Every place I have worked has a common practice to mount surface mount fluorescent fixtures to sheetrocked lids by punching a hole into the back of the fixture, bring the NM wire through the hole and then making up the fixture. The fixture is the junction box. Most of the holes punched are 2" done clean using a KO punch, but I have also seen butcher jobs using tin snips that leave a terrible jagged hole. The NM is not protected and certainly not connected with a proper connector. What is the rule????
