Where's the "Outlet" under the 2020 NEC -- for outdoor hardwire EVSEs

[don_resqcapt19]

... Or admit that if an EVSE has GFCI protection for personnel then it would meet the requirements of that section....

Please show me a listing document that shows the EVSE is listed to UL 943...without such a listing it does not have the GFCI protection that is required by the NEC.

 

[jim dungar]

If the power consumed by a GFCI receptacle is incidental, then so is the power consumed by a Level II EVSE. Or, neither are. There's nothing in NEC definitions that supports your making a distinction here.


The thing I posted a picture of is.


'Wiring device' is not an NEC defined term. If the plug portion of the charger (how is it a 'system'?) is not part of the premises wiring, then neither is a GFCI receptacle that consumes power to perform a function.

Just be consistent. Either admit that 210.8(F) doesn't say what you thought it said, or what you wish it said. Or admit that if an EVSE has GFCI protection for personnel then it would meet the requirements of that section. I think either interpretation is justifiable given the lack of specificity in the definitions of premises wiring and utilization equipment. But there's no justification for not being consistent.

I think a lot the issue here is demistifying what a Level II charging box actually does. It serves only to connect or disconnect the car from the mains voltage. It doesn't convert the power, control the current, convert it to a different form of energy, or do anything else that utilization equipment normally does.

Wiring devices is a term used in the NEC. A GFCI receptacle is a wiring device and has a UL Listing as such. What UL listing does your connection box have?

The picture looks like a connection box which transitions from the premises wiring to a flexible cord with a connector that the NEC says is part of the vehicle and not the premises wiring.

 

[jaggedben]

Please show me a listing document that shows the EVSE is listed to UL 943...without such a listing it does not have the GFCI protection that is required by the NEC.

That's not what's at stake in the discussion. What's at stake is whether, if I could show you that document, you'd accept that it provides the outlet with the required GFCI protection.

 

[wwhitney]

Wiring devices is a term used in the NEC. A GFCI receptacle is a wiring device and has a UL Listing as such. What UL listing does your connection box have?

UL 2594.

Speaking of devices, the functions an EVSE performs fall squarely within the definition of "device":

Device. A unit of an electrical system, other than a conductor, that carries or controls electric energy as its principal function.

The picture looks like a connection box which transitions from the premises wiring to a flexible cord with a connector that the NEC says is part of the vehicle and not the premises wiring.

The thing pictured in post #33 is the "vehicle connector" at the end of the EVSE cord, and it plugs into the "vehicle inlet" which is part of the vehicle. Your NEC reference is to the vehicle inlet, not the vehicle connector.

So in the analogy with a cord and plug connected piece of utilization equipment, we have EV = utilization equipment; vehicle inlet = plug on the utilization equipment ; vehicle connector = receptacle. The EV side is a bit like an electric chain saw that has a shrouded inlet on it, for use with the female end of an extension cord.

Cheers, Wayne

 

[jaggedben]

Wiring devices is a term used in the NEC. A GFCI receptacle is a wiring device and has a UL Listing as such. What UL listing does your connection box have?

The picture looks like a connection box which transitions from the premises wiring to a flexible cord with a connector that the NEC says is part of the vehicle and not the premises wiring.

I don't follow what any of that has to do with anything. You're making a roundabout argument about how UL standards inform the meaning of an undefined NEC term ("wiring devices")? Does this tell us whether a EVSE is utilization equipment and a GFCI receptacle is not? Does UL tell us what utilization equipment is? You're gonna have to explain this better in order for me to follow.

The picture I posted is a standard J1772 connector that could be part of a hardwired EVSE or a plug in one.

 

[don_resqcapt19]

I am done...we have been around and around and there will NEVER be any minds changed on these issues

 

[jim dungar]

UL 2594.

Speaking of devices, the functions an EVSE performs fall squarely within the definition of "device":

Device. A unit of an electrical system, other than a conductor, that carries or controls electric energy as its principal function.


