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National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org NEC Code-Making Panel 17 Second Draft Meeting Agenda November 2-4, 2015 San Diego, CA Item No. Subject 15-11 -1 Call to Order 15-11-2 Introduction of Members and Guests 15-11-3 Approval of A2016 First Draft Meeting Minutes 15-11-4 Review of Meeting Procedures and Revision Schedule 15-11-5 Task Group Reports 15-11-6 Process Public Comments and Develop Second Revisions 15-11-7 Fire Protection Research Foundation Requests 15-11-8 Old Business 15-11-9 New Business 15-11-10 Adjournment

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Page 1: National Fire Protection Association · 2016-04-08 · National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 •

National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org

NEC Code-Making Panel 17

Second Draft Meeting Agenda

November 2-4, 2015

San Diego, CA

Item No. Subject 15-11 -1 Call to Order 15-11-2 Introduction of Members and Guests 15-11-3 Approval of A2016 First Draft Meeting Minutes 15-11-4 Review of Meeting Procedures and Revision Schedule 15-11-5 Task Group Reports 15-11-6 Process Public Comments and Develop Second Revisions 15-11-7 Fire Protection Research Foundation Requests 15-11-8 Old Business 15-11-9 New Business 15-11-10 Adjournment

Page 2: National Fire Protection Association · 2016-04-08 · National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 •

Public Comment No. 1721  Article after 422 submitted

Public Comment No. 618  100, Equipment Ground‐Fault Protective NEHAD EL‐SHERIF

Public Comment No. 745 Section No. 422.2 L. Keith Lofland

Public Comment No. 810 Section No. 422.5 Edward Rodriguez

Public Comment No. 1047 Section No. 422.5(A) Ron Chilton

Public Comment No. 1432 Section No. 422.5(A) submitted

Public Comment No. 854 Section No. 422.5(A) Ed Larsen

Public Comment No. 1409 Section No. 422.6 submitted

Public Comment No. 1517 Section No. 422.6 submitted

Public Comment No. 1650 Section No. 422.6 submitted

Public Comment No. 1250 Section No. 422.15(A) submitted

Public Comment No. 941 Section No. 422.16(B)(1) Gary Siggins

Public Comment No. 1211 Section No. 422.16(B)(2) L. Keith Lofland

Public Comment No. 942 Section No. 422.16(B)(2) Gary Siggins

Public Comment No. 944 Section No. 422.16(B)(4) Gary Siggins

Public Comment No. 662 Section No. 422.18 AMY CRONIN

Public Comment No. 663 Section No. 422.33 AMY CRONIN

Public Comment No. 1251 Section No. 422.50 submitted

Public Comment No. 1606 Section No. 424.38 submitted

Public Comment No. 1593  Section after 424.38 submitted

Public Comment No. 1602  Section after 424.38 submitted

Public Comment No. 945 Section No. 424.39 Gary Siggins

Public Comment No. 1805 Section No. 424.66(B) submitted

Public Comment No. 777 Section No. 424.66(B) JOHN MASARICK

Public Comment No. 1623 Section No. 424.92(D) submitted

Public Comment No. 1612 Sections 424.99(B)(5), 424.99(B)(6) submitted

Public Comment No. 1806  Section after 424.99(B)(6) submitted

Public Comment No. 422 Section No. 425.1 MARK WIRFS

Public Comment No. 551 Section No. 426.28 ALFIO TORRISI

Public Comment No. 1252 Section No. 426.54 submitted

Public Comment No. 206 Section No. 427.1 Aaron Adamczyk

Public Comment No. 1089 Section No. 680.4 L. Keith Lofland

Public Comment No. 1098 Section No. 680.7 L. Keith Lofland

Public Comment No. 782 Section No. 680.21 NEHAD EL‐SHERIF

Public Comment No. 732 Section No. 680.21(A)(1) Phil Simmons

Public Comment No. 783 Section No. 680.22(A) NEHAD EL‐SHERIF

Public Comment No. 1100 Section No. 680.22(A)(2) L. Keith Lofland

Public Comment No. 947 Section No. 680.22(B)(7) Gary Siggins

Public Comment No. 1302 Section No. 680.23(A)(2) submitted

Public Comment No. 1303 Section No. 680.24(A)(1) submitted

Public Comment No. 1055 Section No. 680.25(1) John Weritz

Public Comment No. 1243 Section No. 680.25(1) submitted

Public Comment No. 731 Section No. 680.25(1) Phil Simmons

Public Comment No. 1305 Section No. 680.42(A) [Excluding any Sub submitted

Public Comment No. 1308 Section No. 680.42(B) submitted

Public Comment No. 1309 Section No. 680.43 [Excluding any Sub‐Se submitted

Public Comment No. 1310 Section No. 680.43(D) submitted

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Public Comment No. 1311 Section No. 680.44(A) submitted

Public Comment No. 785 Section No. 680.58 NEHAD EL‐SHERIF

Public Comment No. 1313 Section No. 680.62(A)(1) submitted

Public Comment No. 787 Section No. 680.62(A)(2) NEHAD EL‐SHERIF

Public Comment No. 1660 Section No. 680.74 submitted

Public Comment No. 1185 Section No. 680.81 L. Keith Lofland

Page 4: National Fire Protection Association · 2016-04-08 · National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 •

Public Comment No. 1721-NFPA 70-2015 [ New Article after 422 ]

See Substantiation below.

Statement of Problem and Substantiation for Public Comment

PI 2898 was resolved and the Panel 2 statement indicated that they were not going to delete the section and they requested that “the NEC CC forward this PI to CMP17 for consideration.” That request to forward would not/does not move it to Panel 17’s jurisdiction. However, FR No. 349 did delete 210.8 and within the statement they request “the NEC CC forward this PI to CMP17” (although it is assumed that it should have read FR not PI).

Unfortunately, it does not appear that the correlating committee caught the requests of Panel 2 to forward this information to Panel 17. The BCDC does not want Panel 17 may create a SR to add the text/requirement to Article 422. BCDC requests that this text remain out of the NEC.

Related Item

Public Input No. 2898-NFPA 70-2014 [Section No. 210.8(D)]

Submitter Information Verification

Submitter Full Name: Jim Muir

Organization: Building Safety Division, Clark County, WA

Affilliation: NFPAs Building Code Development Committee (BCDC)

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 25 17:57:47 EDT 2015

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Public Comment No. 618-NFPA 70-2015 [ New Definition after Definition: Equipment. ]

Equipment Ground-Fault Protective Device (EGFPD).

A device identified for use as an Equipment Ground-Fault Protective Device or EGFPD that operates to disconnect theelectric circuit from the source of supply when ground-fault current exceeds the ground-fault pick-up level marked on the device.

Informational Note: Ground-fault current pick-up level of equipment ground-fault protective devices is adjustable from 6 to 100mA.

Statement of Problem and Substantiation for Public Comment

This new definition is needed for a proposed change to Article 590.6(B) that was submitted to CMP 3

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 615-NFPA 70-2015 [Section No. 590.6(B)]

Related Item

Public Input No. 2191-NFPA 70-2014 [New Definition after Definition: Ground-Fault Protection of...]

Public Input No. 2197-NFPA 70-2014 [New Section after 590.6(B)(2)]

Submitter Information Verification

Submitter Full Name: NEHAD EL-SHERIF

Organization: Littelfuse Startco

Street Address:

City:

State:

Zip:

Submittal Date: Sat Sep 12 16:41:19 EDT 2015

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Public Comment No. 745-NFPA 70-2015 [ Section No. 422.2 ]

422.2 Definition.

Vending Machine. Any self-service device that dispenses products or merchandise without the necessity of replenishing thedevice between each vending operation. In exchange for service, it is designed to require insertion of coin, paper currency, token, card,key, or receipt of payment by other means.

Statement of Problem and Substantiation for Public Comment

I would ask CMP-17 to reconsider the proposed deletion of the definition of a "Vending Machine." Without a proper definition of the device, due to the requirements of 422.5 (was 422.51), all kinds of things would be opened up for interpretation as to requiring GFCI protection that CMP-17 has already deemed in the past unnecessary for GFCI protection, such as a casino slot machine, ATM machines, hotel ice machines, etc. A hotel ice machine might need GFCI protection (that is another discussion for another day), due to its own shock hazards, not because an AHJ has deemed it to be a "vending machine." Contrary to what is stated in the Panel Statement for FR 4875, requiring all appliances to be listed DOES NOT eliminate the need for a definition of vending machine. It only opens up inconsistent interpretation and enforcement as to what constitutes a vending machine and what does not. A definition of a vending machine gives the AHJ a good solid starting point in enforcement of proposed 422.5(A)(7) requiring GFCI protection for "vending machines."

Please note that I have proposed to break up the long sentence that was the definition of "Vending Machine" from the 2014 NEC and add the phrase, "In exchange for service, it is designed..." in the proposed definition. This will again aid in enforcement of this requirement and interpretation of the rules pertaining to GFCI requirements for vending machines.

Related Item

First Revision No. 4875-NFPA 70-2015 [Section No. 422.2]

Submitter Information Verification

Submitter Full Name: L. Keith Lofland

Organization: International Association of Electrical Inspectors (IAEI)

Affilliation: None

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 18 16:27:07 EDT 2015

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Public Comment No. 810-NFPA 70-2015 [ Section No. 422.5 ]

422.5 Ground-Fault Circuit-Interrupter (GFCI) Protection for Personnel.

(A) General. Appliances identified in 422.5(A)(1) through (

7

5 ) rated 250 volts or less and 60 amperes or less, single- or 3-phase, shall be provided with GFCI protection for personnelwithin the branch circuit or outlet . Multiple GFCI protective devices shall be permitted but shall not be required.

(1) Automotive vacuum machines provided for public use

(2) Boat hoists

(3) Drinking water coolers

(4) Dwelling unit dishwashers

(5) High-pressure spray washing machines — cord-and-plug-connected

(6) Tire inflation machines provided for public use

(7) Vending machines

(B) Type.

The GFCI shall be readily accessible, listed, and located in one or more of the following locations:

Within the branch circuit overcurrent device

A device or outlet within the supply circuit

An integral part of the attachment plug

Within

Appliances indentified in 422.5(B)(1) and (2) rated 250 volts or less and 60 amperes or less, single- or 3-phase, shall beprovided with GFCI protection for personnel as intergral part of the attachement plug, within the supply cord not more than 300mm (12 in.) from the attachment plug

Factory

, or factory installed within the appliance . Multiple GFCI protective devices shall be permitted but shall not be required.

(1) cord- and plug-connected high pressure spray washing machines

(2) Vending machines

Statement of Problem and Substantiation for Public Comment

The intent of CMP 17 to centralize all appliance GFCI requirements from 210.8 to Article 422 is justified. But there is something inherently wrong with the wording in FR 4801. Automotive vacuum machines, boat hoists, drinking water coolers, dishwashers and tire inflation machines are typically fastened in place. There is no UL standard that requires GFCI protection for the aforementioned appliances, therefore replacements may not be provided with GCFI protection, within the supply cord, the attachment plug or factory installed within the appliance.

High-pressure spray washing machines and some vending machines are portable and generally are not fastened in place. The requirements of providing GFCI protection for personnel within the supply cord, the attachment plug or factory installed within the appliance should remain as CMP 17 intended.

Related Item

First Revision No. 4801-NFPA 70-2015 [Section No. 422.5]

Submitter Information Verification

Submitter Full Name: Edward Rodriguez

Organization: IEC Texas Gulf Coast

Street Address:

City:

State:

Zip:

Submittal Date: Sun Sep 20 20:54:16 EDT 2015

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Public Comment No. 1047-NFPA 70-2015 [ Section No. 422.5(A) ]

(A) General.

Appliances identified in 422.5(A)(1) through (7) rated 250 volts or less and 60 amperes or less, single- or 3-phase, shall beprovided with GFCI protection for personnel. Multiple GFCI protective devices shall be permitted but shall not be required.

(1) Automotive vacuum machines provided for public use

(2) Boat hoists

(3) Drinking water coolers

(4) Dwelling unit dishwashers

(5)

(6) High-pressure spray washing machines — cord-and-plug-connected

(7) Tire inflation machines provided for public use

(8) Vending machines

Statement of Problem and Substantiation for Public Comment

GFCI protection for specific, non-cord and plugged appliances is a growing contentious issue in dwellings where the concern is addressing the quality of the appliance from the manufacturer. Why the need for dishwashers in approaching protection for end of life cycle problems when there are numerous devices purchased daily for use in the kitchen without GFCI protection being required. Shouldn't all of these appliances then be considered, as well as other appliances throughout the dwelling?

The Panel substantiation is troubling to say the least in that they decided the most convenient place for the cost of the protection. Their determination that the outlet protection is best weighed against the manufacturer to protect persons from problems cause by aging of the appliance cannot be explained to the Public. One of our responsibilities as Code creators is being able to produce Codes that are enforceable for buildings that are constructed. When the entities responsible for adoption of Codes asks questions regarding this particular provision there is no response that justifies where this burden is placed.

In addition, GFCI protection requirements that originated in dwellings in the early 1970's was to protect persons from leakage current, the Panel's substantiation was directed at fire protection. This is not the characteristic of GFCI devices.

Related Item

Public Input No. 3889-NFPA 70-2014 [Section No. 210.8(D)]

Submitter Information Verification

Submitter Full Name: Ron Chilton

Organization: North Carolina Code Clearing Committee

Street Address:

City:

State:

Zip:

Submittal Date: Wed Sep 23 11:36:10 EDT 2015

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Public Comment No. 1432-NFPA 70-2015 [ Section No. 422.5(A) ]

(A) General.

Appliances identified in 422.5(A)(1) through (7) rated 250 volts or less and 60 amperes or less, single- or 3-phase, shall beprovided with GFCI protection for personnel. Multiple GFCI protective devices shall be permitted but shall not be required.

(1) Automotive vacuum machines provided for public use

(2) Boat hoists

(3) Drinking water coolers, unless double insulated

(4) Dwelling unit dishwashers

(5) High-pressure spray washing machines — cord-and-plug-connected

(6) Tire inflation machines provided for public use

(7) Vending machines

Statement of Problem and Substantiation for Public Comment

Drinking water coolers, unlike traditional water fountains, are often all plastic external construction and may or may not even be connected to plumbing. An alternate means of protection like double insulation should be allowed in lieu of GFCI protection, as is often the case with portable tools.

Related Item

Public Input No. 3530-NFPA 70-2014 [Section No. 422.52]

Submitter Information Verification

Submitter Full Name: Richard Holub

Organization: The DuPont Company, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 25 11:11:55 EDT 2015

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Public Comment No. 854-NFPA 70-2015 [ Section No. 422.5(A) ]

(A) General.

Appliances identified in 422.5(A)(1) through (7) rated 250 volts or less and 60 amperes or less, single- or 3-phase, shall beprovided with GFCI protection for personnel. Multiple GFCI protective devices shall be permitted but shall not be required.

(1) Automotive vacuum machines provided for public use

(2) Boat hoists

(3)

(4) Drinking water coolers

(5) Dwelling unit dishwashers

(6) High-pressure spray washing machines — cord-and-plug-connected

(7) Tire inflation machines provided for public use

(8) Vending machines

Statement of Problem and Substantiation for Public Comment

The 2014 NEC addresses the hazard associate with boat hoists beginning with the outlet serving the boat hoist up to 240V in Section 210.8(C). Protection is not limited to just protecting the hoist. There can be cord and plug connected boat hoists. A hazard may exist when inserting or removing the plug from the receptacle, therefore the protection needs to be in the branch circuit. Since the protection needs to remain in the branch circuit the requirement in the NEC must remain in 210.8. 210.8(C) should not be moved to Article 422.

