laundry room arc fault

[GoldDigger]

It is unfortunate that the section explicitly limits itself to extensions. This allows the paradoxical interpretation that replacing a device without extending the wiring triggers the AFCI requirement but a short extension triggers the exemption.
A logical deduction (not determinative in Code interpretation) is that CMP 2 felt that without an extension, a device replacement would not trigger AFCI and so they did not need to address that issue. .

 

[peter d]

It is unfortunate that the section explicitly limits itself to extensions. This allows the paradoxical interpretation that replacing a device without extending the wiring triggers the AFCI requirement but a short extension triggers the exemption.
A logical deduction (not determinative in Code interpretation) is that CMP 2 felt that without an extension, a device replacement would not trigger AFCI and so they did not need to address that issue. .

The bottom line for me is that the code did not actually accomplish what it intended to accomplish, which was retrofitting AFCI into existing circuits whenever devices are replaced. I know many simply install AFCI every time they replace devices, however.

 

[don_resqcapt19]

I'm curious, Don, if 2014 NEC 406.4(D)(4) requires an AFCI of either the OBC or circuit breaker type, how do you know? I don't see the laundry outlet described in the text of 406.4(D)(4).

That's a rhetorical question.

One turn's to 2014 NEC 210.12.

My real question, Don, is how do you decide that 2014 NEC 210.12(B) Exception does not apply?

406.4(D)(4) applies any time a receptacle is being replaced. It does not matter where that receptacle is installed at, it only matters that the current code would require a new branch circuit supplying a receptacle in that location to have AFCI protection.

As far as the exception, I don't seen any exception to 406.4(D)(4) and don't see how an exception in another article would apply. There is no general provision in the code to permit a rule in one Chapter 1-4 Article to modify a rule in another Chapter 1-4 Article.

 

[al hildenbrand]

406.4(D)(4) applies any time a receptacle is being replaced. It does not matter where that receptacle is installed at, it only matters that the current code would require a new branch circuit supplying a receptacle in that location to have AFCI protection.

As far as the exception, I don't seen any exception to 406.4(D)(4) and don't see how an exception in another article would apply. There is no general provision in the code to permit a rule in one Chapter 1-4 Article to modify a rule in another Chapter 1-4 Article.

Two follow on questions.

1. If 404.4(D)(4) leads you to know that receptacle replacement on an existing circuit that is serving the Laundry Area requires AFCI, and the same receptacle replacement in an existing dedicated branch circuit for a 125 V 20 A cord and plug connected sump pump located in an unfinished basement area does not require AFCI, you are using 210.12 to interact with 404.6(D).

The Code is silent about Chapter 2 modifying Chapter 4. If it is not prohibited, it is allowed.

2. 406.4(D)(4) does not say anything about "new" vs. "existing". Again, where is the restriction that excludes everything "elsewhere in this Code" that is not included in the list of spaces / areas in the beginning of 210.12(A)? There is no such restriction.

 

[don_resqcapt19]

Two follow on questions.

1. If 404.4(D)(4) leads you to know that receptacle replacement on an existing circuit that is serving the Laundry Area requires AFCI, and the same receptacle replacement in an existing dedicated branch circuit for a 125 V 20 A cord and plug connected sump pump located in an unfinished basement area does not require AFCI, you are using 210.12 to interact with 404.6(D).

Yes, there is interaction because of the wording in 406.4(D)(4), but one rule is not changing or modifying another rule. The rules just says that if you replace a receptacle in a location that would require a new circuit to have AFCI protection then that replacement receptacle must have AFCI protection.

The Code is silent about Chapter 2 modifying Chapter 4. If it is not prohibited, it is allowed.

In my opinion the wording in 90.3 applies. Based on the specific permission for rules in Chapters 5-7 to modify those in Chapters 1-4, I read that as saying rules in 1-4 cannot modify each other.

2. 406.4(D)(4) does not say anything about "new" vs. "existing". Again, where is the restriction that excludes everything "elsewhere in this Code" that is not included in the list of spaces / areas in the beginning of 210.12(A)? There is no such restriction.

The code says that if you are replacing a receptacle in a location where the current code would require the circuit feeding that receptacle to have AFCI protection, then you must provide AFCI protection. Maybe my using the word "new" was confusing, but I don't know a better way to try to explain what the rule says. To me the rule is very clear. The rule in 210.12 tells you what has to be AFCI protected, and the words "as specified elsewhere in this Code" in 406.4(D) just refer you to 210.12 so you know if your replacement receptacle needs AFCI protection.

