Power Bridge

[PowerBridgeTech]

"A wire is not a controller, as it does not govern power in the manner described in the NEC definition of controller."

First, I'm not yet convinced the direction of citing a PowerBridge could apply use as a Controller is applicable, YET.

Perhaps. I would agree with Charlie, but with bias to a definition of "a wire".

A "FIXED" wire cannot be a Controller. It by itself, doesn't have the ability to disconnect automatically or Nonautomatically of itself, as defined in reference to a manual controller that "personal intervention is necessary".

However I'm seeing how a cord/cable passing active energy, as intended to supply another device, (not specifically a motor device) is allowable as a manual, Nonautomatic means of disconnection or interruption of supplied power or service to a device as intended to a electrical utilization device. I could not find anything specific to this as a not-permitted in citing of NEC

You might as well say that a lamp cord is a controller. For that matter, you can hard wire a dishwasher or a disposal to an outlet box in the wall, and you can disable the appliance by snipping the wire with a pair of wire cutters, and I don't think that will cause the wire from the outlet box to the appliance to suddenly meet the definition of controller.

No, the cord/wire of a lamp is not passing power in the direction to the fixed wiring to control a disconnect, however I do see your point, not sure it merits the intention of what is being dicussed in particular to the intended use of the cord in the case of the PowerBridge to EXTEND power to/through devices to control the distribution of power.
Again, not yet convinced this is a possible exception we could propose to NEC without a lot of difficulty. Maybe not?

 

[don_resqcapt19]

...
To know the intended use, would you not refer to instruction manuals or a Listing Report? Code calls that to be the case, install devices to their prespective instructions or labeling or Listing. Right?

While you are correct that 110.3(B) call for compliance with the listing and labeling instructions, there is no provision that permits those instructions to require an installation in violation of the code rules. That is exactly what the instructions for your product tell us to do. They are directing us to use the cord as a substitute for the fixied wiring of the building in direct violation of 400.8(1).

Submit your request to the NFPA for a FI or submit a proposal.

I expect that you don't want to do that because you believe that there is a possibility that the CMP would agree that there is a violation of 400.8(1).

Without action by the CMP, I would cite this installation as a violation.

 

[al hildenbrand]

I assure you that even though it is not documented, if I unplug a table lamp that is on, it will shut off; if I plug it back in, it will turn back on. That meets the definition of a controller.

From a common sense approach, yah, sure, you betcha.

I mean, like, I've got this first generation Sears shop vacuum that has more suction than anything else I've ever used. The unit switch on the machine wore out, and I fruitlessly worked with Sears Parts until they convinced me that they weren't ever going to sell me a replacement part. Something about "we don't stock generic parts."

Well it's built in, with a nice handle and all, so, . . . well, . . . I've been "looking" for the replacement switch for, what, 9 years.

Meanwhile, I run the machine by plugging and unplugging it. You Betcha! I have seen some juicy arcs in those 9 years.

I don't need no stinkin' interrupting rating. (Shhh. Don't let my insurance company know.)

 

[wwhitney]

But the disconnect remains in place. It is an entity unto itself, it is still there, and it is doing an important safety job.

Right, the same with the receptacle. Each case, pull-out-disconnect and plug/receptacle, has one piece fixed in place and one piece movable.

I thought you were trying to call the cord and its two end pieces a controller, not calling them part of a controller. Isn’t that the case you are trying to make?

My logic was this: (1) the cord cap and inlet of the PowerBridge certainly compromise a controller; (2) really, we can just consider the whole thing a controller, including the wiring in the wall between the inlet and the receptacle; (3) so no part of the PowerBridge is part of the premises wiring system.

Now that I reflect up on it, (2) is really weak. Rather, I would say that in a typical PowerBridge installation you end up with three controllers, the three places you can unplug the load. Fortunately you agree with me on (3) above, so the controller issue is less important. I like your reasons for (3) better, so I'll drop the controller issue.

Thanks,
Wayne

 

[LarryFine]

The bottom line is that extension cords are temporary wiring, not fixed wiring. We are required to energize the appliance cord with a receptacle. A fixed wiring receptacle and a temporary extension cord are mutually exclusive.

What would you call an affixed extension cord?

 

[wwhitney]

110.3(A)(6)
110.9 Second sentence.

