EVSE

[wwhitney]

It simply says the outlet shall 'have' GFCI protection 'for personnel'. It does not call for protection of wiring and equipment.

You are misparsing it. "Ground-fault circuit-interrupter protection for personnel" means Class A GFCI. The "for personnel" means the trip level is 4-6 ma, in contrast to a Class B GFCI, or GFPE or something else.

So the requirement is that if you impose a 6 ma ground fault at the outlet, the GFCI trip. That can't happen when the GFCI is downstream of the outlet.

Cheers, Wayne

 

[jaggedben]

You are misparsing it. "Ground-fault circuit-interrupter protection for personnel" means Class A GFCI. The "for personnel" means the trip level is 4-6 ma, in contrast to a Class B GFCI, or GFPE or something else.

So the requirement is that if you impose a 6 ma ground fault at the outlet, the GFCI trip. That can't happen when the GFCI is downstream of the outlet.

You are completely making up the 'at the outlet' part. The location of a fault is where personnel would touch the device being used. The only implied location requirement is that the GFCI device be permanently installed and thus enforceable under the scope of the NEC.

 

[wwhitney]

You are completely making up the 'at the outlet' part.

210.8(F) says "All outdoor outlets for dwellings . . . shall have ground-fault circuit-interrupter protection for personnel."

If it's downstream of the outlet, the outlet doesn't have protection. So I'm puzzled by your comments.

Cheers, Wayne

 

[jaggedben]

I'm not agreeing that a receptacle or hardwired EVSE is downstream of the outlet or that the precise location of the outlet is important (or determinable).

Everybody agrees that an outlet with a GFCI receptacle installed 'has' the required protection. So if you're confused about where the outlet is, and you think it matters, work backwards from there to make sense of it. (My advice: Don't. It's not necessary and doesn't matter.) My argument is simply that an EVSE with integral sufficient GFCI is equivalent to the GFCI receptacle in these matters , simply based on the fundamental similarities of a receptacle and any other equipment permanently installed at the end of the wiring method with respect to Article 100 definitions.

If you need further evidence that the NEC can recognize that GFCI protection can 'be provided' by the equipment or appliance itself, see 422.5(B)(5).

 

[wwhitney]

I'm not agreeing that a receptacle or hardwired EVSE is downstream of the outlet or that the precise location of the outlet is important (or determinable).

To me it is cut and dried--the outlet is the point where you must have protection. So determining the outlet location relative to the GFCI protection (upstream or downstream) is critical to applying 210.8(F).

For utilization equipment , the outlet is where the premises wiring connects to the equipment wiring. That point has to have the GFCI protection. Ergo, GFCI protection provided within the equipment does not comply with 210.8(F).

For the case of an EVSE, it is arguable that it is not utilization equipment, and that the EV is the utilization equipment, the EVSE is part of the premises wiring, and the outlet is the J1772 plug. In which case GFCI protection provided by the EVSE (if it is Class A) would comply with 210.8(F). But an EVSE is an unusual case, and this is the only viable avenue for arguing that an EVSE that provides Class A GFCI protection does not require upstream protection under 210.8(F).

Everybody agrees that an outlet with a GFCI receptacle installed 'has' the required protection.

Yes, because the receptacle is part of the premises wiring, and the outlet is at the wipers of the receptacle.

If you need further evidence that the NEC can recognize that GFCI protection can 'be provided' by the equipment or appliance itself, see 422.5(B)(5).

If anything, the contrast between 422.5 and 210.8 supports the above analysis. As 422.5 requires the appliance to have GFCI protection, and lists the options for complying with that, while 210.8 requires either the receptacle or the outlet to have GFCI protection.

So if EVSEs were listed in 422.5, and were exempt from 210.8, then I would completely agree with your position on a hypothetical EVSE with Class A GFCI protection. But that's not what the NEC currently says.

Cheers, Wayne

 

[wwhitney]

If anything, the contrast between 422.5 and 210.8 supports the above analysis.

For example, say you have a tire inflation machine (required under 422.5 to have GFCI protection) which comes with a whip for hard-wiring, and it has internal factory installed GFCI protection. That GFCI protection complies with 422.5.

But now say it is installed outdoors at a dwelling unit, so 210.8(F) applies. That requires GFCI protection of the outlet, not just the equipment. The outlet is at the end of the whip where it is connected to the premises wiring. So the GFCI within the equipment does not satisfy 210.8(F), and upstream GFCI within the premises wiring system will be required to protect the outlet.

That is why (2020) 422.5(A) has an informal note at the end: "Section 210.8 specifies requirements for GFCI protection for the branch-circuit outlet where the covered location warrants such protection."

Cheers, Wayne

 

[jaggedben]

Nothing you're saying here is swaying my opinion.

I think where you're going wrong is treating the outlet like it's a very precise location. I know Article 100 uses the word 'point' but that's not meant like the mathematical definition of point. For one thing, every circuit involves at least two wires so any outlet must involve at least two mathematical points. But I think it's meant like when you're driving down the highway and you see a sign that says 'Vista Point' and you turn off and end up in a parking lot. (And the one at the north end of the Golden Gate Bridge has how many parking spaces?) As long as you are in the parking lot you are still at the point. As long as you are in either the device that is wired to the premises wiring system, or the enclosure where that wiring occurs, inclusive, you are still at the outlet. So debating where within that area a GFCI function is wired is, in my opinion, unnecessary and irrelevant.

