,"
National Fire Protection Association
NFPJ(
Electrical Engineering, 1 Batteryarch Park , Quincy, MA 02169- 7471
Phone: 617- 770- 3000. Fax: 617- 984- 7070. wwnfpa. org
National Electrical CodeCI Committee
ME M 0 RA' N DUM
TO:
Members of Code- Making Panel
FROM:
Jean O' Connor
SUBJECT:
Letter Ballot on Panel Actions on Comments for the 2008 National
Electrical Code
DATE:
, 2006
In accordance with the NFPA Regulations Governing Committee Projects , the Panel
Actions on Comments for the 2008 National Electrical Code are hereby submitted to
you for letter ballot.
Enclosed is a copy of all the actions for your Panel' s Comments with the Panel Actions
and Panel Statements (where required) on the Comments as agreed upon by a majority
of the voting members in attendance at the recent meeting of your Panel in Redondo
Beach , CA.
Also enclosed is a ballot form. For nonvoting members, the ballot is enclosed for
information only. The
letter ballot contains a summary of the Comment number , log
number , NEC section , and Panel Action. Please keep in mind that your vote on this
letter ballot is based on concurrence or otherwise with the Panel Action taken by
the Panel at the meeting, and not on the Comment itself.
If you are voting affirmatively on all Panel Actions , you may return only the first
page of the ballot. Therefore , if you concur with all of the Panel Actions , you may
indicate concurrence by checking the first box at the top of the ballot. You would then
sign and date the first page and return it to NFPA.
If you do not concur with all of the Panel Actions and wish to vote " affirmative
with comment" negative " or indicate " abstaining " on certain Comments , please
check the second box at the top of the ballot and place an " X" in the appropriate
column(s) adjacent to the Panel Action. Please return only those ballot pages which
, "
you have marked with an " X" along with the corresponding reasons for such " affirmative
comment" negative " and " abstaining " votes.
Affirmative comments and reasons for negatives/abstentions must accompany the
ballot pages. We ask that your reasons be listed on a separate sheet of paper , not on
the ballot sheets. When listing affrmative comments and negative/abstention reasons
please identify the person voting (your name), the Comment number , and the action
you are taking (affirmative comment , negative or abstaining) along with your comment
or reason.
A completed copy of the ballot , including any reasons and attachments, must be
received by the NFPA Electrical Department as soon as possible but no later than
5:00 p. m. EST on January 9, 2007. You may fax your ballot to Jean O' Connor at
(617) 984- 7070. Either mail it or fax it , please do not do both.
Following receipt of ballots by NFPA , all reasons for negative and abstaining votes will
be mailed to all members of your Panel by January 18 , 2007.
NOTE: Please remember that the return of ballots and attendance at Committee
Meetings is required in accordance with the Regulations Governing Committee
Projects.
COMMENT BALLOT DUE BY:
Tuesday, January 9 ,
2007
NFPA 70 NEC. PI5
National Electrical Code
Staff Liaison: Mark W. Earley
7070
Return Completed Ballot To: Jean O' Connor
Fax to (617) 984-
One Batterymarch Par
Committee Action Key:
A = Accept
Reject
Quincy,
::: in Pm
:::: E
;J
With respect to the Committee Actions on the Comments which accompanied
the ballot , please record me as voting: (check one):
Affrmative On All Items. I agree with all committee meeting actions without comment.
to NFP A.
Please return this Ballot Page
Except
Affrmative With Exception(s): I agree with all
for the Affirmative with comment , Negative and lor Abstention checked below.
*Reasons must accompany these votes.
committee meeting actions
Signed:
Date:
Name:
Type or Print black ink
Vote
Comment
on Prop#
Log No
Section
15-
542
100. Hospital Grade Receptacles
15-
15-
400
517.
15-
15-
431
517.2
15-
15-
1634
517.2
15-
15-
1635
517.
15-
15-
1636
517.
15-
15-
1637
517.2
15-
15-
1638
517.
15-
15-
1639
517.2
15-
15- J 0
1640
517.2
15-
Comment No
Committee
Action
APR
APR
Affrm with
Comment*
Negative
Abstain
Comment
on Prop#
Vote
Committee
Action
Comment No
Log No.
Section
15-
1641
517.2
15-
15-
1642
517.
15-
15-
1643
517.
15-
15-
1644
517.2
15-
15-
1645
517.2
15-
15-
1646
517.2
15-
APP
15-
2329
517.2
2113
APR
15- 17a
CC1500
517.2 517.20 , 517. 20(A) and 517.
15-
1257
517.13(B) Exception No.
15-
15-
783
517.13(B) Exception No.
15-
15-
1422
517.17(B)
15-
15-
2233
517.17(B)
15-
15-
2352
517.17(B)
15-
15-
2051
517. 17(B)(2)
15-
15-
831
517.18(B)
15-
264
517.18(B) and 517. 18(B)(2)
15-
2163
517. 18(B)
(B) (2)
15-
15-
2103
517. 18(B) and 517.19 (B)(2)
15-
15-
795
517 .18(B) and 517 .19(B)(2)
15-
15-
1031
517.18(B) and 517.19(B)(2)
15-
1476
517. 18(B) and 517.19(B)(2)
15-
15-
1695
517.18(B) and 517. 19(B)(2)
15-
15-
2148
517. 18(B)
and 517. 19(B)(2)
15-
15-
700
517.
15-
15-
1352
517.26
15-
15-
2269
517.
15-
15-
1647
517. 30(B)(4)
15-
15-
1386
517. 30(C)(3)
15-
J 5-
1648
517.30(C)(3)
15-
15-
2045
517. 30(C)(3)
15-
15-
147
517. 30(C)(3)(4) and 517.30(C)(3)(2) 15-
15-
359
517. 30(C)(3)(4)
and 517. 19
APR
APR
APP
15-
and 517. 30(C)(3)(2) 15-
APR
Affrm with
Comment*
Negative
Abstain
Comment
on Prop#
Comment No
Log No.
Section
15-
1649
517.32(H) (New)
15-
) 5-
1650
517. 32(H) (New)
15-
15-
1651
517.32(1) (New)
15-
15-
148
517.34(B)(5)
15-
) 5-
1652
517. 34(B)(5)
15-
) 5-
1653
517.35(C)
15-
15-
1654
517040(A)
15-
1655
) 5-
Vote
Committee
Action
15-
APR
517040(B)
15-
APA
712
517042
15-
15-
1827
517.
15-
) 5-
1656
517044(C)
15-
15-
338
517. 61(B)(5)
15-
15-
1657
517. 63(A)
15-
15-
453
517. 71(A)
15-
15-
2050
517. 80 Exception No. 3 (New)
15- 103
15-
430
517.160(A)(1)
15- 105
15-
2270
517. 160(A)(5)
15- 106
15-
1658
517.160(B)
15- 107
15-
805
51804(A)
15- 110
15-
1679
51804(A)
15- 110
15-
1387
51804(C)
15-
318
518.
15- 116
15-
150
519 (New)
15- 121
15-
291
519 (New)
15- 121
15-
684
519 (New)
15- 121
15-
151
520.
15- 133
15-
1259
520.
15-
) 5-
152
525.2
15- 145
15-
1359
525. 2. Operator , Portable Structures
15- 144a
15-
1360
525.
15- 150
APR
15-
1363
525.
15- 150
APR
15-
1361
525. 21(A)
15- 152
Exception
Exception (New)
APR
APA
15- 112
APR
APR
Affrm with
Comment*
Negative
Abstain
Comment
Comment No
Log No.
Section
15-
1362
525.
15- 74a
CC1501
530.
) 5-
1260
530. 64(B)
on Prop#
15- 156
15-
Vote
Committee
Action
Affrm with
Comment*
Negative
Abstain
'----'
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2007
15Log #542 NEC- P15
(100. Hospital Grade Receptacles)
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NFP A 70
Final Action: Reject
Submitter: Deborah J. Mann , Debbie Mann Consulting, Inc.
Comment on Proposal No: 15-
Recommendation: Define " Hospital Grade Receptacles " and place the term in the Index. It is currently used in regard
to patient bed areas , but is not defined or referenced in the index.
Substantiation: I asked ten people , including two inspectors, what a hospital grade receptacle actually is and nobody
knew correctly. Several people thought it was an insulated ground receptacle , including an electrical inspector.
Panel Meeting Action: Reject
Panel Statement: The term " Hospital Grade " used in reference to a receptacle refers to a standard of device
manufacture and performance. Article 100 Definitions describe general conditions or installation considerations rather
than device specifications.
In addition , the submitter did not provide a specific recommendation for action on Proposal 15- 34.
Printed on 12/13/2006
ort
on
June
Comments -
2007
Log #400 NEC- P15
15-
NFP A 70
Final Action: Reject
(517.
Submitter: Daniel Leaf ,
Seneca, SC
Comment on Proposal No: 15Recommendation: Accept the proposal.
Substantiation: Ungrounded circuits may be supplied from an isolating (isolation) transformer with a grounded
secondary such as a 2-wire 240 volt circuit from a 120/240 volt secondary which is grounded. The proposal should be
judged on merit , not conformance to other standards.
Panel Meeting Action: Reject
Panel Statement: Proposal 15- 3 suggests additional language that would expand the definition beyond its current
scope. The existing definition includes language: " and its ungrounded circuit conductors , which clearly indicates the
secondary circuit conductors must be ungrounded.
Printed on 12/13/2006
Report on Comments -
June 2007
Final Action: Reject
Log #431 NEC- P15
15-
NFP A 70
(517.
Submitter: Dan Leaf , Seneca, SC
Comment on Proposal No: 15Recommendation: Accept proposal.
Substantiation: See proposal
substantiation. Proposal should be judged on merit not whether it conforms to other
standards.
Panel Meeting Action: Reject
Panel Statement: The terms " isolation
isolating " and " isolated" are used to state the purpose, performance and
condition of the specific equipment andlor system. The terms are clearly understood in their context as used.
It is the intent of the panel to use extracted material whenever possible in order to maintain consistency between
documents. In this case, the source document is NFPA 99.
Printed on
12/13/2006
~~~
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15-4 Log #1634 NEC- P15
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Final Action: Accept in Principle
(517.
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept Proposal 15Substantiation: It is not within the scope of the National Electrical Code project to define the various types of health
care facilities that exist within the U. S.
This is the responsibility of the
TIC
on Safety to Life.
Panel Meeting Action: Accept in Principle
Revise Ambulatory Health Care Facility to read as follows:
Ambulatory Health Care Occupancy. A building or portion thereof used to provide services or treatment simultaneously
to four or more patients that provides , on an outpatient basis , one or more of the following:
(1) treatment for patients that renders the patients incapable of taking action for self- preservation under emergency
conditions without the assistance of others;
(2) anesthesia that renders the patients incapable of taking action for self- preservation under emergency conditions
without the assistance of others;
(3) emergency or urgent care for patients who, due to the nature of their injury or illness , are incapable of taking action
for self- preservation under emergency conditions without the assistance of others. (101 :3. 168. 1 J
Panel Statement: The panel understands that the intent of the submitter is to correlate with the definition from LSC
101. The panel agrees with the submitter.
The panel requests the Standards Council to review and clarify the ownership of definitions common to NFPA 99, LSC
101 and NFPA 70.
Printed on
12/13/2006
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Final Action: Reject
Log #1635 NEC- P15
15-
(517.
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15-
Recommendation: Accept Proposal
15-
Substantiation: NFPA Standards Council has written that it wants one definition of a term used in NFPA documents. it
is not within the scope of the National Electrical Code project to define the parameters of an anesthetizing location.
Panel Meeting Action: Reject
Panel Statement: The panel action on Proposal 15- 1 retains the existing definition for " Anesthetizing Location
contained in NFPA 70. This action is consistent with provisions of the NFPA Glossary of Terms , Section 2. 2(b) for
Secondary Definitions.
NFPA 70 , as an international document, should continue to recognize the use of flammable anesthesia.
Printed on 12/13/2006
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Report on Comments - June
-"""-' -."""-"''''' '-'-'"''
NFP A 70
2007
Final Action: Accept in Principle
Log #1636 NEC- P15
15-
,,-.
(517.
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15-
Recommendation: Accept Proposal
15-
on Essential Electrical Systems (NFPA 76A)
when it established requirements for essential electrical systems in health care facilities.
Substantiation: Term " critical
branch" originated in the 1960s by the
TIC
Panel Meeting Action: Accept in Principle
Revise Critical Branch to read as follows:
Critical Branch. A subsystem of the emergency system consisting of feeders and branch circuits supplying energy to
task illumination , special power circuits, and selected receptacles serving areas and functions related to patient care and
that are connected to alternate power sources by one or more transfer switches during interruption of normal power
source. (99:3. 26)
Panel Statement: The panel understands that the intent of the submitter is to correlate with the definition from NFPA
99. The panel agrees with the submitter.
The panel requests the Standards Council to review and clarify the ownership of definitions common to NFPA 99 , LSC
101 and NFPA 70. The NFPA Glossary of Terms currently indicates that NFPA 70 is the responsible document for this
definition.
Printed on
12/13/2006
J.Q.
!?.o_
15-
Log #1637 NEC- P15
Final
Action: Reject
(517.
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept Proposal 15NFPA Standards Council policy on one definition for a term. Not within the scope of the
National Electrical Code project to define parameters of a critical (patient) care area.
Substantiation: Conform to
Panel Meeting Action: Reject
Panel Statement: There are sufficient differences between the definitions and , as such , an extract reference is not
appropriate.
The panel action on Proposal 15- 1 retains the existing definition for " Critical Care Area " contained in NFPA 70. This
action is consistent with the provisions of NFPA Glossary of Terms , Section 2. 2(b) for Secondary Definitions.
Printed on 12/13/2006
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Report on Comments -
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Log #1638 NEC- P15
15-
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Final Action: Accept
(517.
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept Proposal 15- 1 O.
TIC
on Safe Use of Electricity in Patient Care Areas of Health Care Facilities created and defined term
electrical life support equipment" in 1980s . Question NFPA Glossary of Terms assignment of responsibility for this
Substantiation:
term.
