How we construe 210.12(D) - Branch Circuit Extensions or Modifications

[b_electric]

Client has a 10-unit apartment building with Zinsco sub-panels installed for each unit and his insurance carrier is requiring the sub-panels to be changed out.

I'm literally just swapping the sub-panels and breakers, strictly line-side-isolated scope of work while no modifications are being made to any of the branch circuits themselves... so what constitutes a "modification"?

I'm concerned the AHJ will construe a sub-panel/breaker swap rises to the level of modification for the purposes of this code section.

It's a difference of about $5k in breaker cost.

Thanks in advance for your insights!

 

[petersonra]

Client has a 10-unit apartment building with Zinsco sub-panels installed for each unit and his insurance carrier is requiring the sub-panels to be changed out.

I'm literally just swapping the sub-panels and breakers, strictly line-side-isolated scope of work while no modifications are being made to any of the branch circuits themselves... so what constitutes a "modification"?

I'm concerned the AHJ will construe a sub-panel/breaker swap rises to the level of modification for the purposes of this code section.

It's a difference of about $5k in breaker cost.

Thanks in advance for your insights!

Why not ask them?

If they require more expense just tell your customer that it is the city causing the price to go up. Your customer will understand that since causing unnecessary cost with little or no benefit is something governments are extremely good at.

 

[Jaybone812]

Client has a 10-unit apartment building with Zinsco sub-panels installed for each unit and his insurance carrier is requiring the sub-panels to be changed out.

I'm literally just swapping the sub-panels and breakers, strictly line-side-isolated scope of work while no modifications are being made to any of the branch circuits themselves... so what constitutes a "modification"?

I'm concerned the AHJ will construe a sub-panel/breaker swap rises to the level of modification for the purposes of this code section.

It's a difference of about $5k in breaker cost.

Thanks in advance for your insights!

If you replace any receptacles 406.4(d)(3) requires gfci protection for replacements in locations that where gfci protection elsewhere in the code
And 406.4(d)(4) requires afci protection for receptacles replaced in areas listed in 210.12(a)(b)or (c)
210.12(e) exception: afci protection shall not be required where the extension of existing branch circuit conductors is not more than 6’

So basically if you extend and existing branch circuit for any area in 210.12(b)(c) or (D) more than 6’ you need to provide afci protection for that circuit


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[electrofelon]

I'm concerned the AHJ will construe a sub-panel/breaker swap rises to the level of modification for the purposes of this code section.

As Jay says, the code is very clear here. If you just change a panel you will almost certainly be under the 6' of modification so no other updates required.

 

[Seven-Delta-FortyOne]

The 6’ rule was specifically put in to cover panel changeouts and not require AFCI upgrades.

 

[Jaybone812]

As Jay says, the code is very clear here. If you just change a panel you will almost certainly be under the 6' of modification so no other updates required.

Exactly.Replacing the load centers and breakers like for requires no upgrade


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[infinity]

The 6’ rule was specifically put in to cover panel changeouts and not require AFCI upgrades.

Yes and it was written by Dennis one of moderators. Also the 2023 clarified that the 6' measurement is the extension of the cable or raceway not the total conductor length.

 

[Seven-Delta-FortyOne]

Yes and it was written by Dennis one of moderators. Also the 2023 clarified that the 6' measurement is the extension of the cable or raceway not the total conductor length.

Didn’t know Dennis Alwon was responsible for that. We all owe him a dept of gratitude.

 

[b_electric]

(Just playing devil's advocate here...)
Where it is true I'm not extending the branch circuit specifically, the OCPD is a device that is solely dedicated and directly integral to the operation of that branch circuit, so one could argue that the breaker falls under the description of branch circuit device and subject to the code's modification verbiage as I am most certainly modifying the branch circuit by installing a new circuit breaker, and considering this all set within the context of installing AFCI protection, there really couldn't be a more obvious modification which would present the most viable opportunity to provide AFCI protection.

I think this code section is verbose in that the word modification is included alongside modification definitive words. It leaves a window open to interpret modifications to be more than what is intended.

 

[electrofelon]

(Just playing devil's advocate here...)
Where it is true I'm not extending the branch circuit specifically, the OCPD is a device that is solely dedicated and directly integral to the operation of that branch circuit, so one could argue that the breaker falls under the description of branch circuit device and subject to the code's modification verbiage as I am most certainly modifying the branch circuit by installing a new circuit breaker, and considering this all set within the context of installing AFCI protection, there really couldn't be a more obvious modification which would present the most viable opportunity to provide AFCI protection.

I think this code section is verbose in that the word modification is included along with definitions of modifications. It leaves a window open to interpret modifications to be more than that which is intended.

But it is not the circuit breaker that needs AFCI protection, it is the branch circuit.

 

[Jaybone812]

(Just playing devil's advocate here...)
Where it is true I'm not extending the branch circuit specifically, the OCPD is a device that is solely dedicated and directly integral to the operation of that branch circuit, so one could argue that the breaker falls under the description of branch circuit device and subject to the code's modification verbiage as I am most certainly modifying the branch circuit by installing a new circuit breaker, and considering this all set within the context of installing AFCI protection, there really couldn't be a more obvious modification which would present the most viable opportunity to provide AFCI protection.

I think this code section is verbose in that the word modification is included alongside modification definitive words. It leaves a window open to interpret modifications to be more than what is intended.

210.12(e) Is in regards to the branch circutt wiring. When you swap a panel and breakers like for like in exact same location you’re not modifying, extending or replacing the wiring You’re replacing the ocpd’s for the branch ciruit and replacing the load center Allot of times panel upgrades are done to address a safety cocern with the existing panel and/or the branch circuit ocpd’s . if it’s to accommodate new branch circuits the new circuits in locations that require afci & gfci protection we have to provide the protection
When you replace receptacles 406.4(d){3)&(4) requires us to provide gfci and afci protection for those receptacles the receptacles are located in a area the current code requires the protection
I feel the code rule is very clear on when when the afci protection must become provided


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[Jaybone812]

But it is not the circuit breaker that needs AFCI protection, it is the branch circuit.

I did not see this post before I made mine but you pretty much said the same thing I did I fewer words lol


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[LarryFine]

. . . I am most certainly modifying the branch circuit by installing a new circuit breaker . . .

We disagree here. That is specifically not a modification, it is a replacement or a repair.

 

[Jaybone812]

We disagree here. That is specifically not a modification, it is a replacement or a repair.

I feel the code is clear as to when we are required to provide afci protection when replacing devices . And a replacement breaker is not required to provide afci protection unless it’s to accommodate a replacement, modification or extension of the branch circuit wiring

 

[augie47]

I think we all agree AFCI is not required but, as petersonra suggested, double check with your AHJ. Sometimes they have a different outlook and rarely concern themselves with what we say here.