9-28 Log #1210 NEC-P09
Final Action: Accept
(314.27(D))
____________________________________________________________
Submitter:
James W. Carpenter, International Association of Electrical
Inspectors
Comment on Proposal No:
9-60
Recommendation:
The Proposal should be Rejected.
Substantiation:
Electrical inspectors should not be put in the position of
enforcing requirements motivated by an assumption of future actions on the
part of an owner. There was no fact-finding work to support the proposal, only
a very questionable assertion of a likely outcome. UL 507 requires clearly
visible markings on the outside of the carton for ceiling-suspended (paddle)
fans as well as statements in the installation instructions regarding proper
support for these fans.
The scenario presented in the proposal therefore amounts to a subterfuge.
If the new owners are aware that they will be installing paddle fans on
substandard boxes, then it is a conspiracy and the NEC cannot be written in
such a way as to preclude such effects. If the new owners are not aware of
the rules, and if the builders tell them that a fan with conventional mounting
arrangements is an option, then such owners are the victims of a fraud. Listed
fan boxes present such little marginal cost in comparison to the significant
risk to those who would perpetrate such a practice that the likelihood of this
practice being widespread seems remote. Although wiring such ceiling boxes
for future fan use is noted from time to time, the usual condition is to supply
fan boxes in those cases. Furthermore there are other legitimate reasons for
running multiple switched conductors to ceiling boxes.
Many chandeliers are wired with one set of lamps controlled independently
from the remaining lamps. Many ceilings are wired with multi-circuit
lighting track for which such switching arrangements are required. An
additional switched conductor may be run to an overhead outlet box because
the electrician knows that although the wall will not be accessible after
construction, the ceiling will be (as in an unfinished attic) and there will be an
additional light provided for accent lighting. Some wiring layouts, even at the
time of the rough inspection, have an additional switched conductor entering a
ceiling box and then extended to a switched receptacle or second lighting outlet
in the same room.
In addition, fan boxes are not and never have been the only acceptable method
of hanging a paddle fan. They are only required when the box is the sole
support of the fan. One major paddle fan manufacturer is now producing an
enormous volume of paddle fans (sold through major home supply channels)
that come complete with installation directions that do not recognize fan box
support, and that instead call for direct support of the fan bracket using long
screws that extend through the standard mounting hole pattern of steel boxes
and into framing above the box.
The proposal applies to any ceiling outlet box, even one too close to a wall to
be used for a paddle fan, and even one in a commercial or industrial occupancy
for which no conceivable paddle fan use would be likely. In addition, there
are many applications for which no fan box is now and ever would be likely
available. For example, there are no plaster rings now listed for fan support,
because of the obvious difficulties involved in attempting to cover all possible
combinations in a testing laboratory. The inspection community should never
be forced to routinely apply 90.4 (which requires special permission) for all
these legitimate applications, both residential and nonresidential.
The proposal violates the fundamental principles of the scope of the NEC
in 90.1. A ceiling outlet box wired as described in the proposal is entirely
safe until and unless a paddle fan is mounted in such a way that the box is
the sole support of the fan. And 90.1(B) clearly tells us that NEC compliant
installations today may not be suitable for future uses tomorrow.
What stands between today and tomorrow is qualified, disinterested thirdparty
inspection. If some jurisdictions are seeing the instances described in the
proposal substantiation, it can only be because these jurisdictions have failed
to create a regulatory environment that supports such inspections. This was the
importance of the “Inspection Initiative” in the 1990s. Without inspection (and
also without product standards) the NEC becomes invalid on its face, and our
electrical safety system unravels. Rules based on a presumption of the absence
of inspection create a completely misleading sense of security.
Panel Meeting Action: Accept
Number Eligible to Vote: 11
Ballot Results:
Affirmative: 8 Negative: 3
Explanation of Negative:
BELISLE, R.: See my explanation of negative vote on Comment 9-22.
RUPP, B.: NEMA understands that the wording of the original proposal
would add requirements to installations that were not intended to be covered,
however the panel should have worked to correct the problems rather than
reversing its action at the proposal stage. It is our opinion that the practice
of installing “spare” circuit conductors to a location such as a bedroom light
without installing an outlet box or system designed to support a fan is a
potential safety issue.
SZENDRE, M.: See my explanation of negative vote on Comment 9-22.
