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

[jim dungar]

For the latter case, what is the basis for saying that it is not part of the premises wiring?

Which portions of the NEC apply to the internal wiring and parts of the EVSE and its output cable? How is the EVSE really different than an appliance or control panel?

 

[jaggedben]

Which portions of the NEC apply to the internal wiring and parts of the EVSE and its output cable? How is the EVSE really different than an appliance or control panel?

Lots of parts of premises wiring systems like those that Wayne mentioned have internals not subject to the NEC. Transformers, panelboards, receptacles and lighted switches (according to you). What is it about an EVSE that is different?

One way I believe we have already agreed that it is different from an appliance is that it is not utilization equipment.

 

[wwhitney]

Which portions of the NEC apply to the internal wiring and parts of the EVSE

Which portions of the NEC apply to the internal wiring and parts of a GFCI receptacle?

and its output cable?

That's a good question. Say you have EMT running across the ceiling to a junction box with a hole in its cover, a flexible cord coming out with proper strain relief, and the cord hanging down to a pendant box that contains a receptacle. Are the cord, pendant box, and receptacle part of the premises wiring?

So the possible answer to this question is Article 400.

How is the EVSE really different than an appliance or control panel?

It's different from an appliance, in that its job or purpose is only to safely transfer AC power to the EV, where the on-board charger converts that to DC and charges the EV's battery. As such it meets the definition of "device" much better than it meets the definition of "utilization equipment."

As to control panels, I'm not certain of the full breadth of functionality that term can cover, so I can't really answer.

As a thought exercise, suppose we had an EVSE where the "box" is hard wired and has a special receptacle on it, and the EV cord and vehicle connector are detachable, with a special plug for that special receptacle. Does this change whether the EVSE box is part of the premises wiring system?

Cheers, Wayne

 

[jaggedben]

If the EVSE is not utilization equipment, then by definition the point where it connects to the wiring is not an outlet. The outlet must be at the connector to the vehicle. Which in turn by definition makes the EVSE part of the premises wiring since it's between the power source and the outlet.

 

[wwhitney]

I mentioned this product back in post #38, but it was via an external link, so I think it's worth reprising and posting a photo.

This is an Eaton EVSE that is built into a smart circuit breaker that installs into one of their panelboards. The EVSE breaker takes up 4 spaces and appears to be a normal double pole breaker widened to provide space for the EVSE electronics. The breaker has 5 terminals for the 5 conductors in an EV cord. One installation option is to have the EV cord come directly out of the side of a surface mounted panel, perhaps one you already have in your garage.

So in this arrangement, is the EVSE smart breaker part of the premises wiring system? Is the EV cord and vehicle connector part of the premises wiring system?

These are only available in 40A models and I believe provide only CCID20 protection; at a dwelling unit, can I install one of these EVSE breakers in an outdoor 3R panelboard, or would that violate 2020 NEC 210.8(F)? [A real question about an actual product!]

Cheers, Wayne

 

[Filthy]

Reading through this post made me think and read. So my $.02 and maybe just pouring fuel on the fire. EVCS has its own entire section in the NEC so unless referenced from or referenced to falls outside of most of the above arguments. The issue of Personnel Protection is specifically mentioned in 625.22. Mind you I'm reading from 2017 so maybe some changes since.

 

[don_resqcapt19]

Reading through this post made me think and read. So my $.02 and maybe just pouring fuel on the fire. EVCS has its own entire section in the NEC so unless referenced from or referenced to falls outside of most of the above arguments. The issue of Personnel Protection is specifically mentioned in 625.22. Mind you I'm reading from 2017 so maybe some changes since.

That is not how the NEC works. See Section 90.3. All of the rules in Chapters 1 though 4 apply to an Article 625, Electric Vehicle Charging System installation, unless those rules are specifically modified in Article 625.

 

[Filthy]

So chapter 6 supplements or modifies sections 1-4

 

[don_resqcapt19]

So chapter 6 supplements or modifies sections 1-4 View attachment 2568332

Yes, but it only modifies a Chapter 1-4 rule, if the language in a Chapter 6 rule specifically says that. An example of a specific modification is the following from Article 725.

725.3 Other Articles.
Circuits and equipment shall comply with the articles or sections listed in 725.3(A) through (N). Only those sections of Article 300 referenced in this article shall apply to Class 1, Class 2, and Class 3 circuits.

 

[retirede]

Darned…..we almost made it a whole day. I was hoping this thread would die!

 

[brycenesbitt]

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

That right there indicates there's a problem with the code.
The only conclusion I can reach here is that the code committees need to take this up and decide if a 6mA Type A GFCI is needed upstream of a 6mA/20mA "GFCI like device" already inside hardwire EVSEs under 60A.