Panel Meeting Action: Accept
Panel Statement: The panel requests the Standards Council to review and clarify the ownership of definitions
common to NFPA 99 , LSC 101 and NFPA 70.
Printed on
12/13/2006
Report on Comments 15-
Log #1639 NEC- P15
June 2007
NFP A 70
Final Action: Reject
(517.
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Correlate use of term " Emergency System " in Article 700 with same term as used in Article 517.
TIC
on Essential Electrical Systems in the
Substantiation: Term " emergency system " was created and defined by the
1960s. Both Article 517 and Article 700 use the term. Article 517 uses the term in the same way that NFPA 99 uses the
term. Article 700 has a different meaning for the term , correlation is required.
Panel Meeting Action: Reject
Panel Statement: The term " Emergency System " as applied in Article 517 is not in conflict with use of the term in
Article 700. There is correlation between the appropriate parts of each article by means of reference(s) in each to the
other.
Printed on
12/13/2006
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2007
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Final Action: Reject
Log #1640 NEC- P15
15-
(517.
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept Proposal 15- 12.
Substantiation: 1. Term " equipment system " was created
and defined by the
TIC
on Essential Electrical Systems in
the 1960s. Both Article 517 and Article 700 use the term, and use the term in the same way. Question NFPA Glossary of
Terms assignment of responsibility for this term.
2. Article 700 has a different meaning for the term. Correlation is required.
Panel Meeting Action: Reject
Panel Statement: There are suffcient differences between the definitions and , as such , an extract reference is not
appropriate.
Use of the defined term " Equipment System " is unique to Article 517 in NFPA 70. It is not used in Article 700 as a
defined system or portion of a system. Correlation is not needed.
The panel requests the Standards Council to review and clarify the ownership of definitions common to NFPA 99, LSC
101 and NFPA 70.
Printed on
12/13/2006
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NFP A 70
Final Action: Accept in Principle
(517.
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept Proposal 15- 13.
TIC
on Essential Electrical
Substantiation: Term " essential electrical system " was originated in the 1960s by the
Systems (NFPA 76A) when it established requirements for essential electrical systems in health care facilities. Question
NFPA Glossary of Terms assignment of responsibility for this term.
Panel Meeting Action: Accept in Principle
Revise Essential Electrical System to read as follows:
Essential Electrical System. A system comprised of alternate sources of power and all connected distribution systems
and ancilary equipment , designed to ensure continuity of electrical power to designated areas and functions of a health
care facility during disruption of normal power sources, and also to minimize disruption within the internal wiring system.
(993. 3.44)
Panel Statement: The panel understands that the intent of the submitter is to correlate with the definition from NFPA
99. The panel agrees with the submitter.
The panel requests the Standards Council to review and clarify the ownership of definitions common to NFPA 99, LSC
101 and NFPA 70. The NFPA Glossary of Terms currently indicates that NFPA 70 is the responsible document for this
definition.
Printed on
12/13/2006
~~~
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Log #1642 NEC- P15
15-
Final Action: Reject
(517.
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept Proposal 15- 14.
on Safe Use of Inhalation Anesthetics created and defined the term " flammable anesthetizing
location " in 1930s. Question NFPA Glossary of Terms assignment of responsibility for this term.
Substantiation:
TIC
Panel Meeting Action: Reject
Panel Statement: This definition is not in the body of NFPA 99. The submitter references material contained in an
informative annex and since the annex is not mandatory text, an extract is not appropriate.
Printed on
12/13/2006
June 2007
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Final Action: Accept in Principle
Log #1643 NEC- P15
(517.
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept Proposal
Substantiation:
TIC
15- 15.
on Safe Use of Electricity in Patient Care Areas of Health Care Facilities created and defined term
general care area " in 1970s. Term was revised for 2005 edition of NFPA 99.
Not within the scope of the National Electrical Code project to determine parameters of a general (patient) care area.
Panel Meeting Action: Accept in Principle
Revise General Care Areas to read as follows:
General Care Areas. Patient bedrooms, examining rooms, treatment rooms , clinics , and similar areas in which it is
intended that the patient will come in contact with ordinary appliances such as a nurse-call system , electric beds
examining lamps , telephones, and entertainment devices, (99:3. 138.
Panel Statement: The panel understands that the intent of the submitter is to correlate with the definition from NFPA
99. The panel agrees with the submitter.
The panel requests the Standards Council to review and clarify the ownership of definitions common to NFPA 99, LSC
101 and NFPA 70,
Printed on
12/13/2006
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Report on Comments - June
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Log #1644 NEC- P15
15-
2007
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Final Action: Reject
(517.
Submitter: Marvin J. Fischer, Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept Proposal 15- 17.
Substantiation: 1. Standards Council has stated that it wants one definition for a term used in NFPA documents. There
should not be differences in definitions between same term used by two NFPA documents (per NFPA Standards
Council).
2. It is not within the scope of the National Electrical Code project to define parameters of a health care facility.
Panel Meeting Action: Reject
Panel Statement: There are sufficient differences between the definitions and, as such, an extract reference is not
appropriate.
The panel action on Proposal 15- 1 retains the existing definition for " Critical Care Area " contained in NFPA 70. This
action is consistent with the provisions of NFPA Glossary of Terms, Section 2. 2(b) for Secondary Definitions,
Printed on 12/13/2006
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Log #1645 NEC- P15
15-
Final Action: Accept
(517.
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept Proposal 15- 19.
on Essential Electrical Systems (NFPA
76A) when it established requirements for essential electrical systems in health care facilities.
Substantiation: Term " life
safety branch" originated in the 1960s by the
TIC
Panel Meeting Action: Accept
Panel Statement: The panel requests the Standards Council to review and clarify the ownership of definitions
common to NFPA 99 , LSC 101 and NFPA 70.
Printed on
12/13/2006
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Log #1646 NEC- P15
15-
,,--,, ,-,,-,,
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Final Action: Accept in Principle in Part
(517.
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept in Part Proposal 15- 22. Revise definition of " patient care area " as recommended by Mr.
Erickson in his negative vote.
stated that it wants one definition for a term used in NFPA documents. Not
within the scope of the National Electrical Code project to define parameters of a patient care area.
Substantiation: Standards Council has
Panel Meeting Action: Accept in Principle in Part
Revise Patient Care Area to read as follows:
Patient Care Area. Any portion of a health care facility wherein patients are intended to be examined or treated. Areas
of a health care facility in which patient care is adm inistered are classified as general care areas or critical care areas
t:illlt:1 uf vv ivl, ,"ay Ut: vla",,, ifit:J a'" a vvd lu"a liull . The governing body of the facility designates these areas in
accordance with the type of patient care anticipated and with the following definitions of the area classification.
FPN: Business offices, corridors, lounges , day rooms , dining rooms, or similar areas typically are not classified as
patient care areas.
Revise Wet Locations to read as follows:
Wet Locations. Those spaces within patient care areas where a procedure is performed and that are normally subject
to wet conditions while patients are present. These include standing fluids on the floor or drenching of the work area
either of which condition is intimate to the patient or staff. Routine housekeeping procedures and incidental spilage of
liquids do not define a wet location.
Panel Statement: The panel accepts the submitter s recommendation pertaining to the definition of patient care area.
The panel rejects the submitter s recommendation to remove reference to governing bodies.
The panel rejects the changes to the definition to wet locations and provides alternate text that better defines the
location. This text addresses the submitter s desire to better correlate with NFPA 99.
Printed on 12/13/2006
2...
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15-
Log #2329 NEC- P15
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Final Action: Accept in Principle
(517.
Submitter: Marcus Sampson , Lysistrata Electric
Comment on Proposal No: 2113
Recommendation: The panel should review the merits of this proposal.
The term " Wet Locations " should should be change to " Wet Procedure Areas " to clearly differentiate the condition.
installers familiar with the long-time NEC classifications of patient care areas in
health care facilities (may) understand the distinction between " Location , Wet" as defined in Article 100 and and " Wet
Locations " as used in Article 517 , adopting this proposal eliminates an unnecessarily subtle nuance.
Substantiation: While inspectors and
Code requirements should not be esoteric,
Users should find clear , readily understood terms that are used consistently throughout the document. This minor
change would result in a better understanding of the meaning of the term. For consistency and clarity, " Patient Care
Areas " should be divided into three other types of AREAS - not two types of " areas " and one type of " location.
517, 18 General Care Areas
517, 19 Critical Care Areas
517. 20 Wet Procedure Areas
While the panel' s response indicates that the change would not comply with the NEC Style Manual for extracted text,
Article 517 is not made up entirely of extractions from NFPA 99, The submitter did indicate that this proposal was also
sent to that committee.
Panel Meeting Action: Accept in Principle
Change the title of " Wet Locations " to " Wet Procedure Locations
Panel Statement: The panel agrees with the submitter to change the title of the definition, The panel replaces the
word " areas " with " locations " because it is a location within an area.
Printed on 12/13/2006
Report on Comments - June
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17a Log #CC1500 NEC- P15
(517.
517.
, 517. 20(A) and
Submitter: Code- Making
Final Action: Accept
517. 60)
Panel 15
Comment on Proposal No:
Recommendation: Change the terms " wet location " to " wet procedure location " and " wet locations " to " wet procedure
locations " in Section 517. , 517. , 517.20(A) and 517. 60.
Substantiation: This is required as the title was changed. See panel action and statement in Comment 15. 17.
Panel Meeting Action: Accept
Printed on 12/13/2006
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Log #1257 NECFinal Action: Accept
15(517. 13(B) Exception No. , 517. 18. (B), 517. 19(B)(2), and 517. 19(D))
Submitter: Neil F. LaBrake , Jr., Syracuse, NY
Comment on Proposal No: 15Recommendation: Continue to accept the following portions of the TCC Grounding and Bonding Task Group proposal
15- 2 as modified and revised by the actions of CMP- 15 for which the TCC Grounding and Bonding Task Group agrees
with the CMP- 15 editorial revisions to the Sections 517. 13(B) Exception No. , 517. 18(B), 517. 19(B)(2), and 517. 19(D).
Substantiation: TCC Grounding and Bonding Task Group understands the revisions to the proposal have been made
for clarity and continue to be consistent with the Grounding and Bonding Task Group s original initiatives.
This Comment was developed by a Task Group assigned by the NEC Technical Correlating Committee to address
actions that were other than " accept" taken by Code- Making Panels on proposals from the TCC to resolve 2005 NEC
Proposal 5- 1 and Comment 5- 1. Members of the Task Group on Grounding and Bonding for this Comment included: C.
Douglas White; Michael Johnston; Jeffrey Boksiner; Daleep Mohla; Phil Simmons; Christopher Hutchings; James
Carroll; Alan Rebeck; Richard Loyd; Paul Dobrowsky; and Neil F. LaBrake, Jr.
Panel Meeting Action: Accept
Printed on 12/13/2006
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19 Log #783 NEC- P15
(517. 13(6)
Final Action: Accept in Principle in Part
Exception No.
Submitter: David G. Humphrey, Midlothian, VA
Comment on Proposal No: 15Recommendation: Revise text to read as follows:
Luminaires (light fixtures) more than 2. 3 m (7 1/2 ft) above the floor and switches located outside of the patient vicinity
shall 'lul!Jt: ,t:yu i, t: J lu !Jt: I UUI, Jt;J !Jy CIII ill::u ICllt:J t:yu il-llIt:1I I uUIIJill vUIIJudul. be permitted to be arounded bv
the metal raceway svstem. or metallc cable armor. or sheath assemblv complvina with 517. 13(A).
Substantiation: The existing text of 517. 13(6) Exception NO. 2 permits the omission of an insulated equipment
grounding conductor for luminaires more than 7 1/2 ft above the floor and switches located outside of the patient vicinity.
A literal reading of 517. 13(B)( would require an insulated " copper" equipment grounding conductor with Exception NO.
merely permitting this copper conductor to be uninsulated. 517. 13(A) requires a metal raceway system , or metallic cable
armor , or sheath assembly qualifying as an equipment ground return path in accordance with 250. 118 as a wiring
method for fixed electric equipment in patient care areas. The proposed text revision would both reinforce the
requirements of 517 . 13(A) and clarify that an insulated equipment grounding conductor , copper or otherwise for
luminaires located more than 7 1/2 ft above the floor or switches located outside of the patient vicinity is optional.
Panel Meeting Action: Accept in Principle in Part
Revise Exception No. 2 to read as follows:
(71/2
fl.) above the floor and switches located
Exception NO. 2: Luminaires (light fixtures) more than
J
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outside of the patient vicinity shall
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517.
13fAJ.
Panel Statement: The panel accepts the removal of the wording referring to an insulated equipment grounding
conductor.
The panel rejects reference to specific wiring system methods and instead references to an equipment grounding
return path complying with 517. 13(A).
The revised wording provides clarity while meeting the submitter s intent.
Printed on 12/13/2006
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15Log #1422 NEC- P15
(517. 17(8))
Submitter: Vince Baclawski ,
Final Action: Hold
National Electrical Manufacturers Association (NEMA)
Comment on Proposal No: 15-
Recommendation: NEMA recommends that Proposal 15- 29 be Accept as written.
Substantiation: In order to provide the reliability in the essential electrical system that the CMP wants, multiple levels
of GFP (ground fault protection) must be provided for the following reasons:
1. Ground faults are the most common form of faults in a operating electrical system. Multiple levels of GFP on both
the normal and alternate source sides of the system are needed to isolate such faults as close to their point of
occurrence as possible, thus providing a level of selective coordination and yielding the minimum disruption to the
essential electrical system. It would seem that minimizing such disruption is even more important when a ground fault
has occurred.
2. Closing a transfer switch or a generator into a ground fault presents the real possibility of damaging the transfer
switch, or generator , or both , thus potentially decreasing system reliability.
As Mr. Wiseman pointed out in his negative comment , the panel statement is incorrect. The proposed deletion does
not establish a conflict. The conflict is in the existing language since the additional level of ground-fault protection is
prohibited in portions of the essential electrical system that could be fed from the alternate power source , while Article
700 actually permits ground- fault protection at the source. There is no substantiation that deviating from the requirement
in Article 700 for ground- fault protection enhances the reliability of the system.
The panel statement suggests that most generators are small and , therefore, the risk of burn- down is not an issue.
