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

[jim dungar]

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


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.


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.


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


(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.

A receptacle is not utilization equipment. Per the NEC it is a contact device.

A GFCI also is not utilization equipment, its purpose is not to consume energy. It is a device for protecting personnel from ground faults. An argument can be made it is a controller of electrical current.

Yes, the NEC definition of equipment includes devices.
The NEC definition of utilization devices does not make any reference to it drawing current. Instead it mentions using electrical energy for purposes like heating, lighting, and electronic.
We do not consider all devices which have incidental current draw as utilization equipment, for example neither lighted wall switches nor occupancy sensors are included when making load calculations.

The NEC clearly requires GFCI protection to be before a plug and cord connected EVSE, so there is no reason to believe it considers EVSE protection to equal that of a GFCI.

Whether the NEC should be changed to remove GFCI protection requirements for some outlets such as hardwired equipment has not been part of my discussion.

 

[ActionDave]

...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.

I'm staying out of the debate on where the outlet is but on this point I agree.

 

[jaggedben]

A receptacle is not utilization equipment. Per the NEC it is a contact device. A GFCI also is not utilization equipment,

Please refer to the NEC definitions instead of simply making a bald unsupported assertion over and over and over.
"Equipment: A general term, including ... devices..."
"Utilization Equipment: Equipment that utilizes electric energy for electronic ...[etc.] or similar purposes."
A GFCI receptacle plainly utilizes electric energy for electronic purposes, and therefore fits under those definitions.
As retirede pointed out in post #32, "The NEC does not limit what comprises utilization equipment based on the power it consumes."

There is nothing in the NEC that says that because something is a receptacle or a contact device that it is not also utilization equipment. Please cite the NEC if you disagree.

[A GFCI receptacle's] purpose is not to consume energy.

Neither is an EVSE's. You keep making statements that don't make a meaningful distinction between an EVSE and GFCI receptacle with reference to any NEC rule or definition.

It is a device for protecting personnel from ground faults. An argument can be made it is a controller of electrical current.

Yes, the NEC definition of equipment includes devices.
The NEC definition of utilization devices does not make any reference to it drawing current. Instead it mentions using electrical energy for purposes like heating, lighting, and electronic.
We do not consider all devices which have incidental current draw as utilization equipment, for example neither lighted wall switches nor occupancy sensors are included when making load calculations.

You're right, it mentions electronic purposes, which applies to a GFCI receptacle. And the NEC makes reference to none of these other things and therefore we may judge whether a GFCI receptacle is utilization equipment by looking plainly at the definition.

The NEC clearly requires GFCI protection to be before a plug and cord connected EVSE,

I agree, but WE ARE NOT TALKING ABOUT PLUG AND CORD CONNECTED EVSEs. We are talking about hard-wired EVSEs and have been this whole thread. All the original examples in the thread were hardwired EVSEs.

so there is no reason to believe it considers EVSE protection to equal that of a GFCI.

There's no reason to believe the opposite, either, provided the equipment is listed to an applicable standard.

As a practical question, please explain how a hardwired Level II EVSE sitting there by itself presents a different hazard than a receptacle with respect to GFCI.

Whether the NEC should be changed to remove GFCI protection requirements for some outlets such as hardwired equipment has not been part of my discussion.

? Nor mine.

 

[retirede]

An EVSE is quite frankly a GFCI with a pulse width modulated amperage signal. That's literally all it does.

You are describing only the simplest EVSEs. There are also more complex units that connect to WiFi, log data and upload to the cloud, interact with local power monitoring, and coordinate charging with solar generation.

Saying this is nothing more than a GFCI receptacle is just wrong. It’s like saying a desktop computer tower is just a receptacle because it has a convenience outlet to power a monitor.

 

[brycenesbitt]

You are describing only the simplest EVSEs. There are also more complex units that connect to WiFi, log data and upload to the cloud, interact with local power monitoring, and coordinate charging with solar generation. Saying this is nothing more than a GFCI receptacle is just wrong. It’s like saying a desktop computer tower is just a receptacle because it has a convenience outlet to power a monitor.

I disagree. A bathroom GFCI outlet with WiFi, current monitoring and a backscratching attachment would still fundamentally be a GFCI.
I agree that I was incomplete:
An EVSE is a normally-off GFCI WITH the ability to signal the circuit capacity AND a make safe circuit that disconnects power if the plug is removed from the car.
--
But let's for the moment get to hazard.
We'll all agree that an unbonded/ungrounded washing machine case is a hazard.
But what about an EVSE?