The thing pictured in post #33 is the "vehicle connector" at the end of the EVSE cord, and it plugs into the "vehicle inlet" which is part of the vehicle. Your NEC reference is to the vehicle inlet, not the vehicle connector.

So in the analogy with a cord and plug connected piece of utilization equipment, we have EV = utilization equipment; vehicle inlet = plug on the utilization equipment ; vehicle connector = receptacle. The EV side is a bit like an electric chain saw that has a shrouded inlet on it, for use with the female end of an extension

This pretty much started with the picture of a connection point in post #6. The item that mates with this connection point has the cord shown in post #33.
My point has been this connection point is where the premises wiring ends and therfore it is an outlet, but not a 'receptacle outlet'. Any GF function offered by anything connected to this item does not meet the NEC requirements for GFCI protection.

 

[jaggedben]

This pretty much started with the picture of a connection point in post #6. The item that mates with this connection point has the cord shown in post #33.
My point has been this connection point is where the premises wiring ends and therfore it is an outlet, but not a 'receptacle outlet'. Any GF function offered by anything connected to this item does not meet the NEC requirements for GFCI protection.

Then I take it your position is that a GFCI outlet cannot provide the protection required in 210.8(F). Since the receptacle is the item that mates with the connection point that you believe is the outlet.

Please, if you disagree, explain yourself by referring to the NEC definition of Utilization Equipment. I'm not arguing that the outlet isn't a receptacle outlet, 210.8(F) doesn't refer to receptacle outlets, and nothing I'm saying rests on that one way or the other.

 

[wwhitney]

This pretty much started with the picture of a connection point in post #6. The item that mates with this connection point has the cord shown in post #33.
My point has been this connection point is where the premises wiring ends and therfore it is an outlet, but not a 'receptacle outlet'.

The termination in post #6 certainly shows where the building wire ends, but it's not obvious it's where the premises wiring ends. The functions of an EVSE are comparable to a glorified receptacle, and it fits the definition of a device better than it fits the definition of utilization equipment. Devices are commonly part of the premises wiring system.

Personally, I'm torn on this question, but am happy that so far it's moot, so I don't have to take a position.

Cheers, Wayne

 

[brycenesbitt]

Right, but ultimately we need to know what protection the EVSE actually provides. And I frankly don't understand why EVSE protection couldn't meet the requirements for personnel.

Emporia's website recently recommended using a less sensitive type of GFCI breaker: one with a 30 mA trip point instead of a 5 mA trip point. That's also known as an equipment protection GFCI breaker: https://web.archive.org/web/2023072...cles/13491077155095-GFCI-Breaker-Installation
For reference North America is an outlier in the 6mA GFCI standard. See IEC60479.


Oregon has a tech bulletin: https://www.oregon.gov/bcd/codes-stand/Documents/sam-2022-02-ev-gfci.pdf

Statewide Alternate Method No. 22-01
In order to address the nuisance tripping and to bring consistency to the requirements for GFCI protection in
Oregon, when the electrical contractor or equipment owner has determined an incompatibility issue between
the EV charging equipment and GFCI protection due to nuisance tripping, a standard overcurrent device may
be installed in place of the circuit GFCI protection.
Changes to this section were not made during the development of the 2023 NEC, and therefore, will be
reviewed and revised appropriately in the next edition of the OESC.

UL 2231 Requirements met by all EVSEs (text from OpenEVSE):

• GFCI--Ability to respond to a 20mA ground fault (Power on and any time before relays close)
• Missing Ground (Any time Relays are closed)
• Welded Relay Contact Monitor (Any time Relays are open)
• Pilot line status
• Ground Monitoring If ground is lost charging is discontinued. (SAE J1772)

Ground Fault Interrupt
Fault sensitivity of Min 15ma - Max 20ma trip for protection against electric shock of personnel. (NEC 625.22) (SAE J1772) (UL 2231)
After each GFCI event OpenEVSE will retry charging up to 4 times after a 15 minute delay per event. (UL 2231) Ground Fault circuit tested during Power on Self-test.

