Results 1 to 34 of 34
  1. #1
    Join Date
    Oct 2014
    Location
    Maryland, DC, and Northern Virginia, electrical only
    Posts
    444

    Default GFCI protection absent: do you flag this?

    Do you tell homebuyers and other clients when GFCI protection is needed and missing?

    I'm thinking about outdoor receptacles especially, but this applies to bathrooms as well, even in jurisdictions that aren't up to date. Neither the ASHI nor the InterNACHI SOP seems to require this, just to note any dud GFCIs or bad installs.

    Do you figure it's not your job to say these omissions (or violations depending on when devices were installed or replaced) are none of your business, or does everyone here note lacking GFCIs as a problem? Or does it depend on which GFCI requirements, and when the house you're looking at was wired or rewired?

    Similar Threads:
    Crawl Space Creeper

  2. #2
    Join Date
    Mar 2007
    Location
    Fletcher, NC
    Posts
    28,032

    Default Re: GFCI protection absent: do you flag this?

    David, I hope you don't mind me adding these GFCI and AFCI pages to your thread (I had a PM asking if I would repost these and your thread was timely for that).

    They are only up to the 2014 NEC, I never updated them to the 2017 or 2020 NEC.

    Quote Originally Posted by david shapiro View Post
    Do you figure it's not your job to say these omissions (or violations depending on when devices were installed or replaced) are none of your business, or does everyone here note lacking GFCIs as a problem? Or does it depend on which GFCI requirements, and when the house you're looking at was wired or rewired?


    I noted missing GFCI and AFCI locations, and most (all?) inspectors I knew also listed those missing protection locations in their reports. Those locations were reported not as being "required locations" for the protection, but as 'current national safety standards indicates the need for this protection at these minimum locations, other locations may benefit from said protections
    ' (wording varies by inspector).

    Attached Files Attached Files
    Last edited by Jerry Peck; 05-20-2023 at 07:19 AM.
    Jerry Peck
    Construction/Litigation/Code Consultant - Retired
    www.AskCodeMan.com

  3. #3
    Join Date
    Oct 2014
    Location
    Maryland, DC, and Northern Virginia, electrical only
    Posts
    444

    Default Re: GFCI protection absent: do you flag this?

    Jerry, I'm glad you tagged this on to the thread. IFF you permit, I will quote you as part of a NFPA 73 PI, just, just to require the 1971 compliance.

    If folks would find this of value, I can update what Jerry provided, adding the 2017, 2020, and 2023 revisions.

    The common statement you point to might be imperfectly accurate, if the inspector assumes grandfathering of replacement devices. Whenever the 2011 NEC was adopted in an area, if it would require AFCI protection as a new install, a replacement receptacle now required AFCI protection-- barring local amendments removing 406.4(D)(4). Back up to (D)(3), and now you might go back as much as 20 years. Replacement receptacles had the same GFCI requirements as new installs in the 2002 NEC.


  4. #4
    Join Date
    Mar 2007
    Location
    Santa Rosa, CA
    Posts
    3,154

    Default Re: GFCI protection absent: do you flag this?

    Quote Originally Posted by david shapiro View Post
    J If folks would find this of value, I can update what Jerry provided, adding the 2017, 2020, and 2023 revisions.
    David,

    A couple of years ago, with JP's consent, I modified his original matrix, updated it, and sent it to him asking that he review for errors. I have not yet updated the matrix with the current NEC (and, since I am in California, I added California information).

    When I have time, I will update mine and share it.

    Depending on the age of the home, I will generally recommend GFCIs as an upgrade or state that they were likely required at time of original construction (whichever I believe to be the case), but not found. In either case, I do suggest installation.

    As of right now, I usually mention that no AFCIs are present and suggest consulting with an electrical contractor.

    Attached Files Attached Files
    Department of Redundancy Department
    Supreme Emperor of Hyperbole
    http://www.FullCircleInspect.com/

  5. #5
    Join Date
    Mar 2007
    Location
    Fletcher, NC
    Posts
    28,032

    Default Re: GFCI protection absent: do you flag this?

    David, yes, no problem with including that.

    If you would like the Word doc file of each, I will email them to you.

    Gunnar, looks very good!

    Jerry Peck
    Construction/Litigation/Code Consultant - Retired
    www.AskCodeMan.com

  6. #6
    Join Date
    Oct 2014
    Location
    Maryland, DC, and Northern Virginia, electrical only
    Posts
    444

    Default Re: GFCI protection absent: do you flag this?

    Thanks, Gunnar.
    And thank you, Jerry. Shall I use your name or anonymize?
    It's not going to be worth anyone's while to wait a year, but I'm sure that NFPA 73, Tables B1 a,b, and c will be updated by the time the first draft of the 2025 edition is posted. These give the dates of GFCI requirements in alphabetical order by location, then in chronological order; and then AFCI requirements by chronological order.

    I was looking at an NEISS report recently, and in 2021 a woman was shocked at her apartment house's swimming pool due to a shorted underwater light. This is the very first item for which GFCI protection was required, 60-odd years before.


  7. #7
    Join Date
    Mar 2007
    Location
    Fletcher, NC
    Posts
    28,032

    Default Re: GFCI protection absent: do you flag this?

    David, you can use my name, no problem.
    u
    Send me a PM with your email address if you would like the Word doc files.

    Quote Originally Posted by david shapiro View Post
    I was looking at an NEISS report recently, and in 2021 a woman was shocked at her apartment house's swimming pool due to a shorted underwater light. This is the very first item for which GFCI protection was required, 60-odd years before.
    Are you referring to the 1962 NEC, when 680 Swimming Pools, was added?

    680-4 Lighting.
    (g) All circuits supplying underwater fixtures should be isolated. If the circuit voltage is greater than 30 volts, an approved fail-safe ground detector device which automatically de-energizes the circuit or an approved grid structure or similar safeguard should be used.

    What is an approved "grid structure or similar safeguard"? Is that the steel structural grid cast into the concrete as referenced in 680-7 Grounding?

    This "an approved fail-safe ground detector device which automatically de-energizes the circuit" could be termed as a "ground-fault circuit interrupter" (GFCI) ... but that was an option as there was an "or" which followed it, and that "or" was the "grid structure or similar safeguard".

    At one time I looked up and found when that 'GFCI' was required for the underwater lights, but that was so many years ago that I'd have to go through my codes and find it again ... but that is your job now, not mine.

