EVSE and GFCI PROTECTION

[ramsy]

..right now none of them provide protection equal to a UL 943 Class A GFCI device.

The IAEI article below appears to confuse alterating current RCD devices, rated for 6mA, with circuits modified from a standard ANSI/UL 943 device.

IAEI Article
For AC pass-through charging stations, the primary system is listed according to ANSI/UL 2594 (Electric Vehicle Supply Equipment). For off-board DC charging, we rely on ANSI/UL 2202 (Electric Vehicle (EV) Charging System Equipment). Any of these systems perform a modified ground-fault circuit interrupt function, with the related safety components complying to ANSI/UL 2231-1/-2 (Personnel Protection Systems for Electric Vehicle (EV) Supply Circuits). These safety circuits are modified from a standard ANSI/UL 943 device to prevent excessive nuisance tripping during overnight charging events.

 

[Rjryan]

625.54 GFCI PROTECTION FOR PERSONNEL. All receptacles installed for connection of electric vehicle charging shall have GFCI for personnel.
The explanation under this code section,(typed above) there is a distinction made between hard wired and a receptacle connection. My question really was why GFCI needed receptacles but left up to the manufacturer if hard wired. If I am understanding this right, RCD (European name for GFCI) are built into EVSE's by industry standards. My next question is, no GFCI can be attached to the load side of another or they will interfere with each other? A little confusing.The NEC seems straight forward, but in reality this seems confusing. Straighten me out.

Spent the morning speaking with a senior engineer at UL. This is what I got from the conversation:
1. Receptacle powered EVSEs are treated differently than hardwire EVSE because of the ground. A hardwired EVSE has a secured ground where
a receptacle ground is subject to missing ground pin or a bad connection.
2. RCDs are built into a hard wired EVSE. A RCD is not exactly the same as a GFCI but also protect personnel from current faults.
3. You might see other than a 6mA rating on a hardwired EVSE, because UL standards take 3 things into consideration (a) frequency (b) time it takes to shut down the EVSE and (c) actual mAs. If the EVSE has a UL approval it meets NEC requirements and UL standards for personnel protection.

 

[wwhitney]

RCDs are built into a hard wired EVSE. A RCD is not exactly the same as a GFCI but also protect personnel from current faults.

That's fine, and the RCDs provide the "listed system of protection against electric shock of personnel" required by NEC 625.22. However, they can not provide the GFCI protection for personnel required by 625.54 for any receptacle supplying the EVSE.

And if the EVSE is in a location for which 210.8(F) requires GFCI protection of the outlet, the RCD can't possibly provide that unless it is also listed as a GFCI. Which is not the case for any currently commercially available EVSE I'm aware of. If you found an EVSE in which the internal RCD is also listed as a GFCI, and you hardwired such an EVSE in a location subject to 210.8(F), then we could have a debate as to where the "outlet" is located, which would determine whether the internal RCD/GFCI of this mythical EVSE would protect it.

Cheers, Wayne

 

[Knuckle Dragger]

I'm curious how using a standard breaker vs a GFCI breaker is a big saver on time and material. Sure the breaker is ~$100 more but this gets charged to the customer. Time wise the only difference is landing the line neutral on the neutral buss which should take less than a minute.

It's the nusence trips more than anything else.
When ever I can I'll install an small outdoor sub panel with the GFCI circuit breaker right beside the receptacle so the home owners can reset the breaker conveniently.

 

[ramsy]

Spent the morning speaking with a senior engineer at UL. This is what I got from the conversation:
..If the EVSE has a UL approval it meets NEC requirements and UL standards for personnel protection.

Thank you for helping clarify that.

 

[wwhitney]

If the EVSE has a UL approval it meets NEC requirements and UL standards for personnel protection.

Only NEC 625.22, not NEC 625.54 if applicable, nor NEC 210.8(F) if applicable (at least for currently available products).

Cheers, Wayne

 

[Rjryan]

That's fine, and the RCDs provide the "listed system of protection against electric shock of personnel" required by NEC 625.22. However, they can not provide the GFCI protection for personnel required by 625.54 for any receptacle supplying the EVSE.

