GFCI Protection for Receptacles in Cabinet Under Sink?

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CuriousHomeInspector

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For clarification, all of the following is considered to be inside a dwelling unit.

I know this has been kicked around before, but I haven't seen any clear stance from the NFPA on this issue. I know some municipalities use a "cord path" type length and that passing through a door (including cabinet door) negates the need for GFCI protection.

With that said it is my understanding that in past commentary 210.8(A)7 was intended for GFCI protection of receptacles within 6 ft of all OTHER sinks (indicating that it did not apply in the kitchen). That wording is not there. Is the receptacle under the sink "within 1.8 (6 ft) of the outside edge of the sink" in terms of needing GFCI protection? Is this an all encompassing measurement for each level of the home (stopping at the floor/ceiling) or a straight line distance from the edge? If it is a cord-connected path distance, does the measurement stop when it encounters a cabinet door?

Also for clarification, I get argued time and time again that laundry room washing machine receptacles are not required to be GFCI protected unless they are within 6ft of a sink. My understanding is that 210.8(A)(10) includes the washing machine receptacle, AND it must be accessible (not blocked).

Thanks for any insight.
 
If building new project it will depend which code cycle you are on and if existing home it will depend on which code cycle the home was built under.
 
I thought I had seen a local jurisdiction's clarification that the 6 feet was to be measured along the path that the cord would run from the outlet to the sink, and not a straight line from one to the other. I looked, but I did not find that in either the Washington State code or the City of Seattle amendments. That is, nevertheless, my own interpretation. My belief is based on the notion of plugging something into the receptacle and then accidently dropping that thing into the sink. If a six foot cord could not reach, the outlet does not need GFCI protection.

I agree with your interpretation on the laundry machine. The code is clear enough (it does happen sometimes) that receptacles in the laundry area require GFCI protection, regardless of whether they are close to a sink.

Welcome to the forum.
 
CuriousHomeInspector said:
For clarification, all of the following is considered to be inside a dwelling unit.

I know this has been kicked around before, but I haven't seen any clear stance from the NFPA on this issue. I know some municipalities use a "cord path" type length and that passing through a door (including cabinet door) negates the need for GFCI protection.

With that said it is my understanding that in past commentary 210.8(A)7 was intended for GFCI protection of receptacles within 6 ft of all OTHER sinks (indicating that it did not apply in the kitchen). That wording is not there. Is the receptacle under the sink "within 1.8 (6 ft) of the outside edge of the sink" in terms of needing GFCI protection? Is this an all encompassing measurement for each level of the home (stopping at the floor/ceiling) or a straight line distance from the edge? If it is a cord-connected path distance, does the measurement stop when it encounters a cabinet door?

Also for clarification, I get argued time and time again that laundry room washing machine receptacles are not required to be GFCI protected unless they are within 6ft of a sink. My understanding is that 210.8(A)(10) includes the washing machine receptacle, AND it must be accessible (not blocked).

Thanks for any insight.
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What code cycle? Earlier cycles 2008, 2011, etc. only required GFCI protection for receptacles serving the kitchen counter top. Under the sink would not need GFCI protection even if less than 6' from the sink edge.
 
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For clarification, it would be 2014 NEC with the only exceptions adopted by the state being not requiring AFCI in the kitchen or laundry room areas.

And (part of) what I'm required to report on is unsafe conditions, defined as "A condition in a readily accessible, installed system or component which is judged to be a significant risk of personal injury during normal, day-to-day use;the risk may be due to damage, deterioration, improper installation, or a change in accepted residential construction standards." So when the home was built is a non issue in this case. If it would be a safety hazard due to a change in accepted residential construction standards, it is supposed to be noted.

What I am curious about is what in the 2014 210.8(A)(7) would exclude under sink receptacles? Are they not within 6 ft of the sink? Not even saying I agree with them being GFCI protected due to not being able to find incidents of injury. Just trying to figure out what the NFPA stance is on it, and have no means to request an interpretation directly. I can request an ICC interpretation of the IRC, but in our state the electrical chapters of the IRC are basically replaced with refer to the NEC as adopted by the state.
 
IMO, if it is existing you home you can not write up a safety violation under the current code. Unless it is life and death safety (grounding wire being used as a current carry conductor).
 
edward said:
IMO, if it is existing you home you can not write up a safety violation under the current code. Unless it is life and death safety (grounding wire being used as a current carry conductor).
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And that is fine. I am however required by state laws/regulations to IDENTIFY safety hazards that exist due to changes in accepted residential construction standards. Doesn't mean somebody HAS to change it (I have no authority), just means I have to identify it and I even go as far as to note it was not likely required at time of original construction, but if enhanced safety is desired upgrade should be considered.

With that said. 2014 NEC. Why would the 6 ft rule not apply to the receptacle under the kitchen sink? I'm actually looking for an out b/c I personally think it is ridiculous, but if there is no out I have to report it for liability concerns.
 