With a GFCI outlet in a bathroom, you pull out your desk lamp and place it next to the tub.
It falls in and the GFCI damn well better turn off the circuit fast: power is already in the water.

With the EVSE the hazard does not seem even comparable. The device is OFF until the GFCI says things are clear AND the cable is plugged in. On removal of the cable, the EVSE opens the circuit. There are no terminals to stick a knife or spoon into. To create an unsafe situation with an EVSE you have to either disassemble it OR spoof the proximity detection THEN use a wire or similar object to touch the exposed 240V terminals. If you damage the cable or mess with the plug you're safe.

Basics of SAE J1772

Introduction Basics of the J1772 standard. Charging Voltage Max Current Level 1 (L1) 120VAC 16A max per J1772 Level 2 (L2) 208 - 240VAC 80A Pilot Max Current Duty Cycle Max Current < 3% Error 3% - 7% Digitial Co...

openev.freshdesk.com

--
If we need a second GFCI for an EVSE is it because of rule reading, or an addressed hazard?
What is the hazard?
Is it crashing into the EVSE with a car, and if so how is that different than crashing into an outdoor GFCI outlet?

 

[brycenesbitt]

The NEC clearly requires GFCI protection to be before a plug and cord connected EVSE, so there is no reason to believe it considers EVSE protection to equal that of a GFCI.

@jim dungar the question on the table is a hardwired EVSE, typically with conduit coming in from a dedicated breaker.

 

[wwhitney]

An EVSE is a normally-off GFCI . . .

Since this is an NEC forum, please use the NEC definition of "GFCI" and stop calling an EVSE a GFCI, when most (almost all?) EVSEs don't implement Class A GFCI protection.

Cheers, Wayne

 

[brycenesbitt]

Since this is an NEC forum, please use the NEC definition of "GFCI" and stop calling an EVSE a GFCI, when most (almost all?) EVSEs don't implement Class A GFCI protection.
Cheers, Wayne

Ok, fair enough. I'll start saying that an EVSE has an "IEC 62955/UL 2231 compliant default off GFCI".

Here's a bit more from Martin Scottorn, Final Distribution Product Manager, Schneider Electric in New Zealand:

https://www.pdl.co.nz/about-us/trade-blog/type-b-rcd-vs-an-rdc-dd

On the distinction between Type A, Type B RCCB and RCD-DD devices.
-----
I'm still asking is there an identified safety hazard, or any record of an incident, with hardwired EVSEs without separate upstream Type A UL 943 GFCI?

 

[jaggedben]

You are describing only the simplest EVSEs. There are also more complex units that connect to WiFi, log data and upload to the cloud, interact with local power monitoring, and coordinate charging with solar generation.

Saying this is nothing more than a GFCI receptacle is just wrong. It’s like saying a desktop computer tower is just a receptacle because it has a convenience outlet to power a monitor.

Two points:
First, if the desktop were (for the sake of argument) hardwired, but it contained listed GFCI protection for the convenience outlet and in general, why should the code require a GFCI breaker at the branch circuit origin? 422.5 has long allowed GFCI to be in the equipment for cases similar to this.

Second, with 210.8(D) and (F) as written in 2023, the issue is when you go the other way; how small and irrelevant do you have to make the receptacles electronic consumption to make it not utilization equipment? You yourself were the first in this thread to point out that the NEC makes no distinction here based on the amount of power or energy used.

As long CMPs continue this trend of requiring 'outlets' to have protection while not explicitly allowing hardwired equipment to provide that protection, this controversy will continue to grow and I'm going to keep pointing out how misguided and unsubstantiated this approach is.

 

[jim dungar]

Please refer to the NEC definitions instead of simply making a bald unsupported assertion over and over and over.
"Equipment: A general term, including ... devices..."
"Utilization Equipment: Equipment that utilizes electric energy for electronic ...[etc.] or similar purposes."
A GFCI receptacle plainly utilizes electric energy for electronic purposes, and therefore fits under those definitions.
As retirede pointed out in post #32, "The NEC does not limit what comprises utilization equipment based on the power it consumes."

My descriptions have come directly from the NEC definitions.

Is it the purpose of a GFCI to utilize electrical energy? According to the NEC definition, a GFCI's purpose is to provide personnel protection from ground faults.

I do not see where incidental consumption of electrical energy, such as a lighted switch or status lights on a surge suppressor changes the device into utilization equipment. Does any NEC Listing agency require this incidental energy usage to be reported on the nameplate of the device? Do these devices fall under some 'energy act' energy usage limitations?

I guess this is why it is up to AHJs to determine products are being applied correctly per their Listings.