And if the EVSE is in a location for which 210.8(F) requires GFCI protection of the outlet, the RCD can't possibly provide that unless it is also listed as a GFCI. Which is not the case for any currently commercially available EVSE I'm aware of. If you found an EVSE in which the internal RCD is also listed as a GFCI, and you hardwired such an EVSE in a location subject to 210.8(F), then we could have a debate as to where the "outlet" is located, which would determine whether the internal RCD/GFCI of this mythical EVSE would protect it.

Cheers, Wayne

As for hardwired , if the outlet is outside and a dwelling the 210.8(F) would require GFCI protection up to 50 amps. EVSE that require hardwiring are over 50 amps.

 

[jaggedben]

...EVSE that require hardwiring are over 50 amps.

Not necessarily.

 

[jim dungar]

.... If the EVSE has a UL approval it meets NEC requirements....

I don't think UL can speak for the NEC. Well maybe for 110.3, but it is ultimately only AHJ can make the final decision.

 

[tortuga]

Spent the morning speaking with a senior engineer at UL. This is what I got from the conversation:

3. You might see other than a 6mA rating on a hardwired EVSE, because UL standards take 3 things into consideration (a) frequency (b) time it takes to shut down the EVSE and (c) actual mAs. If the EVSE has a UL approval it meets NEC requirements and UL standards for personnel protection.

Sounds like the problem HVAC equipment tripping 2-pole GFCI's.
I still think the manufacturers need to bite the bullet and QA their circuits, if a spa and pool pump motor don't trip a GFCI I dont think a car on 4 insulated tires should either. We had the RCD vs GFCI debate a while back.
Worst case if there is some reason we cant go GFCI then don't re-invent the wheel and we should put RCD's in the code for equipment.

 

[ramsy]

I don't think UL can speak for the NEC.

Does the NEC apply to end use equipment?

 

[jim dungar]

Does the NEC apply to end use equipment?

The issue is UL effectively saying, 'if UL approves something, it can be installed per the NEC', but per the NEC all equipment approvals must come from the AHJ.

 

[tortuga]

Does the NEC apply to end use equipment?

The NEC applies to end use equipment [90.2(E) 90.2(C)(6)], its just a question of who needs to inspect the equipment. Listed equipment is inspected by a testing lab to the NEC and other applicable standards that are up to the particular lab [90.7].
A construction inspector need not inspect 'listed' equipment again.
Anyone is free to make a voluntary product standard but if there is a conflict with the NEC the NEC prevails.
Product standards are voluntary, the NEC is law (where its adopted).
Sections in the NEC called 'construction specifications' historically where larger and are intended for manufacturers.

 

[Fred B]

Am I reading 625.54 correctly, if EVSE is plug and cord connected it must be GFCI protected, but if direct connected only if the manufacture specifies in the instructions? So in direct connecting an outlet for an EVSE it would be possible to skip the GFCI, UNLESS CALLED FOR BY THE MANUFACTURE. This could be a big cost savings in time and material if true. What am I missing?

625.54 is rather simple and clear that the GFCI requirement is strictly related to a receptical outlet - direct wire is exempt.
625.54 Ground-Fault Circuit-Interrupter Protection for Personnel.
All receptacles installed for the connection of electric vehicle charging shall have ground-fault circuit-interrupter protection for personnel.

Chapters 5,6,7 modifies or adds to requirements found in Chapters 1-4, thus discussion of chapter 2 requirement of gfci on "outlets" is modified by chapter 6.

 

[jaggedben]

625.54 is rather simple and clear that the GFCI requirement is strictly related to a receptical outlet - direct wire is exempt.
625.54 Ground-Fault Circuit-Interrupter Protection for Personnel.
All receptacles installed for the connection of electric vehicle charging shall have ground-fault circuit-interrupter protection for personnel.

Chapters 5,6,7 modifies or adds to requirements found in Chapters 1-4, thus discussion of chapter 2 requirement of gfci on "outlets" is modified by chapter 6.