 

[jaylectricity]

The rules just says that if you replace a receptacle in a location that would require a new circuit to have AFCI protection then that replacement receptacle must have AFCI protection.


The code says that if you are replacing a receptacle in a location where the current code would require the circuit feeding that receptacle to have AFCI protection, then you must provide AFCI protection.

I don't see those words in the article.

Maybe my using the word "new" was confusing, but I don't know a better way to try to explain what the rule says. To me the rule is very clear. The rule in 210.12 tells you what has to be AFCI protected, and the words "as specified elsewhere in this Code" in 406.4(D) just refer you to 210.12 so you know if your replacement receptacle needs AFCI protection.

You can't just add words that change the meaning.

 

[peter d]

If the branch circuit was installed in 1990 and you are simply replacing a device, no AFCI is required because AFCI was not required in 1990.

If you are replacing a device in 2015 and the branch circuit was installed in 2011 in a location where AFCI is required, then you must maintain the AFCI protection by any of the options given (breaker or receptacle type AFCI). Again, I know what was intended by the rule but the words say what they say.

IMO, of course.

 

[don_resqcapt19]

I don't see those words in the article.

You can't just add words that change the meaning.

(4) Arc-Fault Circuit-Interrupter Protection. Where a receptacle outlet is supplied by a branch circuit that requires arc-fault circuit-interrupter protection as specified elsewhere in this Code, a replacement receptacle at this outlet shall be one of the following:
...

I am not adding any words or changing the meaning.

 

[don_resqcapt19]

If the branch circuit was installed in 1990 and you are simply replacing a device, no AFCI is required because AFCI was not required in 1990.

If you are replacing a device in 2015 and the branch circuit was installed in 2011 in a location where AFCI is required, then you must maintain the AFCI protection by any of the options given (breaker or receptacle type AFCI). Again, I know what was intended by the rule but the words say what they say.

IMO, of course.

The replacement rule is in the 2014 NEC, and the circuits that are to be AFCI protected are per the 2014 NEC. If the replacement rule was only based on the previous NEC AFCI rules, there would be no need for the replacement rule.

 

[don_resqcapt19]

18-30 Log #3561 NEC-P18 Final Action: Accept in Principle
(406.3(D)(4) (New) )
_______________________________________________________________
Submitter: James T. Dollard, Jr., IBEW Local 98
Recommendation: Add a new list item to 406.3(D) as follows:
406.3(D)(4) Arc-Fault Circuit Interrupters. Arc-Fault circuit-interrupter protected receptacles shall be provided where replacements are made at receptacle outlets that are required to be so protected elsewhere in this Code.

Substantiation: The NEC presently addresses receptacle replacement in 406.3(D). This proposal seeks to expand the present receptacle replacement requirements to include arc fault protected receptacles where required elsewhere in the NEC. The existing requirement in 406.3(D)(2) requires GFCI protected receptacles where replacements are made at receptacle outlets that are
required to be so protected elsewhere in the NEC. There is no practical reason to limit the level of safety provided by AFCI’s to new homes only.

The benefits of 210.12 have been well substantiated over the last few NEC cycles, but it is highly unlikely that the fire-reducing provisions of 210.12 will ever result in AFCI protection for existing dwelling units unless branch-circuit circuit breakers are replaced or the service is upgraded. There is no practical reason to limit the level of safety provided by an AFCI to new homes only.

This proposal will provide that extra protection for older homes by requiring the gradual replacement, over time, of non-AFCI-protected receptacles with new AFCI-protected ones.

Panel Meeting Action: Accept in Principle
Add a new (4) to 406.3(D) as follows:
406.3(D) (4) Arc-Fault Circuit-Interrupters. Listed combination arc-fault circuit interrupter receptacles shall be provided where replacements are made at receptacle outlets that are required to be so protected elsewhere in this code.

Exception: Unless the receptacle is protected by an upstream AFCI.

Panel Statement: CMP-18 edited the proposed text for clarity.
Number Eligible to Vote: 11
Ballot Results: Affirmative: 9 Negative: 2

Explanation of Negative:
LOWRANCE, JR., A.: The panel in accepting this proposal has not taken into account the magnitude of this new requirement. In requiring the replacement receptacle, in areas required to be Arc Fault Circuit Interrupter protected, to be an AFCI receptacle type the panel is, in a large amount of the cases, requiring the circuit to be completely rewired. Many older houses have circuits with
shared neutrals, multi wire branch circuits, loose connections, and degraded insulation. In all of these cases the wiring would have to be replaced for the AFCI receptacle to function.