    Jerry Peck
    Construction/Litigation/Code Consultant - Retired
    www.AskCodeMan.com

  8. #8
    Join Date
    Oct 2014
    Location
    Maryland, DC, and Northern Virginia, electrical only
    Posts
    444

    Default Re: GFCI protection absent: do you flag this?

    Jerry, I can't discount the use of the term "approved." There were three choices for underwater lighting:
    ~Isolated power <=30V, no special judgment call required;
    ~something that smelled like a GFCI and that the inspector was willing to stick his neck out to okay;
    ~bonding that the inspector was willing to stick his neck way the hell out to okay.

    As you point out, this is when we start setting NEC rules for pools. It's new code. I don't see it with substantiation in the 1961 Proposed Amendments, but it appears deus ex machina in the committee report and then the approved 1962 code.

    How did AHJs handle this brand new set of requirements? You've answered that, unhappily, in previous posts; judging from other situations, they may even have ignored or overlooked the requirement for isolation. However, a judicious AHJ asked to approve an alternative nowadays might say, "If you want to put in lighting that's over 30V, I want a letter from a licensed/bonded/insured PE saying that their professional evaluation has concluded that your installation will be as safe as one fed at 30V or less. Then I'll inspect it."


  9. #9
    Join Date
    Mar 2007
    Location
    Fletcher, NC
    Posts
    28,032

    Default Re: GFCI protection absent: do you flag this?

    Quote Originally Posted by david shapiro View Post
    Jerry, I can't discount the use of the term "approved."
    .
    .
    However, a judicious AHJ asked to approve an alternative nowadays might say, "If you want to put in lighting that's over 30V, I want a letter from a licensed/bonded/insured PE saying that their professional evaluation has concluded that your installation will be as safe as one fed at 30V or less. Then I'll inspect it."
    "Approved" in 1962 is the basically same as now "Acceptable to the authority enforcing this code".

    In addition to that, in places which use a code based on the ICC codes or have something similar, the "authority having jurisdiction" is the "building official"/"building code administrator", with those under the 'building official' being responsible for their areas (i.e., plumbing, mechanical, electrical, building, etc); however, the 'building official' is the "authority having jurisdiction.

    With that in mind, the ICC codes and those with similar requirements, are the ones with the authority to (from https://codes.iccsafe.org/content/IB...P2_Ch01_SubCh2 ):
    - Section 104
    - - Duties and Powers of Building Official
    - - 104.9 Approved materials and equipment.
    - - 104.10 Modifications.
    - - 104.11 Alternative materials, design and methods of construction and equipment.
    - - - 104.11.1 Research Reports
    - - - 104.11.2 Tests

    With any costs associated with 104.11 being "made without expense to the jurisdiction".

    Back in 1962 ... I'm not sure if the building codes addressed such in a manner which specifically placed any costs associated with 'doing things differently' onto the party which wants to 'do things differently'.

    Jerry Peck
    Construction/Litigation/Code Consultant - Retired
    www.AskCodeMan.com

  10. #10
    Join Date
    Feb 2008
    Location
    Chicago IL
    Posts
    2,048

    Default Re: GFCI protection absent: do you flag this?

    While I don't cite Code in my reports as much as I used to, (nobody cares for regular inspections, mostly only relevant for EW or new construction work) I still do when applicable.
    Nonetheless, I'll address this issue from more of a business perspective. If someone isn't mentioning GFCI protection in their HI report, that's a shortcoming. GFCI protection is kind of a 'duh'.
    Trying to use the Code, grandfathering or association standards to justify not looking for GFCI protection or not recommending it is flat out poor business practice. That HI is essentially putting themselves in the box with the checkbox idiots.
    GFCI's aren't there to be cute. They are there for improved safety. It's not rocket science at this point. Also very easy and affordable installation.
    You think if little Johnny or Grandma gets electrocuted at the kitchen or bath sink, or Dad from the exterior receptacle while doing Xmas lights, some lack of Code requirement is going to save you?
    The heirs will go for a Jury trial and you'll be bleeding out of your ears.

    "GFCI protection should be installed at all currently required locations for improved safety, irregardless of Code requirements at the time of current device installation".

    Why would a good HI avoid the low hanging fruit to provide their client with relevant information and a good thorough inspection?
    Oh, wait, I know, so they can get to their next $199 job having finished the entire report on their phone while doing the inspection.

    www.aic-chicago.com
    773/844-4AIC
    "The Code is not a ceiling to reach but a floor to work up from"

  11. #11
    Join Date
    Oct 2014
    Location
    Maryland, DC, and Northern Virginia, electrical only
    Posts
    444

    Default Re: GFCI protection absent: do you flag this?

    I'm going to compare the info in your charts, Jerry and Gunnar, with a list of dwelling requirements I prepared de novo to submit for updating NFPA 73's Tables. This gives me a much better chance to catch any booboos I've made before it even goes out to the CMP. I waited till I had finished my draft so that yours would provide an independent check.

    If anyone wants, I'll be happy to post mine here as well. I should warn, though, that it provides much sparser information about each of the ~80 items with GFCI requirements. A few of the items have multiple entries to represent significant changes in the related requirement. I did include most of the original section numbers, especially for when the requirement was an alternative or had exceptions. Much more work for users, but I'm not crazy about footnotes or long, long entries.

    Mine omits requirements for integral protection, and requirements related to dwellings that I suspect rarely are inspected post-sale or just aren't found at dwellings: RVs; park trailers; signs in fountains; and natural & artificial bodies of water. I believe that dorms and residential hotels ought to be inspected on behalf of their occupants, but as I strongly suspect they are considered out of NFPA 73's remit, I left them out as well.


  12. #12
    Join Date
    Mar 2007
    Location
    Fletcher, NC
    Posts
    28,032

    Default Re: GFCI protection absent: do you flag this?

    Quote Originally Posted by david shapiro View Post
    If anyone wants, I'll be happy to post mine here as well. I should warn, though, that it provides much sparser information about each of the ~80 items with GFCI requirements.
    David, please post your list as it will likely include GFCI protection for things I did not as mine was specifically for receptacles in dwelling units (okay, and pools, boat houses, etc, associated with same ... oh, and I may have included "circuits" to hydromassage tubs at one point - I'd have to review the list).