That statement may be accurate , but has no relevance to this discussion since the requirement for ground-fault
protection is triggered by the size ofthe service disconnect in 230. 95 or the feeder in 215. 10. Therefore , the smaller
generators which do not include a feeder disconnect rated 1 OOOA or greater are not required to have ground- fault
protection.
There has been no evidence presented or substantiation presented in the panel statement that supports rejecting this
proposal.
Panel Meeting Action: Hold
Panel Statement: The panel
holds both Proposal 15- 29 and Comment 15- 20.
The panel contents that this issue requires further review , study and discussion to understand the complexity in terms
of coordination and protection (including energy produced by standby generator). The panel cannot adequately address
these issues at this time and therefore recommends to place the proposal and comment on hold and create a task group
to research further.
Printed on 12/13/2006
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15Log #2233 NEC- P15
(517. 17(B))
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Final Action: Hold
Submitter: Eugene E. Morgan , Clakamas County, Building Codes Oivison
Comment on Proposal No: 15Recommendation: Panel 15 should reconsider the merits of this proposal. The submitter s intent could be met and
clarified with a revision of existing and new text , rather than a deletion as originally proposed:
517. 15(B) Feeders. Revise last sentence of main paragraph as follows and add new text:
ill ldlld d fullvvv required on the followina svstems
The additional levels of ground-fault protection shall not be
(1) On the load side of an essential electrical system transfer switch . where the alternate power source is 750 kVA or
less
(2) Between the on-site generating unit(s) described in 517. 35(8) and the essential electrical system transfer
switch(es) . where the alternate power source is 750 kVA or les
(3) On electrical systems that are not solidly grounded wye systems with greater than 150 volts to ground but not
exceeding 600 volts phase-to- phase
Essential electrical svstems where the alternate power source is rated over 750 kVA. and the svstem is desianed
under aualified enaineerina supervision. shall be permitted to have around-fault protection. Where the alternate power
source is 750 kVA or less. around-fault detection shall be provided in accordance with 700. 7(o). and shall include
detection at the second level of feeders as specified in this section.
Substantiation: I respectfully disagree with the panel' s action and statement on three points:
(1) The original submittal, and the comment submitted herewith are not in conflict with 700. 7(0), which provides for
ground-fault detection. Article 700 provides for ground-fault detection , but it does not prohibit the use of ground-fault
protection
(2) Section 700. 26 states that ground- fault protection shall not be required, but it is not prohibited.
(3) There is a trend toward larger regional hospitals with generators that exceed 1 megawatt of output. The original
proposal gave the example of an 8 megawatt installation. In the jurisdiction that I serve , there is a new hospital
generator system installation rated at 4. 5 megawatts. The argument that a majority of hospitals have smaller alternate
power sources does not answer the need for safety in the newer , larger installations. In the 4. 5 megawatt system
installed locally, the available fault current at the first transfer switch is 51 800 amps. The potential for a system
meltdown in the event of a fault actually exceeds the fault current and potential damage from the utility transformers.
There should be some valid point at which ground- fault protection is needed. It is true that small alternate power
sources should have ground-fault detection, and not ground- fault protection. The distinction between systems over 750
kVA (typically 1 megawatt or larger), and those 750 kVA or under, distinguishes between systems where available fault
current would be significant. With the revision outlined above, the provision for an engineer to utilize ground-fault
protection is available, but it is clearly at the engineer s discretion and not mandatory. This is also an opportunity to point
out that Section 700. 7(0) provides for ground-fault detection , which should always be installed when ground- fault
protection is not an option.
Panel Meeting Action: Hold
holds both Proposal 15- 29 and Comment 15- 21.
The panel contents that this issue requires further review, study and discussion to understand the complexity in terms
of coordination and protection (including energy produced by standby generator). The panel cannot adequately address
these issues at this time and therefore recommends to place the proposal and comment on hold and create a task group
to research further.
Panel Statement: The panel
Printed on 12/13/2006
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Final Action: Hold
Log #2352 NEC- P15
15(517. 17(B))
Submitter: Alan Manche, Square D Company
Comment on Proposal No: 15-
Recommendation: The Panel should
reconsider Proposal 15- 29
and Accept it.
Substantiation: In order to provide the reliability in the essential electrical system that the CMP wants , multiple levels
of GFP (ground fault protection) must be provided, once the first level is provided, for the following reasons:
1. Ground faults are the most common form of faults in an operating electrical system. Multiple levels of GFP on both
the normal and alternate source sides of the system are needed to isolate such faults as close to their point of
occurrence as possible, thus providing a level of selective coordination and yielding the minimum disruption to the
essential electrical system. It would seem that minimizing such disruption is even more important when a ground fault
has occurred.
2. Closing a transfer switch or a generator into a ground fault presents the real possibility of damaging the transfer
switch, or generator , or both , thus potentially decreasing system reliability.
As Mr. Wiseman pointed out in his negative comment , the panel statement is incorrect. The proposed deletion does
not establish a conflict. The conflict is in the existing language since the additional level of ground-fault protection is
prohibited in portions of the essential electrical system that could be fed from the alternate power source, while NEC 700
actually permits ground- fault protection at the source. There is no substantiation indicating a need to amend NEC
Article 700 for NEC 517 installations nor is there substantiation that disallowing a properly installed ground- fault
protection system will enhance the reliability of the system.
The panel statement suggests that most generators are small and therefore the risk of burn- down is not an issue. That
statement may be accurate but has no relevance to this discussion since the requirement for ground-fault protection is
triggered by the size of the service disconnect in 230. 95 or the feeder in 215. 10. Therefore , the smaller generators
which do not include a feeder disconnect rated 1000A or greater are not required to have ground- fault protection , and
this revision would have no impact on them.
There has been no evidence presented or substantiation presented in the panel statement that supports rejecting this
proposal.
Panel Meeting Action: Hold
Panel Statement: The panel holds both Proposal 15- 29 and Comment 15- 21.
The panel contents that this issue requires further review , study and discussion to understand the complexity in terms
of coordination and protection (including energy produced by standby generator). The panel cannot adequately address
these issues at this time and therefore recommends to place the proposal and comment on hold and create a task group
to research further.
Printed on 12/13/2006
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23
15Log #2051 NEC- P15
(517. 17(B)(2))
---
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Submitter: Hugh O. Nash , Jr. , Nash Lipsey Burch
Comment on Proposal No: 15Recommendation: Continue to reject 15- 29 which applies to 517. 17 Ground- Fault Protection. Add the following
sentence to 517. 17(B)(2):
For solidlv qrounded wve-emerqencv svstems of more than 150 volts to qround and circuit-protective devices rated
1000 or more. refer to 700. 7(0
(Note: The intent is to refer to the language in the 2005 edition. If this wording is deleted, the entire text of
517. 17(B)(2) shall be added here.
Substantiation: Regardless of the size of the alternate source , ground- fault interruption on the alternate source
overcurrent device can cause interruption of the alternate source feed to health care facility essential system loads.
Automatic disconnecting should not be provided under any circumstances. 517. 17(B) states The additional levels of
ground-fault protection shall not be installed as follows: (1) On the load side of the essential electrical system transfer
switch, (2) Between the onsite generating unit as described in 517. 35(B) and the essential electrical system transfer
switch(es). For many years , 517. 17 warned against placing GFP interruption between the alternate source and the
transfer switch(es). This warning has now become a prohibition. There are documented instances where GFP
interrupted the normal source and the alternate source , leaving critical care areas without normal or alternate power.
Panel Meeting Action: Hold
Panel Statement: The panel holds both Proposal 15-29 and Comment 15- 21.
The panel contents that this issue requires further review , study and discussion to understand the complexity in terms
of coordination and protection (including energy produced by standby generator). The panel cannot adequately address
these issues at this time and therefore recommends to place the proposal and comment on hold and create a task group
to research further.
Printed on 12/13/2006
Report OD
Comments -
JUDe 2007
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24
15Log #831 NEC- P15
(517. 18(B))
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NFP A 70
Final Action: Reject
Submitter: Daniel Eagle , Sacred Heart Medical Center
Comment on Proposal No: 5Recommendation: The NEC job is to make sure electrical equipment is installed safely. Its job is not to give us a false
since of security. If the indicator light burns out on the outlet, and the hospital staff panic and unplug a working outlet.
The patient is being put into an unknown risk. I arn sure , the hospital staff is trained to verify the systems that they are
plugging in are working correctly. The manufacture of the outlets will say the lights will burn for hundreds or hours
without a problem. I have seen the cleaning process short out indicator lights on equipment before.
Substantiation: The NEC job is to make sure electrical equipment is installed safely. Its job is not to give us a false
since of security. If the indicator light burns out on the outlet , and the hospital staff panic and unplug a working outlet.
The patient is being put into an unknown risk. I am sure the hospital staff is trained to verify the systems that they are
plugging in , are working correctly. The manufacture of the outlets will say the lights will burn for hundreds or hours
without a problem. I have seen the cleaning process short out indicator lights on equipment before.
Panel Meeting Action: Reject
Panel Statement: No recommended text is provided with the comment as required by 4-
Governing Committee Projects.
Printed on 12/13/2006
3(c) of the Regulations
~~~ ~~~~
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25
Log #264 NEC- P15
15(517. 18(8) and 517. 18(8)(2))
------ -_._- -_._"---Final Action: Accept
Submitter: Stanley J. Folz , Morse Electric , Inc.
Comment on Proposal No: 15-
Recommendation: Delete the text as amended by the CMP.
Substantiation: I am in agreement with all of the negative comments from the CMP- 15 members.
Panel Meeting Action: Accept
Printed on 12/13/2006
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26
Log #2163 NEC- P15
15(517. 18(B) and 517. 19 (B) (2))
Final Action: Accept
Submitter: Susan B. McLaughlin , SBM Consulting, Ltd. / Rep. NFPA Health Care Section Executive Board
Comment on Proposal No: 15Recommendation: Reject this Proposal.
Substantiation: In reviewing this new requirement, the NFPA Health Care Section Executive Board is of the opinion
that the need for indicator lights on receptacles should not become a minimum standard. Panel 15 appears to have
reacted to a proposal based on one reported incident. Is the fix a mechanical one or is there a better way to resolve the
issue with better staff training, panel schedules , etc. ? All newly installed critical care outlets are required to have the
circuit number labeled on the front so that staff can quickly determine if the outlets are on the same circuit. If a hospital
wants to install devices with illuminated faces or indicator lights, they are permitted to do so as this exceeds the Code. A
code is a set of standards that shall have substantial justification behind the need and should not be changed as a result
of a few isolated instances where the staff may not have been properly trained on the environment in which they are
working.
This is not original material; its reference/source is as follows:
Douglas Erickson American Society for Healthcare Engineering.
Panel Meeting Action: Accept
Printed on 12/13/2006
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27 Log #2103 NEC- P15
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Final Action: Accept
(517, 18(B) and 517, 19 (B)(2))
Submitter: Stephen J. Grose , The Washington State Society for Healthcare Engineering
Comment on Proposal No: 15Recommendation: Reject this proposal.
Substantiation: In reviewing this new requirement, it is the opinion of the Washington State Society for Healthcare
Engineering that the need for indicator lights on receptacles should not become a minimum standard, One reported
incident should not justify a new code without careful consideration and a significant review of incident locations facilities
emergency preparation and response, Most hospitals have tied critical equipment into UPS sources that will initiate
alarms when activated allowing for a period of time to react without jeopardizing patient safety, Best practices would
stipulate panel labeling at the outlet and multiple breakers to feed one room to offset just this issue, Code revision based
on this incident will set a precedent that would make code revisions reactive and not proactive raising the already high
costs to build and operate our facilities. The primary responsibility of healthcare engineering is to ensure the
environmental health and safety of the patients , facilities , and staff we serve. If the code recommendation could not be
off set by effective emergency plans, staff training, and following existing code standards, I would support this code, A
proactive review of the incident should show one of these tree elements were missing.
Panel Meeting Action: Accept
Printed on 12/13/2006
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Final Action: Accept
15Log #795 NEC- P15
(517. 18(8) and 517. 19(8)(2))
Submitter: Douglas S. Erickson ,
ZQ..
American Society for Healthcare Engineering (ASHE)
Comment on Proposal No: 15Recommendation: Reject this proposal.
Substantiation: In reviewing this new requirement , the American Society for Healthcare Engineering is of the opinion
that the need for indicator lights on receptacles should not become a minimum standard. Panel 15 appears to have
reacted to a proposal based on one reported incident. Is the fix a mechanical one or is there a better way to resolve the
issue with better staff training, panel schedules , etc? All newly installed critical care outlets are required to have the
circuit number labeled on the front so that staff can quickly determine if the outlets are on the same circuit. If a hospital
wants to install devices with illuminated faces or indicator lights, they are permitted to do so as this exceeds the Code. A
code is a set of standards that shall have substantial justification behind the need and should not be changed as a result
of a few isolated instances where the staff may not have been properly trained on the environment in which they are
working.
Panel Meeting Action: Accept
Printed on 12/13/2006
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29
Log #1031 NEC- P15
15(517. 18(B) and 517. 19(B)(2))
NFP A 70
Final Action: Reject
Submitter: Philip Kercher , Sacred Heart Medical Center
Comment on Proposal No: 5Recommendation: I am opposed to this proposed new text , which requires a receptacle to have an indication light. As
a healthcare Facility Manager for 24 years , my experience indicates no significant added value from this proposal.
Substantiation: Strongly opposed to the proposal.
Panel Meeting Action: Reject
Panel Statement: No recommended text is provided with the proposal as required by 4- 3(c) of the Regulations
Governing Committee Projects.
Printed on 12/13/2006
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NFP A 70
Final Action: Accept
(517. 18(B) and 517. 19(B)(2))
Submitter: Chad E. Beebe , Washington State Department of Health / Rep. NFPA HCS Codes & Standards Review
Committee
Comment on Proposal No: 15Recommendation: Reject this proposal.