Chapter 6 only modifies chapter 2 if it clearly says so, or there's a conflict. That is not the case here.

 

[tortuga]

A few states like Oregon amend 210.8(F) like so, not out of ignorance of safety but due to nuisance tripping:

Outdoor Receptacles Outlets. For dwellings, aAll outdoor general-purpose receptacles outlets, other than those
covered in 210.8(A), Exception No. 1, including outlets installed in the following locations, and supplied by single-
phase branch circuits rated 150 volts or less to ground, 50 amperes or less, shall be provided with GFCI protection.:
(1) Garages that have floors located at or below grade level
(2) Accessory buildings
(3) Boathouses
If equipment supplied by an outlet covered under the requirements of this section is replaced, the outlet shall be
supplied with GFCI protection.
Exception No. 1: GFCI protection shall not be required on lighting outlets other than those covered in 210.8(C).
Exception No. 2: GFCI protection shall not be required for listed HVAC equipment. This exception shall expire
September 1, 2026.
Informational Note: This requirement does not apply to specific-use receptacles that are regulated by other sections in this
code such as 551.71.

Also skimming over complex UK RCD requirements it appears they use a 10ma one for wet locations , so presumably now were down to a 5ma difference between NEC and IEC but we'd need one of our UK members on here to confirm that?

I know I sound like a broken record but I've done quite a few pools and spa's over the years and they can contain plenty of electronics, LV 12V lighting, contactors, motors and controls that are grounded to the nines on the best grounding plane the NEC offers with solid copper grounds everywhere, and we dont have a huge GFCI issue.
I just don't see how car manufacturers can have a hard time with a car tripping a GFCI, but in a way I can becasue I have always had problems with electrical leaks in trucks. I remember when I had to put a huge kill switch on a the - terminal of friends old dodge pickup becasue nobody could figure out what was draining the battery.

 

[retirede]

A few states like Oregon amend 210.8(F) like so, not out of ignorance of safety but due to nuisance tripping:

Also skimming over complex UK RCD requirements it appears they use a 10ma one for wet locations , so presumably now were down to a 5ma difference between NEC and IEC but we'd need one of our UK members on here to confirm that?

I know I sound like a broken record but I've done quite a few pools and spa's over the years and they can contain plenty of electronics, LV 12V lighting, contactors, motors and controls that are grounded to the nines on the best grounding plane the NEC offers with solid copper grounds everywhere, and we dont have a huge GFCI issue.
I just don't see how car manufacturers can have a hard time with a car tripping a GFCI, but in a way I can becasue I have always had problems with electrical leaks in trucks. I remember when I had to put a huge kill switch on a the - terminal of friends old dodge pickup becasue nobody could figure out what was draining the battery.

I don’t think it’s the vehicle. Some EVSEs work fine on GFCI, while others don’t. Even on the same vehicle.


Sent from my iPad using Tapatalk

 

[brycenesbitt]

Nothing that we can read there, but it doesn't matter what they have to say, unless what they say makes it into the NEC.

 

[Fred B]

Chapter 6 only modifies chapter 2 if it clearly says so, or there's a conflict. That is not the case here.

2023NEC 625.54 Ground-Fault Circuit-Interrupter Protection for Personnel.
All receptacles installed for the connection of electric vehicle charging shall have ground-fault circuit-interrupter protection for personnel.
Enhanced content. Direct from NFPA Link:
Portable and fastened-in-place EVSE and WPTE that are permitted to be cord-and plug-connected must be supplied through a GFCI-protected receptacle. This includes all the single- and three-phase receptacle configurations specified in 625.44(A) and (B). The outlet supplying direct-connected EVSE is not required to be GFCI protected, unless specified in the manufacturer’s instructions.
Until It stated directly otherwise by the code the requirements of 625 do supercede chapter 1-4 that conflict with the statements in 625.

 

[don_resqcapt19]

View attachment 2570824

We will see if this public input was accepted by CMP 12 on July 10. 2024. If this is an accepted change, that would be the specific modification of a rule in Chapter 2 by a rule in Chapter 6.