    Trying to include the various changes edition to edition was becoming a bit of a longer list below the chart.

    Jerry Peck
    Construction/Litigation/Code Consultant - Retired
    www.AskCodeMan.com

  13. #13
    Join Date
    Oct 2014
    Location
    Maryland, DC, and Northern Virginia, electrical only
    Posts
    444

    Default Re: GFCI protection absent: do you flag this?

    Will do, Jerry.

    I probably should remind folks that if you want to see the verbatim NEC text that was adopted, free, you can go to nfpa.org/70, choose the year, choose Free Access, and scroll through. (UL allows pretty much the same thing for most of their standards.) #Table B.1(b).pdfTable B.1(b).pdfGunnar, you mentioned not having all the NEC editions you referenced; this takes care of that vexation. This is a hell of a way to find a requirement when you're not sure where it's located, but I do given Section numbers in the sheet I'm attaching. This also is how I justify leaving out all the footnotes and most of the fine details.

    The only building type I've included that commonly isn't treated as a dwelling in code is relocatable structures. I've left out dorms, residential hotels, RVs, a bunch of stuff. Happy to hear your feedback.

    A bit later, maybe before Memorial Day, maybe later, I'll also prepare an alphabetical list.

    I've also an updated AFCI requirements list, and will post that after I take a walk.

    Please do point out any glitches you notice.

    It looks as though I need to upload it as a pdf. If someone want the xl file, say so. Somehow, due to my impressive ignorance of Adobe fine-tuning, the pdf appears to be a single column
    The first section is Category or area; the second, fortunately with matching numbers, is the description; the third, NEC year, enforcement year if different, and NEC section.


  14. #14
    Join Date
    Oct 2014
    Location
    Maryland, DC, and Northern Virginia, electrical only
    Posts
    444

    Default Re: GFCI protection absent: do you flag this?

    And here are the AFCI requirements for dwellings that I've found so far

    *Bedroom receptacles 1999 ef.2002 210.12
    Bedrooms 2002 210.12
    Mobile/manufactured home Bedrooms 2002 550.25
    Family rooms 2008 210.12 (2010 IRC?)
    dining rooms 2008 210.12 (2010 IRC?)
    living rooms 2008 210.12 (2010 IRC?)
    parlors 2008 210.12 (2010 IRC?)
    libraries 2008 210.12 (2010 IRC?)
    dens 2008 210.12 (2010 IRC?)
    sun rooms 2008 210.12 (2010 IRC?)
    recreation rooms 2008 210.12 (2010 IRC?)
    closets 2008 210.12 (2010 IRC?)
    hallways 2008 210.12 (2010 IRC?)
    similar areas 2008 210.12 (2010 IRC?)
    PV 2011 690.11
    Replacements at required locations 2011 406.4(D)(4)
    Kitchens 2014 210.12 (2016 IRC?)
    Laundry areas 2014 210.12 (2016 IRC?)
    *Circuit extension/modification --
    --where required in new installation 2014 210.12(B) (2016 IRC?)
    Devices in rooms previously listed 2014 210.12 (2016 IRC?)
    *Circuit (wiring) Replacement--
    --where required in new installation 2023 210.12(B)
    Heating Cables in walls 2023

    Excludes description of where AFCI protection is not to be provided, and of how it is permitted to be supplied.


  15. #15
    Join Date
    Mar 2007
    Location
    Fletcher, NC
    Posts
    28,032

    Default Re: GFCI protection absent: do you flag this?

    David, a couple of comments:

    - The free view online NFPA standards are anything but user friendly. The NFPA standards are there, are free, but the display and readability is, well, about as non-friendly as NFPA could devise.

    - Can you save the xl file as a Word doc or document file? Not sure if Word offers that ability. If Word can do that, Adobe can probably print it out the same as it would a doc or docx file (in Table format?).

    Jerry Peck
    Construction/Litigation/Code Consultant - Retired
    www.AskCodeMan.com

  16. #16
    Join Date
    Oct 2014
    Location
    Maryland, DC, and Northern Virginia, electrical only
    Posts
    444

    Default Re: GFCI protection absent: do you flag this?

    Quote Originally Posted by Jerry Peck View Post
    - The free view online NFPA standards are anything but user friendly. The NFPA standards are there, are free, but the display and readability is, well, about as non-friendly as NFPA could devise.
    Quite agreed. A considerable change, and in my opinion short-sighted. As I understand it, in at least part the standards were made available for free viewing so no one could say "These rules were adopted into law and now this organization charges us to find out what the law affecting us says."

    When this policy was initiated, the standards used to be easily viewable. Not searchable, but viewable. Now they've changed this radically. While this may help them in converting a commodity into a digital service requiring regular renewal, it also seems to put them at risk of loss due to that initial challenge about privilege, privatizing access to law. I do hope they reconsider. Or if it actually is screwed-up software, that it gets unscrewed.

    In the meantime, they haven't started playing the same game with First Drafts and Second Drafts. Those could offer a way in.

    At the same time, trying to squeeze all the details of a rule into a table strikes me as impossible. If I only squeeze in the most critical ones, there can be those bad calls because what I left out mattered on this inspection. All the footnotes to your and Gunnar's lists don't do it, and consulting footnotes is itself cumbersome. Not as bad, admittedly, as the way standards are written, sending you from here to there to there in order to find out what's supposed to be done. But at least those contain almost all the information needed. Well, at least by reference, sigh.

    Anyway, I hates Word and I hates Excel. Microsoft really got my goat tonight. If you, or anyone on this list, wants my excel spreadsheet, I can email it. Or my Quattro pro version. If I make the time to carry the information from it back to my original list, then I can send plain text or word perfect, or save that as word. But my next step is to start indexing the chronological list. Indexing is a lofty skill, IMO, if you want to go beyond creating a concordance and telling software to match it with pages. It's not a skill I've developed, but if I want a list to help people, I think that's what I need to do for a revision of the standard's Table B.1(a)..


  17. #17
    Join Date
    Mar 2007
    Location
    Fletcher, NC
    Posts
    28,032

    Default Re: GFCI protection absent: do you flag this?

    David, I agree about the choices to be made between a readable and usable list versus one that covers all the details and 'what ifs'.

    I chose readable and usable for the HI with information for HI inspections.