 

[Fred B]

Can't say every mfg is incorporating this or not but everyone that I've installed has an incorporated an interlock that will de-energize the output cable if it is not connected to the vehicle. This it seems would then make a moot point for GFCI for the hardwired EVSE or point of outlet for a "fixed in place" EVSE, as it would not present a shock hazard the GFCI is designed to protect against.
The requirement for a non-hardwired EVSE to have GFCI protection results from the ability to "unplug" the EVSE from the branch circuit and the energized points ahead of the EVS equipment, and potential shock hazard at that location.

 

[retirede]

Can't say every mfg is incorporating this or not but everyone that I've installed has an incorporated an interlock that will de-energize the output cable if it is not connected to the vehicle. This it seems would then make a moot point for GFCI for the hardwired EVSE or point of outlet for a "fixed in place" EVSE, as it would not present a shock hazard the GFCI is designed to protect against.
The requirement for a non-hardwired EVSE to have GFCI protection results from the ability to "unplug" the EVSE from the branch circuit and the energized points ahead of the EVS equipment, and potential shock hazard at that location.

There is the (remote) possibility of a damaged cable being energized while charging.

 

[don_resqcapt19]

That right there indicates there's a problem with the code.
The only conclusion I can reach here is that the code committees need to take this up and decide if a 6mA Type A GFCI is needed upstream of a 6mA/20mA "GFCI like device" already inside hardwire EVSEs under 60A.

In general the Code Making Panels only address the issues brought up by the public inputs. While they can write panel first revisions, that is not really common.

There are Public Inputs related to this thread that the panels are acting on in their Task Group meetings prior to the full committee meetings in Jan. The First Draft Report with the committee action on all of the Public Inputs and any panel created First Revisions will be published on July 10, 2024. The public comment closing date is August 28th.

However I can't see the panels accepting a GFCI like device. The code has been clear in defining the term GFCI as meaning a Class A GFCI device. In the 2023 cycle they did add Special Purpose GFCIs (SPGFCI) that do have a 20 mA trip in Article 680, but those are for use on circuits that you can't use a Class A GFCI device, because the circuit voltage exceeds 150 volts to ground. Note that a SPGFCI is not an equipment protection GFP or GFPE device. The SPGFCIs are Class C, D, and E GFCIs in UL 943C.

 

[brycenesbitt]

There are Public Inputs related to this thread that the panels are acting on in their Task Group meetings prior to the full committee meetings in Jan

Are any of those public inputs public, that you could point us to?

 

[brycenesbitt]

Can't say every mfg is incorporating this or not but everyone that I've installed has an incorporated an interlock that will de-energize the output cable if it is not connected to the vehicle. This it seems would then make a moot point for GFCI

Every EVSE disconnects power when unplugged. It's part of the spec.

What we can't control is Little Electrician Nancy sticking garden stakes into the exposed 14-50 terminals
(for plug connected EVSEs if the EVSE is not present).

A requirement for child locking in-service covers of 14-50 outlets might have accomplished much of the same safety goal.

 

[Fred B]

Every EVSE disconnects power when unplugged. It's part of the spec.

What we can't control is Little Electrician Nancy sticking garden stakes into the exposed 14-50 terminals
(for plug connected EVSEs if the EVSE is not present).

A requirement for child locking in-service covers of 14-50 outlets might have accomplished much of the same safety goal.

You can't even meter for power at the plug end if not plugged into the vehicle as the control wires if not completed into the vehicle turns off feed from the EVSE. Complicated multipoint connections would be required to energize. Would require a tester similar to this to have the EVSE to energize.

Fluke FEV100 EVSE Adapter EV Charger Tester

Fluke FEV100 EVSE Adapter for Electric Vehicle Charger Testing is essential electrical safety test equipment for EVSE systems from installation electric vehicle charging equipment to troubleshooting.

www.fluke.com

 

[retirede]

A requirement for child locking in-service covers of 14-50 outlets might have accomplished much of the same safety goal.

IMO, blade tension is high enough on a 14-50 to make accidental contact with the blades while unplugging a real possibility. I don’t have a problem with the GFCI requirement.

But we are straying from the original topic again.

 

[don_resqcapt19]

Are any of those public inputs public, that you could point us to?

Go to nfpa.org/70 and click on "next edition". Then you can click on "view public inputs online" and scroll through the code and reading the PIs associated with the code sections that you are interested in. For example if you go to the definitions in Article 100, you can view PIs related to the term "outlet".
If you want all of the PIs, you can scroll down to each code making panel, select "public input report" and "view". That will let you download a PDF of all of the PIs that are under the purview of that code making panel. There are 18 panels and about 9000 pages if you download all of them.

 

[brycenesbitt]

Nice technical article on the topic

EV Charger Leakage Protection - LUXMAN New Energy

Manufacturers have implemented a safety regulation and standard that requires all EV chargers to have a leakage protection unit installed in

www.luxmanenergy.com