 

[wwhitney]

Ok, fair enough. I'll start saying that an EVSE has an "IEC 62955/UL 2231 compliant default off GFCI".

Since UL 2331 used the term CCID (charge current interrupting device), that would be a "UL 2331 compliant default off CCID".

Thanks for the pointer to UL 2331. UL 2331-2 (Table 6) does specify the trip time allowed for a CCID5, and it matches the trip time allowed for a Class A GFCI under UL 943, (20/I)^1.43 seconds, with I in mA. So now the discussion is a whole lot less academic:

Under the 2020 NEC, there is no requirement for GFCIs to be listed. Per the definition in Article 100 (which just references trip time), a UL 943 Class A GFCI and a UL 2331-2 CCID5 are both "GFCI". So if we have an EVSE with CCID5, now the location of the outlet is determinative as to whether an outdoor hardwired installation at a dwelling unit complies with 210.8(F).

The 2023 NEC added the requirement to 210.8 that the GFCI be a "listed Class A GFCI". So for the outlet location to matter under the 2023 NEC, we'd need a CCID5 EVSE that also is listed under UL 943 to provide Class A GFCI. I haven't looked at the ancillary requirements for CCID5 vs Class A GFCI, with respect to things like self resetting, testing, etc. It may be that UL 943 places limits on a Class A GFCI that would be undesirable for an EVSE.

Cheers, Wayne

 

[retirede]

I disagree. A bathroom GFCI outlet with WiFi, current monitoring and a backscratching attachment would still fundamentally be a GFCI.
I agree that I was incomplete:
An EVSE is a normally-off GFCI WITH the ability to signal the circuit capacity AND a make safe circuit that disconnects power if the plug is removed from the car.
--
But let's for the moment get to hazard.
We'll all agree that an unbonded/ungrounded washing machine case is a hazard.
But what about an EVSE?

With a GFCI outlet in a bathroom, you pull out your desk lamp and place it next to the tub.
It falls in and the GFCI damn well better turn off the circuit fast: power is already in the water.

With the EVSE the hazard does not seem even comparable. The device is OFF until the GFCI says things are clear AND the cable is plugged in. On removal of the cable, the EVSE opens the circuit. There are no terminals to stick a knife or spoon into. To create an unsafe situation with an EVSE you have to either disassemble it OR spoof the proximity detection THEN use a wire or similar object to touch the exposed 240V terminals. If you damage the cable or mess with the plug you're safe.

Basics of SAE J1772

Introduction Basics of the J1772 standard. Charging Voltage Max Current Level 1 (L1) 120VAC 16A max per J1772 Level 2 (L2) 208 - 240VAC 80A Pilot Max Current Duty Cycle Max Current < 3% Error 3% - 7% Digitial Co...

openev.freshdesk.com

--
If we need a second GFCI for an EVSE is it because of rule reading, or an addressed hazard?
What is the hazard?
Is it crashing into the EVSE with a car, and if so how is that different than crashing into an outdoor GFCI outlet?

I agree with everything you say about the hazards and mitigation thereof, but that is really a separate topic than “Where’s the outlet?”


There is nothing in the NEC that would disqualify a piece of equipment from being “utilization equipment” because of its functional limitations, or whether or not such equipment includes integral GFCI of GFP.

 

[jaggedben]

My descriptions have come directly from the NEC definitions.

Is it the purpose of a GFCI to utilize electrical energy? According to the NEC definition, a GFCI's purpose is to provide personnel protection from ground faults.

I do not see where incidental consumption of electrical energy, such as a lighted switch or status lights on a surge suppressor changes the device into utilization equipment. Does any NEC Listing agency require this incidental energy usage to be reported on the nameplate of the device? Do these devices fall under some 'energy act' energy usage limitations?

Is it the purpose of an EVSE to utilize electrical energy? According to the NEC its purpose is to transfer energy to the vehicle. So what's your point? Either they're both utilization equipment because they use electrical energy for electronic purposes, or neither is, under your reasoning, if that isn't their purpose according to the NEC. *Just be consistent.*

Let me also repeat that this question of what is utilization equipment is only under discussion because the CMP decided to start requiring protection for 'outlets' in the 2020 cycle, using wording that was never used before. Give me a practical substantiation for why the NEC should no longer allow hard wired equipment with listed GFCI (other than receptacles) to meet requirements.

 

[jim dungar]

There is nothing in the NEC that would disqualify a piece of equipment from being “utilization equipment” because of its functional limitations, or whether or not such equipment includes integral GFCI of GFP.