    I did not make it so cumbersome and detailed that it is quotable for litigation reports. The inspector doing an inspection for litigation can use my charts as an initial 'wait, that's not right' indicator, and then follow that up with re-reading the actual code. If an inspector is doing litigation inspections and reports, first and foremost, that inspector needs to know and understand the codes ... which starts with being ICC, IAEI, NFPA certified as an inspector in that particular code (Building, Plumbing, Electrical, Mechanical, Fuel Gas, Accessibility, etc). And in the inspector is also doing other than just Residential litigation inspections, then the inspector also needs the corresponding Commercial designations for each as applicable.

    However, for HI inspections, the list needs to be readable and usable to the HI inspector.

    I knew many AHJ inspectors who used my list as a quick reference guide doing inspections. Again, though, not for the detailed litigation or supportive work needed to back up an inspection - that brings out the code books.

    I used WordPerfect when doing my inspections and reports. I would 'print' as a pdf file to share with clients and attorneys. If needed, WordPerfect allowed me to save the file as Word doc file to use with Word.

    Jerry Peck
    Construction/Litigation/Code Consultant - Retired
    www.AskCodeMan.com

  18. #18
    Join Date
    Mar 2007
    Location
    Santa Rosa, CA
    Posts
    3,154

    Default Re: GFCI protection absent: do you flag this?

    Hi David,

    If you are willing, I would be interested in your document. It seems as though mine, even when updated, might not fill your needs, but I would be willing to share anyway. I can also share my original Excel/Word versions, if you feel they might be of use. I printed to a PDF so things could not be easily changed and the matrix could be read from any device.

    Also, I noticed the 5/27 post about "Mobile/Manufactured Homes... 550.25..."

    According to the Manufactured Home Construction and Safety Standards (MHCSS aka "HUD codes"), AFCIs are not required. NEC 550.25 appears to only apply to if AFCI protection is installed.

    The GFCI for personnel requirement continues to lag behind the NEC/IRC. In the past, GFCI protection in kitchens was only required within 6' of the sink (in addition to bathrooms & exterior). This has since changed and GFCI protection is now required for receptacles serving kitchen countertops. i am having difficulty figuring out when this changed. I have not been able to find older versions of the MCHSS online.

    I did not include GFCI or AFCI for Mobile/Manufactured in my matrix. Now that things have changed, I think I will include MH as well. Might take me a few months to get around to it though.

    If you are interested, you can download the MCHSS here:
    https://www.ecfr.gov/current/title-24/subtitle-B/chapter-XX/part-3280

    From the MCHSS:
    Subpart I?Electrical Systems
    ? 3280.801 Scope.
    (a) Subpart I of this part and Part II of Article 550 of the National Electrical Code (NFPA No. 70?2005) cover the electrical conductors and equipment installed within or on manufactured homes and the conductors that connect manufactured homes to a supply of electricity.
    (b) In addition to the requirements of this part and Part II of Article 550 of the National Electrical Code (NFPA No. 70?2005), the applicable portions of other Articles of the National Electrical Code must be followed for electrical installations in manufactured homes. The use of arc-fault breakers under Articles 210.12(A) and (B), 440.65, and 550.25(A) and (B) of the National Electrical Code, NFPA No. 70?2005 is not required. However, if arc-fault breakers are provided, such use must be in accordance with the National Electrical Code, NFPA No. 70?2005. Wherever the requirements of this standard differ from the National Electrical Code, these standards apply.

    ? 3280.806 Receptacle outlets.
    (a) All receptacle outlets shall be:
    (1) Of grounding type;
    (2) Installed according to Article 406.3 of the National Electrical Code, NFPA No. 70?2005.
    (3) Except when supplying specific appliances, be parallel-blade, 15-ampere, 125-volt, either single or duplex.
    (b) All 125-volt, single-phase, 15- and 20-ampere receptacle outlets installed outdoors, or in compartments accessible from outside the manufactured home, and in bathrooms, including receptacles in light fixtures, must have ground-fault circuit-interrupter protection for personnel. Ground-fault circuit-interrupter protection for personnel must be provided for receptacles serving countertops in kitchens and receptacle outlets located within 6 feet of a wet bar sink, except for receptacles installed for appliances in dedicated spaces, such as dishwashers, disposals, refrigerators, freezers, and laundry equipment.

    Department of Redundancy Department
    Supreme Emperor of Hyperbole
    http://www.FullCircleInspect.com/

  19. #19
    Join Date
    Mar 2007
    Location
    Santa Rosa, CA
    Posts
    3,154

    Default Re: GFCI protection absent: do you flag this?

    Quote Originally Posted by david shapiro View Post
    ... Gunnar, you mentioned not having all the NEC editions you referenced; this takes care of that vexation. This is a hell of a way to find a requirement when you're not sure where it's located, but I do given Section numbers in the sheet I'm attaching. This also is how I justify leaving out all the footnotes and most of the fine details.
    Catching up on my IN reading.

    David,

    Thank you, I did know about the "free access". As you said, not easy to research.

    However, I have been unable to find anything prior to the 1968 and there seems to be a hole between the 1971 and 1978. I find this odd. If they had followed past example of publishing every 3 years, I would have expected 1971, 1974, 1977. But, instead of skipping one and having a 6 year gap, there is a 7 year gap.


    Quote Originally Posted by david shapiro View Post
    It looks as though I need to upload it as a pdf. If someone want the xl file, say so. Somehow, due to my impressive ignorance of Adobe fine-tuning, the pdf appears to be a single column
    The first section is Category or area; the second, fortunately with matching numbers, is the description; the third, NEC year, enforcement year if different, and NEC section.
    If you are willing to send me the Excel file(s), I will try to combine into a single document and send it back. I sent my email address to you in a PM.

    Department of Redundancy Department
    Supreme Emperor of Hyperbole
    http://www.FullCircleInspect.com/

  20. #20
    Join Date
    Oct 2014
    Location
    Maryland, DC, and Northern Virginia, electrical only
    Posts
    444

    Default Re: GFCI protection absent: do you flag this?

    Quote Originally Posted by Gunnar Alquist View Post
    Hi David,
    . . .According to the Manufactured Home Construction and Safety Standards (MHCSS aka "HUD codes"), AFCIs are not required. NEC 550.25 appears to only apply to if AFCI protection is installed.
    . . .