Additionally the homeowner would be tempted to do the replacement his or her self thus bypassing the electrical installation
professional who is acquainted with the hazards inherent in such installations. Enforceability is an additional issue in this change as again the homeowner would be tempted to do the work his or her self without taking advantage of the benefits that an inspection can provide.

We need more experience to be obtained regarding the installation of combination type AFCIs in new dwellings before requiring the installation of AFCIs in wide variety of existing dwellings that will have numerous different wiring configurations.”

TODD, S.: The replacement of the receptacle on a circuit with the Combo AFCI receptacle will only protect the circuit down stream from the AFCI from parallel and series arcs and upstream from series arcs. The Submitter’s substantiation is to make a requirement similar to the receptacle replacement where GFCI receptacles are required elsewhere in the code. The justificationdid not include any documented problems in the field of a safety concern.

Many receptacles are replaced by homeowners who may or may not replace the receptacle with and AFCI type receptacle. This proposed requirement is unenforceable. The committee discussed the operational issues of combining
the AFCI technology with old construction. In addition, if the circuit is protected by an AFCI type circuit breaker then a standard receptacle is acceptable.

Comment on Affirmative:
COSTELLO, P.: The new requirement will now provide AFCI protection to those receptacles in older homes where it would be required today. This is a proactive approach to providing extra protection to a homes aging wiring system.

WELLS, J.: I am voting affirmatively because I believe the submitter has appropriately endeavored to address the problem of electrical fires in existing dwellings. Data indicates that a very significant portion of electrical fires, in fact, occur is such older homes.

During the comment period, I encourage the submitter and others to address what I consider flaws in the wording as Accepted in the panel action. First, the wording should allow AFCIs of either the circuit breaker or outlet branch circuit type to be used in a non discriminatory way for compliance. Second, I am not certain that replacement of an individual receptacle should serve as the
trigger for requiring AFCI protection in existing buildings. Alternative triggers should be considered and proposed during the comment period.

 

[al hildenbrand]

The code says that if you are replacing a receptacle in a location where the current code would require the circuit feeding that receptacle to have AFCI protection, then you must provide AFCI protection. . . . The rule in 210.12 tells you what has to be AFCI protected, and the words "as specified elsewhere in this Code" in 406.4(D) just refer you to 210.12 so you know if your replacement receptacle needs AFCI protection.

Your summation here, these words, I find 100% accurate. I emphasize "210.12" because we have no guidance in the interaction of 406.4(D)(4) to be looking at less.

Maybe my using the word "new" was confusing, but I don't know a better way to try to explain what the rule says. To me the rule is very clear.

And here is the crux. . . that somehow, for you, the only content of 210.12 that interacts with 406.4(D)(4) is the list of areas in 210.12(A).

Where you have your clarity, so, too, did the Code Making Panel 2 when they created the language of the 2014 NEC 210.12(B) Exception and they made the Panel Statement that their wording added "clarity." M. Hilbert goes on to explain, along with other points, the 2014 NEC 210.12(B) Exception applies to the replacement of devices in enclosures, and that no AFCI protection is required when the conductors are extended less than six feet and there is no new outlet or device added. Here is the CMP 2 language in total:

2-115 Log #536 NEC-P02 Final Action: Accept in Principle
(210.12(B))
Submitter:
Dennis Alwon, Alwon Electric Inc.
Recommendation:
Add new text to read as follows:
Exception: Where extension of the branch circuit does not include any added outlets or devices.
Substantiation:
Often times when changing a service in an older home the branch circuit conductors do not reach the new location of the panel. The wire is sometimes just spliced inside the panel to reach the termination points while other times the circuit may need to be extended a short distance to reach the new location. Since many areas are inspecting this differently throughout the country this exception would clarify this section and bring uniformity throughout.
Panel Meeting Action: Accept in Principle
Revise the proposed wording to read as follows: "Exception: AFCI protection shall not be required where the extension of the existing conductors is not more than 1.8 m (6 ft.) and does not include any additional outlets or devices."
Panel Statement:
The revised wording provides clarity and satisfies the intent of the submitter.
Number Eligible to Vote: 11
Ballot Results:
Affirmative: 9 Negative: 1 Abstain: 1
Explanation of Negative:
KING, D.: This Proposal should be rejected. It is the intent of Section 210.12(B) to provide AFCI protection where circuits that are covered by 210.12(A) are "modified." The submitter has not provided any substantiation to allow for an exception for AFCI Protection in the branch circuit modification described in his substantiation. Accepting the proposed exception would greatly dimish the level of safety currently provided by the requirements of 210.12(B).
Explanation of Abstention:
ORLOWSKI, S.: See my Explanation of Vote on Proposal 2-92.
Comment on Affirmative:
HILBERT, M.: Continue to accept in principle. The issues noted in the substantiation for this proposal and Proposal 2-11 are often topics of discussion at IAEI meetings as well as other educational meetings and do need clarification.
The proposed language as revised by the panel's accept in principle action will go a long way in promoting uniform interpretations. It will clarify that extending branch circuit conductors within an enclosure for the purposes of replacing a device or utilization equipment or for extending a branch circuit to a panelboard being replaced or upgraded does not require an AFCI protective device to be installed.
Six feet was chosen for branch circuit extensions as it should provide a sufficient length for most applications where an existing panel is being relocated out of a clothes closet or to comply with readily accessible requirements, etc