 

[jim dungar]

Then I take it your position is that a GFCI outlet cannot provide the protection required in 210.8(F). Since the receptacle is the item that mates with the connection point that you believe is the outlet.

Please, if you disagree, explain yourself by referring to the NEC definition of Utilization Equipment. I'm not arguing that the outlet isn't a receptacle outlet, 210.8(F) doesn't refer to receptacle outlets, and nothing I'm saying rests on that one way or the other.

A GFCI receptacle is part of a premises wiring system and is tested by UL for general connections using its 'contacts'.

The connection item shown in post #6, cannot be used on with any general device. It is part of an assembly listed to UL, similar to the complete device shown in post #11. The final assembly serves a single purpose of being part of an EV charging system. As shown in post #19, NEC 625 says the function of the EVSE is to transfer power from the premises wiring. Specifically, 625.22 requires personnel, such as GFCI, protection to be located before (i.e. as part of the premises wiring) the EVSE, as evidenced by the requirement of GFCI at the plug end of a cord connected installation.

 

[jaggedben]

A GFCI receptacle is part of a premises wiring system and is tested by UL for general connections using its 'contacts'.

The connection item shown in post #6, cannot be used on with any general device.

The word 'general' here is a red-herring you are throwing in. It is not used in any code definitions or requirements.

It is part of an assembly listed to UL, similar to the complete device shown in post #11.

Both a GFCI receptacle and an EVSE are listed to a UL standard, yes. The particular standard they are listed to is not relevant to any code definitions or requirements we are discussing.

The final assembly serves a single purpose of being part of an EV charging system. As shown in post #19, NEC 625 says the function of the EVSE is to transfer power from the premises wiring.

That does not settle whether the EVSE is part of the premises wiring or not. A service transfers energy between the utility and the premises and the service conductors and equipment are still part of the premises wiring. Very similar language in the definitions; Note that both actually say 'between', not 'from'. These definitions do not make the distinction you're claiming they make.

Specifically, 625.22 requires personnel, such as GFCI, protection to be located before (i.e. as part of the premises wiring) the EVSE, as evidenced by the requirement of GFCI at the plug end of a cord connected installation.

625.22 does not say 'before the EVSE'. Your statement completely misrepresents what that section says.

625.22 Personnel Protection System: The equipment shall have a listed system of protection against shock of personnel. Where cord and plug connected equipment is used ...

(A hardwired EVSE is not cord-and-plug connected, so the part where I truncated doesn't apply.)

In fact the language here is no different than the language in 210.8(A) through (C) and others. The "receptacle shall have" GFCI or the "equipment shall have" GFCI. This leaves the option open for the GFCI protection to be either upstream (e.g. GFCI breaker) or at the receptacle or equipment. There's no reference to the outlet and thus no need to look for the location of the outlet and decide which side of the outlet the protection has to be on. In neither case does it hinge on whether the equipment is part of the premises wiring system or where it is in relation to the outlet.

Let me acknowledge at this point that I've been playing devil's advocate. My position is that the a GFCI receptacle obviously can provide the protection required by 210.8(F). My reasoning is that the outlet is not a point in the strict mathematical sense, but is rather a location (albeit a fairly narrow one) that can encompass the device or equipment where current is 'taken' for the load. (See definition of outlet.) In my opinion one does not have to enage in the whole hairsplitting exercise of locating the 'outlet' to a set of terminals on a device or equipment, as ya'll have been doing.

But my point is that if one is going to be liberal in this regard when considering a GFCI receptacle - which is equipment, and a device, and also utilization equipment - to provide the outlet in 210.8(F) with the required protection, then one should be equally liberal in allowing a Level II EVSE to do so (assuming the EVSE has the required functionality, which is a separate issue). Both are the equipment at the outlet.