    From the MCHSS:
    Subpart I?Electrical Systems
    ? 3280.801 Scope.
    . . .The use of arc-fault breakers under Articles 210.12(A) and (B), 440.65, and 550.25(A) and (B) of the National Electrical Code, NFPA No. 70?2005 is not required. However, if arc-fault breakers are provided, such use must be in accordance with the National Electrical Code, NFPA No. 70?2005. Wherever the requirements of this standard differ from the National Electrical Code, these standards apply.
    .
    Thanks, Gunnar. I can sort of maybe see why mobile homes would be treated differently from stick-built, but not manufactured homes.

    In my old neighborhood, the neighboring home was replaced with one of these. Was it inspected at the factory? Sure, presumably. Would this mean no occupant would use an overlong screw to hang shelving, thus creating an arcing connection? Can't see why not. Would a new purchaser want a HI to look it over? I reckon so, if they had the sense to hire one to check out any home they bought. Should the HI look for less protection than in a stick-built home? Weird.

    Now there is a big honking change between the 2020 and the 2023 NECs here. What you quote fits the 2020. The 2023, though, says in 550.25 that all 125V branch circuits that supply 15 and 20 A outlets shall comply with 210.12.

    I wonder whether the MCHSS 2023 update references the 2005 NEC because NFPA 70A, the residential-only version, has not been updated since the 2005 edition. Anyway, once the manufactured homes leave the factory, the AHJs have to bless them, and complying the with 2005 may not be good enough in many jurisdictions.

    I shall PM you the excel file, which I hope will be convenient as a way to get a leg up on your own or Jerry's updates. I don't remember whether I sent my WP AFCI list. My point, like I think yours, is to help people keep their customers/the public safe, so if my bare-bones version is not sufficiently useful, add whatever footnotes seem to make sense.

    The new Codecheck book just came out, and I'm going to look through that to see whether those folks think a lot more info should go in.

    As for checking text, I do have the 1975 edition--every edition for the last century plus a few more, inherited from a dear (and dead) mentor, W. Creighton Schwan. So if NFPA does not make available something you want to check, I will be glad to help--paying it forward from Creighton.

    Last edited by david shapiro; 05-30-2023 at 02:49 PM.

  21. #21
    Join Date
    Mar 2007
    Location
    Fletcher, NC
    Posts
    28,032

    Default Re: GFCI protection absent: do you flag this?

    Quote Originally Posted by david shapiro View Post
    I can sort of maybe see why mobile homes would be treated differently from stick-built, but not manufactured homes.
    David, to clarify, by HUD and building codes, "mobile homes" were manufactured up to June 14, 1976, and "manufactured homes" were manufactured on June 15, 1976 and afterward.

    There is another category of dwelling which frequently resembles "manufactured homes", those would be "modular homes". The difference between a manufactured home and a modular home is that a manufactured home is manufactured to the HUD code for manufactured home; while the modular home is built (manufactured) to the building code.

    Okay, the next question becomes ' to which "building code" '? That "building code" would be the building code in effect where the modular home is to be placed. Thus most modular home manufacturers typically only sell to a limited area near where the modular homes are manufactured as those modular home need to be compliant with the building code of where the units are set up.

    Modular homes, then, have the same GFCI and AFCI requirements as site-built homes in the same area that the modular homes are set up.

    As for checking text, I do have the 1975 edition--every edition for the last century plus a few more, inherited from a dear (and dead) mentor, W. Creighton Schwan. So if NFPA does not make available something you want to check, I will be glad to help--paying it forward from Creighton.
    I also have a good collection of NEC codes, but it sounds like your collection of NEC books is more complete than my collection of NEC books is. My collection is complete back to 1946 (I'd have to look at each again to make sure that is correct), then my collection thins out some to late 1930s, then thins out even more past that, I've got some 20s, teens, and oughts as I recall. I also have the 1897 NEC published in an 1896 book with the version before it went for final approved at the meeting, which made some changes to the final approved 1897 code (which is considered the 'First NEC"). I have a 100th anniversary copy of the 1897 code (but not the 100th anniversary of the 1897 code, it was the 100th anniversary of the forming of the Middle Department - established 1883, this reproductions was published in 1983 - "To commemorate this milestone, we have reproduced the last Middle Department Electrical Code dated 1897, as this date marked the birth of the National Electrical Code."

    Jerry Peck
    Construction/Litigation/Code Consultant - Retired
    www.AskCodeMan.com

  22. #22
    Join Date
    Oct 2014
    Location
    Maryland, DC, and Northern Virginia, electrical only
    Posts
    444

    Default Re: GFCI protection absent: do you flag this?

    Quote Originally Posted by Jerry Peck View Post
    David, to clarify, by HUD and building codes, "mobile homes" were manufactured up to June 14, 1976, and "manufactured homes" were manufactured on June 15, 1976 and afterward.

    There is another category of dwelling which frequently resembles "manufactured homes", those would be "modular homes". The difference between a manufactured home and a modular home is that a manufactured home is manufactured to the HUD code for manufactured home; while the modular home is built (manufactured) to the building code.
    Thank you for the useful clarification. This being the case, it seems that modular homes need no mention in the NEC.

    Manufactured homes, though, appear to suffer from conflicting requirements: HUD and NEC. HUD appears to govern how they're made, and the NEC their acceptance where they end up for people to live in.
    Quote Originally Posted by Jerry Peck View Post
    Okay, the next question becomes ' to which "building code" '? That "building code" would be the building code in effect where the modular home is to be placed. Thus most modular home manufacturers typically only sell to a limited area near where the modular homes are manufactured as those modular home need to be compliant with the building code of where the units are set up.

    Modular homes, then, have the same GFCI and AFCI requirements as site-built homes in the same area that the modular homes are set up.



    I also have a good collection of NEC codes, but it sounds like your collection of NEC books is more complete than my collection of NEC books is. My collection is complete back to 1946 (I'd have to look at each again to make sure that is correct), then my collection thins out some to late 1930s, then thins out even more past that, I've got some 20s, teens, and oughts as I recall. I also have the 1897 NEC published in an 1896 book with the version before it went for final approved at the meeting, which made some changes to the final approved 1897 code (which is considered the 'First NEC"). I have a 100th anniversary copy of the 1897 code (but not the 100th anniversary of the 1897 code, it was the 100th anniversary of the forming of the Middle Department - established 1883, this reproductions was published in 1983 - "To commemorate this milestone, we have reproduced the last Middle Department Electrical Code dated 1897, as this date marked the birth of the National Electrical Code."
    It looks as though we overlap, Jerry. Mine go straight back to the 1915, and that's it other than the reprint. I do have some TCRs/ROPs and TCDs/ROCs giving some substantiations. To my regret, I didn't see the value of these when Creighton offered me his library--and I didn't ASK! He was dying before NFPA offered free public access, so obtaining the NECs seemed key. Later, I came to recognize how important the rationales are in interpreting codes and trying to improve them. I'm pretty sure other proteges inherited them, so they're not lost.


