other AHJ says violation 17AE100877 defined by article 100 of the Calif Elec code.
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Is "17AE100877" even a thing? (Google gives zero hits.) Maybe that's the AHJ's internal, idiosyncratic, violation-tracking system?
 
Lawyer who represents contractors and manufacturers here (and also an electrical product manufacturer myself). Not your company's lawyer though, so this is not formal legal advice, just a general discussion. I think you should involve your company's legal department or outside counsel on this. It will probably be cheaper than UL certification, and you can develop a plan for how to avoid this problem in the future by adjusting your product and its installation process to avoid raising suspicions. My initial reaction is that none of these objections by the AHJs are likely to be legally viable if you formally appeal. Your low-voltage equipment is not required to be listed, and typically would not even be within the jurisdiction of the building inspectors. It's not part of the building's wiring system. However, you may find that the cleanest way to skip this problem altogether is to make your charging system itself cord-and-plug connected on the line-voltage side so it isn't part of the building's wiring either. That way the AHJ never sees or even thinks about your low-voltage equipment, just the listing and rating for the main power supply that plugs into a dedicated receptacle.
 
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