Excellent! I think the other references were not really on point, but these two are great. I now agree that without an interrupting rating, a plug and receptacle can't be a controller.

But one remaining thing confuses me. Isn't some utilization equipment provided with a cord-and-plug and no unit switch? Is such equipment only to be used on an individual branch circuit where the circuit-breaker can be used as a disconnect?

Thanks, Wayne

 

[LarryFine]

If instead you run a flexible cord outside the walls, as a way of avoiding running wires inside the walls, you are doing a substitution.

What if we're using the exterior portion as a way of obtaining power from a device with receptacles, and not a substitute for hard wiring?

Whar's being avoided is bringing the bottom end of the NM out of the wall and plugging the stripped wires into the device's receptacle.

Merely plugging the cord into a nearby premises receptacle, on the other hand, clearly fist your definition of hard-wiring substitution.

 

[LarryFine]

I think the controller and appliance arguments are not relevant.

To me, the simple question is whether this method is using extension-cord materials as a portion of premises wiring, or using premises-wiring materials as a portion of an extension cord.

It is obviously my opinion, and others', that this is a case of the latter.

 

[al hildenbrand]

Is such equipment only to be used on an individual branch circuit where the circuit-breaker can be used as a disconnect?

Say, like a hard wired electric water heater? The breaker has an interrupting rating and, by NEC has to have a lockout if out of sight from the heater.

 

[wwhitney]

The premises wiring system ends at the receptacle. The wiring to the receptacle can be done inside the walls, per chapter 300 methods. If instead you run a flexible cord outside the walls, as a way of avoiding running wires inside the walls, you are doing a substitution.

I'm not clear which of the two receptacles in a Powerbridge installation you are referring to here. I would say that the premises wiring system ends at the first receptacle (into which the Powerbridge cord plug is inserted), and you are running some additional wiring in the wall as a way to avoid running a long power cord directly to that first receptacle. So you are not substituting cord for in-wall wiring, you are substituting in-wall wiring for part of the cord.

Let me try to rephrase my argument about powerbridge and its relationship to utilization equipment that may be either cord-and-plug-connected or hardwired.

(1) If 400.8(1) means "don't use a cord in any place where you could use a Chapter 3 method", then any utilization equipment that could be hard-wired would have to be hard-wired, you couldn't use a cord with it.

(2) That seems absurd, so we reject that interpretation. Instead, 400.8(1) means "don't use a cord as part of the premises wiring system (unless allowed explicity in 400.7)".

(3) With Powerbridge the premises wiring system ends at the first receptacle, so the cord is not part of the premises wiring system, and there is no 400.8(1) violation.

If you don't like either of my interpretations of 400.8(1), please offer your own.

Thanks, Wayne

 

[PowerBridgeTech]

As I see it, the substitution issue does not involve the Power Bridge as an entire ?kit.? This kit is not substitution for a hard wired receptacle. Rather, the flexible cord outside the wall is substituting for a chapter 300 wiring method inside the wall.
Appliances can be hard wired or plug and cord connected, as the manufacturer desires. The NEC does not cover the design, construction, or instruction manuals for appliances. The premises wiring system ends at the receptacle. The wiring to the receptacle can be done inside the walls, per chapter 300 methods. If instead you run a flexible cord outside the walls, as a way of avoiding running wires inside the walls, you are doing a substitution.

Myself and Al have been citing the Listing report, and the DEFINITION Article 100 "whose listing states and is tested and found suitable for a specified purpose."

Also the PowerBridge is inclusive of specific use Labeling, and manufactures instructions as to specified use. The cord which is inclusive of the assembly has a specified purpose as used with the assembly.

Thus the BIG QUESTION! How can you cite the "kit" is not seen as a substitution, just the cord and how it is being used?

The rules of "Listed" as applied, contains direction to QP to accept the kit with its power supply extension cord, with specified purpose as "a-device there of" the listed, labeled, instructed, Assembly Kit being installed and used as specified.
How then, is your bias changed to the context of substitution? (I'll assume you are not the AHJ with a position to not accept Listing by definition.)

I can only assume the WA AHJ has not either read our control report, doesn't apply sections pertaining to Listing as defined for our product or any product, which he decided Listing is not necessary to mandate NEC rules to apply installation, that is his authority to determine, we get that.

Other AHJ may decide to allow the Listing report and the specified purpose.