  23. #23
    Join Date
    Mar 2007
    Location
    Fletcher, NC
    Posts
    28,032

    Default Re: GFCI protection absent: do you flag this?

    Quote Originally Posted by david shapiro View Post
    Manufactured homes, though, appear to suffer from conflicting requirements: HUD and NEC. HUD appears to govern how they're made, and the NEC their acceptance where they end up for people to live in.
    Sort of ...

    HUD has the standard to which the manufactured home is manufactured to. The HUD standard does make some references to some NEC items.

    However, the HUD standard is only related to the manufactured home itself. Once that manufactured home is delivered to the site and set up in accordance with HUD and manufacturer's installation instructions, the manufactured home itself needs to be connected to site utilities.

    Those site utilities (electric, potable water, sewer/septic, mechanical, fuel gas, etc) are subject to the local building codes for each. That is where the NEC comes in with the electrical (other than those references in the HUD standard to the NEC for some items within the manufactured home).

    The NEC itself is way, way, behind the times when it comes to addressing manufactured homes and mobile homes. It is way past time for the NEC to update itself regarding manufactured home and mobile homes being in agreement with what HUD and the industry defines are "mobile homes" and "manufactured homes" are not technically interchangeable ("mobile homes"/"manufactured homes" are frequently interchangeable within the general public's vocabulary ... but ... if NFPA uses that as a reason to maintain their use of "mobile homes", NFPA is giving all others free reign to use 'general public vocabulary' to change NFPA standards to whatever the general public wants - a very slippery slope).

    Jerry Peck
    Construction/Litigation/Code Consultant - Retired
    www.AskCodeMan.com

  24. #24
    Join Date
    Oct 2014
    Location
    Maryland, DC, and Northern Virginia, electrical only
    Posts
    444

    Default Re: GFCI protection absent: do you flag this?

    Jerry, while I certainly wish the NEC were clearer about mobile and manufactured homes in Article 550, these are terms of art defined and to some extent distinguished by the two separate entries in Article 100. I don't believe this permits general public usage to change the meanings and thus the rules, except indirectly via standard NFPA processes.

    I do wish there were more consistency, harmonization, "Can't we all just get along." My understanding is that the HUD rules, like any Federal regs, are mandated to riff off voluntary consensus standards when those exist, more than the other way around. Does this mean NFPA standards? Yes, when those are the primary ones. UL standards? Ditto. Do the manufacturers have similar standards that they have developed through a public consensus process? I just don't know, but I bet you do.


  25. #25
    Join Date
    Mar 2007
    Location
    Fletcher, NC
    Posts
    28,032

    Default Re: GFCI protection absent: do you flag this?

    Quote Originally Posted by david shapiro View Post
    ... mobile and manufactured homes in Article 550, these are terms of art defined and to some extent distinguished by the two separate entries in Article 100. I don't believe this permits general public usage to change the meanings and thus the rules, except indirectly via standard NFPA processes.
    The definitions are, at best, not clear:

    Manufactured Home. A structure, transportable in one or more sections, which in the traveling mode is 2.4 m (8 ft) or more in width or 12.2 m (40 ft) or more in length, or when erected on site is 29.77 m2 (320 ft2) or more or is built on a permanent chassis and is designed to be used as a dwelling with or without a permanent foundation, whether or not connected to the utilities, and includes plumbing, heating, air conditioning, and electrical systems contained therein. The term includes any structure that meets all the requirements of this paragraph except the size requirements and with respect to which the manufacturer voluntarily files a certification required by the regulatory agency. Calculations used to determine the number of square meters (square feet) in a structure are based on the structure's exterior dimensions and include all expandable rooms, cabinets, and other projections containing interior space, but do not include bay windows.






    Mobile Home, A factory-assembled structure or structures transportable in one or more sections that are built on a permanent chassis and designed to be used as a dwelling without permanent foundation where connected to the required utilities and that include plumbing, heating, air-conditioning, and electrical systems contained therein.


    Why not use the HUD definition for consistency?

    Manufactured home means a structure, transportable in one or more sections, which in the traveling mode is 8 body feet or more in width or 40 body feet or more in length or which when erected on-site is 320 or more square feet, and which is built on a permanent chassis and designed to be used as a dwelling with or without a permanent foundation when connected to the required utilities, and includes the plumbing, heating, air-conditioning, and electrical systems contained in the structure. This term includes all structures that meet the above requirements except the size requirements and with respect to which the manufacturer voluntarily files a certification pursuant to ? 3282.13 of this chapter and complies with the construction and safety standards set forth in this part 3280. The term does not include any self-propelled recreational vehicle. Calculations used to determine the number of square feet in a structure will include the total of square feet for each transportable section comprising the completed structure and will be based on the structure's exterior dimensions measured at the largest horizontal projections when erected on site. These dimensions will include all expandable rooms, cabinets, and other projections containing interior space, but do not include bay windows. Nothing in this definition should be interpreted to mean that a manufactured home necessarily meets the requirements of HUD's Minimum Property Standards (HUD Handbook 4900.1) or that it is automatically eligible for financing under 12 U.S.C. 1709(b).

    Mobile Home ... a 'manufactured home' (mobile home) constructed prior to June 15, 1976.


    From HUD FAQ page: "HUD does not inspect homes. Homes built prior to June 15, 1976, even with modifications, do not meet the HUD standards and cannot be accepted as compliant with the HUD Code. As the homeowner, you may find a licensed engineer willing to inspect your home for compliance with your state's housing code. FHA does not insure mortgages on manufactured homes built prior to June 15, 1976. Most other mortgage insurance firms follow FHA's policy."

    "Manufactured Home" did not come into the NEC until 1996 ... that is two decades after HUD established what a "manufactured home" is. Why did it take the NEC so long to grasp 'mobile home' versus 'manufactured home', and then not really grasp what they are?