Substantiation: In reviewing this new requirement, the codes and standards review committee is of the opinion that the
need for indicator lights on receptacles should not become a minimum standard. Panel 15 appears to have reacted to a
proposal based on one reported incident. Is the fix a mechanical one or is there a better way to resolve the issue with
better staff training, panel schedules , etc. All newly installed critical care outlets are required to have the circuit number
labeled on the front so that staff can quickly determine if the outlets are on the same circuit. If a hospital wants to install
devices with illuminated faces or indicator lights , they are permitted to do so as this exceeds the code. A code is a set
of standards that shall have substantial justification behind the need and should not be changed as a result of a few
isolated instances where the staff may not have been properly trained on the environment in which they are working.
Panel Meeting Action: Accept
Printed on 12/13/2006
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15Log #1695 NEC- P15
(517. 18(6) and 517. 19(6)(2))
Final Action: Accept
Submitter: Michael Kelly, Sacred Heart Medical Center
Comment on Proposal No: 15-
Recommendation: Reject proposed language in its entirety.
Substantiation: There
is insufficient data to support this change. There is only
Panel Meeting Action: Accept
Printed on 12/13/2006
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32
Log #2148 NEC- P15
15(517. 18(8) and 517, 19(8)(2))
Final Action: Accept
Submitter: Matthew Campbell , Washington State Department of Health: Construction Review Services
Comment on Proposal No: 15-
Recommendation: Reject this Proposal.
Substantiation: In reviewing this new requirement , it is our opinion that the need for indicator lights on receptacles
should not become a minimum standard. Panel 15 appears to have reacted to a proposal based on one reported
incident. Is the fix a mechanical one or is there a better way to resolve the issue with better staff training, panel
schedules , etc. All newly installed critical care outlets are required to have the circuit number labeled on the front so that
staff can quickly determine if the outlets are on the same circuit. If a hospital wants to install devices with iluminated
faces or indicator lights , they are permitted to do so as this exceeds the Code, A code is a set of standards that shall
have substantial justification behind the need and should not be changed as a result of a few isolated instances where
the staff may not have been properly trained on the environment in which they are working.
Panel Meeting Action: Accept
Printed on 12/13/2006
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33 Log #700 NEC- P15
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Final Action: Reject
(517. 26)
Submitter: Michael J. Johnston , Piano , TX
Comment on Proposal No: 15Recommendation: This proposal should be rejected. Restore the language in this section to the text in the 2005
NEC as follows:
517. 26 Application of Other Articles. The essential electrical system shall meet the requirements of Article 700 , except
as amended by Article 517.
Substantiation: Nothing is gained by this revision as proposed. In fact, much is lost as a result of this action. The
consequences of accepting this change are far reaching as indicated in the statement to the negative by Mr. Morgan
representing Electrical Code Enforcement. Another significant consequence of this change is that selective coordination
of overcurrent protective devices used in emergency systems will be lost for the critical care branch , which, in a hospital
is an extremely important part of the emergency system , for obvious reasons. The proposal reduces current
requirements without adequate substantiation. The submitter correctly made the point about Article 700 being
applicable to the life safety branch , but removing the requirement for selective coordination required by 700.27 goes
against the fundamental concepts of NFPA 99 and its objectives to maintain continuity of power for patient care
electrical systems , especially the critical care branch. I strongly suggest reconsidering the original action on this
proposal and its intended or unintended consequences.
Panel Meeting Action: Reject
Panel Statement: The panel upholds its position on Proposal 15- 43.
The life safety branch of the health care facilty is comparable to the emergency system of commercial (and other)
building types, since both provide power for life safety systems. The critical branch of the health care facility serves
patient care related circuits and equipment , and thus it is not appropriate to apply Article 700.
Emergency power supply systems need to be governed by one entity. The panel requests the Standards Council and
the TCC to review scopes and charges of NFPA 99 , NFPA 110 , Articles 517 and 700 as it pertains to emergency power
systems.
Printed on 12/13/2006
~!?-?!.
~~~~.._:-_
-_..
--_....._.
_-_.._..... ..._._-_..__..__...._,._....._
...
~~~
z....__...._--_.__.._
15-
34 Log #1352 NEC- P15
Final Action: Reject
(517. 26)
Submitter: Tim Janof , Sparling
Comment on Proposal No: 15Recommendation: Revise text to read as follows:
life safetv branch of the emerqencv svstem t:;:;:t:111;0 dt:d, ;"'o l ;:y;:It:111 shall
517. 26 Application of Other Articles. The
The critical branch shall not be required to
meet the requirements of Article 700 , except as amended by Article 517.
meet the requirements of Article 700. The equipment branch shall not be required to meet the requirements of Article
701.
Substantiation: I support
the panel' s action on Article 517.26 and propose to further clarify that the Equipment System
is not required to comply with Article 701. I support the notion that the Life Safety branch is analogous to the Article 700
branch , and I believe the same principle should be extended to the Equipment Branch , in that it is analogous to Article
701 branch. While I do not support the requirement for selective coordination in Articles 700 and 701 , if they are to
remain in the Code , limiting the requirement to the life safety branch in healthcare facilities is sensible.
When selective coordination is considered , most people first envision a patient on an operating room table. This is
perhaps the most emotionally charged scenario depicted by those who support the requirement for selective
coordination. When one examines this situation , however , one finds that the requirement for selective coordination is
difficult to justify. UL , Article 517 , and NFPA 99 already have provisions that result in safe health care facilities:
. UL requires that critical medical equipment have integral batteries. Heart- lung machines , for example , typically have
hour batteries , which is plenty of time for hospital personnel to find and turn on a breaker that may have tripped
inadvertently.
. The NEC requires redundancy in electrical systems in healthcare facilities. For example , facilities with critical care
functions are required to have a back-up emergency power system , such as a diesel generator. The NEC also requires
that power be provided from two separate power branches to each patient care area, including critical care areas and
operating rooms. Power must be fed from both a normal and emergency power branch , or from two separate transfer
switches. If there were an outage in one branch of power , the other branch would still be available. The only scenarios in
which both branches of power would not be available involve some sort of catastrophic event, such as an emergency
generator failure , fire , or earthquake , which the requirement for selective coordination would not prevent. The NEC'
power system redundancy requirements have an excellent track record of supporting the healthcare environment.
. NFPA 99 requires that operating rooms and other anesthetizing locations have lighting with integral 90-minute
battery back-up.
If there were evidence that a lack of selective coordination has resulted in injury or loss of life within healthcare
facilities , I would fully support the requirement for selective coordination. But given the lack of any such case history, I
can see no justification for requiring that owners pay the additional cost and sacrifice the additional space for a system
that will not result in any patient benefit. Healthcare capital development budgets are limited and money not used for
marginal electrical reliability benefits can be directly used for additional beds or rnedical equipment. I am now aware of
any data that demonstrates that lives have been lost or that patients were injured due to a lack of selective coordination
in healthcare facilities.
Panel Meeting Action: Reject
Panel Statement: The panel does not agree with submitter s substantiation relative to UL requirements that critical
medical equipment have integral batteries.
The equipment branch should not be excluded from the requirements of Article 701.
Printed on 12/13/2006
~~~
_._----_._ -_.
-=_
_..._--_._-_._.._..
.___
?..
7____.._..._..._--_.
15-
35 Log #2269 NEC- P15
Final Action: Accept
(517. 26)
Submitter: James Wiseman , Schneider Electric / Square 0
Comment on Proposal No: 15-
Recommendation: The panel should reconsider the action taken on this proposal , Accept in Principle , and relocate
517. 26 to become 517. , reading as follows:
517. 3 Other Articles. The life safety branch of the emergency system shall meet the requirements of Article 700
except as amended by Article 517. The critical branch shall not be required to meet the requirements of Article 700.
the attempt at clarifying the portions of the healthcare electrical system to which the
requirements of Article 700 apply. But the attempt did not go quite far enough. For many years , there has been
confusion because Article 517 uses the " emergency " term differently than it is used in Article 700. Several attempts
have been made , starting with the 1999 NEC edition, to minimize the confusion and still comply with rules for
referencing other NEC Articles. Each has retained some portion of the problem.
The Recommendation and Substantiation in Proposal 15- 43 are entirely consistent with the stance taken by the CMP
(CMP- 17, at that time) during the 2002 cycle. The ROC for that cycle , in Log #206 (Comment 17- , on Proposal 17covering the definition of Emergency System in 517- 3) includes the following sentence as a part ofthe Panel Statement:
The panel' s intent is that Article 700 apply only to the ' Life safety branch.''' Unfortunately, they took no further action
within Article 517 to clear up the confusion for items such as sizing of generators or the number of transfer switches.
The problem with leaving 517. 26 as it is proposed in Proposal 15- 43 is that, due to 517.26 being under Part III of
Article 517 , it leaves the " Equipment System " branch in question. Since Part III covers Essential Electrical Systems , it
addresses not only the " Emergency System " but also the " Equipment System. " If the section is to stay as 517.26 , the
last sentence should be changed to read " Neither the critical branch nor the equipment system shall be required to meet
Substantiation: We support
the requirements of Article 700." Moving the section to become 517. 3 not only eliminates this confusion, but also
matches Article 517 with other Articles in using the . 3 number for " Other Articles
Panel Meeting Action: Accept
Printed on 12/13/2006
?!_
~~~~
=-!~~~~~
36
Log #1647 NEC- P15
15(517. 30(6)(4))
?._----,-".,.....,..."'--_..,.,_......__. ....._._",..,-_..._-_.__..._
.._._-
~~~
Final Action: Reject
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept in Part Proposal 15- 47. Correlate 517. 30(B)(4) with 517.41(B).
Substantiation: Section 517.41
(B) identifies text as extracted from NFPA 99, 4.
Panel Meeting Action: Reject
Panel Statement: No recommended text is provided with the comment as required by 4-
Governing Committee Projects.
Printed on 12/13/2006
3(c) of the Regulations
-,,,--,,",,,,,,,,-,,"-,,,,,,",,,,--,,
-,,-,,,,,----,_.._..,
Report on Comments -
37
15Log #1386 NEC- P15
(517 . 30(C)(3))
-"-
-,-,.
,,,,,'-"'''',"''''''-'''-''''''''''
='-'''",''-''''--'--'"-''-''----''-----
June 2007
NFP A 70
Final Action: Accept in Principle
Submitter: William Wagner , Certification Solutions
Comment on Proposal No: 15Recommendation: This Proposal should continue to be Accepted as follows:
IlulllldCl lli", PVC conduit. Nonmetallic raceways
(1) Nonflexible metal raceways, Type MI cable, or Schedule 80 rigid
shall not be used for branch circuits that supply patient care areas.
IIUllilldCllli", PVC conduit , flexible
(2) Where encased in not less than 50 mm (2 in. ) of concrete, Schedule 40 rigid
nonmetallic or jacketed metallic raceways, or jacketed metallic cable assemblies listed for installation in concrete.
Nonmetallic raceways shall not be used for branch circuits that supply patient care areas.
Substantiation: The only type of rigid nonmetallc conduit that is currently listed in Schedule 40 and Schedule 80
dimensions is rigid PVC conduit. As each of the rigid nonmetallc conduit Articles require the conduit to be listed , this
revision would not inadvertently eliminate any other conduit type. Additionally, with the renaming of Article 352 as a
result of panel action on Proposal 8- , this revision would help to clarify where the applicable requirements are located.
Therefore, the references in 517. 30(C)(3) should be revised as noted above.
Panel Meeting Action: Accept in Principle
Change 517. 30(C)(3) to read as follows:
1 iy iJ IIUIII II dCl II i", PVC conduit. Nonmetallic raceways
(1) Nonflexible metal raceways , Type MI cable, or Schedule 80
shall not be used for branch circuits that supply patient care areas.
I iy iJ IIUIIiI dCllli", PVC conduit, flexible
(2) Where encased in not less than 50 mm (2 in. ) of concrete , Schedule 40
nonmetallic or jacketed metallic raceways, or jacketed metallic cable assemblies listed for installation in concrete.
Nonmetallic raceways shall not be used for branch circuits that supply patient care areas.
Panel Statement: This correlates with action on Comment 15-41.
Printed on 12/13/2006
!,.
=-,~~~
-_...._._-,
38
Log #1648 NEC- P15
15(517. 30(C)(3))
.,.....
-_. .._.._,---_._--.._._..._-, ---_.....,.._..__.--_..,_...,......_._
~~..
Final Action: Reject
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept Proposal 15- 53.
Substantiation: NFPA 99 , section 4.4. 2.4.4 is only stating performance criteria for the emergency system wiring (i.
some mechanical protection in raceway), but referencing NFPA 70 for the installation requirements as to what type of
wiring protection can be used.
Panel Meeting Action: Reject
Panel Statement: Mechanical protection of the emergency system is an installation standard of NFPA 70 ,
not a
performance criteria. NFPA 99 contains performance criteria , and correctly contains the reference to NFPA 70 , rather
than the reverse as the comment suggests.
Printed on 12/13/2006
,,,,,.,,,.",,,-- -..,,,.,,,- ,,,,
-",.,""-"-,'"
--,
Report on Comments - June
"'""'"'
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2007
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39
Final Action: Hold
Log #2045 NEC- P15
15(517 . 30(C)(3))
Submitter: Phil Simmons, National Armored Cable Manufacturers
Comment on Proposal No: 15Recommendation: Revise 517. 30(C)(3) as follows:
(3) Mechanical Protection of the Emergency System. The wiring of the emergency system in hospitals shall be
mechanically protected. Where installed as branch circuits in patient care areas, the installation shall comply with the
requirements of 517. 13(A) and 517. 13(B). The following wiring methods shall be permitted:
(1) Nonflexible metal raceways , Tpe MI cable , or Schedule 80 rigid PVC conduit. Nonmetallic raceways shall not be
used for branch circuits that supply patient care areas.
(2) Where encased in not less than 50 mm (2 in. ) of concrete, Schedule 40 rigid PVC conduit , flexible nonmetallic or
jacketed metallc raceways , or jacketed metallic cable assemblies listed for installation in concrete. Nonmetallic
raceways shall not be used for branch circuits that supply patient care areas.
(3) Listed flexible metal raceways and listed metal-sheathed cable2.