Related Item

First Revision No. 4801-NFPA 70-2015 [Section No. 422.5]

Submitter Information Verification

Submitter Full Name: Ed Larsen

Organization: Schneider Electric USA

Affilliation: Schneider Electric USA

Street Address:

City:

State:

Zip:

Submittal Date: Mon Sep 21 14:17:03 EDT 2015

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Public Comment No. 1409-NFPA 70-2015 [ Section No. 422.6 ]

422.6 Listing Required.

All appliances shall be listed.

DELETE THIS CLAUSE

Statement of Problem and Substantiation for Public Comment

AHAM response to 3026-NFPA 7-2014 New Section 422.6

Delete this clause. The members of AHAM understand and share the commenter’s concern that application of the specific requirements in Art. 422 should be applied in the same way. However, using a universal mandated of “listing” of all appliances will not solve the issues presented and will likely cause more confusion. In the complex world of utilization equipment, there are many different products under the term “appliance.” Art. 422 contains specific requirements for certain equipment but not for most types. We appreciate the desire to have all appliances safety certified, but the voluntary system of safety certification of the US has achieved virtually 100% compliance. The challenges of mandating this are many. The current definition of “appliance” in the NEC may work for the Code but this proposal would now require all Certification Organizations (CO) to comply with this definition for all products under specific standards. The premise of the maker of the proposal that this would bring greater clarity or uniformity is unfortunately not true. There are many problems with the insertion of so simple a phrase.1. The addition of this language could require that AHJ’s take on the role of determining if a piece of utilization equipment is an “appliance” and if the appropriate standard has been used. The AHJ may not have the necessary information on the internal technology of the product, its functions or the usage to make this determination. Examples: is an instantaneous water heater an appliance? Is this still true on the sink? Is a portable fan that operates with C cell batteries an appliance? Is a vacuum cleaner that contains a rechargeable battery an appliance? 2. To require “listing” of a product also requires under the definitions found in NFPA 70, that the product be put onto a “list.” This implies that this list would be used by an AHJ for purposes of determining if the product has been evaluated properly. However, each CO may not agree and the same products could be on different lists. This proposal will not solve this confusion. 3. Many appliances are new and may have requirements under multiple safety standards (example: gas range with electric broiler). The safety certification may not list all the safety standards used in the evaluation. How will the AHJ know whether the correct standards were used?4. Many “appliances” function on low voltage systems either through an external power supply or battery charger. Frequently, only the conversion portion of the “appliance” is listed and not what some would consider is the “appliance.” The proposal would create a conflict between the Code and the listing requirements. These low voltage “appliances” will not appear on any list accessible to the AHJ. 5. Short runs of sample products may be used to gauge consumer interest and may not be certified at the time they are used for marketing purposes. This code change will cause difficulty for companies trying to bring new products to the market quickly.6. Marking, listing, and categories of products are governed by the certification rules of the CO, may not be in the safety standards and may not agree with the specific designations within Art. 422. Between CO’s there is a great deal of variability with respect to when the product must be marked with its category or classification or even the term that is used in the marking or category of a list. This proposal will not bring uniformity to the process.7. Manufacturers may use show samples that display the product but are not working samples. Under this determination, companies could spend huge sums of money having every sales sample evaluated, just because the code now says “all appliances” must be safety certified. Does this include a demonstration, non-functional dishwasher on display at a retailer with a light bulb inside?This proposal will not solve the problems alluded to in the description and will likely cause many others. This is not the right approach.

Related Item

Public Input No. 3026-NFPA 70-2014 [New Section after 422.5]

Submitter Information Verification

Submitter Full Name: Matt Williams

Organization: Association of Home Appliance

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 25 10:28:32 EDT 2015

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Public Comment No. 1517-NFPA 70-2015 [ Section No. 422.6 ]

422.6 Listing Required.

All appliances that are specifically addressed in Article 422 shall be listed.

Statement of Problem and Substantiation for Public Comment

The proposal is based on concerns that an installer may not know what specific installation section to follow in Article 422 unless the appliance is listed and labeled. However, the term "appliance" is very broad, and the proposal could be interpreted as applying to appliances that have no special installation requirements, such as portable appliances. We therefore propose to narrow the application of the requirement to those appliances specifically addressed in Article 422 that require special installation requirements.

Related Item

First Revision No. 4802-NFPA 70-2015 [New Section after 422.5]

Submitter Information Verification

Submitter Full Name: Joseph Harding

Organization: Power Tool Institute

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 25 13:29:32 EDT 2015

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Public Comment No. 1650-NFPA 70-2015 [ Section No. 422.6 ]

422.6 Listing Required.

All appliances shall be listed.

Statement of Problem and Substantiation for Public Comment

There was no technical substantiation for this change, therefore it violates regulations. Furthermore, I'm not certain that this is possible.

Related Item

First Revision No. 4802-NFPA 70-2015 [New Section after 422.5]

Submitter Information Verification

Submitter Full Name: RYAN JACKSON

Organization: RYAN JACKSON

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 25 15:49:48 EDT 2015

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Public Comment No. 1250-NFPA 70-2015 [ Section No. 422.15(A) ]

(A)

Listed and labeled central vacuum outlet assemblies shall be permitted to be connected to a branch circuit in accordance with210.23(A).

Additional Proposed Changes

File Name Description Approved

Essential_Guide_to_Product_Testing_and_Certification_NOV_2014.pdf

ETL Essential Guide to Product Testing & Certification 2014/2015 North American Edition. Please review document page numbers 5, 8 and 10 to see that ETL has requirements similar to UL, that products that do not bear their certification (listed) mark are not considered by ETL as being listed.

Statement of Problem and Substantiation for Public Comment

UL recognizes the Correlating Committee created a global First Correlating Revision (FCR) which directed that in all locations where the term “and labeled” was added after “listed” during the First Revision Stage, the words “and labeled” after “listed” be deleted, returning to previous text. UL understands that the Correlating Committee appointed a task group to address several issues involving the use of the terms “listed” and “labeled,” most importantly, to clarify and establish a distinction between the terms “listed” and “labeled” which are often used interchangeably. UL supports the need for this task group. However, UL does not expect the work of this task group to affect the 2017 NEC regarding the issue of “listed and labeled.” As such, UL is submitting comments to request that the words “and labeled” be added in various locations throughout the Code for the reasons expressed in the public inputs UL submitted on this issue. UL believes that these revisions will address an ongoing problem that should not wait until the 2020 NEC for resolution.

Subsequent to the Public Input Code Panel Meetings, UL has discussed this issue with its Electrical Council whose membership includes many AHJs. The proposed revisions to the NEC received general support from the membership. This issue was also discussed at a NEMA – NRTLs Forum held on August 14, 2015 at NEMA Headquarters. UL reiterated its support for the proposed revisions. The NRTLs represented at the meeting voiced no objection to the proposals.

The rationale for the revision was simple, to provide information to the AHJ regarding the suitability of equipment they encounter. The mark on the product is the manufacturer’s attestation that the product is in compliance with the appropriate standard. NRTL’s conduct factory surveillance of products, surveillance is one method to validate the manufacturer’s attestation. Should a product be found not to be compliant the manufacturer has the option of removing the mark and shipping the product without the mark, or holding the shipment and bringing the product into compliance. In either case the “Listing” is not impacted, as the “listing” is created at the completion of the “original” certification of the product and indicates the authorization but not the mandate to label products. So the only true way an AHJ can determine whether the product he is seeing is compliant with the applicable standard is via a label on the product. Taking it one step further, listings change with time. It is quite possible that a “listing” has been withdrawn; however labeled product may still be available for sale. Should equipment that is labeled, but not listed, be deemed acceptable? Based on the NEC definitions, it is possible to have a product that meets the Article 100 definition of listed but the testing organization made the manufacture remove the label for a non-compliance issue.

As for the concerns of products that are too small to be labeled, the definition of labeled is not limited to an actual label, it also includes symbols, or other identifying marks. The Safety Standards which define the listing requirements do not address labeling of products as defined by Article 100. As a general rule, NRTL’s do not consider a product as being listed unless it is also labeled. The UL White Book states that “Only those products bearing the appropriate UL Mark and the company's name, trade name, trademark or other authorized identification should be considered as being covered by UL's Certification, Listing, Classification and Follow-Up Service. The UL Mark provides evidence of listing or labeling, which may be required by installation codes or standards.” Again the requirements for the UL Mark are not a Safety Standard requirement, they are a UL requirement and the only way to show that a product is UL Certified (Listed); other NRTL’s have similar requirements.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 532-NFPA 70-2015 [Definition:Labeled.]

This will address parts that may be to small to bear a label, symbol oridentifying mark.

Related Item

Public Input No. 1072-NFPA 70-2014 [Definition: Labeled.]

First Revision No. 4803-NFPA 70-2015 [Global Input]

Public Input No. 909-NFPA 70-2014 [Section No. 422.15(A)]

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Submitter Information Verification

Submitter Full Name: JEFFREY FECTEAU

Organization: UNDERWRITERS LABORATORIES LLC

Affilliation: UL

Street Address:

City:

State:

Zip:

Submittal Date: Thu Sep 24 16:00:14 EDT 2015

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Public Comment No. 941-NFPA 70-2015 [ Section No. 422.16(B)(1) ]

(1) Electrically Operated In-Sink Waste Disposers.

Electrically operated in-sink waste disposers shall be permitted to be cord-and-plug-connected with a flexible cord identified assuitable in the installation instructions of the appliance manufacturer where all of the following conditions are met:

(1) The flexible cord shall be terminated with a grounding-type attachment plug.

Exception: A listed in-sink waste disposer distinctly marked to identify it as protected by a system of double insulation,

or its equivalent,

shall not be required to be terminated with a grounding-type attachment plug.

(2) The length of the cord shall not be less than 450 mm (18 in.) and not over 900 mm (36 in.).

(3) Receptacles shall be located to protect against physical damage to the flexible cord.

(4) The receptacle shall be accessible.

Statement of Problem and Substantiation for Public Comment

In the context of a sink waste disposer, it is unclear in the exception what the equivalent to double insulation is. Since these appliances may either be protected by grounding or double insulation, the “or its equivalent” statement in the requirement could be deleted without affecting product design and to also avoid confusion.

Related Item

First Revision No. 4876-NFPA 70-2015 [Section No. 422.16(B)(1)]

Submitter Information Verification

Submitter Full Name: Gary Siggins

Organization: UL LLC

Street Address:

City:

State:

Zip:

Submittal Date: Tue Sep 22 14:02:06 EDT 2015

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Public Comment No. 1211-NFPA 70-2015 [ Section No. 422.16(B)(2) ]

(2) Built-in Dishwashers and Trash Compactors.

Built-in dishwashers and trash compactors shall be permitted to be cord-and-plug-connected with a flexible cord identified assuitable for the purpose in the installation instructions of the appliance manufacturer where all of the following conditions aremet:

(1) The flexible cord shall be terminated with a grounding-type attachment plug.

Exception: A listed dishwasher or trash compactor distinctly marked to identify it as protected by a system of doubleinsulation, or its equivalent, shall not be required to be terminated with a grounding-type attachment plug.

(2) For a trash compactor, the length of the cord shall be 0.9 m to 1.2 m (3 ft to 4 ft) measured from the face of the attachmentplug to the plane of the rear of the appliance.

(3) For a built-in dishwasher, the length of the cord shall be 0.9 m to 2.0 m (3 ft to 6.5 ft) measured from the face of theattachment plug to the plane of the rear of the appliance.

(4) Receptacles shall be located to protect against physical damage to the flexible cord.

(5) The receptacle for a trash compactor shall receptacle shall be located in the space occupied by the appliance or adjacentthereto.

(6)

(7) The receptacle

for a built-in dishwasher

(8) shall be

located in the space adjacent to the space occupied by the dishwasher.

(9) The receptacle shall be accessible.

Statement of Problem and Substantiation for Public Comment

I would ask CMP-17 to reconsider the proposed requirement that the receptacle for a built-in dishwasher be located only in the space adjacent to the space occupied by the dishwasher. If anything, I would ask CMP-17 to permit the receptacle outlet for a cord-and-plug dishwasher to ONLY be allowed to be in the same space occupied by the dishwasher. By requiring the receptacle outlet in the space adjacent to the dishwasher, this would typically constitute a hole drilled in the cabinet wall and the flexible cord required to pass through said drilled hole to the receptacle in the adjacent space. With the necessity to pull and push the dishwasher in and out of the dedicated space for the dishwasher (for maintenance and repair), this action would subject the flexible cord to the possibility of MORE physical damage than if the receptacle outlet were located behind the dishwasher in the same space. I suspect that most AHJs would look at the flexible cord ran through a drilled hole in a cabinet as a violation of 400.8(2) and 400.8(7).The submitter of the Public Input that drove this proposed change indicated in his substantiation that UL 749 forbids electrical receptacles for dishwashers to be installed in the cabinet recess where the dishwasher is installed and requires the receptacle to be installed in a location adjacent to the dishwasher. The substantiation also indicated that the discontinuity between the product safety standard and the NEC needs to be corrected. While I agree with the last statement, perhaps the product standard needs to be changed rather than the NEC changed to allow more potential physical damage to the dishwasher flexible cord.The proposed new length of said cord is a needed change regardless of the location of the receptacle outlet.

Related Item

Public Input No. 1245-NFPA 70-2014 [Section No. 422.16(B)(2)]

First Revision No. 4804-NFPA 70-2015 [Section No. 422.16(B)(2)]

Submitter Information Verification

Submitter Full Name: L. Keith Lofland

Organization: International Association of Electrical Inspectors (IAEI)

Affilliation: None

Street Address:

City:

State:

Zip:

Submittal Date: Thu Sep 24 13:17:44 EDT 2015

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Public Comment No. 942-NFPA 70-2015 [ Section No. 422.16(B)(2) ]

(2) Built-in Dishwashers and Trash Compactors.

Built-in dishwashers and trash compactors shall be permitted to be cord-and-plug-connected with a flexible cord identified assuitable for the purpose in the installation instructions of the appliance manufacturer where all of the following conditions aremet:

(1) The flexible cord shall be terminated with a grounding-type attachment plug.

Exception: A listed dishwasher or trash compactor distinctly marked to identify it as protected by a system of doubleinsulation,

or its equivalent,

shall not be required to be terminated with a grounding-type attachment plug.

(2) For a trash compactor, the length of the cord shall be 0.9 m to 1.2 m (3 ft to 4 ft) measured from the face of the attachmentplug to the plane of the rear of the appliance.

(3) For a built-in dishwasher, the length of the cord shall be 0.9 m to 2.0 m (3 ft to 6.5 ft) measured from the face of theattachment plug to the plane of the rear of the appliance.

(4) Receptacles shall be located to protect against physical damage to the flexible cord.

(5) The receptacle for a trash compactor shall be located in the space occupied by the appliance or adjacent thereto.

(6) The receptacle for a built-in dishwasher shall be located in the space adjacent to the space occupied by the dishwasher.

(7) The receptacle shall be accessible.

Statement of Problem and Substantiation for Public Comment

In the context of dishwashers or trash compactors, it is unclear in the exception what the equivalent to double insulation is. Since these appliances may either be protected by grounding or double insulation, the “or its equivalent” statement in the requirement could be deleted without affecting product design and to also avoid confusion.

Related Item

First Revision No. 4804-NFPA 70-2015 [Section No. 422.16(B)(2)]

Submitter Information Verification

Submitter Full Name: Gary Siggins

Organization: UL LLC

Street Address:

City:

State:

Zip:

Submittal Date: Tue Sep 22 14:05:53 EDT 2015

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Public Comment No. 944-NFPA 70-2015 [ Section No. 422.16(B)(4) ]

(4) Range Hoods.

Range hoods shall be permitted to be cord-and-plug-connected with a flexible cord identified as suitable for use on range hoodsin the installation instructions of the appliance manufacturer, where all of the following conditions are met:

(1) The flexible cord is terminated with a grounding-type attachment plug.

