Would you consider this a kitchen?

Status
Not open for further replies.
Hey guys/gals I've been thinking a lot about this specific job and whether or not I would consider this a kitchen. First a little back story for me. I work for a school district and we service mobile trailers for schools whom don't have enough room. On one side of the trailer there are counter-tops with a sink and a couple of receptacles. One receptacle is a dedicated circuit for a microwave, the other is a convenience outlet. By definition in the NEC a kitchen is An area with a sink and permanent provisions for food preparation and cooking. Small children's food is warmed up in the microwave for a snack. Would this be considered a kitchen? Is this exempt from definition of a kitchen because it's not exactly permanent? I'm just asking to see if these receptacles require GFCI protection by code. I'm aware it's just easier to put a GFCI in but I'm curious on the proper answer for knowledge purposes. Thanks in advance.
 
It is not a kitchen IMO.

You do have this though:

210.8(B)(5) Sinks ? where receptacles are installed within 1.8 m
(6 ft) of the outside edge of the sink

Personaly, I would put in GFCI if I could.
 
In my personal opinion it is a kitchen others will feel differently but the only opinion that will matter will be the AHJs or possible an accident investigators.

I would treat it as a commercial kitchen.
 
It is not a kitchen IMO.

You do have this though:

210.8(B)(5) Sinks ? where receptacles are installed within 1.8 m
(6 ft) of the outside edge of the sink

Personaly, I would put in GFCI if I could.

Ironically I just read that article. Thanks for the advice, I agree with what your saying.

I meant to define this as well in my first post but completely forgot:

Dwelling Unit: A single unit, providing complete and independent living facilities for one or more persons, including permanent provisions for living, sleeping, cooking, and sanitation.

By definition the trailer is clearly not a dwelling unit. I think the only code that can apply here is article 210.8(B)(5) as jumper already stated. Please share your thoughts.

EDIT: Also, I've already installed GFCI's just because. Even if they're not required, honestly what's it going to hurt? I was just making this thread for my own self knowledge. Thank you all for your responses.
 
Last edited:
Dwelling Unit: A single unit, providing complete and independent living facilities for one or more persons, including permanent provisions for living, sleeping, cooking, and sanitation.

By definition the trailer is clearly not a dwelling unit.

Of course it is not a dwelling unit.

In my opinion it is a kitchen, I know that our inspectors in this area would call it a kitchen. I spend a ton of time working in areas that are boarderline kitchens and the inspectors like GFCIs.
 
I don't see how a microwave sitting on a counter is permanent.

What makes an appliance permanent? Is any appliance really permanent?

If I was the AHJ I think it would be quite reasonable to say that a microwave is permanent provisions for cooking.

EI: What is the use of this space?

EC: Food preparation and serving.

EI: If that microwave breaks will it be replaced with another?

EC: I don't know .... I guess so.

EI: So it is safe to say this space will always have a cooking appliance?

EC: Yeah... I guess.

EI: It is a kitchen.


Your mileage may vary but that is pretty much how I see it playing out here.
 
What makes an appliance permanent? Is any appliance really permanent?

If I was the AHJ I think it would be quite reasonable to say that a microwave is permanent provisions for cooking.

EI: What is the use of this space?

EC: Food preparation and serving.

EI: If that microwave breaks will it be replaced with another?

EC: I don't know .... I guess so.

EI: So it is safe to say this space will always have a cooking appliance?

EC: Yeah... I guess.

EI: It is a kitchen.


Your mileage may vary but that is pretty much how I see it playing out here.
Is a coffee maker a cooking appliance?

Next question - is the entire room the kitchen or just the space near the sink/counter and cooking appliance(s)?

When the entire room is primarily for food preparation I have little to question but this is more of a space found in a restaurant kitchen or a similar, these little break areas - not so clear as sometimes they are just a space within another space that has other functions.
 
......... I'm aware it's just easier to put a GFCI in but I'm curious on the proper answer for knowledge purposes. Thanks in advance.

Sometimes there is no "proper Answer" it is just opinion and interpretation of the code by the installer and/or the AHJ.

I don't see it as a "kitchen" but rather as a counter that has a sink and microwave and I would treat it as a wet bar sink.