 

[wwhitney]

Say, like a hard wired electric water heater? The breaker has an interrupting rating and, by NEC has to have a lockout if out of sight from the heater.

I was thinking of a portable appliance without a unit switch. Like say a portable sump pump with a float switch and no other off switch. If you drop it in a big pool of water and plug it in, you will get an arc. If you want to turn it off before the water drains, then you have to either disconnect the plug under load or flip the circuit breaker. So I was wondering if such appliances would have a plug with an interrupting rating.

Cheers, Wayne

 

[jim dungar]

And last, but far from least:

110.9 Second sentence.

Effectively 110.9 only requires the device be able to interrupt the current flowing through it when it opens.
So a manually operated 15A plug can meet 110.9 as long as it is not breaking more than 15A.

OSHA recognizes a 'plug' as a disconnect, in fact several companies sell LOTO boots just for this application.

 

[wwhitney]

Effectively 110.9 only requires the device be able to interrupt the current flowing through it when it opens. So a manually operated 15A plug can meet 110.9 as long as it is not breaking more than less than 15A.

So are you saying that all 15A plugs have an interrupting rating of at least 15A? Is this documented somewhere?

Thanks, Wayne

 

[PowerBridgeTech]

While you are correct that 110.3(B) call for compliance with the listing and labeling instructions, there is no provision that permits those instructions to require an installation in violation of the code rules. That is exactly what the instructions for your product tell us to do. They are directing us to use the cord as a substitute for the fixied wiring of the building in direct violation of 400.8(1).

Submit your request to the NFPA for a FI or submit a proposal.

I expect that you don't want to do that because you believe that there is a possibility that the CMP would agree that there is a violation of 400.8(1).

Without action by the CMP, I would cite this installation as a violation.

Don, respectfully I don't completely agree with your assertion that we are directing you to violate code rules when there are rules that can/could be applied to the specified purpose called out in our Listing, I've claimed them here and it is subjective to exception or allowance by AHJ, that is the case for anything in Code, respectfully.

As to submission to the NFPA to an exception, that thought has been entertained in the past and by directive to desire a positive outcome. The advise then, was to allow this to be determined as to specified use of the Listing. Obviously, any manufacturer could have their Listed product called out by an AHJ for just about any reason, inclusive of Code application. It is valued for now to stand on the Listing value to allow determination.

Annex H: Adminstration (G) Appeals allows conditions to apply on a case by case as necessary.

Honestly the WA call out is the first and only citing we are aware of up until now.

 

[PowerBridgeTech]

UL Cord Sets and Power-supply Cords

UL Cord Sets and Power-supply Cords

I thought we all could use additional definition to apply to 400.8(1) and the use of the words "substitution for the fixed wiring of a structure"
Per UL ELBZ

"Cord-sets and power-supply cords are not intended to be used as a substitute for the fixed wiring of a structure and, HENCE, are not intended to be FASTENED IN PLACE."

Is the definition of UL, as applied to cord-sets, applicable to 400.8(1) to apply "substitution" as a claim to bias and separate the use of ALL cords as intended, are infact violation of 400.8(1)
Does the HENCE citation allow us to apply INTENDED condition of the use as to substitution as to fasten in place?

Is this truely the intention of the NEC to disallow all cord-sets to be in violation? Doubtful.
Why do cords exist if 400.8(1) cites this so ambigusly as to 4 basic words.
Perhaps NEC used UL to cite this and the wording BY MEANS OF FASTENING was implied as Premise Wiring of the structure is ATTACHED as part of the structure wiring system. Are we as QP and AHJ to apply through definition in NEC this means the words of ATTACHMENT appear further in 400.8 to apply?

In further reading, to address other objections, within the entire ELBZ description, no mention of the words "temporary" or specified "duration of use" is implied for this device known as a cord-set.

 

[wwhitney]

So are you saying that all 15A plugs have an interrupting rating of at least 15A? Is this documented somewhere?

I googled the ul database for various combinations of interrupting rating with inlet or receptacle, and the only thing I found that seemed relevant was under RTDV--Receptacles:

Devices marked "Not for Current Interruption" are not intended to be disconnected while under load. They are intended to be installed in series with switches or other appropriate disconnecting means.

