Does under-cabinet lighting receptacle installed in cabinet require GFCI protection?

[hurk27]

But the point is, it is not intended to serve the countertop surface. Say it's a duplex receptacle and two under-cabinet luminaries are to be plugged into it. GFCI protection required or not?

If it is in the wall not in the cabinet at 16" above then it would clearly require GFCI protection as it can be reached by a kitchen appliance cord intended or not, and can be considered serving the counter top, lights plugged in or not, the code is kind of bland in 210.8 in the way it just says receptacles serving the counter top, the same goes for a bathroom we wouldn't argue that any receptacle in a bathroom is required to be GFCI protected if it is an installed receptacle no matter what it was installed for (not the one inside of a bath fan that is a part of the fan)

Heres another problem that could come up, there was an allowance for receptacle mounted on the bottom of the cabinets facing down to allow for designs where some do not want the receptacles visible to be included in the required receptacles for the countertop 2'/4' rule.

Here is a quote from the 2011 hand book on this:

The maximum permitted height (20 in.) for a receptacle
outlet serving a countertop is based on the standard dimension
measured from the countertop to the bottom of the cabinets
located above the countertop. This provision allows
multioutlet assemblies installed on the bottom of the upper
cabinets to be used as the required countertop receptacle
outlet(s).

So if the receptacle can be used also for the counter top is has to be GFCI protected even if it is cut into the cabinet but facing down, sure one could say that it is in the cabinet but the fact remains that the receptacle is accessible from the counter top if it is within 20" I would even say if any appliance cord could reach it which would be 24" but that is stretching it, that is why I said as you did that if it is inside of the cabinet it is no longer accessible from the counter top as the distance would be too long.

Myself I would look at it from a liability point of view, if a homeowner were to plug in a faulty appliance into a receptacle that could be accessible from the counter top, how would you defend yourself if they were electrocuted? refrigerator and other fixed in-place appliance receptacles are clear they don't need GFCI protection as well as receptacles located "inside" of cabinets as we both agree on, these you would have an out if it came to a court battle but not one facing down in the bottom of a cabinet.

We all know Joe homeowner will unplug a light, sump pump, or even a garage door opener, if they needed another outlet, it was this reason they removed the exception to garages and basements and even went as far as to even require a GDO receptacle to be GFCI protected, and yes I have seen extension cords run to the GDO outlet because there was only one outlet for the whole garage installed.

 

[iwire]

If it is in the wall not in the cabinet at 16" above then it would clearly require GFCI protection as it can be reached by a kitchen appliance cord intended or not, and can be considered serving the counter top,

You seem to be saying things that are in direct contradiction.

The code uses the word 'intended', in smarts example they are not intended to serve the countertop. End of story as far as the code IMO, no GFCI required

 

[Smart $]

You seem to be saying things that are in direct contradiction.

The code uses the word 'intended', in smarts example they are not intended to serve the countertop. End of story as far as the code IMO, no GFCI required

I appreciate the support. However, Code does not use the word 'intended' for this particular requirement, though it does infer contingent upon purpose.

(6) Kitchens? where the receptacles are installed to serve the countertop surfaces

 

[Smart $]

If it is in the wall not in the cabinet at 16" above then it would clearly require GFCI protection as it can be reached by a kitchen appliance cord intended or not, and can be considered serving the counter top, lights plugged in or not, the code is kind of bland in 210.8 in the way it just says receptacles serving the counter top, the same goes for a bathroom we wouldn't argue that any receptacle in a bathroom is required to be GFCI protected if it is an installed receptacle no matter what it was installed for (not the one inside of a bath fan that is a part of the fan)

Heres another problem that could come up, there was an allowance for receptacle mounted on the bottom of the cabinets facing down to allow for designs where some do not want the receptacles visible to be included in the required receptacles for the countertop 2'/4' rule.

Here is a quote from the 2011 hand book on this:


So if the receptacle can be used also for the counter top is has to be GFCI protected even if it is cut into the cabinet but facing down, sure one could say that it is in the cabinet but the fact remains that the receptacle is accessible from the counter top if it is within 20" I would even say if any appliance cord could reach it which would be 24" but that is stretching it, that is why I said as you did that if it is inside of the cabinet it is no longer accessible from the counter top as the distance would be too long.