CI. 'NIIt:1
t: u;:t: J
CI;:;:t:1 I I lJ I
it:;: ill ClI'Y u f II It: fulluvv il'Y.
ill blt: J fl' dCllJ, i"'Cl lt:J 1I,t:Ji"'Cl IIIt:Cl JvvCllb
lJ. IIi li;: tt:J uffi"'t: fUll l i;: 1 Iii IY;:
"'. V,, I,t:1 t:
fd It:J i'llu t:l\i;:li'IY wCl lb UI "'t: iliIIY;:, Ilul v lllt:1 w i;:t: CI"'''t:;:;: ilJlt: ClII J Ilvl ;:u lJjt:d lv fl lly;: i"'Cl I JCllllClye
J. VI/I It:' t: 11t:"'t:;:;:ClI Y fUI flt:l\ ilJlt: "'U, II It: diul'
lu t:LjU ifllllt:111.
(4) Flexible power cords of appliances or other utilization equipment connected to the emergency system.
(5) Secondary circuits of Class 2 or Class 3 communication or signaling systems with or without raceways.
FPN: See 517. 13 for additional grounding requirements in patient care areas.
Substantiation: Listed Type AC and Type MC cables are more than adequate to provide mechanical protection of the
emergency systems in hospitals and should be accepted for that purpose. In fact, Code Panel 15 made that appropriate
conclusion in its Panel Statement on Proposal 15- 42 for the 2005 NEC. CMP 15 stated in part Types AC and MC
cables that are listed provide adequate physical and mechanical protection for the emergency system of health care
facilities. " We agree with the Panel' s conclusion. However , we feel the Panel inappropriately, and without technical
justification for such action , limited the use of Type MC and AC cables as shown in the 2005 NEC.
Adequate documentation on the rigorous testing Type AC and MC cables must pass to be listed was submitted with
, no doubt led to the
Proposal 15- 42. This documentation, plus the satisfactory field experience of CMP- 15 members
conclusion reached by the Panel in processing the 2005 NEC.
Type AC and MC cables are required to satisfactorily pass brutal treatment during the listing process. The testing
includes crushing, bending and elongating. The tests the cables must satisfactorily pass are no doubt harsher than
would be expected during installation of the cables.
The UL Fact- Finding Report on Nail Penetration of Types AC and MC Cable Installed Parallel to Framing Members
(provided) show the cable is more resistant to damage from nails and screws than is Electrical Metallic Tubing. Type
MC and AC cables need to be accepted for mechanical protection of the emergency system in hospitals to be treated
equally.
It should be noted that items (3)(1) and (3)(2) in the list of accepted uses of listed flexible metal raceways and listed
metal-sheathed cables seem to be incorrect as the wiring methods used in the construction of listed equipment by the
manufacturer is controlled by the UL Safety Standard that regulates the construction of such equipment. See also 90.
for an explanation of field examination or evaluation of listed equipment.
The information in this comment should not be considered a new concept as the issue has been before the Panel
during the processing of both the 2005 and 2008 NECs.
Note: Supporting material is available for review at NFPA Headquarters.
Panel Meeting Action: Hold
Panel Statement: The panel intends to hold the comment only.
The proposed revision(s) dealing with AC cable and unrestricted use constitutes new material that has not had the
benefit of public review during this cycle and cannot be considered at this stage of the Code-making cycle. Refer to
4.4. 6.2.2 of the Regulations Governing Committee Projects.
Printed on 12/13/2006
~~~
~~~~~
-=-.
40
15Log #147 NEC- P15
(517. 30(C)(3)(4) and 517. 30(C)(3)(2))
_....
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Final Action: Accept
Submitter: Technical Correlating Committee on National Electrical CodeC1
Comment on Proposal No: 15Recommendation: It was the action of the Technical Correlating Committee that this Proposal be reconsidered and
correlated with the action on Proposal 8- 53. This action will be considered by the Panel as a Public Comment.
Substantiation: This is a direction from the National Electrical Code Technical Correlating Committee in accordance
with 3.4. 2 and 3.4. 3 of the Regulations Governing Committee Projects.
Panel Meeting Action: Accept
The panel accepts the direction of the TCC to reconsider and corrolate with the action on Proposal
53.
See panel action and statement on Comment 15-41.
Panel Statement:
Printed on 12/13/2006
,,----,,' , -, """,,,"
,
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--
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Report on Comments - June
15-
41 Log #359 NEC- P15
... .._, "".'"..,,,
-"".--",,.- . ..-
NFP A 70
2007
Final Action: Accept
(517. 30(C)(3)(4) and 517. 30(C)(3)(2))
Submitter: Code- Making Panel 8
Comment on Proposal No: 15Recommendation: CMP- 8 recommends that CMP- 15 accept this proposal in principle with the revised text:
I iy iJ IIUllill dCllli", PVC conduit. Nonmetallc raceways
(1) Nonflexible metal raceways , Type MI cable , or Schedule 80
shall not be used for branch circuits that supply patient care areas.
iJ IIUIIlIitCllli", PVC conduit, flexible
(2) Where encased in not less than 50 mm (2 in. ) of concrete, Schedule 40
,
or
jacketed
metallic
cable
assemblies
listed for installation in concrete.
nonmetallic or jacketed metallc raceways
Nonmetallc raceways shall not be used for branch circuits that supply patient care areas.
Substantiation: CMP- 8 recommends that CMP- 15 Accept in Principle Proposal 15- 57 with the proposed revised
wording. The word " rigid" was also deleted in addition to " nonmetallic " to correlate with the action taken by CMP- 8 on
Proposal 8- 53.
This comment has been balloted through CMP- 8 with the following ballot results:
12 Eligible to Vote
11 Affirmative
1 Negative
Mr. J. Dabe voted negatively stating: " CMP- 8 recommends that CMP- 15 reconsider this proposal and Accept in
Principle. CMP- 15 should add RTRC to the wiring methods in both (1) and (2).
Mr. R. Loyd voted affirmatively stating: " Proposal 15- 57 was to Accept. I agree with Mr. Burns ' recommendation to
revise the panel action.
Panel Meeting Action: Accept
Printed on 12/13/2006
Report on Comments - June
2007
42
15Log #1649 NEC- P15
(517. 32(H) (New) )
P A 70
Final
Action: Reject
Submitter: Marvin J. Fischer ,
Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept Proposal 15- 62.
Substantiation: Responsibility for what systems or equipment is to be connected to the Life Safety Branch is Health
Care Facilities project. If wording is not clear, proposal should be submitted to NFPA 99 to clarify.
Panel Meeting Action: Reject
Panel Statement: As stated in the action on Proposal 15- , it is unclear what additional functions of the fire alarm
combination system is intended in NFPA 99:4.4. 2.2. 2.2(8). Connection of fire alarm to the life safety branch is already
covered under NFPA 70 , 517. 32(C)(1).
Printed on 12/13/2006
"-",,",,,,,,,,,,,,, ,._,,-,,,,,",-,,,,,,,,,,"-,,,--, =-..,,,,-,,,..,,.,,,''''---'
Report on Comments 15-
-""
-",""",,,,""'-",,",,,,,,,,",,',,,,_
'''"""",---"
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June 2007
N',
43 Log #1650 NEC- P15
-,_,,w"-
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-",''-'' -""..,,.__..-
NFP A 70
Final Action: Reject
(517. 32(H) (New))
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15-
Recommendation: Reject Proposal
15- 63.
is outside the scope of the National Electrical Code project. Responsibility of what equipment
is to be connected to the Life Safety Branch is the T/C on Electrical Systems of the Health Care Facility Project.
Proposal should be submitted to NFPA 99.
Substantiation: Proposal
Panel Meeting Action: Reject
Panel Statement: The option of connecting control systems and accessories for life safety system operation is a
design function that should be permitted , whether it is contained in NFPA 99 text or not.
Printed on 12/13/2006
-"-'-' -"--"'-'-'''-
Report on Comments - June
15-
2007
44 Log #1651 NEC- P15
NFP A 70
Final Action: Reject
(517. 32(1) (New) )
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15-
Recommendation: Reject Proposal 15- 64.
is outside the scope of the National Electrical Code project. Responsibility of what equipment
is to be connected to the Life Safety Branch is the T/C on Electrical Systems of the Health Care Facility Project.
Substantiation: Proposal
Panel Meeting Action: Reject
Panel Statement: Additional safety to persons working in the generator system vicinity and panels is achieved with
this change. Electrical safety for personnel performing maintenance, tests or examining equipment is within the scope
of NFPA 70.
Printed on 12/13/2006
~~.
~~~~~
=--
~~~
?_.._.
....
...
..... ..._._..__..........,._...__........_... ....
--_..._-_..._
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45
15Log #148 NEC- P15
(517. 34(B)(5))
Final Action: Accept
Submitter: Technical Correlating Committee on National Electrical CodeCI
Comment on Proposal No: 15-
Recommendation: It was the action of the Technical Correlating Committee that further consideration be given
to the comments expressed in the voting. This action will be considered by the panel as a public comment
Substantiation: This is a direction from the National Electrical Code Technical Correlating Committee in accordance
with 3.4. 2 and 3.4. 3 of the Regulations Governing Committee Projects.
Panel Meeting Action: Accept
Retain original Code text of 517. 34(B)(5).
Panel Statement: The panel accepts the direction of the TCC to reconsider the comments expressed in the voting.
Previous action on Proposal 15- 70 has been reconsidered , and is hereby withdrawn. 2005 NFPA 70 language is
restored: 517. 34(B)(5) Automatically operated doors.
Printed on 12/13/2006
,,"""""" -'--""
-""
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'''''',".., '--'
,-,,-
--,,,, '," .""". ''' '''''''''''
",,""""" ,- '" .""
2007
w",-
46
15Log #1652 NEC- P15
(517. 34(B)(5))
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-,_..".
",,,--,-,,- ,,,. ,.-"",..,-...--
NFP A 70
Final Action: Reject
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept Proposal 15- 70.
action. Automatically operated doors , other than those in means of egress , can
be connected to Equipment System per 4.4. 2.2. 5 in NFPA 99 , or 517. 34(B)(9) in Article 517.
Substantiation: Concur with Panel 15
Panel Meeting Action: Reject
Panel Statement: See panel action and statement on Comment 15-45.
Automatic doors used for egress are required to be connected to the life safety branch per 517. 32(0). There are many
applications for non-egress automatic doors within a hospital , Article 517. 34(0)(5) provide for the continued operation of
these doors in an off-normal situation while not further burdening the life safety branch.
Printed on 12/13/2006
~~~~~
._--------_._,._. --""------ ,__
=-"
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Z_.__.."
15-
47 Log #1653 NEC- P15
Final Action: Reject
(517. 35(C))
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept in Principle Proposal 15- 71.
should read:
1.2(5)).
(NFPA 99 A.4A.
Substantiation: Correct reference
Change reference to
AAA.
1.2(5)
so that extract reference
from NFPA 99 is text as listed in Annex A of NFPA 99.
Panel Meeting Action: Reject
Panel Statement: This text is not in the body of NFPA 99. The submitter references material contained in an
informative annex and since the annex is not mandatory text , an extract is not appropriate.
Printed on 12/13/2006
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~~~
.,.
_...,..,-
.._-
---,.,-_..__................."_..__.._ ..._.._._._--_.
J..-
2.,._-"..,-,.
15-
48 Log #1654 NEC- P15
Final Action: Accept in Principle
(517.40(A) Exception)
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept Proposal 15- 72 using text included in negative vote of Mr. Erickson.
Substantiation: Agree with
negative vote of O. Erickson.
Panel Meeting Action: Accept in Principle
Change the extract reference (NFPA 99: 17.
1.4. , 18. 3.4. 2)" to (NFPA 99: 17. 3.4.2. 2(3),
Panel Statement: The panel corrects the extract reference.
Printed on 12/13/2006
~~~
18. 3.4.
2(3))"
"",,,,-,,,,,
--,,-,,-, --,,
.._,-.,-,..._..,,
,,,",",
Report on Comments 15-
.,,-=-- --..,.-",,,,,- ,,-
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,,--,,,,, ,--,,-",,,,,,
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-''"--''
'-''''--.'''-
June 2007
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49 Log #1655 NEC- P15
''-'''Y',,"
----'
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NFP A 70
Final Action: Accept in Part
(517.40(8))
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept Proposal 15- 73.
Substantiation: 1. I agree with negative vote of Mr. Erickson.
2. Responsibility for specifying which type of essential electrical system is required for a health care facility is the
responsibility of the Health Care Facility project. Referenced change was made in NFPA 99- 2005 edition to
requirements for nursing homes.
Panel Meeting Action: Accept in Part
Change 517.40(B) to read as follows:
Nursinq homes and limited care facilities that admit patients who need to be
(B) Inpatient hospital care facilities.
sustained bv electrical life support equipment. the essential electrical svstem from the source to the portion of the facilitv
where such patients are treated shall comply with requirements of Part III, 517. 30 through 517. 35.
Panel Statement: The panel accepts the submitter s text.
The panel rejects the extract reference " (NFPA 99: 17. 3.4. 2.4 , 18. 3.4. 2.4)" because the entire paragraph is not
extracted material.
Printed on 12/13/2006
Report on Comments 15-
June 2007
50 Log #712 NEC- P15
NFP A 70
Final Action: Reject
(517.42)
Submitter: Burton R. Klein , Burton Klein Associates
Comment on Proposal No: 15Recommendation: Accept Proposal 15- 77.
Substantiation: NFPA 99 , section 4. 2.2 , already uses the term " Emergency System " for the items listed in 517.42.
2.2. This issue is not related to that of subdividing the
The list in 517.42 is the same as that in NFPA 99 , section 4.
emergency system " in nursing homes into 2 branches.
Panel Meeting Action: Reject
Panel Statement: Section 517.40(B) requires that Nursing Homes which incorporate " Inpatient
Hospital Care
Facilities " must have an Essential Electrical System meeting the requirements of 517. 30 through 517. 35. Within those
requirements , Section 517. 31 addresses requirements of the emergency system , including automatic connection to
alternate power after interruption of the normal power source. The submitter s concerns are addressed in existing code
language.
Printed on 12/13/2006
!.?
".."., ._--_.... .-.-._..-.... ",-
C?~
15-
:c.",
51 Log #1827 NEC- P15
~2......"-,--
"...._--"_.