That said, I also think the trend of requiring "outlets" to have GFCI is a bad trend that is going to lead to further confusion and controversy of the kind we're witnessing here. It was started with 210.8(F) and now unfortunately has been expanded to change how 422.5 handles things, in a bad way that reduces options for manufacturers and installers. It doesn't appear to be being done in coordination with manufacturers or UL and I can ascertain for no good reason for it. It used to be clear that equipment "at the outlet" could provide the required protection (without having to ask whether it's part of the premises wiring or where exactly the outlet is). Now that's getting muddied.

 

[wwhitney]

l It was started with 210.8(F) and now unfortunately has been expanded to change how 422.5 handles things, in a bad way that reduces options for manufacturers and installers.

2023 NEC 422.5(B) gives plenty of guidance and flexibility on where the GFCI may be located. This is in contrast to 210.8(F) that provides no location guidance other than saying the "outlet" must be protected, which as you point out leads to discussion on the exact outlet location.

Cheers, Wayne

 

[jaggedben]

2023 NEC 422.5(B) gives plenty of guidance and flexibility on where the GFCI may be located. This is in contrast to 210.8(F) that provides no location guidance other than saying the "outlet" must be protected, which as you point out leads to discussion on the exact outlet location.

Cheers, Wayne

Sorry, misremembered which section. See the new 210.8(D) in 2023 which seems to usurp the jurisdiction of 422.5.

 

[brycenesbitt]

So in the analogy with a cord and plug connected piece of utilization equipment, we have EV = utilization equipment; vehicle inlet = plug on the utilization equipment ; vehicle connector = receptacle. The EV side is a bit like an electric chain saw that has a shrouded inlet on it, for use with the female end of an extension cord.
Cheers, Wayne

@wwhitney there are separate cases to discuss, and I fear that cord connected EVSE are again leaking into this discussion:

breaker->premises wiring->outlet->plug->cord->EVSE w/GFCI->cable->plug->vehicle
breaker->premises wiring->outlet (no EVSE present)
breaker->premises wiring->EVSE w/GFCI->cable->plug->vehicle

And for completeness Mode 1 chargers which nobody uses I hope:
breaker->premises wiring->outlet->plug->cord->vehicle
-
In particular in the second case there is no part of the system that can be accessed without specialized tools. You can't stick a knife into a J1772 plug and do anything. The EVSE contains a relay, much like a bathroom GFCI, with the main difference in that it defaults to OFF rather than defaulting to ON.
-
Would it help the case if the EVSE had a lock or security screws, or maybe a software interlock that keeps anyone from taking it apart?

 

[wwhitney]

@wwhitney there are separate cases to discuss, and I fear that cord connected EVSE are again leaking into this discussion:

breaker->premises wiring->outlet->plug->cord->EVSE w/GFCI->cable->plug->vehicle
breaker->premises wiring->outlet (no EVSE present)
breaker->premises wiring->EVSE w/GFCI->cable->plug->vehicle

You need to be more precise in the wording in the above, mindful of the NEC specified terms (Article 100 definitions, or pre-2023 NEC, some of them are in Article 625). I think you mean:

breaker - building wire - receptacle - attachment plug - flexible cord - EVSE body - EV cable - vehicle connector - vehicle inlet
breaker - building wire - receptacle
breaker - building wire - EVSE body - EV cable - vehicle connector - vehicle inlet

In particular "outlet" has a very specific meaning in the NEC, and much of the discussion has been about where the "outlet" is located in case 3.

Anyway, the part of my post you quoted was not related to cord and plug connected EVSEs (case 1). I was comparing the J1772 vehicle connector going into the vehicle inlet on the EV with plugging the cord of some other utilization equipment into a receptacle.

Also, to my knowledge EVSEs don't contain Class A GFCI (4-6ma trip threshold), which is what the NEC means when it refers to just "GFCI". The ones I've looked at all provide CCID20, a ground fault detection circuit that trips at 20ma. CCID20 does not satisfy NEC requirements for GFCI; ignore it for this discussion.