Myself I would look at it from a liability point of view, if a homeowner were to plug in a faulty appliance into a receptacle that could be accessible from the counter top, how would you defend yourself if they were electrocuted? refrigerator and other fixed in-place appliance receptacles are clear they don't need GFCI protection as well as receptacles located "inside" of cabinets as we both agree on, these you would have an out if it came to a court battle but not one facing down in the bottom of a cabinet.

We all know Joe homeowner will unplug a light, sump pump, or even a garage door opener, if they needed another outlet, it was this reason they removed the exception to garages and basements and even went as far as to even require a GDO receptacle to be GFCI protected, and yes I have seen extension cords run to the GDO outlet because there was only one outlet for the whole garage installed.

Simply put, the requirement does not state where receptacles may be used to serve countertop surfaces.

 

[hurk27]

You seem to be saying things that are in direct contradiction.

The code uses the word 'intended', in smarts example they are not intended to serve the countertop. End of story as far as the code IMO, no GFCI required

So your saying that a receptacle installed in the wall at 16" above the counter top doesn't need GFCI protection? I'm not sure if I follow that since it can clearly be used to also feed appliances on the countertop, I don't think what the intended use of a receptacle is what guides us to applying the GFCI rule, otherwise I could install a receptacle in a bathroom for a night light and not have to protect it? but if it in installed in that room it must be GFCI protected as IMO any receptacle that could be used by a kitchen appliance on the counter top with a 24" cord, this was pointed out by the CMP's a few years ago when the discussion on appliance garages was questioned whether they serve the counter top or not their response was that they do serve the counter top but can not be counted in the 2'/4' rule so GFCI protection was required, and this is the problem that there is no clear definition of what is meant by "installed to serve
the countertop surfaces" if we just use this then we could say any receptacle we install to serve undercabinet lighting is exempt even if it is installed at the same hight of the other receptacles?

The 20" above and the "in cabinet" rules are only for the required 2'/4' receptacles and has nothing to do with the GFCI requirement but it could be used as a guide, but the code just doesn't spell that out.

For me unless there is a exemption like there is for fixed inplace appliances such as the receptacle behind a fridge if a 24" cord can reach it from the counter top it gets GFCI protection, thats just my own CMA for me as I don't want to end up trying to explain to a judge why a receptacle wasn't GFCI protected located on the counter top that was installed for lighting but later used for a toaster electrocuted a child.

The NEC really needs to put a definition as to what is considered serving the counter top is, although is seems common sense would say if it can be reached from the counter top with a 24" cord then it serves the counter top.

Remember the 6' rule around sinks in other areas was based upon 6' appliance cords

 

[Smart $]

...

The 20" above and the "in cabinet" rules are only for the required 2'/4' receptacles and has nothing to do with the GFCI requirement but it could be used as a guide, but the code just doesn't spell that out.

...

I disagree. I say it does have to do with the GFCI requirement.

(6) Kitchens? where the receptacles are installed to serve the countertop surfaces​

​

The "20" above... rule" is in 210.52(C)(5)...

210.52 Dwelling Unit Receptacle Outlets.
(C) Countertops. In kitchens...
(5) Receptacle Outlet Location.

210.52(C) establishes "receptacles... installed to serve the countertop surfaces".


But that is not what is being debated.

...

Remember the 6' rule around sinks in other areas was based upon 6' appliance cords

Perhaps the best remedy would be the CMP's removing the excepting clause for kitchens...

(7) Sinks ? located in areas other than kitchens where receptacles are installed within 1.8 m (6 ft) of the outside edge of the sink

 

[GoldDigger]

210.8(A)(6) and 210.52(B)(5)
There are listed receptacles designed for use with dimmers.

For those who are search challenged, this is described in this thread.

Lutron Electronics has a UL listed half and full duplex receptacle that may be controlled by a dimmer switch (see their application note # 109). It is defined as a "special purpose connector" because it comes as a receptacle with a rejector-pin paired with a special plug with a receiver socket.

And it is only listed to be used with specific Lutron dimmers.

But does being a "special purpose connector" exempt it from the GCI requirement? And if not, then if the remotely located dimmer is fed from a GFCI breaker does that count?

Has anything significant changed since that 2005 thread?