This highlighted clarification by M. Hilbert was then re-published by the NFPA in the IAEI Analysis of Changes in the 2014 NEC in the collective attempt to explain to us what they did.

What I find interesting is the collective mesmerization about how the REAL intent is that AFCI HAS to be installed.

 

[don_resqcapt19]

CMP 2 is not the authority for the replacement of a receptacle. CMP 18 is. Mr. Costello of CMP 18 said the following in his affirmative comment on proposal 18-30 for the 2011 code.

Comment on Affirmative:
COSTELLO, P.: The new requirement will now provide AFCI protection to those receptacles in older homes where it would be required today. This is a proactive approach to providing extra protection to a homes aging wiring system.

 

[al hildenbrand]

CMP 2 is not the authority for the replacement of a receptacle. CMP 18 is.

Yes, I agree. But, you see in 406.4(D)(4) the requirement, created by CMP 18, to not consult their work, but to consult "elsewhere in this Code" to determine whether AFCI protection is required. . . . CMP 18 does not say that AFCI protection is required without exception, or any thing else, EXCEPT to go "elsewhere." They abdicate themselves.

Mr. Costello of CMP 18 said the following in his affirmative comment on proposal 18-30 for the 2011 code.

Comment on Affirmative:
COSTELLO, P.: The new requirement will now provide AFCI protection to those receptacles in older homes where it would be required today. This is a proactive approach to providing extra protection to a homes aging wiring system.

I agree that there are those who say exactly that and there is nothing in the Code that will change their opinion to consider the 2014 NEC 210.12 of TODAY.

Instead of looking backward, look to the emerging 2017 NEC Draft that is in the last of the comment stage. It appears that CMP 18 is taking the ball back and running with it to clarify what CMP 2 started in the 2014 NEC 210.12(B) Exception. CMP 18 is receiving comments on some powerful exceptions in 406.4(D)(4) to the "a replacement receptacle must always be AFCI protected" meme.

 

[kwired]

Yes, I agree. But, you see in 406.4(D)(4) the requirement, created by CMP 18, to not consult their work, but to consult "elsewhere in this Code" to determine whether AFCI protection is required. . . . CMP 18 does not say that AFCI protection is required without exception, or any thing else, EXCEPT to go "elsewhere." They abdicate themselves.


I agree that there are those who say exactly that and there is nothing in the Code that will change their opinion to consider the 2014 NEC 210.12 of TODAY.

Instead of looking backward, look to the emerging 2017 NEC Draft that is in the last of the comment stage. It appears that CMP 18 is taking the ball back and running with it to clarify what CMP 2 started in the 2014 NEC 210.12(B) Exception. CMP 18 is receiving comments on some powerful exceptions in 406.4(D)(4) to the "a replacement receptacle must always be AFCI protected" meme.

So is 2017 still going to contradict itself? It sure would be nice to read the content of the code and not have to go back to the proposals and comments to figure out what is required, we are electricians not lawyers

 

[al hildenbrand]

So is 2017 still going to contradict itself? It sure would be nice to read the content of the code and not have to go back to the proposals and comments to figure out what is required, we are electricians not lawyers

I'm sure will find plenty to discuss in great depth, here.

Here's the Draft of the 2017 NEC 406.4(D)(4) that is still in the comment stage at the NFPA. Note that Exception No. 2 disconnects the interaction of 210.12(B) Exception from 406.4(D)(4), which, all by itself, is proof that in the minds of CMP 18 that the 2014 NEC 210.12(B) Exception does, in fact, apply to replacements. I see this as a removing of any instances where contradiction that might arise between 210.12(B) Exception and the new 2017 NEC 406.4(D)(4) Exception No. 1 are being removed.