I think the only real substantive question left here that pertains to the OP is whether the Tesla Wall Connector's GFCI function meets the Class A requirements in Article 100. If it does, then no other GFCI should be needed. If it doesn't, then it's instructions contradict the NEC for many and possibly all installations so it can't be installed where the NEC applies. While I'm no fan of Tesla, I think the latter conclusion would be an incredibly stupid result.

There's also the fact that the GFCI requirements in 210.8(F), 625.17, 625.22, 625.54 and possibly the UL standard are duplicative and confusing, and that 625 repeatedly steps outside the scope of the NEC.

 

[tortuga]

Any wiring before the 'outlet point' would be the branch circuit. The outlet point and anything after the outlet is what joe six pack can plug into or his kid can and thats who needs the GFCI protection.
So in this case of a hardwired charger outdoors of any amperage I'd say the outlet is the cord that plugs into the car.

I do agree with Don that a UL listing can not override code, whenever there is a discrepancy between manufacturers instructions and the NEC and I have taken the time to contact the manufacturer they say the NEC prevails.

 

[wwhitney]

I think where you're going wrong is treating the outlet like it's a very precise location. I know Article 100 uses the word 'point' but that's not meant like the mathematical definition of point.

OK we have identified where we disagree. To me it means a pretty precise point, as close to the mathematical definition of point as is reasonable given the context. The only necessary "breadth" of that point is because as you say the circuit has 2 or more conductors, so it's really 2 or more spatially close points. So it's more like "point on a one line diagram."

Other than this one issue, I think we are basically in agreement. I'll just close by noting again your interpretation renders the Informational Note on 422.5(A) pointless. That's not very strong evidence, as Informational Notes are not enforceable, but I'll look up the PI that added it and see if any of the commentary sheds light on this. [Nope, it came from a Second Revision and the committee statement on the revision is silent on the informational note.]

Cheers, Wayne

 

[wwhitney]

whether the Tesla Wall Connector's GFCI function meets the Class A requirements in Article 100.

I thought it was suspicious that it didn't say Class A GFCI in the manual for the Gen 3 Tesla Wall Connector, so I took a closer look and I see that the specs say "Ground Fault Circuit Interrupter -- Integrated, no additional required (CCID20)".

CCID20 is apparently at a term from UL 2231-2 "Personnel Protection Systems for Electric Vehicle (EV) Supply Circuits: Particular Requirements for Protection Devices for Use in Charging Systems," and it refers to a trip threshold of 15-20 ma.

So, in fact, the Gen 3 Tesla Wall Connector does not include Class A GFCI protection, and our discussion about the "outlet" location is moot for this product. If it's cord and plug connected, or if it's installed outdoors at a dwelling unit on a branch circuit of 50A or less, the NEC requires Class A GFCI protection, which the product does not provide on its own.

Thus the comment in the manual "no additional required" is often incorrect for installations subject to the NEC.

Cheers, Wayne

 

[don_resqcapt19]

That's true for the 2020 NEC, but the 2023 NEC extended 210.8(F) to include garages, accessory buildings, and boathouses. So at a dwelling, a 50A or less EVSE in the garage will require GFCI protection under the 2023 NEC.

Cheers, Wayne

It still only applies to outdoor outlets at those buildings.

210.8(F) Outdoor Outlets.
For dwellings, all outdoor 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: ...

However the use of the word "in" can be confusing. I have a PI to replace "in" with "at" for clarification.

 

[wwhitney]

It still only applies to outdoor outlets at those buildings.

I'm not sure I agree. The use of the word "including" does seem to be in conflict with the use of the word "in." But the intention could just as easily be that "including" was meant to be "along with," rather than that "in" was meant to be "at."

If it's only for outdoor outlets, why does it matter what the elevation of the floor level of the garage is? That would make no sense, an outlet on the outside of the garage would be subject to the same hazards if the garage floor is above grade.

The relevant part of the Committee Statement regarding the First Revision that let to this change (I didn't check the Second Draft or NITMAM):

"This section was modified to expand coverage of GFCI protection for dwelling outdoor outlets. The addition of these outlets address similar safety hazard exposures and should be afforded with the same level of protection as a receptacle outlet on the exterior of a dwelling unit."

Cheers, Wayne

 

[don_resqcapt19]

I'm not sure I agree. The use of the word "including" does seem to be in conflict with the use of the word "in." But the intention could just as easily be that "including" was meant to be "along with," rather than that "in" was meant to be "at."

If it's only for outdoor outlets, why does it matter what the elevation of the floor level of the garage is? That would make no sense, an outlet on the outside of the garage would be subject to the same hazards if the garage floor is above grade.