    The definition for "manufactured home" had been established 20 years before the NEC decided to ... define it as something else?

    And why does it matter that NFPA defines it differently than HUD and than is used in the building codes?

    The ICC IBC, Chapter 27, Electrical, provides:
    - 2701.1 Scope
    - - The provisions of this chapter and NFPA 70 shall govern the design, construction, erection and installation of electrical components, appliances, equipment and systems used in buildings and structures covered by this code. blah, blah, blah

    Unless NFPA 70 is adopted individually by jurisdictions, those jurisdictions which adopt the ICC codes as their base codes, by reference in Chapter 27, also adopt NFPA 70.

    In Chapter 35, Referenced Standards, the edition of N.FPA 70 is addressed, and is often changed by amending the adopted ICC codes.

    70-20 National Electrical Code is listed in Chapter 35, then the references to NFPA in the IBC are then listed.

    Do the manufacturers have similar standards that they have developed through a public consensus process? I just don't know, but I bet you do.
    In a way, yes.

    Each lawsuit by a member of the public, and the outcome of the lawsuits let the manufacturers know what and how to revise their installation instructions.

    Additionally, with the codes setting the standard for the installation and use of the appliances, the manufacturers installation instructions must meet those requirements and limiations.

    Jerry Peck
    Construction/Litigation/Code Consultant - Retired
    www.AskCodeMan.com

  26. #26
    Join Date
    Mar 2007
    Location
    Fletcher, NC
    Posts
    28,032

    Default Re: GFCI protection absent: do you flag this?

    Why my previous long post matters (I wanted to keep this part separated, then got delayed in getting back to my computer to include this separately).

    From the ICC IBC:
    [A} 102.4 Referenced codes and standards.
    - The codes and standards referenced in this code shall be considered to be part of the requirements of this code to the prescribed extent of each such reference and as further regulated in Sections 102.4.1 and 102.4.2.
    - - 102.4.1 Conflicts.
    - - - Where conflicts occur between provisions of this code and referenced codes and standards, the provisions of this code shall apply.
    - - 102.4.2 Provisions in referenced codes and standards.
    - - - Where the extent of the reference to a referenced code or standard includes subject matter that is within the scope of this code or the International Codes specified in Section 101.4, the provisions of this code or the International Codes specified in Section 101.4, as applicable, shall take precedence over the provisions in the referenced code or standard.

    Regarding our discussion of manufactured homes and mobile homes, the definition in the NEC is mostly moot as the IBC.

    To place the above in order in the code: (underlining is mine)
    Section 102
    - Applicability
    - - [A] 102.1 General.
    - - [A] 102.2 Other laws.
    - - - The provisions of this code shall not be deemed to nullify and provisions of local, state or federal law.
    - - [A] 102.3 Application of references.
    - - [A] 102.4 Referenced codes and standards.


    Notice that 102.2 Other laws, precedes 102.4 Referenced codes and standards, and that the HUD manufactured home standard is a federal law which governs and addresses manufactured homes and mobile homes.

    As such, the HUD standard defines manufactured homes and mobile homes for these codes.

    I could go on and point out some of the inconsistencies in the NEC definition, but those inconsistencies do not really matter when the ICC codes are adopted or used as base codes with these sections unchanged and as being the base (reference) which brings NFPA 70 into the code.

    If NFPA 70 was adopted independently of the ICC codes, or coming in under another similar code, then the NEC definitions would be a topic for discussion.

    But ... it makes for an interesting discussion ... at least to some who don't mind .

    Jerry Peck
    Construction/Litigation/Code Consultant - Retired
    www.AskCodeMan.com

  27. #27
    Join Date
    Mar 2007
    Location
    Fletcher, NC
    Posts
    28,032

    Default Re: GFCI protection absent: do you flag this?

    David, this wasn't meant for you. I'm hoping you didn't stop posting on this topic because of this:

    Quote Originally Posted by Jerry Peck View Post
    If NFPA 70 was adopted independently of the ICC codes, or coming in under another similar code, then the NEC definitions would be a topic for discussion.

    But ... it makes for an interesting discussion ... at least to some who don't mind .
    *I* am one who doesn't mind for the sake of working through a discussion.

    I was just pointing out the interrelationship of the NEC and ICC codes when the NEC is brought in by being a referenced standard in the ICC codes, which typically start with the IBC.

    The IBC brings in the IRC and other codes where applicable.

    I know thst some states, such as California, are different (Gunnar can address California better) in that California brings in the IRC (sort of), but may not use the IBC as a base for anything. As I recall, California still uses the IAPMO and UPC.

    Jerry Peck
    Construction/Litigation/Code Consultant - Retired
    www.AskCodeMan.com

  28. #28
    Join Date
    Oct 2014
    Location
    Maryland, DC, and Northern Virginia, electrical only
    Posts
    444

    Default Re: GFCI protection absent: do you flag this?

    No worries, Jerry; I stopped because I didn't have more to say.

    Since then, a senior gent at NFPA invited me to a Teams session to discuss some concerns. He told me that they do want to push subscriptions and thus don't want to make free access as comfortable as it has been, but they do want to maintain it. After I shared my screen, he said he'd talk to their IT about making the access path more legible.

    I also came away with the idea that the dissonance between Art 550 and the HUD standard is something NFPA had wanted to resolve, but the mills of cfr grind slowly, for one thing. (More via PM if you wish, but probably you can guess.)

    Why is the one&two family electrical code, 2005NFPA70A, still around? I didn't hear a real satisfying answer. Why hasn't it been updated? My understanding is that because it consists of excerpts, staff-created, it has not followed the normal process for a voluntary consensus standard. My instinct (which may stinct--you can tell me) is that it best would both be updated to 2023 and downgraded to a guidance document.


  29. #29
    Join Date
    Mar 2007
    Location
    Fletcher, NC
    Posts
    28,032

    Default Re: GFCI protection absent: do you flag this?

    David, making a reference or inclusion in a government document which is rarely updated to any document or standard that is regularly updated is, at best, a recipe for failure.

    If the HUD document simply referenced "as stated in the most current edition of the National Electrical Code", that HUD document would not be a standalone document.