Exception: A listed range hood distinctly marked to identify it as protected by a system of double insulation,

or its equivalent,

shall not be required to be terminated with a grounding-type attachment plug.

(2) The length of the cord is not less than 450 mm (18 in.) and not over 1.2 m (4 ft).

(3) Receptacles are located to protect against physical damage to the flexible cord.

(4) The receptacle is accessible.

(5) The receptacle is supplied by an individual branch circuit.

Statement of Problem and Substantiation for Public Comment

In the context of range hoods it is unclear in the exception what the equivalent to double insulation is. Since these appliances may either be protected by grounding or double insulation, the “or its equivalent” statement in the requirement could be deleted without affecting product design and to also avoid confusion.

Related Item

First Revision No. 4805-NFPA 70-2015 [Section No. 422.16(B)(4)]

Submitter Information Verification

Submitter Full Name: Gary Siggins

Organization: UL LLC

Street Address:

City:

State:

Zip:

Submittal Date: Tue Sep 22 14:09:59 EDT 2015

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Public Comment No. 662-NFPA 70-2015 [ Section No. 422.18 ]

422.18 Support of Ceiling-Suspended (Paddle) Fans.

Ceiling-suspended (paddle) fans shall be supported independently of an outlet box or by one of the following:

(a) listed outlet box or

(b) outlet box systems identified for the use and installed in accordance with 314.27(C)

(c) outlet box systems identified for use utilizing listed locking support and mounting receptacle used in combination with alisted device including a compatible factory installed attachment fitting designed for support and installed in accordance with314 . 27(E).

Statement of Problem and Substantiation for Public Comment

The text was editorially modified to be a list, and only item (3) was added as new text. This proposed text is not considered “new material” because it is added to coordinate with new text in 314.27(E) proposed and approved by CMP 9 in FR 2411 that reads as follows:(E) Separable Attachment Fittings. Outlet boxes shall be permitted to support listed locking support and mounting receptacles used in combination with compatible attachment fittings designed for the support of equipment covered within and subject to all weight and orientation limits contemplated by the listing. Where such fittings are used, the equipment mounted shall comply with 314.27(A) through (D) as applicable. Where the supporting receptacle is installed within a box, it shall be included in the fill calculation covered in 314.16(B)(4).

Additionally, the “list” format of options is more user friendly.

Related Item

First Revision No. 2411-NFPA 70-2015 [Section No. 314.27]

Submitter Information Verification

Submitter Full Name: AMY CRONIN

Organization: STRATEGIC CODE SOLUTIONS LLC

Affilliation: Safety Quick Lighting and Fans Corp.

Street Address:

City:

State:

Zip:

Submittal Date: Tue Sep 15 13:33:18 EDT 2015

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Public Comment No. 663-NFPA 70-2015 [ Section No. 422.33 ]

422.33 Disconnection of Cord-and-Plug-Connected or Attachment Fitting-Connected Appliances.

(A) Separable Connector or an Attachment Plug (or Attachment Fitting) and Receptacle.

For cord-and-plug-(or attachment fitting) connected appliances, an accessible separable connector or an accessible plug (orattachment fitting) and receptacle combination shall be permitted to serve as the disconnecting means. Where the separableconnector or plug (or attachment fitting) and receptacle combination are not accessible, cord-and-plug-connected orattachment fitting-and-plug-connected appliances shall be provided with disconnecting means in accordance with 422.31.

(B) Connection at the Rear Base of a Range.

For cord-and-plug-connected household electric ranges, an attachment plug and receptacle connection at the rear base of arange, accessible from the front by removal of a drawer, shall meet the intent of 422.33(A).

(C) Rating.

The rating of a receptacle or of a separable connector shall not be less than the rating of any appliance connected thereto.

Exception: Demand factors authorized elsewhere in this Code shall be permitted to be applied to the rating of a receptacle orof a separable connector.

Statement of Problem and Substantiation for Public Comment

This proposed text is not considered “new material” because it is added to coordinate with new text in 314.27(E) proposed and approved by CMP 9 in FR 2411 that reads as follows:

(E) Separable Attachment Fittings. Outlet boxes shall be permitted to support listed locking support and mounting receptacles used in combination with compatible attachment fittings designed for the support of equipment covered within and subject to all weight and orientation limits contemplated by the listing. Where such fittings are used, the equipment mounted shall comply with 314.27(A) through (D) as applicable. Where the supporting receptacle is installed within a box, it shall be included in the fill calculation covered in 314.16(B)(4).

It should be noted that for user-friendliness purposes, the definition for “attachment fitting” was previously submitted as PI 4316, and is now resubmitted as a Public Comment in light of the newly added text in 314.27(E).

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 661-NFPA 70-2015 [NewDefinition after Definition: Associated NonincendiveFi...]

Definition of "attachment fitting" is one of two definitions that should beadded as a result of the new text added in FR 2411. The term must bedefined.

Public Comment No. 661-NFPA 70-2015 [NewDefinition after Definition: Associated NonincendiveFi...]

Related Item

First Revision No. 2411-NFPA 70-2015 [Section No. 314.27]

Submitter Information Verification

Submitter Full Name: AMY CRONIN

Organization: STRATEGIC CODE SOLUTIONS LLC

Affilliation: Safety Quick Lighting and Fans Corp.

Street Address:

City:

State:

Zip:

Submittal Date: Tue Sep 15 13:41:15 EDT 2015

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Public Comment No. 1251-NFPA 70-2015 [ Section No. 422.50 ]

422.50 Cord-and Plug-Connected Pipe Heating Assemblies.

Cord-and plug-connected pipe heating assemblies intended to prevent freezing of piping shall be listed and labeled .

Additional Proposed Changes

File Name Description Approved

Essential_Guide_to_Product_Testing_and_Certification_NOV_2014.pdf

ETL Essential Guide to Product Testing & Certification 2014/2015 North American Edition. Please review document page numbers 5, 8 and 10 to see that ETL has requirements similar to UL, that products that do not bear their certification (listed) mark are not considered by ETL as being listed.

Statement of Problem and Substantiation for Public Comment

UL recognizes the Correlating Committee created a global First Correlating Revision (FCR) which directed that in all locations where the term “and labeled” was added after “listed” during the First Revision Stage, the words “and labeled” after “listed” be deleted, returning to previous text. UL understands that the Correlating Committee appointed a task group to address several issues involving the use of the terms “listed” and “labeled,” most importantly, to clarify and establish a distinction between the terms “listed” and “labeled” which are often used interchangeably. UL supports the need for this task group. However, UL does not expect the work of this task group to affect the 2017 NEC regarding the issue of “listed and labeled.” As such, UL is submitting comments to request that the words “and labeled” be added in various locations throughout the Code for the reasons expressed in the public inputs UL submitted on this issue. UL believes that these revisions will address an ongoing problem that should not wait until the 2020 NEC for resolution.

Subsequent to the Public Input Code Panel Meetings, UL has discussed this issue with its Electrical Council whose membership includes many AHJs. The proposed revisions to the NEC received general support from the membership. This issue was also discussed at a NEMA – NRTLs Forum held on August 14, 2015 at NEMA Headquarters. UL reiterated its support for the proposed revisions. The NRTLs represented at the meeting voiced no objection to the proposals.

The rationale for the revision was simple, to provide information to the AHJ regarding the suitability of equipment they encounter. The mark on the product is the manufacturer’s attestation that the product is in compliance with the appropriate standard. NRTL’s conduct factory surveillance of products, surveillance is one method to validate the manufacturer’s attestation. Should a product be found not to be compliant the manufacturer has the option of removing the mark and shipping the product without the mark, or holding the shipment and bringing the product into compliance. In either case the “Listing” is not impacted, as the “listing” is created at the completion of the “original” certification of the product and indicates the authorization but not the mandate to label products. So the only true way an AHJ can determine whether the product he is seeing is compliant with the applicable standard is via a label on the product. Taking it one step further, listings change with time. It is quite possible that a “listing” has been withdrawn; however labeled product may still be available for sale. Should equipment that is labeled, but not listed, be deemed acceptable? Based on the NEC definitions, it is possible to have a product that meets the Article 100 definition of listed but the testing organization made the manufacture remove the label for a non-compliance issue.

As for the concerns of products that are too small to be labeled, the definition of labeled is not limited to an actual label, it also includes symbols, or other identifying marks. The Safety Standards which define the listing requirements do not address labeling of products as defined by Article 100. As a general rule, NRTL’s do not consider a product as being listed unless it is also labeled. The UL White Book states that “Only those products bearing the appropriate UL Mark and the company's name, trade name, trademark or other authorized identification should be considered as being covered by UL's Certification, Listing, Classification and Follow-Up Service. The UL Mark provides evidence of listing or labeling, which may be required by installation codes or standards.” Again the requirements for the UL Mark are not a Safety Standard requirement, they are a UL requirement and the only way to show that a product is UL Certified (Listed); other NRTL’s have similar requirements.

Related Public Comments for This Document

Related Comment Relationship

Public Comment No. 532-NFPA 70-2015 [Definition: Labeled.] This will address small parts.

Related Item

Public Input No. 910-NFPA 70-2014 [Section No. 422.50]

First Revision No. 4803-NFPA 70-2015 [Global Input]

Submitter Information Verification

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Submitter Full Name: JEFFREY FECTEAU

Organization: UNDERWRITERS LABORATORIES LLC

Affilliation: UL

Street Address:

City:

State:

Zip:

Submittal Date: Thu Sep 24 16:06:45 EDT 2015

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Public Comment No. 1593-NFPA 70-2015 [ New Section after 424.38 ]

424.37 On Walls. When permitted by the manufacturer, listed and labelled heating cables shall be permittedto be installed on walls of bathrooms, tub or shower spaces. Cables shall be covered per the manufacturer’sinstructions. Unless otherwise specified in the installation instructions, cables shall be spaced not less than150 mm (6 in.) from the ceiling and not less than 50 mm (2 in.) from an adjacent wall. Cables shall not beinstalled within 200 mm (8 in.) of luminaires, outlets, or wall penetration.

Where heating cables are installed in walls a warning label suitable for the environment shall be affixed to thesurface indicating the presence of electric heating cables and that penetrations are not permitted.

Statement of Problem and Substantiation for Public Comment

NEW Substantiation: Some heating cables are now specifically designed to be installed in the walls of indoor damp locations to facilitate the evaporation of excessive moisture on wall surfaces. This also inhibits the formation of damp conditions favorable for mold and fungus growth in wall cavities. Listed cables installed on walls under ceramic or stone tile will be protected from physical damage.

Related Item

Public Input No. 3527-NFPA 70-2014 [Section No. 424.38(A)]

Submitter Information Verification

Submitter Full Name: Julia Billen

Organization: WarmlyYours

Affilliation: Submitted on behalf of Pete at NuHeat Industries LTD

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 25 14:57:55 EDT 2015

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Public Comment No. 1602-NFPA 70-2015 [ New Section after 424.38 ]

424.37 On Walls. When permitted by the manufacturer, listed and labelled heating cables shall be permitted to beinstalled in walls of tub or shower spaces. Cables shall be covered per the manufacturer’s instructions. Unlessotherwise specified in the installation instructions, cables shall be spaced not less than 150 mm (6 in.) from the ceilingand not less than 50 mm (2 in.) from an adjacent wall. Cables shall not be installed within 200 mm (8 in.) of luminaires,outlets, or wall penetration.

Where heating cables are installed in walls a warning label suitable for the environment shall be affixed to the surfaceindicating the presence of electric heating cables and that penetrations are not permitted.

Statement of Problem and Substantiation for Public Comment

Heating cables are now specifically designed to be installed in the walls of indoor damp locations to facilitate the evaporation of excessive moisture on wall surfaces. This also inhibits the formation of damp conditions favorable for mold and fungus growth in wall cavities. Listed cables installed on walls under ceramic or stone tile will be protected from physical damage.

Related Item

Public Input No. 3527-NFPA 70-2014 [Section No. 424.38(A)]

Submitter Information Verification

Submitter Full Name: Julia Billen

Organization: WarmlyYours

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 25 15:06:39 EDT 2015

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Public Comment No. 1606-NFPA 70-2015 [ Section No. 424.38 ]

424.38 Area Restrictions.

(A) Extending Beyond the Room or Area.

Heating cables shall be permitted to extend beyond the room or area in which they originate.

(B) Uses Not Permitted.

Heating cables shall not be installed as follows:

(1) In closets, other than as noted in 424.38(C) 424.38(D)

(2) Over the top of walls where the wall intersects the ceiling

(3) Over partitions that extend to the ceiling, unless they are isolated single runs of embedded cable

(4) Under or through walls

(5) Over cabinets whose clearance from the ceiling is less than the minimum horizontal dimension of the cabinet to thenearest cabinet edge that is open to the room or area

(6) In tub and shower walls

(7) Under cabinets or similar built-ins having no clearance to the floor

(C) In Closet Ceilings as Low-Temperature Heat Sources to Control Relative Humidity.

The provisions of 424.38(B) shall not prevent the use of cable in closet ceilings as low-temperature heat sources to controlrelative humidity, provided they are used only in those portions of the ceiling that are unobstructed to the floor by shelves orother permanent luminaires.

(D) Heating panels and heating panel sets shall be permitted in ceilings and floors of clothes closets when installed outside thecloset storage space as defined in 410.2 and provided with independent temperature control.

Statement of Problem and Substantiation for Public Comment

The popularity of in-floor heating products has triggered the desire for warmed flooring in larger, walk-in type closets. Installing the cable only in the walkway would provide the necessary comfort without any fire risk. Using the existing definition of closet storage space from Article 410 and installing a control as specified in Canadian code would eliminate any safety concerns.

We believe we should incorporate the following recommendation according to the Canadian Electrical Code:Rule 62-212 Article 6: Heating Panels and Heating Panels Sets shall be permitted in ceilings and below floors of clothes closets if they are provided with independent temperature control.

Related Item

Public Input No. 3531-NFPA 70-2014 [New Section after 424.38(C)]

Submitter Information Verification

Submitter Full Name: Julia Billen

Organization: WarmlyYours

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 25 15:12:01 EDT 2015

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Public Comment No. 945-NFPA 70-2015 [ Section No. 424.39 ]

424.39 Clearance from Other Objects and Openings.

Heating elements of cables installed in ceilings shall be separated at least 200 mm (8 in.) from the edge of outlet boxes andjunction boxes that are to be used for mounting surface luminaires. A clearance of not less than 50 mm (2 in.) shall be providedfrom recessed luminaires and their trims, ventilating openings, and other such openings in room surfaces. No heating cableshall be covered by any surface-mounted equipment.

Statement of Problem and Substantiation for Public Comment

As amended in the First Revision, the requirement no longer distinguishes between the heating and non-heating conductors of heating cables. The non-heating conductors are unnecessarily being required to be separated 8 in. from surface luminaire outlet and junction boxes and 2 in from recessed luminaires, their trim and ventilating openings. Such conductors are arguably no different from other current carrying conductors that are not similarly restricted in theirlocation.

Related Item

First Revision No. 4828-NFPA 70-2015 [Section No. 424.39]

Submitter Information Verification

Submitter Full Name: Gary Siggins

Organization: UL LLC

Street Address:

City:

State:

Zip:

Submittal Date: Tue Sep 22 14:13:57 EDT 2015

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Public Comment No. 1805-NFPA 70-2015 [ Section No. 424.66(B) ]

(B) Limited Access.

Where the enclosure is located in a space above a ceiling, all of the following shall apply:

(1) The enclosure shall be accessible through a lay-in type ceiling or an access panel(s).

(2) The width of the working space shall be the width of the enclosure or a minimum of 762 mm (30 in.), whichever is greater.