CuriousHomeInspector said:
With that said. 2014 NEC. Why would the 6 ft rule not apply to the receptacle under the kitchen sink? I'm actually looking for an out b/c I personally think it is ridiculous, but if there is no out I have to report it for liability concerns.
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Simply because it was not required because it does not serve the counter top.
 
CuriousHomeInspector said:
And that is fine. I am however required by state laws/regulations to IDENTIFY safety hazards that exist due to changes in accepted residential construction standards. Doesn't mean somebody HAS to change it (I have no authority), just means I have to identify it and I even go as far as to note it was not likely required at time of original construction, but if enhanced safety is desired upgrade should be considered.

With that said. 2014 NEC. Why would the 6 ft rule not apply to the receptacle under the kitchen sink? I'm actually looking for an out b/c I personally think it is ridiculous, but if there is no out I have to report it for liability concerns.
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:thumbsup::thumbsup:
 
CuriousHomeInspector said:
For clarification, it would be 2014 NEC with the only exceptions adopted by the state being not requiring AFCI in the kitchen or laundry room areas.

And (part of) what I'm required to report on is unsafe conditions, defined as "A condition in a readily accessible, installed system or component which is judged to be a significant risk of personal injury during normal, day-to-day use;the risk may be due to damage, deterioration, improper installation, or a change in accepted residential construction standards." So when the home was built is a non issue in this case. If it would be a safety hazard due to a change in accepted residential construction standards, it is supposed to be noted.
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Are you supposed to identify things from an NEC edition that hasn't even been adopted yet?
 
http://i.imgur.com/1pqV5Mi.jpg <-- This is what I am referring to.

I understand that 210.8(A)(6) requires all kitchen receptacles that serve the counter top to be GFCI protected.

I also was under the impression that 210.8(A)(7) requires Sinks - where receptacles are installed within 1.8 m of the outside edge of the sink to be GFCI protected. This is in addition to 6, not a part of 6.

So would a receptacle UNDER a sink that is within 6 ft have to be GFCI protected as per the 2014 NEC? If it has cabinet doors? If it does not have cabinet doors? Regardless if it is in a kitchen or not?
 
And for clarification my understanding was that this 210.8(A)(7) was added to include living room receptacles and/or wet bar receptacles that may serve counter top surfaces, but I don't see that wording anywhere. I'm looking for the out. I agree that it is likely that the intent was not to require GFCI protection of the receptacle under the sink, but the recent addition of 210.8(D) muddies the water on that argument.
 
CuriousHomeInspector said:
And for clarification my understanding was that this 210.8(A)(7) was added to include living room receptacles and/or wet bar receptacles that may serve counter top surfaces, but I don't see that wording anywhere. I'm looking for the out. I agree that it is likely that the intent was not to require GFCI protection of the receptacle under the sink, but the recent addition of 210.8(D) muddies the water on that argument.
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The house was built before the addition. Also, maybe iwire mentioned it as part of MA building code or maybe a CMP comment, but iirc any permanent barriers such as walls, countertops, and cabinets kill the 6' straight line requirement (i.e., you arent allowed to pull a magic tape measure thru a permanent barrier to get your distance, you have to go around).

We arent on the 2014 NEC so I cannot help you there.

eta: under the 2008 NEC, 210.A(6) requires GFCI for kitchen countertop receptacles, and 210.A(7) requires receptacles within 6' of laundry, utility and wet bar sinks, not the kitchen sink.
 
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NEC 2017 clarifies the not to penetrate a cabinet because the 2014 for GFI within 6' of all sinks was poorly written -- now we have fixed barrier which can be interpreted as a trash compactor/ refrigerator IMHO though AFCI protectuion is required
 
edward said:
IMO, if it is existing you home you can not write up a safety violation under the current code. Unless it is life and death safety (grounding wire being used as a current carry conductor).
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That is the case for an electrical inspection not the case with a home inspection.
 
CuriousHomeInspector said:
But the kitchen counter top receptacle GFCI requirement is now separate from the 6 ft from sink requirement, or am I reading that wrong? The 6 ft from sinks rule doesn't not care if it is in a kitchen or not.
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Yes, for the 2014 and 2017 NEC. I was mistaken in a earlier post where I had mentioned the 2014 did not have the 6' of a sink requirement, it does. The 2011 specifies for counter top receptacles only. Pardon my error I have corrected my earlier post.
 
infinity said:
Yes, for the 2014 and 2017 NEC. I was mistaken in a earlier post where I had mentioned the 2014 did not have the 6' of a sink requirement, it does. The 2011 specifies for counter top receptacles only. Pardon my error I have corrected my earlier post.
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No worries. I spoke today with an individual from the electrical examiners board in Arkansas and they also clarified that as of now it is required, but will most likely change later this year with the 2017 code cycle change. For now you can take a string from the edge of a sink and run it 6 ft and touch a receptacle, GFCI protection is required (in Arkansas anyway).
 
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