    If the HUD document simply included the requirements stated in the NEC edition, without reference to that NRC edition, at the time that the HUD document was updated, then those requirements would very soon be "out of date" and inconsistent with "current" requirements. Yet would be no different than the rest of the HUD document itself being "out of date" with its other requirements related to manufacturing and construction practices, means, and methods. Also, NFPA would not be given credit for such included requirements (would that be acceptable to NFPA?).

    I suspect that the latter would be the way to go. Make the HUD document stand on its own, and when sufficient manufacturing and/or construction practices, means, and methods advance enough to get the HUD document committee to make an update, get together and make the update.

    Jerry Peck
    Construction/Litigation/Code Consultant - Retired
    www.AskCodeMan.com

  30. #30
    Join Date
    Oct 2014
    Location
    Maryland, DC, and Northern Virginia, electrical only
    Posts
    444

    Default Re: GFCI protection absent: do you flag this?

    Thank you, Jerry.

    I do believe that NFPA would accept government use, perhaps with rewording. Reword significantly, and as I understand it the changed text now is your IP, not that of the outfit originating the concepts it conveys. De gedanken sind frei.

    Here's another issue. I do take your point about self-contained documents.
    Yet PUBLIC LAW 104-113, the NATIONAL TECHNOLOGY TRANSFER AND ADVANCEMENT ACT OF 1995, says agencies should rely on voluntary consensus standards where suitable ones are available (rather than reinventing the wheels within wheels tovarich).

    The OSH act blah blah hence NFPA 70E blah blah NFPA 70B tra-la.

    Please correct me on this, but I imagine the biggest issue is that HUD is responsible for updating their rules, and the manufacturers have more clout with them in dealing with mobile homes than do AHJs. And why would manufacturers want the expense of changing their products with additional mandated safety features?






  31. #31
    Join Date
    Mar 2007
    Location
    Fletcher, NC
    Posts
    28,032

    Default Re: GFCI protection absent: do you flag this?

    Quote Originally Posted by david shapiro View Post
    Here's another issue. I do take your point about self-contained documents. Yet PUBLIC LAW 104-113, the NATIONAL TECHNOLOGY TRANSFER AND ADVANCEMENT ACT OF 1995, says agencies should rely on voluntary consensus standards where suitable ones are available (rather than reinventing the wheels within wheels tovarich).


    The OSH act blah blah hence NFPA 70E blah blah NFPA 70B tra-la.

    As in: GFCI and AFCI protection as required by NFPA 70, National Electrical Code, edition xxxx ... which is basically what they did ... and the information became outdated.


    The other option is to refer to the most current edition, which means manufacturers will be at the mercy of NFPA.


    Please correct me on this, but I imagine the biggest issue is that HUD is responsible for updating their rules, and the manufacturers have more clout with them in dealing with mobile homes than do AHJs. And why would manufacturers want the expense of changing their products with additional mandated safety features?

    Agreed. Why would manufacturers want to update every 3 years?


    Heck, many AHJ don't update every 3 years either, and while some do update every 3 years, some are 3 years back (or even older) due to their own review, approval, and adoption practices, or simply because they don't agree with the updated requirements.


    Should HUD regularly update its manufactured safety requirements? Yes. Then the question becomes "How often?"

    Jerry Peck
    Construction/Litigation/Code Consultant - Retired
    www.AskCodeMan.com

  32. #32
    Join Date
    Oct 2014
    Location
    Maryland, DC, and Northern Virginia, electrical only
    Posts
    444

    Default Re: GFCI protection absent: do you flag this?

    Quote Originally Posted by Jerry Peck View Post
    The other option is to refer to the most current edition, which means manufacturers will be at the mercy of NFPA.
    When compliance with the OSH act means an expectation that worker protection follows current best practices, this is essentially what we get, without explicit reference to an external document. Nicht war?




    Should HUD regularly update its manufactured safety requirements? Yes. Then the question becomes "How often?"
    The answer that strikes me as next-most logical is as often as the voluntary consensus standard is changed.

    The answer that strikes me as most logical is as often as the voluntary consensus standard changes in response to significant new research, and otherwise with slower periodicity. Consider the change in derating requirements for conductors above roofs. Why wouldn't you apply that to manufactured homes that come with built-on PV, if any do or will?

    If HUD won't trust NFPA to decide what changes wil result in significant safety improvements, despite the organization presumably representing a broad range of stakeholders equitably, then it falls on them to use their expertise, or to call on other agencies to do this for them; or to gather a broad, equitable, etc., including manufactures, AHJs, test labs, non-affiliated scholars, CPSC &c reps, . . . because I agree they should have a transparent process to do something about regular updates.

    Without funding for this, of course, zip.


  33. #33
    Join Date
    Mar 2007
    Location
    Fletcher, NC
    Posts
    28,032

    Default Re: GFCI protection absent: do you flag this?

    Quote Originally Posted by david shapiro View Post
    The answer that strikes me as most logical is as often as the voluntary consensus standard changes in response to significant new research, and otherwise with slower periodicity. Consider the change in ...
    Ah, but David, you are only keyed in the electrical aspect.

    Then there is the mechanical aspect, the plumbing aspect, the structural ... energy ... tie-down ... roofing ... et al ... aspects.

    To even contemplate such changes would require that all aspects/industries adhere to the exact same updating schedule, whether or not there have been any changes in materials, means, or methods.

    Jerry Peck
    Construction/Litigation/Code Consultant - Retired
    www.AskCodeMan.com

  34. #34
    Join Date
    Oct 2014
    Location
    Maryland, DC, and Northern Virginia, electrical only
    Posts
    444

    Default Re: GFCI protection absent: do you flag this?

    I quite agree. It would take immense work to have impartial experts keep an eye out for significant changes in all these realms.

    But wait! I'd think ICC ne plus ultras (I forget their term--master code professionals?) are expected to keep up with significant changes, even outside the IBC or IRC cycle. Not so?

    If yes, why shouldn't the gummint office that tells manufacturers (and concatenatively the public) what represents reasonable safety take on similar responsibility for keeping up?

    Parenthetically, one value I get from participating in this forum is service; another is the voices of bright children who will sound out when the emperor's wearing no clothes; but the biggest is the very wide range of expertise represented here. Sometimes this means answers to my own questions, and other times information on topics I wouldn't even know to ask about.


Tags for this Thread

Bookmarks

Posting Permissions

  • You may not post new threads
  • You may not post replies
  • You may not post attachments
  • You may not edit your posts
  •