(3) All doors or hinged panels shall open to at least 90 degrees.

(4) The space in front of the enclosure shall comply with the depth requirements of Table 110.26(A)(1).

a. A horizontal ceiling T-bar shall be permitted in this space.

b. The work space shall be otherwise unobstructed to the floor

Informational Note: For additional installation information, see NFPA 90A-2015, Standard for the Installation ofAir-Conditioning and Ventilating Systems, and NFPA 90B-2015, Standard for the Installation of Warm Air Heating andAir-Conditioning Systems.

Statement of Problem and Substantiation for Public Comment

The Correlating Committee directs that Public Input 1066 be referred to Code-Making Panel 17 for action due to the creation of First Revision 15 by CMP-1 on 110.26(A)(4).

Related Item

Public Input No. 1066-NFPA 70-2014 [Section No. 424.66]

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NFPA

Street Address:

City:

State:

Zip:

Submittal Date: Tue Sep 29 09:07:27 EDT 2015

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Public Comment No. 777-NFPA 70-2015 [ Section No. 424.66(B) ]

(B) Limited Access.

Where the enclosure is located in a space above a ceiling, all of the following shall apply:

(1) The enclosure shall be accessible through a lay-in type ceiling or an access panel(s).

(2) The width of the working space shall be the width of the enclosure or a minimum of 762 mm (30 in.), whichever is greater.

(3) All doors or hinged panels shall open to at least 90 degrees.

(4) The space in front of the enclosure shall comply with the depth requirements of Table 110.26(A)(1).

(5) A horizontal ceiling T-bar shall be permitted in this space.

(6) The work space shall be otherwise unobstructed to the floor by permanently installed fixtures such as cabinets,walls or partitions.

Informational Note: For additional installation information, see NFPA 90A-2015, Standard for the Installation ofAir-Conditioning and Ventilating Systems, and NFPA 90B-2015, Standard for the Installation of Warm Air Heating andAir-Conditioning Systems.

Statement of Problem and Substantiation for Public Comment

IEC's position is to add language to 424.66(B)(4)(b) - (FR 4840)

As currently written this section would prohibit the occupant of the building from installing movable items such as tables or desks in the space beneath the ceiling.

Related Item

First Revision No. 4840-NFPA 70-2015 [Section No. 424.66(B)]

Submitter Information Verification

Submitter Full Name: JOHN MASARICK

Organization: Independent Electrical Contractors, Inc.

Affilliation: Independent Electrical Contractors, Inc.

Street Address:

City:

State:

Zip:

Submittal Date: Sat Sep 19 15:48:23 EDT 2015

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Public Comment No. 1623-NFPA 70-2015 [ Section No. 424.92(D) ]

(D) Labels Provided by Manufacturer.

The manufacturers of heating panels or heating panel sets shall provide marking labels that indicate that the space-heatinginstallation incorporates heating panels or heating panel sets and instructions that the labels shall be affixed to the panelboardsto identify which branch circuits supply the circuits to those space-heating installations. If the heating panels and heating panelset installations are visible and distinguishable after installation, the labels shall not be required to be provided and affixed tothe panelboards.

Statement of Problem and Substantiation for Public Comment

There are several reasons the panel should reconsider and accept this change. First, the rule is redundant. As the panel stated in the resolution to PI 3514 circuit identification is already adequately addressed by 408.4(A) which requires all circuits and circuit modifications to be marked at the panelboard by a suitable method determined by the installer and accepted by an AHJ. Second, this requirement is vague and unenforceable. There is no direction as to the size, shape, color or placement of the label, just that the label be affixed to the panelboard and identify the branch circuit(s). Third, it is discriminatory. The manufacturer-supplied label rule only applies to heating panels and heating panel sets but not to heating cables.

Related Item

Public Input No. 3547-NFPA 70-2014 [Section No. 424.92(D)]

Submitter Information Verification

Submitter Full Name: Julia Billen

Organization: WarmlyYours

Affilliation: Sam Sampson, Department of Labor & Industry

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 25 15:31:12 EDT 2015

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Public Comment No. 1612-NFPA 70-2015 [ Sections 424.99(B)(5), 424.99(B)(6) ]

Sections 424.99(B)(5), 424.99(B)(6)

(5) Fault Protection.

A device to open all ungrounded conductors supplying the heating panels or heating panel sets, provided by the manufacturer,shall function when a low- or high-resistance line-to-line, line-to-grounded conductor, or line-to-ground fault occurs, such as theresult of a penetration of the element or element assembly.

(6) Grounding Braid or Sheath.

Excluding nonheating leads, grounding means, such as copper braid, metal sheath, or other approved means, shall be providedwith or as integral part of the heating panel or heating panel set.

When required by the manufacturer’s instructions, additional fault protection shall be installed.

Statement of Problem and Substantiation for Public Comment

Heating panels and panel sets, when suitable for installation under floor coverings, are required to be listed for this purpose.When grounded no additional safety device is needed.In most cases, installation of a Fault Detecting Device(such as GFCI, ALCI, RCD), in an ungrounded circuit, provides adequate protection against risk of shock, and is most commonly the only protective device installed, aside from the branch circuit overcurrent device required by other sections of the code.FPN a class 1 GFCI will trend to trip due to other phenomena such as natural leakage, capacitance etc.Therefore, the requirements are being simplified to be clear that a GFCI shall be provided in all cases and an easement on the grounding..For specific products, if required by the listing and manufacturer’s instructions, additional fault protection may be required. When this is the case, this shall be installed and enforced by the AHJ. Therefore, item (5) is being modified to be clear for this requirement also.

Related Item

Public Input No. 3562-NFPA 70-2014 [Section No. 424.99(C)(5)]

Submitter Information Verification

Submitter Full Name: Julia Billen

Organization: WarmlyYours

Affilliation: Jonathan Willner, Heatronix

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 25 15:18:40 EDT 2015

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Public Comment No. 1806-NFPA 70-2015 [ New Section after 424.99(B)(6) ]

See Correlating Note below.

Statement of Problem and Substantiation for Public Comment

The Correlating Committee directs that all other heating related articles be reviewed and correlated with this new article. The Correlating Committee further directs that further consideration be given to the comments expressed in voting on First Revision 4841.

Related Item

First Revision No. 4841-NFPA 70-2015 [New Section after 424.99(C)(5)]

Submitter Information Verification

Submitter Full Name: CC on NEC-AAC

Organization: NFPA

Street Address:

City:

State:

Zip:

Submittal Date: Tue Sep 29 09:09:45 EDT 2015

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Public Comment No. 422-NFPA 70-2015 [ Section No. 425.1 ]

425.1 Scope.

This article covers fixed industrial process heating employing electric resistance or electrode heating technology. For thepurpose of this article, heating equipment shall include boilers, electrode boilers, duct heaters, strip heaters, immersion heaters,process air heaters, or other approved fixed electric equipment used for industrial process heating. This article shall not apply toheating and room air conditioning for personnel spaces covered by Article 424, fixed heating equipment for pipelines andvessels covered by Article 427, and induction and dielectric heating equipment covered by Article 665, or specialty industrialfurnaces incorporating silicon carbide, molybdenum, or graphite process heating elements .

Statement of Problem and Substantiation for Public Comment

While i applaud the efforts for the introduction of this new article the scope could be construed by AHJ's to be applied to all industrial heating applications.

There are many specialized industrial heating applications such as Vacuum Furnaces and Atmospheric Furnaces that use graphite (and others) heating element systems. Industrial heating applications can be much more complex than this article has addressed.

I have been involved in some installations that are 89 KW and 289 KW rated heating elements. The latter system was a dual three-phase heating element system operating at 90 volts and 4,000 amperes controlled by a SCR controlled transformer. These are custom designed and cannot comply with many of the requirements of this section, particularly the limit of 48 ampere heating elements which cannot be generically applied to these industrial heating systems. I refer the committee to www.spangpower.com for information on the specialized transformers and controllers that are used for these applications. At this time the scope of this article needs to exclude these applications.

I have attempted to provide appropriate wording for these applications, but the committee may find better language to exempt these large industrial heating applications until they can find ways to address them suitably.

Related Item

First Revision No. 4841-NFPA 70-2015 [New Section after 424.99(C)(5)]

Submitter Information Verification

Submitter Full Name: MARK WIRFS

Organization: R W ENGINEERING INC

Street Address:

City:

State:

Zip:

Submittal Date: Thu Aug 20 11:59:54 EDT 2015

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Public Comment No. 551-NFPA 70-2015 [ Section No. 426.28 ]

426.28 Ground-Fault Protection of Equipment .

Ground-fault protection of equipment shall be provided for fixed outdoor electric deicing and snow-melting equipment.

Statement of Problem and Substantiation for Public Comment

panel statement was that GFCI was allowed for the required protection. If so the reference to GFP should be more generalized and not stated as GFPE which is defined in our definitions. this change would also makes the exception for GFCI in 210.8 B (3) understandable.

Related Item

Public Input No. 4485-NFPA 70-2014 [Section No. 426.28]

Public Input No. 4486-NFPA 70-2014 [Section No. 427.22]

Submitter Information Verification

Submitter Full Name: ALFIO TORRISI

Organization: master

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 04 14:40:12 EDT 2015

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Public Comment No. 1252-NFPA 70-2015 [ Section No. 426.54 ]

426.54 Cord-and Plug-Connected Deicing and Snow-Melting Equipment.

Cord-and plug-connected deicing and snow-melting equipment shall be listed and labeled .

Additional Proposed Changes

File Name Description Approved

Essential_Guide_to_Product_Testing_and_Certification_NOV_2014.pdf

ETL Essential Guide to Product Testing & Certification 2014/2015 North American Edition. Please review document page numbers 5, 8 and 10 to see that ETL has requirements similar to UL, that products that do not bear their certification (listed) mark are not considered by ETL as being listed.

Statement of Problem and Substantiation for Public Comment

UL recognizes the Correlating Committee created a global First Correlating Revision (FCR) which directed that in all locations where the term “and labeled” was added after “listed” during the First Revision Stage, the words “and labeled” after “listed” be deleted, returning to previous text. UL understands that the Correlating Committee appointed a task group to address several issues involving the use of the terms “listed” and “labeled,” most importantly, to clarify and establish a distinction between the terms “listed” and “labeled” which are often used interchangeably. UL supports the need for this task group. However, UL does not expect the work of this task group to affect the 2017 NEC regarding the issue of “listed and labeled.” As such, UL is submitting comments to request that the words “and labeled” be added in various locations throughout the Code for the reasons expressed in the public inputs UL submitted on this issue. UL believes that these revisions will address an ongoing problem that should not wait until the 2020 NEC for resolution.

Subsequent to the Public Input Code Panel Meetings, UL has discussed this issue with its Electrical Council whose membership includes many AHJs. The proposed revisions to the NEC received general support from the membership. This issue was also discussed at a NEMA – NRTLs Forum held on August 14, 2015 at NEMA Headquarters. UL reiterated its support for the proposed revisions. The NRTLs represented at the meeting voiced no objection to the proposals.

The rationale for the revision was simple, to provide information to the AHJ regarding the suitability of equipment they encounter. The mark on the product is the manufacturer’s attestation that the product is in compliance with the appropriate standard. NRTL’s conduct factory surveillance of products, surveillance is one method to validate the manufacturer’s attestation. Should a product be found not to be compliant the manufacturer has the option of removing the mark and shipping the product without the mark, or holding the shipment and bringing the product into compliance. In either case the “Listing” is not impacted, as the “listing” is created at the completion of the “original” certification of the product and indicates the authorization but not the mandate to label products. So the only true way an AHJ can determine whether the product he is seeing is compliant with the applicable standard is via a label on the product. Taking it one step further, listings change with time. It is quite possible that a “listing” has been withdrawn; however labeled product may still be available for sale. Should equipment that is labeled, but not listed, be deemed acceptable? Based on the NEC definitions, it is possible to have a product that meets the Article 100 definition of listed but the testing organization made the manufacture remove the label for a non-compliance issue.

As for the concerns of products that are too small to be labeled, the definition of labeled is not limited to an actual label, it also includes symbols, or other identifying marks. The Safety Standards which define the listing requirements do not address labeling of products as defined by Article 100. As a general rule, NRTL’s do not consider a product as being listed unless it is also labeled. The UL White Book states that “Only those products bearing the appropriate UL Mark and the company's name, trade name, trademark or other authorized identification should be considered as being covered by UL's Certification, Listing, Classification and Follow-Up Service. The UL Mark provides evidence of listing or labeling, which may be required by installation codes or standards.” Again the requirements for the UL Mark are not a Safety Standard requirement, they are a UL requirement and the only way to show that a product is UL Certified (Listed); other NRTL’s have similar requirements.

Related Item

Public Input No. 911-NFPA 70-2014 [Section No. 426.54]

First Revision No. 4803-NFPA 70-2015 [Global Input]

Submitter Information Verification

Submitter Full Name: JEFFREY FECTEAU

Organization: UNDERWRITERS LABORATORIES LLC

Affilliation: UL

Street Address:

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Public Comment No. 206-NFPA 70-2015 [ Section No. 427.1 ]

427.1 Scope.

The requirements of this article shall apply to electrically energized heating systems and the installation of these systems usedwith pipelines or vessels or both.

Informational Note: For further information, see ANSI/IEEE 515-2011, Standard for the Testing, Design, Installation andMaintenance of Electrical Resistance Trace Heating for Industrial Applications; ANSI/IEEE 844-2000, RecommendedPractice for Electrical Impedance, Induction, and Skin Effect Heating of Pipelines and Vessels; and ANSI/NECA202 and NECA NEIS 202 -2013, Standard for Installing and Maintaining Industrial Heat Tracing Systems.

Statement of Problem and Substantiation for Public Comment

Reference changed from ANSI/NECA 202 to read NECA NEIS 202 in the informational note.

Related Item

First Revision No. 4847-NFPA 70-2015 [Section No. 427.1]

Submitter Information Verification

Submitter Full Name: Aaron Adamczyk

Organization: [ Not Specified ]

Street Address:

City:

State:

Zip:

Submittal Date: Thu Jul 09 18:41:27 EDT 2015

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Public Comment No. 1089-NFPA 70-2015 [ Section No. 680.4 ]

680.4 Approval of Equipment.

All electrical equipment installed in the water, walls, or decks of pools, fountains, and similar installations shall comply with theprovisions of this article. Equipment and products shall be listed for swimming pool and spa use .

Statement of Problem and Substantiation for Public Comment

Wanting equipment and products used in the swimming pool and spa environment to be listed is a good thing, but listed for what? Prior to the 2005 NEC revision cycle, the NEC Technical Correlating Committee issued a directive to all of the Code Making Panels to clear up what "listed for the purpose" meant in their particular articles. In other words, don't just tell the user of the Code that something has to be "listed for the purpose" but tell us what that purpose is. That 2005 Code cycle was when CMP-17 changed 680.23(A)(2) from "transformers or power supplies used to supply underwater luminaires shall be listed for the purpose" to "transformers or power supplies used to supply underwater luminaires shall be listed for swimming pool and spa use." The presently proposed text would allow any equipment that was "listed" to used in the swimming pool and spa environment. This equipment could be "listed" for a dry location. Simply trying to close a loop-hole here gentleman.

Related Item

Public Input No. 3834-NFPA 70-2014 [Section No. 680.4]

First Revision No. 4851-NFPA 70-2015 [Section No. 680.4]

Submitter Information Verification

Submitter Full Name: L. Keith Lofland

Organization: International Association of Electrical Inspectors (IAEI)

Affilliation: None

Street Address:

City:

State:

Zip:

Submittal Date: Wed Sep 23 16:27:51 EDT 2015

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Public Comment No. 1098-NFPA 70-2015 [ Section No. 680.7 ]

680.7 Grounding and Bonding Terminals.

Grounding and bonding terminals shall be identified for use in wet and corrosive environments. Field-installed grounding andbonding connections in a damp, wet, or corrosive environment shall be composed of copper, copper alloy, or stainless steel.They shall be listed for direct burial or concrete-encasement use.