DRAFT of the 2017 NEC

406.4(D)(4) Arc-Fault Circuit-Interrupter Protection.

Where a receptacle outlet is supplied by a branch circuit that requires arc-fault circuit-interrupter protection as specified elsewhere in this Code, a replacement receptacle at this outlet shall be one of the following:

(1) A listed outlet branch-circuit type arc-fault circuit-interrupter receptacle

(2) A receptacle protected by a listed outlet branch-circuit type arc-fault circuit-interrupter type receptacle

(3) A receptacle protected by a listed combination type arc-fault circuit-interrupter type circuit breaker

Exception No. 1: Arc-fault circuit-interrupter protection shall not be required where:

(1) The replacement complies with 406.4(D)(2)(b).

(2) It is impracticable to provide an equipment grounding conductor as provided by 250.130(C).

(3) A receptacle protected by a listed combination type arc-fault circuit-interrupter circuit breaker is not commercially available.

(4) There is no GFCI/AFCI combination receptacle commercially available.

Exception No. 2: 210.12(B) exception does not apply to replacement of receptacles.

 

[don_resqcapt19]

I'm sure will find plenty to discuss in great depth, here.

Here's the Draft of the 2017 NEC 406.4(D)(4) that is still in the comment stage at the NFPA. Note that Exception No. 2 disconnects the interaction of 210.12(B) Exception from 406.4(D)(4), which, all by itself, is proof that in the minds of CMP 18 that the 2014 NEC 210.12(B) Exception does, in fact, apply to replacements. I see this as a removing of any instances where contradiction that might arise between 210.12(B) Exception and the new 2017 NEC 406.4(D)(4) Exception No. 1 are being removed.

There is no proof that CMP 18 thinks that....the change could very well be because code users think that and CMP 18 is addressing those code users.

There have been many changes in the code over the years just because the code users were not reading the code in the manner that the panel had intended.

 

[al hildenbrand]

There is no proof that CMP 18 thinks that....the change could very well be because code users think that and CMP 18 is addressing those code users.

There have been many changes in the code over the years just because the code users were not reading the code in the manner that the panel had intended.

This is my point, in a nutshell, Don. The proposed new exceptions to 406.4(D)(4) are being written to show there are, in fact, exceptions to some Code users claim that the published 2011 NEC CMP member remark about an affirmative vote trumps actual 2014 NEC language in 210.12(B) Exception.

Clinging to the mystical intent that AFCIs must always be installed is just plain wrong, IMHO.

 

[don_resqcapt19]

This is my point, in a nutshell, Don. The proposed new exceptions to 406.4(D)(4) are being written to show there are, in fact, exceptions to some Code users claim that the published 2011 NEC CMP member remark about an affirmative vote trumps actual 2014 NEC language in 210.12(B) Exception.

Clinging to the mystical intent that AFCIs must always be installed is just plain wrong, IMHO.

Al,
And my point is that the new wording in 406.4(D) says that the exception to 210.12(B) does not apply where you are replacing a receptacle...in other words you can't add a pig tail and say you made an extension that does not require the AFCI.

 

[al hildenbrand]

Al,
And my point is that the new wording in 406.4(D) says that the exception to 210.12(B) does not apply where you are replacing a receptacle...in other words you can't add a pig tail and say you made an extension that does not require the AFCI.

Because, in the 2014 NEC interaction of 406.4(D)(4) and 210.12, one CAN add a pig tail to the black and the white, as long as each is less than six feet and there are no additional devices or receptacles, and be allowed to replace a device without adding AFCI.

 

[al hildenbrand]

Al,
And my point is that the new wording in 406.4(D) says that the exception to 210.12(B) does not apply where you are replacing a receptacle...in other words you can't add a pig tail and say you made an extension that does not require the AFCI.

Because, in the 2014 NEC interaction of 406.4(D)(4) and 210.12, one CAN add a pig tail to the black and the white, as long as each is less than six feet and there are no additional devices or receptacles, and be allowed to replace a device without adding AFCI.

I mean, look at what those proposed 2017 NEC 406.4(D)(4) Exceptions are aimed at: two-wire non-grounding type receptacle replacement; ungrounded wiring method receptacle replacement; along with service centers that are either fuse or of manufacture by other than the big four AFCI manufacturers; or where the wall case is too small or the EGC is not available in a "practical" manner; and my personal favorite, where manufacturers have not yet made a single device that is both an AFCI and a GFCI.

That looks like a lot of existing housing stock to me, that is old, and not upgraded, that can be maintained with fresh devices without the economic pain of what AFCI solutions require, in many cases.