I would install a GFCI.
 
you can have an inspector that over reaches, it is not all that uncommon.

that does not make him right.

OTOH, if all he wants is a GFCI, I would be inclined to just do it as it will cost a lot more to argue over it, even if one ultimately prevails.
 
Is a coffee maker a cooking appliance?

Next question - is the entire room the kitchen or just the space near the sink/counter and cooking appliance(s)?

When the entire room is primarily for food preparation I have little to question but this is more of a space found in a restaurant kitchen or a similar, these little break areas - not so clear as sometimes they are just a space within another space that has other functions.

In my area, in my experience with numbers of these borderline areas the EIs will treat it as a kitchen.

If you go back to the reason GFCIs for commercial kitchens were brought into the code it makes sense to include these prep areas as well.

IMO there is enough room in the NEC sections to give the EIs this authority. Again, what is permanent? What are provisions for cooking? To me those are all calls to be made by the AHJ or their surrogate.

I will give you an example, most large supermarkets will have a large refrigerated room out back called produce prep. They are always wet, floors, walls, counters etc. they are also full of electrical appliances, scales, wrappers, cutters etc. and while GFCI rules clearly apply near the sinks what about the outlets across the room?

Time and again the local EIs will require GFCIs for all 125 volt 20 amp receptacles in the entire space. Same with meat cutting rooms, Seafood prep areas, Deli / prepared food areas etc.
 
In my area, in my experience with numbers of these borderline areas the EIs will treat it as a kitchen.

If you go back to the reason GFCIs for commercial kitchens were brought into the code it makes sense to include these prep areas as well.

IMO there is enough room in the NEC sections to give the EIs this authority. Again, what is permanent? What are provisions for cooking? To me those are all calls to be made by the AHJ or their surrogate.

I will give you an example, most large supermarkets will have a large refrigerated room out back called produce prep. They are always wet, floors, walls, counters etc. they are also full of electrical appliances, scales, wrappers, cutters etc. and while GFCI rules clearly apply near the sinks what about the outlets across the room?

Time and again the local EIs will require GFCIs for all 125 volt 20 amp receptacles in the entire space. Same with meat cutting rooms, Seafood prep areas, Deli / prepared food areas etc.
I think most of your examples are a good place for GFCI but may or may not necessarily be spaces that NEC requires GFCI.

Can we extend this kitchen definition to a plant that processes food products? I think there may be areas within the plant that GFCI protection is a good idea or maybe even required, but I don't think the entire processing area of the plant should be considered a commercial kitchen either, though you may be able to call it that from the definition in NEC. I have such a place I frequently work in, all their finished product is ingredients for other food production companies, none of it is something you would want to eat as is either but is still food grade products. It is all processed and sent out in either 50 pound bags or 2500 pound totes. Your supermarket areas description are just a little closer to the consumption end of the chain, and some finished product may be ready to eat, some may still need further cooking or other processing.
 
In my personal opinion it is a kitchen others will feel differently but the only opinion that will matter will be the AHJs or possible an accident investigators.

I would treat it as a commercial kitchen.

Agreed.

Kitchen. An area with a sink and permanent provisions for
food preparation and cooking.

Please note that the red was added in 2011.

As to it being a dwelling unit. If it is a manufactured home it is considered a dwelling unit. In Ohio all must be inspected regardless of use.

I have inspected over 1000 'sets'. Back in 2007-09. When the program was first implemented.

It is illegal to move/transport one (Ohio) without a permit. Yes this includes buying one and putting it in your farm field.

Ohio began inspecting ALL 'sets' in 2007. This is why:

http://omhc.ohio.gov/LinkClick.aspx?fileticket=BkZI-F-INXQ=&tabid=66&mid=406

SUMMARY: This final rule establishes a
federal manufactured home installation
program, as required by section
605(c)(2)(A) of the National
Manufactured Housing Construction
and Safety Standards Act of 1974. States
that have their own installation
programs that include the elements
required by statute are permitted to
administer, under their state installation
programs, the new requirements
established through this final
rulemaking. The new elements required
by statute to
 
Status
Not open for further replies.
Top