Statement of Problem and Substantiation for Public Comment

Ground clamps listed and identified for use with rebar are typically listed for concrete encasement (not just direct burial if at all). These rebar ground clamps are used regularly for the equipotential bonding grid at swimming pool structures. By adding "or concrete-encasement" will enhance this requirement.

Related Item

Public Input No. 3883-NFPA 70-2014 [New Section after 680.5]

First Revision No. 4852-NFPA 70-2015 [New Section after 680.6]

Submitter Information Verification

Submitter Full Name: L. Keith Lofland

Organization: International Association of Electrical Inspectors (IAEI)

Affilliation: None

Street Address:

City:

State:

Zip:

Submittal Date: Wed Sep 23 16:59:32 EDT 2015

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Public Comment No. 782-NFPA 70-2015 [ Section No. 680.21 ]

680.21 Motors.

(A) Wiring Methods.

The wiring to a pool motor shall comply with (A)(1) unless modified for specific circumstances by (A)(2), (A)(3), (A)(4), or (A)(5).

(1) General.

Where branch circuits for pool-associated motors are subject to physical damage and/or installed in wet, damp, or corrosiveenvironments, that portion of the branch circuit shall be installed in rigid metal conduit, intermediate metal conduit, rigid polyvinylchloride conduit, reinforced thermosetting resin conduit, or Type MC cable, suitable for the conditions subject to that location.Wiring methods installed in these locations shall contain an insulated copper equipment grounding conductor sized inaccordance with Table 250.122 but not smaller than 12 AWG.

Where installed in dry, noncorrosive environments, branch circuits shall comply with the general requirements in Chapter 3.

(2) Flexible Connections.

Where necessary to employ flexible connections at or adjacent to the motor, liquidtight flexible metal or liquidtight flexiblenonmetallic conduit with listed fittings shall be permitted.

(3) Cord-and-Plug Connections.

Pool-associated motors shall be permitted to employ cord-and-plug connections. The flexible cord shall not exceed 900 mm (3ft) in length. The flexible cord shall include a copper equipment grounding conductor sized in accordance with 250.122 but notsmaller than 12 AWG. The cord shall terminate in a grounding-type attachment plug.

(B) Double Insulated Pool Pumps.

A listed cord-and-plug-connected pool pump incorporating an approved system of double insulation that provides a means forgrounding only the internal and nonaccessible, non–current-carrying metal parts of the pump shall be connected to any wiringmethod recognized in Chapter 3 that is suitable for the location. Where the bonding grid is connected to the equipmentgrounding conductor of the motor circuit in accordance with the second sentence of 680.26(B)(6)(a), the branch-circuit wiringshall comply with 680.21(A).

(C) GFCI Protection.

Outlets supplying pool pump motors connected to single-phase, 120-volt through 240-volt branch circuits, whether by receptacleor by direct connection, shall be provided with ground-fault circuit-interrupter protection for personnel.

(D) SPGFCI Protection. Outlets supplying pool pump motors connected to single-phase and three-pahse branch circuits,rated more that 150 volts to ground and up to 600 volts between ungrounded conductors, 100 amperes or less, whether byreceptacle or by direct connection, shall be provided with special-purpose ground-fault circuit-interrupter protection forpersonnel.

Additional Proposed Changes

File Name Description Approved

GFCI_Classes.pdf GFCI Classes A, C, and D tripping Characteristics

Statement of Problem and Substantiation for Public Comment

The committee resolution of PI-2207 was: "GFCIs rated in excess of 250 volts do not always provide protection against "let-go" (devices trip at up to 20 mA) which is important when dealing with bodies of water due to the risk of drowning".

The submitter agrees with the committee that GFCI classes C, D and E (collectively referred to as SPGFCIs) don't provide let-go protection because of the 20 mA trip level which is above the let-go threshold. Yet, SPGFCIs provide protection against ventricular fibrillation, the condition that typically leads to cardiac arrest resulting in drowning. SPGFCIs use the same tripping characteristics of Class A GFCIs (A graph of the tripping characteristics is submitted with the support material of this public comment). The only difference is that the start of the curve (i.e. tripping action) is delayed from 6 mA to 20 mA (moved to the right).

Accordingly, SPGFCIs provide the exact protection level of Class A GFCIs for ground faults of 20 mA and higher. In other words, SPGFCIs are guaranteed to interrupt the source of power fast enough, and therefore protecting the person in the water from drowning, because the current going through the swimmer’s heart is interrupted.

During the first draft meeting, CMP 2 recognized SPGFCIs as a potential improvement to safety and created FR-339 and FR-347 to include a new definition for SPGFCIs and an installation requirement in Article 210.8(B) respectively.

Related Item

Public Input No. 2207-NFPA 70-2014 [Section No. 680.21(C)]

First Revision No. 339-NFPA 70-2015 [New Definition after Definition: Ground-Fault Circuit Inter...]

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Tripping Characteristics

Source: UL 943

20 6

Class A

Classes C & D

20 6

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First Revision No. 347-NFPA 70-2015 [Section No. 210.8(B)]

Submitter Information Verification

Submitter Full Name: NEHAD EL-SHERIF

Organization: Littelfuse Startco

Street Address:

City:

State:

Zip:

Submittal Date: Sun Sep 20 14:27:55 EDT 2015

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Public Comment No. 732-NFPA 70-2015 [ Section No. 680.21(A)(1) ]

(1) General.

Where branch Branch circuits for pool-associated motors that are subject to physical damage and/or installed in shall beinstalled in a wiring method that is identified for protection against physical damage. Branch circuits installed in wet, damp, orcorrosive environments , that portion of the branch circuit shall be installed in rigid metal conduit, intermediate metal conduit,rigid polyvinyl chloride conduit, reinforced thermosetting resin conduit, or Type MC cable, suitable for the conditions subject toa wiring method that is identified for the specific condition(s) at that location. Wiring methods installed in these locations shallcontain an insulated copper equipment grounding conductor sized in accordance with Table 250.122 but not smaller than 12AWG.

Where installed in dry, noncorrosive environments, branch circuits shall comply with the general requirements in Chapter 3.

Statement of Problem and Substantiation for Public Comment

This Comment is intended to simplify the Panel's stated goal of simplifying the wiring methods permitted for branch circuits to pool associated motors. However, some serious oversights are corrected in this Comment. For example, all PVC conduit is not identified for protection against physical damage or for all corrosive environments. Only Schedule 80 is suitable for protection against physical damage. PVC conduit in Schedules 40 and 80 are suitable for some but not all corrosive conditions. The manufacturers can and will willingly provide the list of corrosive conditions the PVC conduit is suitable for. Type RTRC conduit is not permitted where subject to physical damage unless identified for such use. This is stated in 355.12(C) under "Uses Not Permitted." Where subject to physical damage unless identified for such use. The UL White Book indicates only RTRC conduit with a suffix "XW" is suitable for protection against physical damage. The term "identified" is defined in Article 100 and is recommended for use in this Section. It means recognized as suitable for the use. Manufacturers, product standards or the NEC in the XXX.10 and XXX.12 sections identify the Uses Permitted and Not Permitted. Furthermore, these wiring methods are required to be listed which provides information to the installer and inspector that the wiring method is suitable for the application.

Related Item

First Revision No. 4855-NFPA 70-2015 [Section No. 680.21(A)]

Submitter Information Verification

Submitter Full Name: Phil Simmons

Organization: Simmons Electrical Services

Street Address:

City:

State:

Zip:

Submittal Date: Thu Sep 17 23:19:14 EDT 2015

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Public Comment No. 783-NFPA 70-2015 [ Section No. 680.22(A) ]

(A) Receptacles.

(1) Required Receptacle, Location.

Where a permanently installed pool is installed, no fewer than one 125-volt, 15- or 20-ampere receptacle on a general-purposebranch circuit shall be located not less than 1.83 m (6 ft) from, and not more than 6.0 m (20 ft) from, the inside wall of the pool.This receptacle shall be located not more than 2.0 m (6 ft 6 in.) above the floor, platform, or grade level serving the pool.

(2) Circulation and Sanitation System, Location.

Receptacles that provide power for water-pump motors or for other loads directly related to the circulation and sanitation systemshall be located at least 1.83 m (6 ft) from the inside walls of the pool.These receptacles shall have GFCI protection and be ofthe grounding type.

(3) Other Receptacles, Location.

Other receptacles shall be not less than 1.83 m (6 ft) from the inside walls of a pool.

(4) GFCI Protection.

All 15- and 20-ampere, single-phase, 125-volt receptacles located within 6.0 m (20 ft) of the inside walls of a pool shall beprotected by a ground-fault circuit interrupter.

(5) SPGFCI Protection

All 100 amperes or less, single-phase and three-phase receptacles rated more that 150 volts to ground and up to 600 voltsbetween ungrounded conductors, located within 6.0 (20 ft) of the inside walls of a pool shall be protected by a special-purposeground-fault circuit interrupter.

(6) Measurements.

In determining the dimensions in this section addressing receptacle spacings, the distance to be measured shall be the shortestpath the supply cord of an appliance connected to the receptacle would follow without piercing a floor, wall, ceiling, doorwaywith hinged or sliding door, window opening, or other effective permanent barrier.

Additional Proposed Changes

File Name Description Approved

GFCI_Classes.pdf Tripping characteristics of Classes A, C, and D GFCIs

Statement of Problem and Substantiation for Public Comment

The committee resolution of PI-2206 was: "GFCIs rated in excess of 250 volts do not always provide protection against "let-go" (devices trip at up to 20 mA) which is important when dealing with bodies of water due to the risk of drowning".

The submitter agrees with the committee that GFCI classes C, D and E (collectively referred to as SPGFCIs) don't provide let-go protection because of the 20 mA trip level which is above the let-go threshold. Yet, SPGFCIs provide protection against ventricular fibrillation, the condition that typically leads to cardiac arrest resulting in drowning. SPGFCIs use the same tripping characteristics of Class A GFCIs (A graph of the tripping characteristics is submitted with the support material of this public comment). The only difference is that the start of the curve (i.e. tripping action) is delayed from 6 mA to 20 mA (moved to the right).

Accordingly, SPGFCIs provide the exact protection level of Class A GFCIs for ground faults of 20 mA and higher. In other words, SPGFCIs are guaranteed to interrupt the source of power fast enough, and therefore protecting the person in the water from drowning, because the current going through the swimmer’s heart is interrupted.

During the first draft meeting, CMP 2 recognized SPGFCIs as a potential improvement to safety and created FR-339 and FR-347 to include a new definition for SPGFCIs and an installation requirement in Article 210.8(B) respectively.

Related Item

Public Input No. 2206-NFPA 70-2014 [Section No. 680.22(A)(4)]

First Revision No. 339-NFPA 70-2015 [New Definition after Definition: Ground-Fault Circuit Inter...]

First Revision No. 347-NFPA 70-2015 [Section No. 210.8(B)]

Submitter Information Verification

Submitter Full Name: NEHAD EL-SHERIF

Organization: Littelfuse Startco

Street Address:

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Public Comment No. 1100-NFPA 70-2015 [ Section No. 680.22(A)(2) ]

(2) Circulation and Sanitation System, Location.

Receptacles that provide power for water-pump motors or for other loads directly related to the circulation and sanitation systemshall be located at least 1.83 m (6 ft) from the inside walls of the pool.These receptacles shall have GFCI protection and be ofthe grounding type. , or not less than 900 mm (3 ft) from the inside walls of the pool if they meet all of the following conditions:

(1) Consist of a single receptacle

(2) Employ a locking configuration

(3) Be of the grounding type

(4) Include GFCI protection

Statement of Problem and Substantiation for Public Comment

This section got fouled up when the consistent distance of 1.83 m (6 ft) was desired and created for Article 680 during the 2008 NEC Code cycle. Prior to this 1.83 (6 ft) consistent distance for all or most measurements in Article 680, all receptacle outlets had to be at least 3.0 m (10 ft) from the water's edge except for the pool pump motor receptacle outlet, which could be located up to 1.5 m (5 ft) from the pool if it meet certain conditions (single, locking and grounding type, GFCI protected). This single and locking configuration eliminates someone plugging in a radio or something like that into the receptacle dedicated to the pool pump motor and setting the radio right beside the pool's edge. Pool equipment (including motors) are installed in close proximity to pools and spas on a regular basis. Since this change in the 2008 NEC, this is a common complaint among pool contractors and installers is that the NEC would no longer allow the receptacle for the pool pump motor to be located in close proximity to the pool as well. this restriction typically results in the motor being hard-wired. Any equipment located within 1.5 m (5 ft) of the pool would have to be bonded to the equipotential bonding grid. Any electrical equipment (pool pump motor) would have to be connected to the equipotential bonding grid regardless of it's location to the pool. With the single, locking and grounding type, GFCI-protected receptacle, I see no hazard that this allowance would create. This same basic requirement was part of the Code for years prior to the 2008 NEC and resulted in no major issues that I'm aware of.

Related Item

First Revision No. 4856-NFPA 70-2015 [Section No. 680.22(A)(2)]

Public Input No. 358-NFPA 70-2014 [Section No. 680.22(A)(2)]

Public Input No. 4351-NFPA 70-2014 [Section No. 680.22(A)(2)]

Submitter Information Verification

Submitter Full Name: L. Keith Lofland

Organization: International Association of Electrical Inspectors (IAEI)

Affilliation: None

Street Address:

City:

State:

Zip:

Submittal Date: Wed Sep 23 17:17:32 EDT 2015

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Public Comment No. 947-NFPA 70-2015 [ Section No. 680.22(B)(7) ]

(7) Low-Voltage Gas-Fired Electronic Luminaires. Fired Luminaires, Decorative Fireplaces, Fire Pits ans Similar Equipment

Listed and labeled low-voltage gas-fired electronically ignited luminaires and outdoor luminaire lighting appliances with fired luminaires, decorative fireplaces, fire pits and similar equipment using low-voltage ignitors that do not require grounding, thatdo not exceed the low-voltage contact limit, and that are supplied by listed and labeled transformers or power supplies thatcomply with 680.23(A)(2) with outputs that do not exceed the low-voltage contact limit, shall be permitted to be located lessthan 1.5 m (5 ft) from the inside walls of the pool. Metallic luminaires and outdoor luminaire lighting appliances equipment shallbe bonded in accordance with the requirements in 680.26(B). Transformers or power supplies supplying these luminaires andoutdoor lluminaire lighting appliances this type of equipment shall be installed in accordance with the requirements in 680.24.Metallic gas piping shall be bonded in accordance with the requirements in 250.104(B) and 680.26(B)(7).

Statement of Problem and Substantiation for Public Comment

Clarification of the meaning of “outdoor luminated lighting appliances” is required. This type of equipment includes gas-fired fireplaces, fire pits and similar equipment. In addition, clarification is needed that it is the equipment power supply that is “low voltage.” The text “and labeled” was added to replicate similar changes made by the Panel.

Related Item

First Revision No. 4857-NFPA 70-2015 [New Section after 680.22(B)(6)]

Submitter Information Verification

Submitter Full Name: Gary Siggins

Organization: UL LLC

Street Address:

City:

State:

Zip:

Submittal Date: Tue Sep 22 14:16:55 EDT 2015

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Public Comment No. 1302-NFPA 70-2015 [ Section No. 680.23(A)(2) ]

(2) Transformers and Power Supplies.