So if an equipment's intended purpose is not important. then shouldn't these also be utilization equipment?
Circuit breakers as they use electrical energy for their thermal, magnetic, or electronic trip elements.
Fuses because they convert current into heat.
Wi-fi light switches, they use electronics and have indicating lights
Surge suppressors with LED status indication.
Transformers as they produce heat as well as electro-magnetic fields.

I have tried to limit my discussion to 'where is the outlet'. I feel the outlet is the place where the premises wiring, or branch circuit, conductors end and utilization equipment begins.

 

[retirede]

So if an equipment's intended purpose is not important. then shouldn't these also be utilization equipment?
Circuit breakers as they use electrical energy for their thermal, magnetic, or electronic trip elements.
Fuses because they convert current into heat.
Wi-fi light switches, they use electronics and have indicating lights
Surge suppressors with LED status indication.
Transformers as they produce heat as well as electro-magnetic fields.

I have tried to limit my discussion to 'where is the outlet'. I feel the outlet is the place where the premises wiring, or branch circuit, conductors end and utilization equipment begins.

I agree with all of that. The items you mention are clearly installed upstream of (some) premises wiring or are a part of premises wiring. An EVSE is not. It is utilization equipment and nothing beyond the EVSE is premises wiring.

I was countering the assertion that an EVSE is not utilization equipment because of its simplicity.

 

[jaggedben]

So if an equipment's intended purpose is not important. then shouldn't these also be utilization equipment?
Circuit breakers as they use electrical energy for their thermal, magnetic, or electronic trip elements.
Fuses because they convert current into heat.
Wi-fi light switches, they use electronics and have indicating lights
Surge suppressors with LED status indication.
Transformers as they produce heat as well as electro-magnetic fields.

I have tried to limit my discussion to 'where is the outlet'. I feel the outlet is the place where the premises wiring, or branch circuit, conductors end and utilization equipment begins.

Just be consistent. If you're using NEC definitions describing intended purpose to determine what is utilization equipment, then neither a GFCI receptacle nor a hardwired EVSE are utilization equipment, and then the outlet of the EVSE is at the end of the J1772 plug where it connects to the car. So then if you think that a GFCI receptacle can provide compliance with 210.8(F), you should think the same for an EVSE that contains a listed GFCI.

(Granted, as Wayne says, it's academic until we can find such a one. But then the OP has shown that conceivably it's feasible for an EVSE to comply with the UL Standard.)

 

[jaggedben]

I agree with all of that. The items you mention are clearly installed upstream of (some) premises wiring or are a part of premises wiring. An EVSE is not. It is utilization equipment and nothing beyond the EVSE is premises wiring.

According to Jim, if I'm understanding his position correctly, an EVSE is not utilization equipment because the NEC definition describes its purpose in a way that doesn't fit under the definition of Utilization Equipment.

 

[jim dungar]

According to Jim, if I'm understanding his position correctly, an EVSE is not utilization equipment because the NEC definition describes its purpose in a way that doesn't fit under the definition of Utilization Equipment.

My point is that an ESVE is not part of premises wiring and its ground fault protection function and location does not satisfy the current NEC requirements for personnel protection at an outlet. It has not been my intent to debate if NEC requirements should be changed.

 

[xformer]

Where's the "outlet" in each of these situations?
View attachment 2568190


In the case of the bath GFCI the outlet and receptacle are the same thing.
In the case of the HVAC the "outlet" seems likely to be the shutoff switch, right?
---
But for the EVSE without a shutoff switch or receptacle, would the "outlet" be the EVSE or the supply breaker? Why?
---
I am aware there's a lot of confusion on these points, and differing interpretations:

210.8(F) GFCI Protection

Nothing written by a manufacture ever eliminates a code requirement. The manufacturer can require additional protections that require more that what the NEC requires, but they cannot eliminate a protection required by the NEC. When a manufacture says do not connect to GFCI protection, all...

forums.mikeholt.com

I would disagree with the statement in red. I would say that in the case of the bath GFCI the outlet contains a receptacle.

 

[wwhitney]

My point is that an ESVE is not part of premises wiring

There are various equipment types that can be part of the premises wiring, or portable. E.g. a transformer, it can be permanently installed between two panelboards. Or you could have a cord-and-plug connected transformer, say one that plugs into a NEMA 5-15 receptacle and provides some European 220V receptacle with a limited maximum power.

The same applies for EVSEs, they can be cord and plug connected. Or they can be hardwired and fixed in place. For the latter case, what is the basis for saying that it is not part of the premises wiring?

Cheers, Wayne