That seems to imply that it is commonly recognized that receptacles may be used for current interruption, but is not explicit. Also, I believe the usual UL category for receptacles is RTRT--Receptacles for Plugs and Attachment Plugs. Such language is not present in the guideinfo for that category.

Cheers, Wayne

 

[PowerBridgeTech]

I'm not clear which of the two receptacles in a Powerbridge installation you are referring to here. I would say that the premises wiring system ends at the first receptacle (into which the Powerbridge cord plug is inserted), and you are running some additional wiring in the wall as a way to avoid running a long power cord directly to that first receptacle. So you are not substituting cord for in-wall wiring, you are substituting in-wall wiring for part of the cord.

Let me try to rephrase my argument about powerbridge and its relationship to utilization equipment that may be either cord-and-plug-connected or hardwired.

(1) If 400.8(1) means "don't use a cord in any place where you could use a Chapter 3 method", then any utilization equipment that could be hard-wired would have to be hard-wired, you couldn't use a cord with it.

(2) That seems absurd, so we reject that interpretation. Instead, 400.8(1) means "don't use a cord as part of the premises wiring system (unless allowed explicity in 400.7)".

(3) With Powerbridge the premises wiring system ends at the first receptacle, so the cord is not part of the premises wiring system, and there is no 400.8(1) violation.

If you don't like either of my interpretations of 400.8(1), please offer your own.

Thanks, Wayne

Cheers Wayne! I of course agree. 400.8(1) is vauge and in my opinion needs to have additional description to direct.

I added the UL report description of a cord-set to allow further interpretation.

 

[don_resqcapt19]

Don, respectfully I don't completely agree with your assertion that we are directing you to violate code rules when there are rules that can/could be applied to the specified purpose called out in our Listing, I've claimed them here and it is subjective to exception or allowance by AHJ, that is the case for anything in Code, respectfully.

You suggested that the listing and labeling instructions for your product are to be followed and that results in a code violation. There is nothing you can say that will change my mind as to the the cord used with your product not being a substitute for the fixed wiring of the building.

As to submission to the NFPA to an exception, that thought has been entertained in the past and by directive to desire a positive outcome. The advise then, was to allow this to be determined as to specified use of the Listing. Obviously, any manufacturer could have their Listed product called out by an AHJ for just about any reason, inclusive of Code application. It is valued for now to stand on the Listing value to allow determination.

I still don't see where the listing has anything to do with the code issue. Nothing in a listing can change a code rule.

Annex H: Adminstration (G) Appeals allows conditions to apply on a case by case as necessary.

In Illinois, I am not aware of any unit of government that has adopted Annex H. The provisions in Annex H are covered by state statute and cannot be changed by local units of government. I expect that is the case in other states also.

Honestly the WA call out is the first and only citing we are aware of up until now.

I am sure that most installations of your product are not done under a permit and inspection, so few have had the opportunity to red tag the installation.

 

[don_resqcapt19]

I thought we all could use additional definition to apply to 400.8(1) and the use of the words "substitution for the fixed wiring of a structure"
Per UL ELBZ

"Cord-sets and power-supply cords are not intended to be used as a substitute for the fixed wiring of a structure and, HENCE, are not intended to be FASTENED IN PLACE."

Is the definition of UL, as applied to cord-sets, applicable to 400.8(1) to apply "substitution" as a claim to bias and separate the use of ALL cords as intended, are infact violation of 400.8(1)
Does the HENCE citation allow us to apply INTENDED condition of the use as to substitution as to fasten in place?

Is this truely the intention of the NEC to disallow all cord-sets to be in violation? Doubtful.
Why do cords exist if 400.8(1) cites this so ambigusly as to 4 basic words.
Perhaps NEC used UL to cite this and the wording BY MEANS OF FASTENING was implied as Premise Wiring of the structure is ATTACHED as part of the structure wiring system. Are we as QP and AHJ to apply through definition in NEC this means the words of ATTACHMENT appear further in 400.8 to apply?

In further reading, to address other objections, within the entire ELBZ description, no mention of the words "temporary" or specified "duration of use" is implied for this device known as a cord-set.

If was fastened in place that would be direct evidence that it is being used as a substitute for the building wiring, but just because the cord in not fastened in place does not mean that the cord is not being used as substitute for the permanent wiring of the building.
I can see no code compliant use of a cord that supplies power to the fixed wiring of the building other than an Article 702 application or a Article 590 application.