Transformers and power supplies used for the supply of underwater luminaires, together with the transformer or power supplyenclosure, shall be listed, labeled and identified for swimming pool and spa use. The transformer or power supply shallincorporate either a transformer of the isolated winding type, with an ungrounded secondary that has a grounded metal barrierbetween the primary and secondary windings, or one that incorporates an approved system of double insulation between theprimary and secondary windings.

Additional Proposed Changes

File Name Description Approved

Essential_Guide_to_Product_Testing_and_Certification_NOV_2014.pdf

ETL Essential Guide to Product Testing & Certification 2014/2015 North American Edition. Please review document page numbers 5, 8 and 10 to see that ETL has requirements similar to UL, that products that do not bear their certification (listed) mark are not considered by ETL as being listed.

Statement of Problem and Substantiation for Public Comment

UL recognizes the Correlating Committee created a global First Correlating Revision (FCR) which directed that in all locations where the term “and labeled” was added after “listed” during the First Revision Stage, the words “and labeled” after “listed” be deleted, returning to previous text. UL understands that the Correlating Committee appointed a task group to address several issues involving the use of the terms “listed” and “labeled,” most importantly, to clarify and establish a distinction between the terms “listed” and “labeled” which are often used interchangeably. UL supports the need for this task group. However, UL does not expect the work of this task group to affect the 2017 NEC regarding the issue of “listed and labeled.” As such, UL is submitting comments to request that the words “and labeled” be added in various locations throughout the Code for the reasons expressed in the public inputs UL submitted on this issue. UL believes that these revisions will address an ongoing problem that should not wait until the 2020 NEC for resolution.

Subsequent to the Public Input Code Panel Meetings, UL has discussed this issue with its Electrical Council whose membership includes many AHJs. The proposed revisions to the NEC received general support from the membership. This issue was also discussed at a NEMA – NRTLs Forum held on August 14, 2015 at NEMA Headquarters. UL reiterated its support for the proposed revisions. The NRTLs represented at the meeting voiced no objection to the proposals.

The rationale for the revision was simple, to provide information to the AHJ regarding the suitability of equipment they encounter. The mark on the product is the manufacturer’s attestation that the product is in compliance with the appropriate standard. NRTL’s conduct factory surveillance of products, surveillance is one method to validate the manufacturer’s attestation. Should a product be found not to be compliant the manufacturer has the option of removing the mark and shipping the product without the mark, or holding the shipment and bringing the product into compliance. In either case the “Listing” is not impacted, as the “listing” is created at the completion of the “original” certification of the product and indicates the authorization but not the mandate to label products. So the only true way an AHJ can determine whether the product he is seeing is compliant with the applicable standard is via a label on the product. Taking it one step further, listings change with time. It is quite possible that a “listing” has been withdrawn; however labeled product may still be available for sale. Should equipment that is labeled, but not listed, be deemed acceptable? Based on the NEC definitions, it is possible to have a product that meets the Article 100 definition of listed but the testing organization made the manufacture remove the label for a non-compliance issue.

As for the concerns of products that are too small to be labeled, the definition of labeled is not limited to an actual label, it also includes symbols, or other identifying marks. The Safety Standards which define the listing requirements do not address labeling of products as defined by Article 100. As a general rule, NRTL’s do not consider a product as being listed unless it is also labeled. The UL White Book states that “Only those products bearing the appropriate UL Mark and the company's name, trade name, trademark or other authorized identification should be considered as being covered by UL's Certification, Listing, Classification and Follow-Up Service. The UL Mark provides evidence of listing or labeling, which may be required by installation codes or standards.” Again the requirements for the UL Mark are not a Safety Standard requirement, they are a UL requirement and the only way to show that a product is UL Certified (Listed); other NRTL’s have similar requirements.

Related Item

Public Input No. 929-NFPA 70-2014 [Section No. 680.23(A)(2)]

First Revision No. 4803-NFPA 70-2015 [Global Input]

Submitter Information Verification

Submitter Full Name: JEFFREY FECTEAU

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Public Comment No. 1303-NFPA 70-2015 [ Section No. 680.24(A)(1) ]

(1) Construction.

The junction box shall be listed, labeled and identified as a swimming pool junction box and shall comply with the followingconditions:

(1) Be equipped with threaded entries or hubs or a nonmetallic hub

(2) Be comprised of copper, brass, suitable plastic, or other approved corrosion-resistant material

(3) Be provided with electrical continuity between every connected metal conduit and the grounding terminals by means ofcopper, brass, or other approved corrosion-resistant metal that is integral with the box

Additional Proposed Changes

File Name Description Approved

Essential_Guide_to_Product_Testing_and_Certification_NOV_2014.pdf

ETL Essential Guide to Product Testing & Certification 2014/2015 North American Edition. Please review document page numbers 5, 8 and 10 to see that ETL has requirements similar to UL, that products that do not bear their certification (listed) mark are not considered by ETL as being listed.

Statement of Problem and Substantiation for Public Comment

UL recognizes the Correlating Committee created a global First Correlating Revision (FCR) which directed that in all locations where the term “and labeled” was added after “listed” during the First Revision Stage, the words “and labeled” after “listed” be deleted, returning to previous text. UL understands that the Correlating Committee appointed a task group to address several issues involving the use of the terms “listed” and “labeled,” most importantly, to clarify and establish a distinction between the terms “listed” and “labeled” which are often used interchangeably. UL supports the need for this task group. However, UL does not expect the work of this task group to affect the 2017 NEC regarding the issue of “listed and labeled.” As such, UL is submitting comments to request that the words “and labeled” be added in various locations throughout the Code for the reasons expressed in the public inputs UL submitted on this issue. UL believes that these revisions will address an ongoing problem that should not wait until the 2020 NEC for resolution.

Subsequent to the Public Input Code Panel Meetings, UL has discussed this issue with its Electrical Council whose membership includes many AHJs. The proposed revisions to the NEC received general support from the membership. This issue was also discussed at a NEMA – NRTLs Forum held on August 14, 2015 at NEMA Headquarters. UL reiterated its support for the proposed revisions. The NRTLs represented at the meeting voiced no objection to the proposals.

The rationale for the revision was simple, to provide information to the AHJ regarding the suitability of equipment they encounter. The mark on the product is the manufacturer’s attestation that the product is in compliance with the appropriate standard. NRTL’s conduct factory surveillance of products, surveillance is one method to validate the manufacturer’s attestation. Should a product be found not to be compliant the manufacturer has the option of removing the mark and shipping the product without the mark, or holding the shipment and bringing the product into compliance. In either case the “Listing” is not impacted, as the “listing” is created at the completion of the “original” certification of the product and indicates the authorization but not the mandate to label products. So the only true way an AHJ can determine whether the product he is seeing is compliant with the applicable standard is via a label on the product. Taking it one step further, listings change with time. It is quite possible that a “listing” has been withdrawn; however labeled product may still be available for sale. Should equipment that is labeled, but not listed, be deemed acceptable? Based on the NEC definitions, it is possible to have a product that meets the Article 100 definition of listed but the testing organization made the manufacture remove the label for a non-compliance issue.

As for the concerns of products that are too small to be labeled, the definition of labeled is not limited to an actual label, it also includes symbols, or other identifying marks. The Safety Standards which define the listing requirements do not address labeling of products as defined by Article 100. As a general rule, NRTL’s do not consider a product as being listed unless it is also labeled. The UL White Book states that “Only those products bearing the appropriate UL Mark and the company's name, trade name, trademark or other authorized identification should be considered as being covered by UL's Certification, Listing, Classification and Follow-Up Service. The UL Mark provides evidence of listing or labeling, which may be required by installation codes or standards.” Again the requirements for the UL Mark are not a Safety Standard requirement, they are a UL requirement and the only way to show that a product is UL Certified (Listed); other NRTL’s have similar requirements.

Related Item

Public Input No. 930-NFPA 70-2014 [Section No. 680.24(A)(1)]

First Revision No. 4803-NFPA 70-2015 [Global Input]

Submitter Information Verification

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Public Comment No. 1055-NFPA 70-2015 [ Section No. 680.25(1) ]

(1) Feeders.

Where feeders are subject to physical damage and/ or installed in wet, damp, or corrosive environments, that portion of thefeeder shall be installed in rigid metal conduit, intermediate metal conduit,rigid polyvinyl chloride conduit, or reinforcedthermosetting resin conduit, or listed cable wiring method, suitable for the conditions. Where installed in dry, noncorrosiveenvironments, feeders shall comply with the general requirements in Chapter 3. Wiring methods installed in wet, damp, orcorrosive environments shall contain an insulated copper or covered equipment grounding conductor sized in accordance withTable 250.122, but not less than 12 AWG copper or 10 AWG aluminum or copper-clad aluminum shall be required.

Statement of Problem and Substantiation for Public Comment

There is lack of substantiation for what constitutes a defined "corrosive environment" and for adding copper as the "only" acceptable equipment grounding conductor when installed in wet, damp or corrosive environment. Section 250.118 permits copper, aluminum, or copper-clad aluminum that is insulated, covered, or bare as an equipment grounding conductor, so is the covered aluminum conductor in Type SE Cable, which is acceptable in a wet location above ground, considered a “corrosive environment”? For example, there is no evidence that Type SE-R Cable supplied from an exterior meter/main service equipment (wet location), that then enters the structure (on its path to an interior remote panelboard that may supply branch circuits to a pool application) is a shock hazard, yet it would be prohibited under the new language. However, if the FR 4863 is accepted as written it would have a negative impact on the use of a well-established and listed product that has a proven track record in wet, damp and dry locations. In addition, physical damage when considering corrosive locations is well established in Section 338.12(A)(1), (2) and (3) and if a specific location is determined to be a corrosive environment, Section 250.120(B) would also provide guidance. Type SE Cable, Both Style U and R have been used for many years in wet and damp locations which are arguably considered corrosive environments without any serious issues. The FR proposed by CMP 17 did not provide any guidance on what they considered a "corrosive environment" to support the new language.

Related Item

First Revision No. 4863-NFPA 70-2015 [Section No. 680.25(1)]

Submitter Information Verification

Submitter Full Name: John Weritz

Organization: The Aluminum Association

Affilliation: The Aluminum Association

Street Address:

City:

State:

Zip:

Submittal Date: Wed Sep 23 12:47:01 EDT 2015

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Public Comment No. 1243-NFPA 70-2015 [ Section No. 680.25(1) ]

(1) Feeders.

Where feeders are subject to physical damage and/or installed in wet, damp, or corrosive environments, that portion of thefeeder shall be installed in rigid metal conduit, intermediate metal conduit,rigid polyvinyl chloride conduit, or reinforcedthermosetting resin conduit, suitable for the conditions. Where installed in dry, noncorrosive environments, feeders shall complywith the general requirements in Chapter 3. Wiring methods installed in wet, damp, or corrosive environments shall contain aninsulated copper equipment grounding conductor sized in accordance with Table 250.122, but not less than 12 AWG shall berequired.

Informational Note: This would include the feeder/branch circuit to a self-contained spa or hot tub disconnect wether thedisconecting means has supplementary overcurrent device(s) in it or not.

Statement of Problem and Substantiation for Public Comment

There are alot of AHJs that cant agree if you have to have an insulated EGC inside of the building to a hot tub disconnect. Some say you do if the disconnect has the GFCI breaker in it, because then it is a feeder. Then you don't if you put the GFCI in the main service then put a nonfusible disconnect by the hot tub, then it is a branch circuit. I have seen NM cable from the service to the hot tub disconnect for as long as i have been in the field, but then in the last couple years there has been confusion on this.

Related Item

First Revision No. 4863-NFPA 70-2015 [Section No. 680.25(1)]

Submitter Information Verification

Submitter Full Name: Brent Schoulte

Organization: South Dakota Electrical Comm

Street Address:

City:

State:

Zip:

Submittal Date: Thu Sep 24 15:31:19 EDT 2015

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Public Comment No. 731-NFPA 70-2015 [ Section No. 680.25(1) ]

(1) Feeders.

Where feeders are subject to physical damage and/or , the wiring method shall be identified for protection against suchdamage. Wiring methods installed in wet, damp, or corrosive environments, that portion of the feeder shall be installed in rigidmetal conduit, intermediate metal conduit,rigid polyvinyl chloride conduit, or reinforced thermosetting resin conduit, suitable forthe conditions shall be identified for such locations . Where installed in dry, noncorrosive environments, feeders shall complywith the general requirements in Chapter 3. Wiring methods installed in wet, damp, or corrosive environments shall contain aninsulated copper equipment grounding conductor sized in accordance with Table 250.122, but not less smaller than 12 AWGshall be required .

Statement of Problem and Substantiation for Public Comment

This Comment is intended to simplify the Panel's stated goal of simplifying the wiring methods permitted for feeders. However, some serious oversights are corrected in this Comment. For example, all PVC conduit is not identified for protection against physical damage or for all corrosive environments. Only Schedule 80 is suitable for protection against physical damage. PVC conduit in Schedules 40 and 80 are suitable for some but not all corrosive conditions. The manufacturers can and will willingly provide the list of corrosive conditions the PVC conduit is suitable for. Type RTRC conduit is not permitted where subject to physical damage unless identified for such use. This is stated in 355.12(C) under "Uses Not Permitted." Where subject to physical damage unless identified for such use. The UL White Book indicates only RTRC conduit with a suffix "XW" is suitable for protection against physical damage. The word "less" is replaced with "smaller" because "less" refers to quantity and "smaller" refers to the size which is the subject of the size of the equipment grounding conductor. The ending phrase "shall be required" is repetitive of the requirement earlier in the sentence as thus is shown being deleted.

Related Item

First Revision No. 4863-NFPA 70-2015 [Section No. 680.25(1)]

Submitter Information Verification

Submitter Full Name: Phil Simmons

Organization: Simmons Electrical Services

Street Address:

City:

State:

Zip:

Submittal Date: Thu Sep 17 21:48:01 EDT 2015

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Public Comment No. 1305-NFPA 70-2015 [ Section No. 680.42(A) [Excluding any Sub-Sections] ]

Listed and labeled packaged spa or hot tub equipment assemblies or self-contained spas or hot tubs utilizing a factory-installedor assembled control panel or panelboard shall be permitted to use flexible connections as covered in 680.42(A)(1) and (A)(2).

Additional Proposed Changes

File Name Description Approved

Essential_Guide_to_Product_Testing_and_Certification_NOV_2014.pdf

ETL Essential Guide to Product Testing & Certification 2014/2015 North American Edition. Please review document page numbers 5, 8 and 10 to see that ETL has requirements similar to UL, that products that do not bear their certification (listed) mark are not considered by ETL as being listed.

Statement of Problem and Substantiation for Public Comment

UL recognizes the Correlating Committee created a global First Correlating Revision (FCR) which directed that in all locations where the term “and labeled” was added after “listed” during the First Revision Stage, the words “and labeled” after “listed” be deleted, returning to previous text. UL understands that the Correlating Committee appointed a task group to address several issues involving the use of the terms “listed” and “labeled,” most importantly, to clarify and establish a distinction between the terms “listed” and “labeled” which are often used interchangeably. UL supports the need for this task group. However, UL does not expect the work of this task group to affect the 2017 NEC regarding the issue of “listed and labeled.” As such, UL is submitting comments to request that the words “and labeled” be added in various locations throughout the Code for the reasons expressed in the public inputs UL submitted on this issue. UL believes that these revisions will address an ongoing problem that should not wait until the 2020 NEC for resolution.

Subsequent to the Public Input Code Panel Meetings, UL has discussed this issue with its Electrical Council whose membership includes many AHJs. The proposed revisions to the NEC received general support from the membership. This issue was also discussed at a NEMA – NRTLs Forum held on August 14, 2015 at NEMA Headquarters. UL reiterated its support for the proposed revisions. The NRTLs represented at the meeting voiced no objection to the proposals.