."c...._.-................-
Final Action: Reject
(517. 26)
Submitter: Eugene E. Morgan , Clakamas County, Building Codes Oivison
Comment on Proposal No: 15Recommendation: The Panel 15 should reconsider its action. Proposal 15-43 should be rejected , leaving existing text
as is.
NFPA 99 and NEC Article 517, the critical branch is considered an inseparable part of the
emergency system. By definition , the critical branch serves such important functions as task illumination, special power
circuits, and selected receptacles related to patient care. A more complete list of locations served by those circuits is in
NFPA 99, 4.4. 2.2. 3. It includes locations such as coronary care, intensive care, postoperative recovery rooms
hemodialysis rooms and emergency rooms.
Removal of the requirements to comply with Article 700 is more than an editorial change. It would literally remove
requirements such as: Identification of boxes , enclosures and panels as part of the emergency system (700. 9); the
requirement for audible and visual signals for the alternate power source (700. 7); and the periodic testing required by
Substantiation: Throughout
700.4.
Removing the requirements of Article 700 from the critical branch may be mistakenly seen by some designers and
installers of smaller facilities as eliminating the requirements for emergency systems in Article 517; such as separation
from other circuits , and mechanical protection.
The only apparent reason for removing the critical branch from the requirements of Article 700 would be a possible
cost saving, which in my view , does not justify the change. The critical branch should remain as a recognizable , integral
part of the emergency system.
Panel Meeting Action: Reject
Panel Statement: The panel notes the print line is incorrect; it should be 517. 26.
The panel upholds its position on Proposal 15- 43.
The life safety branch of the health care facility is comparable to the emergency system of commercial (and other)
building types, since both provide power for life safety systems. The critical branch of the health care facility serves
patient care related circuits and equipment, and thus it is not appropriate to apply Article 700.
Emergency power supply systems need to be governed by one entity. The panel requests the Standards Council and
the TCC to review scopes and charges of NFPA 99, NFPA 110, Articles 517 and 700 as it pertains to emergency power
systems.
Printed on 12/13/2006
Report on Comments - June
15-
NFP A 70
2007
'-'''N''''''''
52 Log #1656 NEC- P15
"""m"'""'''''''
Final Action: Reject
(517.44(C))
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept Proposal 15- 83.
extracted text that is " recommended" in NFPA 99 (A.4.4. 1.2(5)), and made it
mandatory, it is still based on text in another NFPA document , and thus subjected to " Extract Policy. " Not clear
however , whether this action is acceptable under NFPA Standards Council policy on " Extract Policy
Substantiation: Although Panel 15 has
Panel Meeting Action: Reject
Panel Statement: This text is not in the body of NFPA 99. The submitter references material contained in an
informative annex and since the annex is not mandatory text , an extract is not appropriate.
Printed on 12/13/2006
Report on Comments 15-
June 2007
53 Log #338 NEC- P15
(517. 61
-"-''--=-''''''',m.."--"'''--'''''--'-'''--'''-
NFP A 70
Final Action: Accept
(8)(5))
Submitter: Michael J. Johnston , Piano, TX
Comment on Proposal No: 15-
Recommendation: The proposal should have been rejected. Restore the original language as follows:
(5) Receptacles and Attachment Plugs. Receptacles and attachment plugs located above hazardous (classified)
anesthetizing locations shall be listed for hospital use for services of prescribed voltage , frequency, rating, and number
of conductors with provision for the connection of the grounding conductor. This requirement shall apply to attachment
plugs and receptacles of the 2- pole, 3-wire grounding type for single- phase , 120-volt , nominal , ac service.
Substantiation: This section is specific to receptacles and attachment plugs used above a hazardous (classified)
anesthetizing location. The type of receptacle used in these applications is a specific type that is listed for hospital use.
These receptacles and attachment plug configurations are unique in design to allow only restricted compatibility and
use, thus reducing hazards in these locations. While it is understood that many health care facilities no longer use
flammable anesthetizing agents , the requirements in the NEC (an international electrical Code) still continues to include
rules for facilities that use flammable anesthetics and are thus classified as hazardous locations in accordance with
517. 60.
Note: Supporting material is available for review at NFPA Headquarters.
Panel Meeting Action: Accept
Printed on 12/13/2006
Report on Comments '" -"'c''''''
June 2007
''''''',"'Y
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54
--"""'-o,'
NFP A 70
Final Action: Reject
15Log #1657 NEC- P15
(517. 63(A))
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15Recommendation: Accept Proposal 15- 93.
Substantiation: NFPA 99 reference to 700. 12(E) in NFPA 70 was intended for the wiring of such lighting units , not for
the requirement of installing battery-operated lights in anesthetizing locations. Responsibility for requiring
battery-operated lights in anesthetizing locations for the purpose of providing lighting is a Health Care Facility project
responsibility. Such lighting units are
not for emergency exiting purposes; rather they are for evaluating patient
condition , as well as eliminate need for anesthesiologist(s) to hold a flashlight while trying to assess patient condition.
A proposal to NFPA 99 may be in order to clarify this more.
Panel Meeting Action: Reject
Panel Statement: The reference in NFPA 99: 13.4.
numbering in the 2005 edition. NFPA 99: 13.4.
700. 12(F).
Printed on 12/13/2006
1 (E) to NFPA 70 , 700. 12(E) is incorrect due to revision in
1 (E) refers to 517. 63(A) which contains the correct reference to
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June 2007
55
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NFP A 70
Final Action: Accept in Principle
Log #453 NEC- P15
15(517. 71 (A))
Submitter: Dan Leaf , Seneca , SC
Comment on Proposal No: 15-
Recommendation: Accept as revised:
by means of a wiring method
II'Clllllt:t:b IIIt:
\:t:IIt:1 ClI, t:yu il
t:lllt:llb v f II I i;: ",v Jt: in accordance with 517. 12.
requirements " is vague and can be perceived as including all wiring methods. The proposal
has nothing to do with equipment wiring between parts , which may be cords , but conductors that connect to the power
Substantiation: " General
supply. The exception permits cords for such connections.
Panel Meeting Action: Accept in Principle
Revise 517. 71(A)
to read as follows:
517. 71(A) Fixed and Stationary Equipment. Fixed and stationary X-ray equipment shall be connected to the power
supply by means of a wiring method
complvinq with applicable requirements of Chapters 1 throuqh 4 of this
modified bv this Article. II'Cll'IIt:t:b II It: \:t:IIt:1 Cl il t:yu il t:111t:I, b vf II Ii;: CuJt:.
Exception remains unchanged.
Panel Statement: The text change improves usability and satisfies the submitter s
Printed on 12/13/2006
intent.
Code.
?!_
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~~~
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---_
-=2
15-
56 Log #2050 NEC- P15
(517. 80
Exception NO.
!.E
Final Action: Accept
3 (New) )
Submitter: Hugh O. Nash , Jr. , Nash Lipsey Burch
Comment on Proposal No: 15- 103
Recommendation: Delete 517. 80 Patient Care Areas , including the FPN. Add an additional exception under
517. 13(B).
Secondarv circuits of Class 2 and Class 3 communications or siqnalinq svstems.
has been a source of confusion for many years. Nurse call and other Class 2 and Class 3
communications systems at the patient bedside are intrinsically safe. This section has been misinterpreted by many
AHJs. Some have interpreted this section to mean that nurse call wiring must be installed in metallc conduit for
mechanical protection. This has never been the intent of 517. , since nurse call systems are not a part of the
emergency system. Some AHJs have required insulated green ground conductors and metallc conduit.
517. 30(C)(3)(5) permits secondary circuits of Class 2 or Class 3 communication or signaling systems to be installed
without mechanical protection. The proposed exception under 517 . 13(B) will make it clear that metal conduit and an
insulated green ground conductor are not required for electrical safety.
Exception NO.
3 shall read:
Substantiation: 517. 80
Panel Meeting Action: Accept
Printed on 12/13/2006
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15-
57 Log #430 NEC- P15
Final Action: Accept in Part
(517. 160(A)(1 ))
Submitter: Dan Leaf , Seneca, SC
Comment on Proposal No: 15- 105
Recommendation: Accept revised:
I'Clv i'l\: IIU dt:dl i"'Cl I Will It: diul
isolation transformers,
Such isolation shall be accompl ished by means of one or more
electricallv isolated batteries.
generator sets, or by means of
l.dvvt:t:, I fJ' illlClI Y ClII J ;:t:"'UIIJClI y by means of
Isolation transformers. motor- driven qenerators. and charqers for isolated batteries shall be supplied from the critical
I
mo
branch.
is no need to describe characteristics of the transformer if specified as an isolation type which is
types may be suitable. " Suitably " is subjective and not specific. The
definition of " isolated" in Article 100 pertains to accessibility while the intent appears to pertain to electrical separation.
Proposal clarifies the supply system branch.
Substantiation: There
defined. Generators other than motor- driven
Panel Meeting Action: Accept in Part
Change 517. 160(A)(1) to read as follows:
517 . 160(A)( 1) Isolated Power Circuits. Each isolated power circuit shall be controlled by a switch that has a
disconnecting pole in each isolated circuit conductor to simultaneously disconnect all power. Such isolation shall be
I "'UI II It:diull l.dvvt:t:I' fJl i'IICI'
IIClv ill\: IIU t:t:d, i"'Cl
isolation transformers,
Y ClIIJ
accomplished by means of one or more
isolated batteries.
ilCl
l.ly
electricallv
;:u
;:t:"'UIIJClI Y vv i,IJi'I\:;:, l. y means of moenerator sets , or by means of
Panel Statement: The panel accepts that part of the comment that improves readability of the section.
The panel rejects the submitter s second sentence as connection to the critical branch is already required by Section
517. 33(A)(1).
Printed on 12/13/2006
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58
15Log #2270 NEC- P15
(517. 160(A)(5))
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NFP
A 70
"'e,
Final Action: Reject
Submitter: James Wiseman , Schneider Electric / Square 0
Comment on Proposal No: 15- 106
Recommendation: The Panel should
reconsider Proposal 15- 106 and Reject it.
with the panel action and panel statement. While we certainly agree with the critical
nature of these circuits , we do not agree that a change in color coding is desirable. The use of orange and brown in
isolated power systems has been mandated by the NEC since 1978 , at least. It is our contention that this long-standing
use along with the low probability of intermixing, as cited below leaves no question as to the nature of their service
(quoting the Panel Statement.)
The submitter correctly notes that the NEC also uses orange as the color to identify the high leg of a 3- phase , 4-wire
delta system, and also cites the practice of using orange and brown in 480Y/277 V systems. While the latter may be
true , it is not a requirement of the NEC. But , more importantly, the probability of encountering either of the other two
uses of the orange / brown color-coding in the same area occupied by conductors on an isolated power system is
extremely low.
Properly designed and installed, isolated power systems have very few joints made up within junction boxes or other
enclosures. And they are not installed in the same raceway with other systems. So the probability of an electrician
being misled through the act of checking for voltage- to- ground on a brown or orange wire - an example of the potential
problems that was cited during the Panel meeting - is very low. (That same approach for determining if a circuit is
de-energized also would be ineffectual if used on the orange wire of a 4-wire delta system. Only through knowledge of
the voltage systems in use in the area and the use of proper verification techniques can an electrician assure a circuit is
not energized.
Additionally, we are concerned that this change would significantly impact reasonable availability of properly
color-coded conductors for isolated power systems. This has two components. The first is the obvious one of a striped
conductor having lower commercial demand than a solid-colored one. The other issue is that isolated power systems
typically are designed to use insulated conductors having a very low dielectric constant (as mentioned in 517. 160(A)(6)
FPN No. 2) in order to meet the requirements of NFPA 99 and expected performance requirements. Availability of such
conductors with striped insulation should be assured before a change of this nature is considered.
Substantiation: We disagree
Panel Meeting Action: Reject
Panel Statement: The panel reaffirms its position on Proposal 15- 106.
The requirement for color coding of isolation systems provides an additional level of safety. The unique color stripe
provides identification for safety purposes.
Printed on 12/13/2006
!:!,
~~~
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Z-._-_._,,--_..__._
15-
59 Log #1658 NEC- P15
Final Action: Reject
(517. 160(B))
Submitter: Marvin J. Fischer , Monroe Township, NJ
Comment on Proposal No: 15- 107
Recommendation: Accept Proposal 15- 1 07.
in 517. 160(B) are performance characteristics for line isolation monitors (e. , level of
hazard current at which alarm wil be activated , use of lights to indicate LlM status). Wording is very much , if not
identical, to that in NFPA 99.
Substantiation: Requirements
Panel Meeting Action: Reject
Panel Statement: There are suffcient differences between the defined characteristics contained in NFPA 99 and
NFPA 70, and therefore , an extract reference is not appropriate.
The panel requests the Standards Council to review and clarify the ownership of defined characteristics common to
NFPA 99 and NFPA 70.
Printed on 12/13/2006
Report on Comments -
June 2007
60
15Log #805 NEC- P15
(518.4(A))
NFPA 70
Final Action: Accept
Submitter: John Kincaid, Systimax Solutions
Comment on Proposal No: 15- 110
Recommendation: Continue to reject this proposal.
s substantiation does not address the fact the general- purpose cables are used in
concealed spaces unless the concealed space is part of the air handling system; only then are plenum cables , which sit
atop the cable substitution hierarchy, required.
It appears that the submitter is attempting to change the requirements for cables in an air handling system. Standards
Council Decision 05- 24 (SC#05- 4) dated July 29 , 2005 requires that the NEC Project maintain the status quo on
issues related to plenum cables.
Substantiation: The submitter
Panel Meeting Action: Accept
Printed on 12/13/2006
~~~~~~
=--~~~~
61
15Log #1679 NEC- P15
(518.4(A))
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Final Action: Accept
Submitter: Richard J. Rockosi , ARKEMA Chemicals
Comment on Proposal No: 15- 110
Recommendation: Continue to reject this proposal.
Substantiation: The submitter s statement about "fluropolymers " (sic) is grossly inaccurate. Fluoropolymers are used
to make the highest performing plenum cables available on the market today. The first plenum cables listed by UL in
1978 had fluoropolymer insulation. Their combustion toxicity was reviewed by the NFPA Toxicity Advisory Committee
(see their report dated 5/21/84). A toxic hazard evaluation has been published; see Richard W. Bukowski Toxic Hazard
Vol. 21 , No. , November 1985, p. 25.