The relevant part of the Committee Statement regarding the First Revision that let to this change (I didn't check the Second Draft or NITMAM):

"This section was modified to expand coverage of GFCI protection for dwelling outdoor outlets. The addition of these outlets address similar safety hazard exposures and should be afforded with the same level of protection as a receptacle outlet on the exterior of a dwelling unit."

Cheers, Wayne

The title governs...If I am not outside, I don't even look at the section.

 

[Bill Snyder]

FWIW (and I find it hard to tell if this has been said or what's still being argued about)...

In this picture the liquidtight is supplied by the installer so the outlet is at the EVSE. (Other EVSE manufacturers provide factory liquidtight whips so then you could say the outlet at the j-box, but I don't think this is an important difference.)

The OP provided a snapshot of some instructions for this same unit in post #5. Since this is a hardwired unit which includes GFCI protection, no additional GFCI protection (such as a circuit breaker) is required. If installed outside with a 50A breaker or less, then the EVSE itself satisfies the requirements of 210.8(F).

Thus, there is no conflict here between the manufacturers instructions and NEC requirements. In fact, if installed inside or with a 60A breaker, the unit exceeds NEC requirements.

I agree with you but if you are right then that would say there is no outlet at a hardwired A/C unit and they don't like that narrative.

 

[Bill Snyder]

I'm not sure I agree. The use of the word "including" does seem to be in conflict with the use of the word "in." But the intention could just as easily be that "including" was meant to be "along with," rather than that "in" was meant to be "at."

If it's only for outdoor outlets, why does it matter what the elevation of the floor level of the garage is? That would make no sense, an outlet on the outside of the garage would be subject to the same hazards if the garage floor is above grade.

The relevant part of the Committee Statement regarding the First Revision that let to this change (I didn't check the Second Draft or NITMAM):

"This section was modified to expand coverage of GFCI protection for dwelling outdoor outlets. The addition of these outlets address similar safety hazard exposures and should be afforded with the same level of protection as a receptacle outlet on the exterior of a dwelling unit."

Cheers, Wayne

If only that had technical merit.

 

[Bill Snyder]

Nothing you're saying here is swaying my opinion.

I think where you're going wrong is treating the outlet like it's a very precise location. I know Article 100 uses the word 'point' but that's not meant like the mathematical definition of point. For one thing, every circuit involves at least two wires so any outlet must involve at least two mathematical points. But I think it's meant like when you're driving down the highway and you see a sign that says 'Vista Point' and you turn off and end up in a parking lot. (And the one at the north end of the Golden Gate Bridge has how many parking spaces?) As long as you are in the parking lot you are still at the point. As long as you are in either the device that is wired to the premises wiring system, or the enclosure where that wiring occurs, inclusive, you are still at the outlet. So debating where within that area a GFCI function is wired is, in my opinion, unnecessary and irrelevant.

I think the only real substantive question left here that pertains to the OP is whether the Tesla Wall Connector's GFCI function meets the Class A requirements in Article 100. If it does, then no other GFCI should be needed. If it doesn't, then it's instructions contradict the NEC for many and possibly all installations so it can't be installed where the NEC applies. While I'm no fan of Tesla, I think the latter conclusion would be an incredibly stupid result.

There's also the fact that the GFCI requirements in 210.8(F), 625.17, 625.22, 625.54 and possibly the UL standard are duplicative and confusing, and that 625 repeatedly steps outside the scope of the NEC.

Ask any of these people to point out the location it is ridiculous that they are pushing this for no reason. There was a child's tragic death in 2007 but the A/C unit was not wired with an EGC and CMP-2 got greedy and tried to expand class A protection to everything they were quoted stating that dwelling units were just the beginning and we say it's the end of meritless expansion.

 

[tortuga]

CCID20 is apparently at a term from UL 2231-2 "Personnel Protection Systems for Electric Vehicle (EV) Supply Circuits: Particular Requirements for Protection Devices for Use in Charging Systems," and it refers to a trip threshold of 15-20 ma.

So, in fact, the Gen 3 Tesla Wall Connector does not include Class A GFCI protection

Thats interesting and very unfortunate, thanks for digging into that.
I wonder and hope Tesla can fix that with a firmware update for US devices.
The old Blink ones I have serviced had a CT feeding an analog input to a microcontroller, so I believe all the protection was done in software and was at 5ma.
I could also see the auto industry digging into their deep pockets to pay for a peer reviewed study that demonstrates 15-20ma of protection is sufficient, as thats whats accepted overseas.

 

[LarryFine]

Ask any of these people to point out the location . . .

In my opinion, either 2 or 3/5, depending on whether the whip is part of the appliance.

 

[Bill Snyder]

In my opinion, either 2 or 3/5, depending on whether the whip is part of the appliance.

So a GFCI receptacle installed outdoors is hardwired to an outlet and requires GFCI protection?

 

[ActionDave]

Ask any of these people to point out the location it is ridiculous that they are pushing this for no reason. There was a child's tragic death in 2007 but the A/C unit was not wired with an EGC and CMP-2 got greedy and tried to expand class A protection to everything they were quoted stating that dwelling units were just the beginning and we say it's the end of meritless expansion.

Do you use a keyboard are you talking into a phone when you post?