The rationale for the revision was simple, to provide information to the AHJ regarding the suitability of equipment they encounter. The mark on the product is the manufacturer’s attestation that the product is in compliance with the appropriate standard. NRTL’s conduct factory surveillance of products, surveillance is one method to validate the manufacturer’s attestation. Should a product be found not to be compliant the manufacturer has the option of removing the mark and shipping the product without the mark, or holding the shipment and bringing the product into compliance. In either case the “Listing” is not impacted, as the “listing” is created at the completion of the “original” certification of the product and indicates the authorization but not the mandate to label products. So the only true way an AHJ can determine whether the product he is seeing is compliant with the applicable standard is via a label on the product. Taking it one step further, listings change with time. It is quite possible that a “listing” has been withdrawn; however labeled product may still be available for sale. Should equipment that is labeled, but not listed, be deemed acceptable? Based on the NEC definitions, it is possible to have a product that meets the Article 100 definition of listed but the testing organization made the manufacture remove the label for a non-compliance issue.

As for the concerns of products that are too small to be labeled, the definition of labeled is not limited to an actual label, it also includes symbols, or other identifying marks. The Safety Standards which define the listing requirements do not address labeling of products as defined by Article 100. As a general rule, NRTL’s do not consider a product as being listed unless it is also labeled. The UL White Book states that “Only those products bearing the appropriate UL Mark and the company's name, trade name, trademark or other authorized identification should be considered as being covered by UL's Certification, Listing, Classification and Follow-Up Service. The UL Mark provides evidence of listing or labeling, which may be required by installation codes or standards.” Again the requirements for the UL Mark are not a Safety Standard requirement, they are a UL requirement and the only way to show that a product is UL Certified (Listed); other NRTL’s have similar requirements.

Related Item

Public Input No. 931-NFPA 70-2014 [Section No. 680.42(A) [Excluding any Sub-Sections]]

First Revision No. 4803-NFPA 70-2015 [Global Input]

Submitter Information Verification

Submitter Full Name: JEFFREY FECTEAU

Organization: UNDERWRITERS LABORATORIES LLC

Affilliation: UL

Street Address:

City:

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State:

Zip:

Submittal Date: Thu Sep 24 18:48:52 EDT 2015

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Public Comment No. 1308-NFPA 70-2015 [ Section No. 680.42(B) ]

(B) Bonding.

Bonding by metal-to-metal mounting on a common frame or base shall be permitted. The metal bands or hoops used to securewooden staves shall not be required to be bonded as required in 680.26.

Equipotential bonding of perimeter surfaces in accordance with 680.26(B)(2) shall not be required to be provided for spas andhot tubs where all of the following conditions apply:

(1) The spa or hot tub shall be listed, labeled and identified as a self-contained spa for aboveground use.

(2) The spa or hot tub shall not be identified as suitable only for indoor use.

(3) The installation shall be in accordance with the manufacturer’s instructions and shall be located on or above grade.

(4) The top rim of the spa or hot tub shall be at least 710 mm (28 in.) above all perimeter surfaces that are within 760 mm (30in.), measured horizontally from the spa or hot tub. The height of nonconductive external steps for entry to or exit from theself-contained spa shall not be used to reduce or increase this rim height measurement.

Informational Note: For information regarding listing requirements for self-contained spas and hot tubs, see ANSI/UL1563 - 2010, Standard for Electric Spas, Equipment Assemblies, and Associated Equipment.

Additional Proposed Changes

File Name Description Approved

Essential_Guide_to_Product_Testing_and_Certification_NOV_2014.pdf

ETL Essential Guide to Product Testing & Certification 2014/2015 North American Edition. Please review document page numbers 5, 8 and 10 to see that ETL has requirements similar to UL, that products that do not bear their certification (listed) mark are not considered by ETL as being listed.

Statement of Problem and Substantiation for Public Comment

UL recognizes the Correlating Committee created a global First Correlating Revision (FCR) which directed that in all locations where the term “and labeled” was added after “listed” during the First Revision Stage, the words “and labeled” after “listed” be deleted, returning to previous text. UL understands that the Correlating Committee appointed a task group to address several issues involving the use of the terms “listed” and “labeled,” most importantly, to clarify and establish a distinction between the terms “listed” and “labeled” which are often used interchangeably. UL supports the need for this task group. However, UL does not expect the work of this task group to affect the 2017 NEC regarding the issue of “listed and labeled.” As such, UL is submitting comments to request that the words “and labeled” be added in various locations throughout the Code for the reasons expressed in the public inputs UL submitted on this issue. UL believes that these revisions will address an ongoing problem that should not wait until the 2020 NEC for resolution.

Subsequent to the Public Input Code Panel Meetings, UL has discussed this issue with its Electrical Council whose membership includes many AHJs. The proposed revisions to the NEC received general support from the membership. This issue was also discussed at a NEMA – NRTLs Forum held on August 14, 2015 at NEMA Headquarters. UL reiterated its support for the proposed revisions. The NRTLs represented at the meeting voiced no objection to the proposals.

The rationale for the revision was simple, to provide information to the AHJ regarding the suitability of equipment they encounter. The mark on the product is the manufacturer’s attestation that the product is in compliance with the appropriate standard. NRTL’s conduct factory surveillance of products, surveillance is one method to validate the manufacturer’s attestation. Should a product be found not to be compliant the manufacturer has the option of removing the mark and shipping the product without the mark, or holding the shipment and bringing the product into compliance. In either case the “Listing” is not impacted, as the “listing” is created at the completion of the “original” certification of the product and indicates the authorization but not the mandate to label products. So the only true way an AHJ can determine whether the product he is seeing is compliant with the applicable standard is via a label on the product. Taking it one step further, listings change with time. It is quite possible that a “listing” has been withdrawn; however labeled product may still be available for sale. Should equipment that is labeled, but not listed, be deemed acceptable? Based on the NEC definitions, it is possible to have a product that meets the Article 100 definition of listed but the testing organization made the manufacture remove the label for a non-compliance issue.

As for the concerns of products that are too small to be labeled, the definition of labeled is not limited to an actual label, it also includes symbols, or other identifying marks. The Safety Standards which define the listing requirements do not address labeling of products as defined by Article 100. As a general rule, NRTL’s do not consider a product as being listed unless it is also labeled. The UL White Book states that “Only those products bearing the appropriate UL Mark and the company's name, trade name, trademark or other authorized identification should be considered as being covered by UL's Certification, Listing, Classification and Follow-Up Service. The UL Mark provides evidence of listing or labeling, which may be required by installation codes or standards.” Again the requirements for the UL Mark are not a Safety Standard requirement, they are a UL requirement and the only way to show that a product is UL Certified (Listed);

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other NRTL’s have similar requirements.

Related Item

Public Input No. 932-NFPA 70-2014 [Section No. 680.42(B)]

First Revision No. 4803-NFPA 70-2015 [Global Input]

Submitter Information Verification

Submitter Full Name: JEFFREY FECTEAU

Organization: UNDERWRITERS LABORATORIES LLC

Affilliation: UL

Street Address:

City:

State:

Zip:

Submittal Date: Thu Sep 24 18:53:24 EDT 2015

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Public Comment No. 1309-NFPA 70-2015 [ Section No. 680.43 [Excluding any Sub-Sections] ]

A spa or hot tub installed indoors shall comply with the provisions of Parts I and II of this article except as modified by thissection and shall be connected by the wiring methods of Chapter 3.

Exception No. 1: Listed and Labeled spa and hot tub packaged units rated 20 amperes or less shall be permitted to becord-and-plug-connected to facilitate the removal or disconnection of the unit for maintenance and repair.

Exception No. 2: The equipotential bonding requirements for perimeter surfaces in 680.26(B)(2) shall not apply to a listed andlabeled self-contained spa or hot tub installed above a finished floor.

Exception No. 3: For a dwelling unit(s) only, where a listed and labeled spa or hot tub is installed indoors, the wiring methodrequirements of 680.42(C) shall also apply.

Additional Proposed Changes

File Name Description Approved

Essential_Guide_to_Product_Testing_and_Certification_NOV_2014.pdf

ETL Essential Guide to Product Testing & Certification 2014/2015 North American Edition. Please review document page numbers 5, 8 and 10 to see that ETL has requirements similar to UL, that products that do not bear their certification (listed) mark are not considered by ETL as being listed.

Statement of Problem and Substantiation for Public Comment

UL recognizes the Correlating Committee created a global First Correlating Revision (FCR) which directed that in all locations where the term “and labeled” was added after “listed” during the First Revision Stage, the words “and labeled” after “listed” be deleted, returning to previous text. UL understands that the Correlating Committee appointed a task group to address several issues involving the use of the terms “listed” and “labeled,” most importantly, to clarify and establish a distinction between the terms “listed” and “labeled” which are often used interchangeably. UL supports the need for this task group. However, UL does not expect the work of this task group to affect the 2017 NEC regarding the issue of “listed and labeled.” As such, UL is submitting comments to request that the words “and labeled” be added in various locations throughout the Code for the reasons expressed in the public inputs UL submitted on this issue. UL believes that these revisions will address an ongoing problem that should not wait until the 2020 NEC for resolution.

Subsequent to the Public Input Code Panel Meetings, UL has discussed this issue with its Electrical Council whose membership includes many AHJs. The proposed revisions to the NEC received general support from the membership. This issue was also discussed at a NEMA – NRTLs Forum held on August 14, 2015 at NEMA Headquarters. UL reiterated its support for the proposed revisions. The NRTLs represented at the meeting voiced no objection to the proposals.

The rationale for the revision was simple, to provide information to the AHJ regarding the suitability of equipment they encounter. The mark on the product is the manufacturer’s attestation that the product is in compliance with the appropriate standard. NRTL’s conduct factory surveillance of products, surveillance is one method to validate the manufacturer’s attestation. Should a product be found not to be compliant the manufacturer has the option of removing the mark and shipping the product without the mark, or holding the shipment and bringing the product into compliance. In either case the “Listing” is not impacted, as the “listing” is created at the completion of the “original” certification of the product and indicates the authorization but not the mandate to label products. So the only true way an AHJ can determine whether the product he is seeing is compliant with the applicable standard is via a label on the product. Taking it one step further, listings change with time. It is quite possible that a “listing” has been withdrawn; however labeled product may still be available for sale. Should equipment that is labeled, but not listed, be deemed acceptable? Based on the NEC definitions, it is possible to have a product that meets the Article 100 definition of listed but the testing organization made the manufacture remove the label for a non-compliance issue.

As for the concerns of products that are too small to be labeled, the definition of labeled is not limited to an actual label, it also includes symbols, or other identifying marks. The Safety Standards which define the listing requirements do not address labeling of products as defined by Article 100. As a general rule, NRTL’s do not consider a product as being listed unless it is also labeled. The UL White Book states that “Only those products bearing the appropriate UL Mark and the company's name, trade name, trademark or other authorized identification should be considered as being covered by UL's Certification, Listing, Classification and Follow-Up Service. The UL Mark provides evidence of listing or labeling, which may be required by installation codes or standards.” Again the requirements for the UL Mark are not a Safety Standard requirement, they are a UL requirement and the only way to show that a product is UL Certified (Listed); other NRTL’s have similar requirements.

Related Item

Public Input No. 933-NFPA 70-2014 [Section No. 680.43 [Excluding any Sub-Sections]]

First Revision No. 4803-NFPA 70-2015 [Global Input]

Submitter Information Verification

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Submitter Full Name: JEFFREY FECTEAU

Organization: UNDERWRITERS LABORATORIES LLC

Affilliation: UL

Street Address:

City:

State:

Zip:

Submittal Date: Thu Sep 24 18:57:27 EDT 2015

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Public Comment No. 1310-NFPA 70-2015 [ Section No. 680.43(D) ]

(D) Bonding.

The following parts shall be bonded together:

(1) All metal fittings within or attached to the spa or hot tub structure

(2) Metal parts of electrical equipment associated with the spa or hot tub water circulating system, including pump motors,unless part of a listed self , labeled and identified self -contained spa or hot tub

(3) Metal raceway and metal piping that are within 1.5 m (5 ft) of the inside walls of the spa or hot tub and that are notseparated from the spa or hot tub by a permanent barrier

(4) All metal surfaces that are within 1.5 m (5 ft) of the inside walls of the spa or hot tub and that are not separated from thespa or hot tub area by a permanent barrier

Exception: Small conductive surfaces not likely to become energized, such as air and water jets and drain fittings,where not connected to metallic piping, towel bars, mirror frames, and similar nonelectrical equipment, shall not berequired to be bonded.

(5) Electrical devices and controls that are not associated with the spas or hot tubs and that are located less than 1.5 m (5 ft)from such units; otherwise, they shall be bonded to the spa or hot tub system

Additional Proposed Changes

File Name Description Approved

Essential_Guide_to_Product_Testing_and_Certification_NOV_2014.pdf

ETL Essential Guide to Product Testing & Certification 2014/2015 North American Edition. Please review document page numbers 5, 8 and 10 to see that ETL has requirements similar to UL, that products that do not bear their certification (listed) mark are not considered by ETL as being listed.

Statement of Problem and Substantiation for Public Comment

UL recognizes the Correlating Committee created a global First Correlating Revision (FCR) which directed that in all locations where the term “and labeled” was added after “listed” during the First Revision Stage, the words “and labeled” after “listed” be deleted, returning to previous text. UL understands that the Correlating Committee appointed a task group to address several issues involving the use of the terms “listed” and “labeled,” most importantly, to clarify and establish a distinction between the terms “listed” and “labeled” which are often used interchangeably. UL supports the need for this task group. However, UL does not expect the work of this task group to affect the 2017 NEC regarding the issue of “listed and labeled.” As such, UL is submitting comments to request that the words “and labeled” be added in various locations throughout the Code for the reasons expressed in the public inputs UL submitted on this issue. UL believes that these revisions will address an ongoing problem that should not wait until the 2020 NEC for resolution.

Subsequent to the Public Input Code Panel Meetings, UL has discussed this issue with its Electrical Council whose membership includes many AHJs. The proposed revisions to the NEC received general support from the membership. This issue was also discussed at a NEMA – NRTLs Forum held on August 14, 2015 at NEMA Headquarters. UL reiterated its support for the proposed revisions. The NRTLs represented at the meeting voiced no objection to the proposals.

The rationale for the revision was simple, to provide information to the AHJ regarding the suitability of equipment they encounter. The mark on the product is the manufacturer’s attestation that the product is in compliance with the appropriate standard. NRTL’s conduct factory surveillance of products, surveillance is one method to validate the manufacturer’s attestation. Should a product be found not to be compliant the manufacturer has the option of removing the mark and shipping the product without the mark, or holding the shipment and bringing the product into compliance. In either case the “Listing” is not impacted, as the “listing” is created at the completion of the “original” certification of the product and indicates the authorization but not the mandate to label products. So the only true way an AHJ can determine whether the product he is seeing is compliant with the applicable standard is via a label on the product. Taking it one step further, listings change with time. It is quite possible that a “listing” has been withdrawn; however labeled product may still be available for sale. Should equipment that is labeled, but not listed, be deemed acceptable? Based on the NEC definitions, it is possible to have a product that meets the Article 100 definition of listed but the testing organization made the manufacture remove the label for a non-compliance issue.

As for the concerns of products that are too small to be labeled, the definition of labeled is not limited to an actual label, it also includes symbols, or other identifying marks. The Safety Standards which define the listing requirements do not address labeling of products as defined by Article 100. As a general rule, NRTL’s do not consider a product as being listed unless it is also labeled. The UL White Book states that “Only those products bearing the appropriate UL Mark and the company's name, trade name, trademark or other authorized identification should be considered as being covered by UL's Certification, Listing, Classification and Follow-Up Service. The UL Mark

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provides evidence of listing or labeling, which may be required by installation codes or standards.” Again the requirements for the UL Mark are not a Safety Standard requirement, they are a UL requirement and the only way to show that a product is UL Certified (Listed); other NRTL’s have similar requirements.