Evaluation of Plenum Cables Fire Techn%gy,
Panel Meeting Action: Accept
Panel Statement: The panel makes no judgment about the technical accuracy of the commenter s substantiation
however , completely aside from toxicity issues , the panel reiterates the other reasons for rejection of the original
proposal as outlined in the ROP.
Printed on 12/13/2006
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Report on Comments M'''""_
62
15Log #1387 NEC- P15
(518.4(C) Exception (New) )
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NFP A 70
Final Action: Reject
Submitter: William Wagner, Certification Solutions
Comment on Proposal No: 15- 112
Recommendation: This Proposal should be Accepted as revised below:
Electrical nonmetallic tubing and rigid nonmetallic conduit are not recognized for use in other space used for
environmental air in accordance with 300. 22(C).
Exception: Phenolic Tvpe RTRC riqid nonmetallic conduit shall be permitted for use in other space used for
environmental air as covered in 300. 22(C) if listed as havinq adequate fire-resistant and low smoke- producinq
characteristics.
was presented as a companion proposal to 3- 92 (NEC 300.22). It was rejected due to
insufficient technical substantiation. However , technical substantiation has now been developed to demonstrate the
ability of these products to be safely used in these applications and is being presented to CMP- 3 in support of revised
proposal 3- , CMP- 8 in support of revised proposals 8- 79 and 8- , and CMP- 15 in support of revised proposal
15- 112.
The position of Underwriters Laboratories in relation to flame spread and smoke developed values for materials used in
plenums was put forth in UL' s Mr. Randy Laymon s letter dated December 15 , 2004.
As a result of my initial proposal, and this UL position paper, FRE Composites (2005) Inc. undertook testing with
Underwriters Laboratories of their phenolic RTRC products to both UL 2024 plenum and riser tests , and the ASTM E84
flame spread and smoke developed tests. As can be seen from the UL test data and reports , phenolic RTRC products,
in a variety of trade sizes , were able to complete each of these testing programs with flame and smoke ratings
significantly below the criteria established for products to be used in both plenum and riser applications.
The performance of these products , as demonstrated, is summarized as follows:
Substantiation: This proposal
INSERT NEC Tb518 L 1387. doc
Therefore , in consideration of the data generated by an independent, NRTL accredited test laboratory, and in
stated position on this issue , these conduit products have conclusively demonstrated their ability to
perform acceptably in both plenum and riser applications and I recommend their inclusion in NEC 355. 10 in accordance
It should be noted that this proposal has been slightly modified from its original version in
with the revised proposal.
order to delete the FPN indicating suggested acceptance criteria for these products. The development of appropriate
flame and smoke criteria , along with the product' s listing requirements is best left to the determination of the listing
organization. However , regardless of which of the established flame and smoke criteria the listing organization chooses,
phenolic RTRC has demonstrated its ability to perform safely.
Additionally, a reference to " phenolic" RTRC conduit has been added in order to limit this proposal to only that conduit
type which was evaluated as part of the technical substantiation provided with this comment.
conjunction with UL' s
Note: Supporting material is available for review at NFPA Headquarters.
Panel Meeting Action: Reject
Panel Statement: Toxicity is not the only issue. Not only are the technical substantiations inadequate and not
appropriate , no mechanical properties were provided. Physical protection is of paramount importance in assembly
occupancies where temporary changes to the venue occur on a regular basis.
This action correlates with the action taken by CPM- 3 on Comment 3- 68 on Proposal 3- 92.
Printed on 12/13/2006
Test
Plenum (UL 2024 Flame
Plenum UL 2024 Smoke Peak
Plenum :u 2024 Smoke A vg.
Riser (U L 2024) Flame
Riser (UIL 2024) Temperature
Maximum
Permitted Value
0 ft
12. 0 ft
850.
Maximum
Test Value
0 ft
0 ft
371'
ASTM E84 Flame Spread Index (PSI)
ASTM E84 Smoke Developed Index (SDI)
NEC (Log #1387) Substantiation
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15-
Final Action: Reject
Log #318 NEC- P15
(518.
Submitter: Code- Making Panel 6
Comment on Proposal No: 15- 116
Recommendation: Accept in principle Proposal 15- 116 by deleting the last sentence of the 2005 text of 518. 5 rather
than by the action published for Proposal 15- 116.
Substantiation: The general
rule of Chapter 3 already requires that any neutral involving a circuit with a major portion
of nonlinear load must be considered a current carrying conductor. 31 0. 15(B)(4) specifies that neutrals of nonlinear
loads are to be counted. Neutrals of linear loads are not directed to be counted as current carrying conductors.
The necessity of considering the neutral of even a linear load dimming system as a current carrying conductor should
be under the control of CMP- 15' s expertise. The 2005 text of 518. 5 served to require that even the neutral of a linear
load dimming system be considered as a current carrying conductor. If CMP- 15 has agreed that linear load dimming
systems no Ibnger need to be included , then the removal of their previous special rule seems the most appropriate and
clear solution.
The inclusion of the words " or may use " would mean that all neutrals would have to be considered current carrying
conductors.
If this comment is accepted , then CMP- 15 may consider a fine print note forewarning of the 31 0. 15(B)(4) requirements
as related to nonlinear loads , including some dimming systems , to protect this special wiring installation.
This comment was balloted through CMP- 6 with the following balloting results:
11 Eligible to Vote
10 Affirmative
1 Negative
Mr. Friedman voted negatively stating: " This comment does not indicate that CMP- 15' s action was incorrect. It only
advised that the method of handling neutrals of nonlinear loads is covered in 310. 15(B)(4).
However , CMP- 15 decided that the best way to handle the proposal was to advise of the two different dimmer systems
and when to count neutrals as current carrying conductors. This was done to be helpful to the users of phase control
and sine wave dimmer systems.
Since the comment statement finds no fault with CMP- 15' s action , but only a different way it could have been done , I
do not agree with the comment.
The CMP-6 comment should be that " CMP- 6 supports CMP- 15 action to clarify de-rating for neutral conductors of
feeders used to supply phase control and solid state sine wave dimmer loads."
Panel Meeting Action: Reject
Panel Statement: Prior to 2005 , there was only one type of solid state dimmer: the phase control type that presented
a nonlinear load and required neutrals of feeders to be considered current carrying conductors. Furthermore that
non- linearity was not due to traditional and recognizable reasons. This required special emphasis in Article 518 and 520.
The emergence of new technology solid state sine wave dimmers that presents a linear load makes it necessary to draw
a clear differentiation between the two types , and the associated special neutral requirements (or lack thereof) for each
type of solid state dimmer. This cannot be left in an ambiguous state by simply leaving out the special neutral
requirements for sine wave dimmers- it needs to be explicitly stated that such dimmers do not require the neutral to be
considered a current-carrying conductor. The wording of the original panel action on the proposal accomplishes this.
Finally, the wording " . . . or may use both phase-control and sine-wave dimmer. . . ' is needed to clearly require that
systems using field- interchangeable plug- in phase-control and sine-wave dimmers must be treated as if the worst case
use of phase control dimmers applies , even if the modules installed at time of system installation are sine wave
modules.
Printed on 12/13/2006
Report on Comments -
"Wo""""",,-,,,
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June 2007
64 Log #150 NEC- P15
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NFP A 70
Final Action: Accept
(519 (New))
Submitter: Technical Correlating Committee on National Electrical CodeQj
Comment on Proposal No: 15- 121
Recommendation: The Technical Correlating Committee directs the following actions on this proposal.
The Technical Correlating Committee directs that the new Article be numbered as Article 522 to provide for
proper placement and allow some additional open article numbers to remain.
Article scope statements and titles are the responsibility of the Technical Correlating Committee and the Technical
Correlating Committee is modifying the panel action on the scope to make it clear that the conductors covered by the
article are control circuit conductors to read as follows:.
control circuit conductors for
519. 1 Scope. This article covers the installation of control circuit power sources and
electrical equipment, including associated control wiring in or on all structures, that are an integral part of a permanent
amusement attraction."
The Technical Correlating Committee accepts the title of the new article.
The Technical Correlating Committee directs the panel to reconsider the proposal and clarify the intended application
of wiring methods. The current text permits multi-conductor cable assemblies to be used , but allows conductors down to
30 AWG. It is unclear as to whether Chapter 3 wiring methods are required or some other method is intended. This
action will be considered by Code- Making Panel 15 as a Public Comment.
The Technical Correlating Committee directs the Panel , in 519. , to change the parenthetical reference to a Fine Print
Note or remove it.
Substantiation: This is a direction from the National Electrical Code Technical Correlating Committee in accordance
with 3.4. 2 and 3.4. 3 of the Regulations Governing Committee Projects.
Panel Meeting Action: Accept
Renumber Article 519 to Article 522.
Revise scope to read as follows:
control circuit conductors for
522. 1 Scope. This article covers the installation of control circuit power sources and
,
that
are
an integral part of a permanent
electrical equipment, including associated control wiring in or on all structures
amusement attraction."
Include Table 522. 22 Include. doc
Change 519. 28 to read as follows:
(illlll.t:1 ;:iUII Ilul illduJt:) is likely to occur , ungrounded
522.28 Control Circuits in Wet Locations. Where wet contact
two-wire dc control circuits shall be limited to 30 volts maximum for continuous dc or 12.4 volts peak for dc that is
(Rdt:. t:11"'t: - CI'ClfJb 9 , T CllAt: 11 B).
interrupted at a rate of 10 to 200 Hz.
Panel Statement: The panel accepts the direction of the TCC to review and act on this proposal.
The panel accepts renumbering of Article 519 to Article 522.
The panel accepts insertion of " control circuit" into Scope as directed.
Table 519.22 appears to have been inadvertently omitted during the Article 519 processing between ballot and
publication of the ROP and replaced with proposed text of Section 505.2. Unrelated text has been inserted into the
ROP which appears to be a transcription error (ROP page 574- 575).
Panel 15 agrees that the parenthetical reference in 522. 28 is inappropriate.
Printed on 12/13/2006
Table 522. 22
Conductor Ampacity Based on Copper Conductors with 60
C and 75
C Insulation in
an Ambient Temperature of 30
Ampacity
Conductor Size A WG
0.5
For
ambient temperatues , other thn 30 , use see Table 310. 16 temperatue correction factors.
Note 2: Ampacity adjustment for Conductors with 90 C or greater inulation shall be based on ampacities
in the 75 C colum.
Note 1:
NEC ROC 2008/ Table 522. 22/ panel action/ Log #150
Report on'''''' Comments
- June
c"" ..'""''
2007
'V,
15-
65 Log #291 NEC- P15
'c''',,
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NFP A 70
Final Action: Accept in Principle
(519 (New))
Submitter: Code- Making Panel 3,
Comment on Proposal No: 15- 121
Recommendation: Accept the change as proposed.
Substantiation: While there may be some similarities with Class 1 , Class 2, and Class 3 circuits , it appears the Task
Group that worked on this proposed new article has covered many of the same issues. For example, overcurrent
protection of the circuit is similar to those found in 725. 21 (A)(2) for power sources other than transformers. A review of
the sections within the new article reveals a thoroughness and attention to detail for this very special system of
permanent amusement rides.
This comment was balloted through CMP- 3 with the following results:
13 Eligible to Vote
12 Affirmative
1 Not Returned (J. Sleights)
Mr. T. Guida voted affrmatively stating: " It is understood that the panel has determined that 30 AWG conductors are
acceptable as shown in 519. 21. The wording of (A) is clear that these conductors are acceptable where a third party
lists the component or assembly. The wording of (B) presents a problem because there are no cables defined in the
NEC with 30 AWG conductors that are suitable for these circuits. Machine Tool Wire has a minimum conductor size of
22 AWG. Type TC and MC cables are 18 AWG and larger. Fixture wire is 18 AWG or larger. Cables with 30 AWG
conductors are Type CM or CL2 for communication or Class 2 circuits. Appliance wiring Material (AWM) is not intended
for evaluation other than as a component of a Listed product."
Mr. M. Sanders voted affirmatively stating: " The Technical Correlating Committee noted that 519. 28 contained the
parenthetical reference " (Reference - Chapter 9 , Table 11 B)" and noted it should either be a Fine Print Note or be
deleted. The specific information for use in 519. 28 eliminates the need to refer users to Chapter 9 , Table 11 (B), and is
not needed and should be deleted as not all parts of this Table are to be mandatory.
Panel Meeting Action: Accept in Principle
Panel Statement: See panel action and statement on Comment 15- 64.
Printed on 12/13/2006
,"
Report on Comments ''''''''''''N'''J' OC.'''"''
15-
66 Log #684 NEC- P15
June 2007
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NFP A 70
Final Action: Accept
(519 (New))
Submitter: James M. Daly, Upper Saddle River , NJ
Comment on Proposal No: 15- 121
Recommendation: I agree with the Panel Action except the word " multi-conductor" should be changed to
multi conductor" in 519. , in two places in 519. 21(B), and in one place in 519. 21(C).
Substantiation: This
is an editorial correction for consistency. Multiconductor is not hyphenated. In the 2005 NEC, the
word " multi-conductor " is only used in Articles 690 and 810 and Annex D. The word " multi conductor " is used in 31
Articles , Chapter 9, and Annex B. In the 2008 preprint multi-conductor" only appears 7 times whereas " multiconductor
appears 142 times.
Panel Meeting Action: Accept
Change " multi-conductor" to " multiconductor" in 519. 20, in two places in 519. 21(B), and in one place in 519.21(C).
Panel Statement: The change meets the submitter s intent.
Printed on 12/13/2006
~~~
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15-
67 Log #151 NEC- P15
Final Action: Accept
(520. 51)
Submitter: Technical Correlating Committee on National Electrical Code(I,
Comment on Proposal No: 15- 133
Recommendation: The Technical Correlating Committee directs that the action on this proposal be correlated with the
action taken on Proposal 15- 134. This action will be considered by the Panel as a Public Comment.
Substantiation: This is a direction from the National Electrical Code Technical Correlating Committee in accordance
with 3.4. 2 and 3.4. 3 of the Regulations Governing Committee Projects.