If you are aware of an EVSE that provides either CCID5 (5ma trip level) or Class A GFCI protection, that would be very interesting to know, please provide an example. Without such an EVSE, much of the discussion so far has been academic. [And in the case of CCID5, further research would be required to see if it also qualifies as a Class A GFCI.

In particular in the second case there is no part of the system that can be accessed without specialized tools. You can't stick a knife into a J1772 plug and do anything.

You mean because there's no EVSE present in the second case? Otherwise I don't follow.

Cheers, Wayne

 

[brycenesbitt]

I know this thread is about the 2020 NEC, but once you’re on the 23 NEC, and the EVSE is installed outdoors on a hard-wired 50A or less branch circuit, the outlet must be protected. Then the outlet location becomes relevant.
We had a big thread about this with regards to HVAC units. Same thing should apply to an EVSE.

This thread is about the 2023 NEC frankly, at least that was my intent as the OP.
I'm still seeking to find the "outlet" in:
meter->main breaker->dedicated breaker->premises wiring->EVSE w/GFCI->cable->J1772 plug->car
----
On the other hand is:
meter->main breaker->dedicated GFCI breaker->premises wiring->NEMA 14-50 outlet
A completely different case: the location of the outlet is clear.

----
An EVSE is quite frankly a GFCI with a pulse width modulated amperage signal. That's literally all it does.
It sends a pilot signal that communicates the circuit capacity to the car, then checks certain parameters including ground and GFCI, then switches on a relay. It's like a bathroom GFCI that defaults to OFF but turns on when you plug in your shaver. The only power used by an EVSE is the same type of vampire power used by a GFCI: internal circuitry and the coil energy for the relay.
----
Unlike HVAC equipment, a typical EVSE is "double insulated" in the sense that a wiring fault inside can't get through the case.

 

[brycenesbitt]

Also, to my knowledge EVSEs don't contain Class A GFCI (4-6ma trip threshold), which is what the NEC means when it refers to just "GFCI". The ones I've looked at all provide CCID20, a ground fault detection circuit that trips at 20ma. CCID20 does not satisfy NEC requirements for GFCI; ignore it for this discussion.
Cheers, Wayne

Could you help with the NEC quotation that defines the bare term GFCI ?
I quoted the EVSE regulations from UL 2231 echoed in (NEC 625.22) (SAE J1772) above.

Here is some 6mA testing of an EVSE for GFCI protection (the device trips at 5.1mA):

According to the video EVSEs need to be tested with the 6mA RDC-DD method. I don't fully understand that, but include it out of potential relevance to this discussion.

 

[jaggedben]

Could you help with the NEC quotation that defines the bare term GFCI ?

It's defined in article 100, and there's an informational note referring to UL 943, Class A, and trip point of 6ma.

I quoted the EVSE regulations from UL 2231 echoed in (NEC 625.22) (SAE J1772) above.

Here is some 6mA testing of an EVSE for GFCI protection (the device trips at 5.1mA):

According to the video EVSEs need to be tested with the 6mA RDC-DD method. I don't fully understand that, but include it out of potential relevance to this discussion.

Interesting.

 

[jaggedben]

This thread is about the 2023 NEC frankly, at least that was my intent as the OP.
I'm still seeking to find the "outlet" in:
meter->main breaker->dedicated breaker->premises wiring->EVSE w/GFCI->cable->J1772 plug->car
----
...

My opinion, which you've seen is controversial, is that the part I've highlighted red is the equipment at the outlet and can provide the protection required in 210.8(F), just like a GFCI receptacle, if in fact the EVSE is listed to provide the protection described in Article 100.

Others in this thread are saying are saying that the outlet is at the arrow I colored orange. And that for some reason that IMO they can't explain, that if you replace the red part with 'GFCI Receptacle' the outlet moves to the arrow that I colored blue.

As for why it's the case that we can't easily point to a hardwired EVSE that in fact is listed to provide that protection, that's another question.