Related Item

Public Input No. 934-NFPA 70-2014 [Section No. 680.43(D)]

First Revision No. 4803-NFPA 70-2015 [Global Input]

Submitter Information Verification

Submitter Full Name: JEFFREY FECTEAU

Organization: UNDERWRITERS LABORATORIES LLC

Affilliation: UL

Street Address:

City:

State:

Zip:

Submittal Date: Thu Sep 24 19:01:52 EDT 2015

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Public Comment No. 1311-NFPA 70-2015 [ Section No. 680.44(A) ]

(A) Listed Units.

If so marked, a listed, labeled and identified self-contained unit or listed and labeled packaged equipment assembly thatincludes integral ground-fault circuit-interrupter protection for all electrical parts within the unit or assembly (pumps, air blowers,heaters, lights, controls, sanitizer generators, wiring, and so forth) shall be permitted without additional GFCI protection.

Additional Proposed Changes

File Name Description Approved

Essential_Guide_to_Product_Testing_and_Certification_NOV_2014.pdf

ETL Essential Guide to Product Testing & Certification 2014/2015 North American Edition. Please review document page numbers 5, 8 and 10 to see that ETL has requirements similar to UL, that products that do not bear their certification (listed) mark are not considered by ETL as being listed.

Statement of Problem and Substantiation for Public Comment

UL recognizes the Correlating Committee created a global First Correlating Revision (FCR) which directed that in all locations where the term “and labeled” was added after “listed” during the First Revision Stage, the words “and labeled” after “listed” be deleted, returning to previous text. UL understands that the Correlating Committee appointed a task group to address several issues involving the use of the terms “listed” and “labeled,” most importantly, to clarify and establish a distinction between the terms “listed” and “labeled” which are often used interchangeably. UL supports the need for this task group. However, UL does not expect the work of this task group to affect the 2017 NEC regarding the issue of “listed and labeled.” As such, UL is submitting comments to request that the words “and labeled” be added in various locations throughout the Code for the reasons expressed in the public inputs UL submitted on this issue. UL believes that these revisions will address an ongoing problem that should not wait until the 2020 NEC for resolution.

Subsequent to the Public Input Code Panel Meetings, UL has discussed this issue with its Electrical Council whose membership includes many AHJs. The proposed revisions to the NEC received general support from the membership. This issue was also discussed at a NEMA – NRTLs Forum held on August 14, 2015 at NEMA Headquarters. UL reiterated its support for the proposed revisions. The NRTLs represented at the meeting voiced no objection to the proposals.

The rationale for the revision was simple, to provide information to the AHJ regarding the suitability of equipment they encounter. The mark on the product is the manufacturer’s attestation that the product is in compliance with the appropriate standard. NRTL’s conduct factory surveillance of products, surveillance is one method to validate the manufacturer’s attestation. Should a product be found not to be compliant the manufacturer has the option of removing the mark and shipping the product without the mark, or holding the shipment and bringing the product into compliance. In either case the “Listing” is not impacted, as the “listing” is created at the completion of the “original” certification of the product and indicates the authorization but not the mandate to label products. So the only true way an AHJ can determine whether the product he is seeing is compliant with the applicable standard is via a label on the product. Taking it one step further, listings change with time. It is quite possible that a “listing” has been withdrawn; however labeled product may still be available for sale. Should equipment that is labeled, but not listed, be deemed acceptable? Based on the NEC definitions, it is possible to have a product that meets the Article 100 definition of listed but the testing organization made the manufacture remove the label for a non-compliance issue.

As for the concerns of products that are too small to be labeled, the definition of labeled is not limited to an actual label, it also includes symbols, or other identifying marks. The Safety Standards which define the listing requirements do not address labeling of products as defined by Article 100. As a general rule, NRTL’s do not consider a product as being listed unless it is also labeled. The UL White Book states that “Only those products bearing the appropriate UL Mark and the company's name, trade name, trademark or other authorized identification should be considered as being covered by UL's Certification, Listing, Classification and Follow-Up Service. The UL Mark provides evidence of listing or labeling, which may be required by installation codes or standards.” Again the requirements for the UL Mark are not a Safety Standard requirement, they are a UL requirement and the only way to show that a product is UL Certified (Listed); other NRTL’s have similar requirements.

Related Item

Public Input No. 935-NFPA 70-2014 [Section No. 680.44(A)]

First Revision No. 4803-NFPA 70-2015 [Global Input]

Submitter Information Verification

Submitter Full Name: JEFFREY FECTEAU

Organization: UNDERWRITERS LABORATORIES LLC

Affilliation: UL

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Street Address:

City:

State:

Zip:

Submittal Date: Thu Sep 24 19:06:21 EDT 2015

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Public Comment No. 785-NFPA 70-2015 [ Section No. 680.58 ]

680.58 GFCI Personnel Protection for Adjacent Receptacle Outlets.

(1) All 15- or 20-ampere, single-phase 125-volt through 250-volt receptacles located within 6.0 m (20 ft) of a fountain edgeshall be provided with GFCI protection.

(2) All 100 amperes or less, single-phase and three-phase receptacles rated more that 150 volts to ground and up to 600 voltsbetween ungrounded conductors, located within 6.0 (20 ft) of a fountain edge shall be provided with SPGFCI protection.

Additional Proposed Changes

File Name Description Approved

GFCI_Classes.pdf Tripping Characteristics of GFCI classes A, C, and D

Statement of Problem and Substantiation for Public Comment

The committee resolution of PI-2208 was: "GFCIs rated in excess of 250 volts do not always provide protection against "let-go" (devices trip at up to 20 mA) which is important when dealing with bodies of water due to the risk of drowning".

The submitter agrees with the committee that GFCI classes C, D and E (collectively referred to as SPGFCIs) don't provide let-go protection because of the 20 mA trip level which is above the let-go threshold. Yet, SPGFCIs provide protection against ventricular fibrillation, the condition that typically leads to cardiac arrest resulting in drowning. SPGFCIs use the same tripping characteristics of Class A GFCIs (A graph of the tripping characteristics is submitted with the support material of this public comment). The only difference is that the start of the curve (i.e. tripping action) is delayed from 6 mA to 20 mA (moved to the right).

Accordingly, SPGFCIs provide the exact protection level of Class A GFCIs for ground faults of 20 mA and higher. In other words, SPGFCIs are guaranteed to interrupt the source of power fast enough, and therefore protecting the person in the water from drowning, because the current going through the swimmer’s heart is interrupted.

During the first draft meeting, CMP 2 recognized SPGFCIs as a potential improvement to safety and created FR-339 and FR-347 to include a new definition for SPGFCIs and an installation requirement in Article 210.8(B) respectively.

Related Item

Public Input No. 2208-NFPA 70-2014 [Section No. 680.58]

First Revision No. 339-NFPA 70-2015 [New Definition after Definition: Ground-Fault Circuit Inter...]

First Revision No. 347-NFPA 70-2015 [Section No. 210.8(B)]

Submitter Information Verification

Submitter Full Name: NEHAD EL-SHERIF

Organization: Littelfuse Startco

Street Address:

City:

State:

Zip:

Submittal Date: Sun Sep 20 16:07:52 EDT 2015

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Public Comment No. 1313-NFPA 70-2015 [ Section No. 680.62(A)(1) ]

(1) Listed Units.

If so marked, a listed, labeled and identified self-contained unit or listed and labeled packaged equipment assembly thatincludes integral ground-fault circuit-interrupter protection for all electrical parts within the unit or assembly (pumps, air blowers,heaters, lights, controls, sanitizer generators, wiring, and so forth) shall be permitted without additional GFCI protection.

Additional Proposed Changes

File Name Description Approved

Essential_Guide_to_Product_Testing_and_Certification_NOV_2014.pdf

ETL Essential Guide to Product Testing & Certification 2014/2015 North American Edition. Please review document page numbers 5, 8 and 10 to see that ETL has requirements similar to UL, that products that do not bear their certification (listed) mark are not considered by ETL as being listed.

Statement of Problem and Substantiation for Public Comment

UL recognizes the Correlating Committee created a global First Correlating Revision (FCR) which directed that in all locations where the term “and labeled” was added after “listed” during the First Revision Stage, the words “and labeled” after “listed” be deleted, returning to previous text. UL understands that the Correlating Committee appointed a task group to address several issues involving the use of the terms “listed” and “labeled,” most importantly, to clarify and establish a distinction between the terms “listed” and “labeled” which are often used interchangeably. UL supports the need for this task group. However, UL does not expect the work of this task group to affect the 2017 NEC regarding the issue of “listed and labeled.” As such, UL is submitting comments to request that the words “and labeled” be added in various locations throughout the Code for the reasons expressed in the public inputs UL submitted on this issue. UL believes that these revisions will address an ongoing problem that should not wait until the 2020 NEC for resolution.

Subsequent to the Public Input Code Panel Meetings, UL has discussed this issue with its Electrical Council whose membership includes many AHJs. The proposed revisions to the NEC received general support from the membership. This issue was also discussed at a NEMA – NRTLs Forum held on August 14, 2015 at NEMA Headquarters. UL reiterated its support for the proposed revisions. The NRTLs represented at the meeting voiced no objection to the proposals.

The rationale for the revision was simple, to provide information to the AHJ regarding the suitability of equipment they encounter. The mark on the product is the manufacturer’s attestation that the product is in compliance with the appropriate standard. NRTL’s conduct factory surveillance of products, surveillance is one method to validate the manufacturer’s attestation. Should a product be found not to be compliant the manufacturer has the option of removing the mark and shipping the product without the mark, or holding the shipment and bringing the product into compliance. In either case the “Listing” is not impacted, as the “listing” is created at the completion of the “original” certification of the product and indicates the authorization but not the mandate to label products. So the only true way an AHJ can determine whether the product he is seeing is compliant with the applicable standard is via a label on the product. Taking it one step further, listings change with time. It is quite possible that a “listing” has been withdrawn; however labeled product may still be available for sale. Should equipment that is labeled, but not listed, be deemed acceptable? Based on the NEC definitions, it is possible to have a product that meets the Article 100 definition of listed but the testing organization made the manufacture remove the label for a non-compliance issue.

As for the concerns of products that are too small to be labeled, the definition of labeled is not limited to an actual label, it also includes symbols, or other identifying marks. The Safety Standards which define the listing requirements do not address labeling of products as defined by Article 100. As a general rule, NRTL’s do not consider a product as being listed unless it is also labeled. The UL White Book states that “Only those products bearing the appropriate UL Mark and the company's name, trade name, trademark or other authorized identification should be considered as being covered by UL's Certification, Listing, Classification and Follow-Up Service. The UL Mark provides evidence of listing or labeling, which may be required by installation codes or standards.” Again the requirements for the UL Mark are not a Safety Standard requirement, they are a UL requirement and the only way to show that a product is UL Certified (Listed); other NRTL’s have similar requirements.

Related Item

Public Input No. 936-NFPA 70-2014 [Section No. 680.62(A)(1)]

First Revision No. 4803-NFPA 70-2015 [Global Input]

Submitter Information Verification

Submitter Full Name: JEFFREY FECTEAU

Organization: UNDERWRITERS LABORATORIES LLC

Affilliation: UL

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Street Address:

City:

State:

Zip:

Submittal Date: Thu Sep 24 19:10:18 EDT 2015

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Public Comment No. 787-NFPA 70-2015 [ Section No. 680.62(A)(2) ]

(2) Other Units.

A therapeutic tub or hydrotherapeutic tank rated 3 phase or rated over 250 volts or with a heater load of more than 50 amperesshall not require the supply to be protected by a special-purpose ground-fault circuit interrupter.

Additional Proposed Changes

File Name Description Approved

GFCI_Classes.pdf Tripping Characteristics of GFCI classes A, C, and D

Statement of Problem and Substantiation for Public Comment

The committee resolution of PI-2209 was: "GFCIs rated in excess of 250 volts do not always provide protection against "let-go" (devices trip at up to 20 mA) which is important when dealing with bodies of water due to the risk of drowning".

The submitter agrees with the committee that GFCI classes C, D and E (collectively referred to as SPGFCIs) don't provide let-go protection because of the 20 mA trip level which is above the let-go threshold. Yet, SPGFCIs provide protection against ventricular fibrillation, the condition that typically leads to cardiac arrest resulting in drowning. SPGFCIs use the same tripping characteristics of Class A GFCIs (A graph of the tripping characteristics is submitted with the support material of this public comment). The only difference is that the start of the curve (i.e. tripping action) is delayed from 6 mA to 20 mA (moved to the right).

Accordingly, SPGFCIs provide the exact protection level of Class A GFCIs for ground faults of 20 mA and higher. In other words, SPGFCIs are guaranteed to interrupt the source of power fast enough, and therefore protecting the person in the water from drowning, because the current going through the swimmer’s heart is interrupted.

During the first draft meeting, CMP 2 recognized SPGFCIs as a potential improvement to safety and created FR-339 and FR-347 to include a new definition for SPGFCIs and an installation requirement in Article 210.8(B) respectively.

Related Item

Public Input No. 2209-NFPA 70-2014 [Section No. 680.62(A)(2)]

First Revision No. 339-NFPA 70-2015 [New Definition after Definition: Ground-Fault Circuit Inter...]

First Revision No. 347-NFPA 70-2015 [Section No. 210.8(B)]

Submitter Information Verification

Submitter Full Name: NEHAD EL-SHERIF

Organization: Littelfuse Startco

Street Address:

City:

State:

Zip:

Submittal Date: Sun Sep 20 16:16:40 EDT 2015

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Public Comment No. 1660-NFPA 70-2015 [ Section No. 680.74 ]

680.74 Bonding.

(A) General.

The following parts shall be bonded together:

(1) All metal fittings within or attached to the tub structure that are in contact with the circulating water

(2) Metal parts of electrical equipment associated with the tub water circulating system, including pump and blower motors

(3) Metal-sheathed cables and raceways and metal piping that are within 1.5 m (5 ft) of the inside walls of the tub and notseparated from the tub by a permanent barrier

(4) All exposed metal surfaces that are within 1.5 m (5 ft) of the inside walls of the tub and not separated from the tub areaby a permanent barrier

(5) Electrical devices and controls that are not associated with the hydromassage tubs and that are located within 1.5 m (5ft) from such units

Exception No. 1: Small conductive surfaces not likely to become energized, such as air and water jets, supply valveassemblies, and drain fittings not connected to metallic piping, and towel bars, mirror frames, and similar nonelectricalequipment not connected to metal framing shall not be required to be bonded.

Exception No. 2: Double-insulated motors and blowers shall not be bonded.

(B)

All metal parts required to be bonded by this section shall be bonded together using a solid copper bonding jumper, insulated,covered, or bare, not smaller than 8 AWG. The bonding jumper(s) shall be required for equipotential bonding in the area of thehydromassage bathtub and shall not be required to be extended or attached to any remote panelboard, service equipment, orany electrode. In all installations a bonding jumper long enough to terminate on a replacement non-double-insulated pump orblower motor shall be provided and shall be terminated to the equipment grounding conductor of the branch circuit of the motorwhen a double-insulated circulating pump or blower motor is used.

Statement of Problem and Substantiation for Public Comment

This rule gets more and more absurd every three years. There has never been a documented incident (that I can find) to warrant its existence, and now we are going to have a rule that will have inspectors mandating that towel bars within 5' of a bathtub be bonded!

Related Item

First Revision No. 4870-NFPA 70-2015 [Section No. 680.74]

Submitter Information Verification

Submitter Full Name: RYAN JACKSON

Organization: RYAN JACKSON

Street Address:

City:

State:

Zip:

Submittal Date: Fri Sep 25 15:59:17 EDT 2015

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