Panel Meeting Action: Accept
Change the last sentence of the present text to read as follows:
conductor of feeders supplying solid-state , 3- phase , 4-wire dimmer systems shall be considered a
The neutral
current-carrying conductor.
Panel Statement:
The panel accepts the direction of the TCC to correlate with the action taken on Proposal 15- 134.
Printed on 12/13/2006
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NFP A 70
Final Action: Accept in Principle
(520. 81)
Submitter: Neil F. LaBrake, Jr. , Syracuse , NY
Comment on Proposal No: 15Recommendation: Continue to accept the following portions of the TCC Grounding and Bonding Task Group proposal
15- 2 as modified and revised by the actions of CMP- 15 for which the TCC Grounding and Bonding Task Group
recommends that CMP- 15 accept the revisions to 520. 81 as proposed in Proposal 15- 2. This retains the specific
references to Parts VI and VII of Article 250 in the last sentence of this section.
Substantiation: The changes proposed to 520. 81 were made as a part of the Task Group s work to meet the
requirements of the NEC Style Manual Section 4. 1 which does not permit a section to refer to an entire article, but
does permit references to the appropriate parts of such articles.
This Comment was developed by a Task Group assigned by the NEC Technical Correlating Committee to address
actions that were other than "accept" taken by Code-Making Panels on proposals from the TCC to resolve 2005 NEC
Proposal 5- 1 and Comment 5- 1. Members of the Task Group on Grounding and Bonding for this Comment included: C.
Douglas White; Michael Johnston; Jeffrey Boksiner; Daleep Mohla; Phil Simmons; Christopher Hutchings; James
Carroll; Alan Rebeck; Richard Loyd; Paul Dobrowsky; and Neil F. LaBrake , Jr.
Panel Meeting Action: Accept in Principle
Delete the last sentence of 520. 81.
Panel Statement: The action satisfies the panel' s contention that more than Part VI an Part VII of Article 250 apply to
Section 520. 81. This change complies with the NEC Style Manual , Section 4.
Printed on 12/13/2006
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Final Action: Accept
(525.
Submitter: Technical Correlating Committee on National Electrical Code(I
Comment on Proposal No: 15- 145
Recommendation: The Technical Correlating Committee directs that the panel clarify the panel action on this
proposal in accordance with 2. 2 of the NEC Style Manual to not contain the term being defined. The panel is also
directed to correlate this proposal with the action taken on Proposal 15- 144a. This action will be considered by the
panel as a public comment.
Substantiation: This is a direction from the National Electrical Code Technical Correlating Committee in accordance
with 3.4. 2 and 3.4. 3 of the Regulations Governing Committee Projects.
Panel Meeting Action: Accept
Panel Statement: The panel accepts the direction of the TCC to clarify the panel action on this proposal and accepts
the definition of portable structure as modified by Comment 15- 70.
See action and statement on Comment 15- 70.
Printed on 12/13/2006
Report on Comments -
70
June 2007
Log #1359 NEC- P15
15(525. 2. Operator, Portable Structures)
NFP
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Final Action: Accept
Submitter: Mark R. Hilbert , Wolfeboro, NH
Comment on Proposal No: 15- 144a
Recommendation: Accept the proposed new definitions in Principle, in Part.
Revise th e proposed new definitions as follows:
he individual responsible for starting, stopping and controlling
Operator. A;: u;:t: i.1 lI. i;: A.li", It: 1I.t: UfJt:1 Cllul ;: IIClIl Lt:
an amusement ride or supervising a concession.
Portable Structures. Units desiqned to be moved includinq, fUI 1I.t: fJUI fJu;:t:;: u f lI. i;: Adidt: II It: It:II.1 fJudClLIt: ;:b udul t:;:
lldll i'I", Jt: but not limited to , amusement rides, attractions , concessions, tents, trailers , trucks, and similar units.
Substantiation: Revising the proposed new definitions in the manner above wil incorporate the directive from the TCC
in Proposal 15- 145 to follow the NEC Style Manual and not include the term being described in the definition. The
language " for the purposes of this Article " was removed from both definitions as it is not necessary in these new
definitions as they are only used in Article 525. Further, revising the definition of " Portable Structures " here will correlate
with the panel action on proposal 15- 145 to be more concise and accurately reflect the terms used in the industry with
this proposal.
Panel Meeting Action: Accept
Printed on 12/13/2006
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Final Action: Accept in Principle
(525. 11)
Submitter: Mark R. Hilbert , Wolfeboro , NH
Comment on Proposal No: 15- 150
Recommendation: Revise text to read as follows:
525. 11 Multiple Sources of Supply. Where multiple services or separately derived systems, or both , supply portable
structures the eauipment aroundina conductors of all the sources of supply that serve such structures separated by less
plt:11I bonded toaether at the portable
,"ullllt: dt:J tu U It: Mil It: \:' UUllJill\: dt:d, uJt:
than 3. 7 m (12 ft) shall be
structures. The bondina conductor shall be sized in accordance with Table 250. 122 based on the laraest overcurrent
supplvina the portable structures.
Substantiation: Revising the meeting
action on this proposal as recommended wil increase safety by using the
shortest means possible to reduce the potential between the portable structures and wil add clarity to this section by
specifying how the conductor is to be sized as the recommended text in Proposal 15- 150 provided no specific guidance
on how to size the bonding conductor. Further , by requiring bonding of the grounding electrode systems , the implication
is that a grounding electrode system must be installed when , in fact , there is no requirement to do so. Prior to the 2005
NEC, the frame of a vehicle mounted generator was recognized by 250. 34 as a grounding electrode and, therefore, the
frames of the vehicles could be bonded together to comply with the intent of 525. 11. However , with the revision of that
section in 2005, the vehicle frame is not recognized as serving as a electrode nor is it required to be connected to one.
Accepting the text as proposed will provide an effective means of reducing the potential differences between portable
structures while providing a prescriptive requirement for the installation.
Panel Meeting Action: Accept in Principle
Revise text to read as follows:
525. 11 Multiple Sources of Supply. Where multiple services or separately derived systems, or both , supply portable
structures the eauipment aroundina conductors of all the sources of supply that serve such structures separated by less
b II bonded toaether at the portable
Cllllt: \:lUulIJill\: t: b., t.uJt:
,"UI II It: dt:J lu lI,t:
than 3. 7 m (12 ft) shall be
structures. The bondina conductor shall be copper and sized in accordance with Table 250. 122 based on the laraest
overcurrent supplvina the portable structures. but not smaller than NO. 6 AWG.
Panel Statement: The panel is concerned that conductors smaller than NO. 6 AWG copper will be subject to physical
damage , therefore , a minimum size is defined.
The change satisfies the submitter s intent.
Printed on 12/13/2006
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NFP A 70
Final Action: Accept in Principle
(525. 11)
Submitter: Mark R. Hilbert , Wolfeboro , NH
Comment on Proposal No: 15- 150
Recommendation: Revise text to read as follows:
525. 11 Multiple Sources of Supply. Where multiple services or separately derived systems, or both , supply portable
structures . the eauipment around in a conductors of all the sources of supply that serve such structures separated by less
,"ullllt:dt:J lu lI,t: ~Cllllt: \: I uUIIJill\: dt:d,u Jt: ~y~It:1I1 bonded toaether at the portable
than 3. 7 m (12 ft) shall be
structures. The bondina conductor shall be sized in accordance with Table 250. 122 based on the laraest overcurrent
supplvina the portable structures
Substantiation: Revising the meeting action on this proposal as recommended will increase safety by using the
shortest means possible to reduce the potential between the portable structures and will add clarity to this section by
specifying how the conductor is to be sized as the recommended text in proposal 15- 150 provided no specific guidance
on how to size the bonding conductor. Further , by requiring the bonding of the grounding electrode systems together the
implication is that a grounding electrode system must be installed when , in fact, there is no requirement to do so. Prior to
the 2005 NEC the frame of a vehicle mounted generator was recognized by 250. 34 as a grounding electrode and
therefore the frames of the vehicles could be bonded together to comply with the intent of 525. 11. However, with the
revision of that section in 2005 , the vehicle frame is not recognized as serving as a electrode nor is it required to be
connected to one. Accepting the text as proposed will provide an effective means of reducing the potential differences
between portable structures while providing a prescriptive requirement for the installation.
Panel Meeting Action: Accept in Principle
Panel Statement: See panel action and statement on Comment 15- 71.
Printed on 12/13/2006
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Log #1361 NEC- P15
15(525. 21 (A))
Final Action: Reject
Submitter: Mark R. Hilbert , Wolfeboro , NH
Comment on Proposal No: 15- 152
Recommendation: Accept this Proposal in Principle and revise as follows:
525. 21 Rides , Tents and Concessions.
(A) Disconnecting Means. Each ride and concession shall be provided with a disconnecting means in accordance with
(2)
(1)"
UlA fused disconnect switch or circuit breaker located within sight and within 1. 8 m (6 ft) of the operator s station. The
disconnecting means shall be readily accessible to the operator , including when the ride is in operation. Where
accessible to unqualified persons , the enclosure for the switch or circuit breaker shall be of the lockable type.
(2) Vv'I,t:It: lI,t: l iJt: UI "ulI"t:~~ iuli i~ fJluv iJt: J vv ill, fu~t:J Ji~"ullllt:d ~vv ild, UI " i,,,u il L.t:Cl I\t:I , ClII Cl JJiliuliCl
Ji~"ullllt: dill\: IIIt:ClII~ vvill,uul ill lt:lIldl UVt:1 "UII t:1I1 fJl ult:diull ~I'dll L.t: fJt:lllIiltt: J VVI,t:1 t: il i~ lu" dt:J vv ill, ill ~ i\: l ClIIJ vvill, ill
ICl liuli. The disconnecting means shall be readily accessible to the operator , including
1.8 III (6 fl) u f lI,t: UfJt:1 dlul
when the ride is in operation. Where accessible to unqualified persons , the enclosure for the switch or circuit breaker
shall be of the lockable type.
Exception: Where the ride or concession is provided with overcurrent protection. the disconnectina means shall not be
reauired to have overcurrent protection.
t3 il A shunt trip device that opens the fused disconnect or circuit breaker when a switch located in the ride
operator s console is closed shall be a permissible method of opening the circuit.
Substantiation: Revising the proposal as indicated above will make it clear that the ride or concession is stil required
to have overcurrent protection while allowing a nonfused disconnect switch to be used within 6 ft of the operator s station
when the ride or concession is provided with overcurrent protection. Although the panel discussion at the ROP meeting
indicated that it was not the intent of the original language requiring a fused disconnect switch or circuit breaker to
provide overcurrent protection for the ride or concession, revising the proposal as recommended by the meeting action
could create a situation where there was no overcurrent protection at the ride or concession or in the disconnecting
means within sight of the operators station. Further this revision will address the concern expressed in the negative vote
as to removing only the overcurrent language in the first sentence of the existing section.
or.
Panel Meeting Action: Reject
Panel Statement: The meaning is not materially changed by the proposed language and it uses an exception , which
is to be avoided per the Manual of Style.
Printed on 12/13/2006
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74 Log #1362 NEC- P15
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NFP A 70
Final Action: Accept
(525. 30)
Submitter: Mark R. Hilbert, Wolfeboro , NH
Comment on Proposal No: 15- 156
Recommendation: Accept Proposal 15- 156 in its entirety.
Substantiation: Accepting the proposal in its entirety will clarify how the bonding required by this section is to take
place. The definition of an equipment grounding conductor in Article 100 on its own does not adequately address how
the bonding required by this section is to take place. Further , not all of those using the NEC read the Rap and ROC to
get the benefit of the additional information provided by NEC Code Making Panels. Including text in this section that
specifically identifies that the equipment grounding conductor of the circuit that is supplying the equipment specified in
525. 30(1) through (3) can serve as the bonding means will reduce the confusion created by the current text and add
clarity to the section. Further, the recommended text in proposal 15- 156 will add consistency to the NEC as it is in line
with the language already used in 250. 104(8) regarding the bonding requirements for " other metal piping.
Panel Meeting Action: Accept
Printed on 12/13/2006
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15- 74a
(530. 20)
Final Action: Accept
Submitter: Code- Making Panel 15,
Comment on Proposal No:
Recommendation: Change 530. 20 to read as follows:
530. 20 Grounding
Type MC cable , Type MI cable, metal raceways, and all non-current-carrying metal parts of appliances, devices , and
equipment shall be connected to an equipment grounding conductor. This shall not apply to pendant and portable
lamps, to stage lighting and stage sound equipment, or to other portable and special stage equipment operating at not
over 150 volts dc to ground.
Substantiation: Comment 15- 75 pointed to a printing error in the ROP dealing with 530. 20. It is section 530. 20 that
refers to Article 250 instead of 530. 64(8). The panel action addresses the intent of the submitter of Comment 15- 75.
Panel Meeting Action: Accept
Printed on 12/13/2006
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Final Action: Reject
Submitter: Neil F. LaBrake , Jr. , Syracuse, NY
Comment on Proposal No: 15Recommendation: Continue to accept the following portions of the TCC Grounding and Bonding Task Group proposal
15- 2 as modified and revised by the actions of CMP- 15 for which the TCC Grounding and 80nding Task Group
recommends that CMP- 15 accept the revisions to 530. 64(8) as proposed in Proposal 15- 2. This retains the specific
references to Parts VI and VII of Article 250 in the last sentence of this section.
Substantiation: The changes proposed to 530. 64(8) were made as a part of the Task Group s work to meet the
requirements of the NEC Style Manual Section 4. 1 which does not permit a section to refer to an entire article, but
does permit references to the appropriate parts of such articles.
This Comment was developed by a Task Group assigned by the NEC Technical Correlating Committee to address
actions that were other than " accept" taken by Code- Making Panels on proposals from the TCC to resolve 2005 NEC
Proposal 5- 1 and Comment 5- 1. Members of the Task Group on Grounding and 80nding for this Comment included: C.
Douglas White; Michael Johnston; Jeffrey 80ksiner; Daleep Mohla; Phil Simmons; Christopher Hutchings; James
Carroll; Alan Rebeck; Richard Loyd; Paul Dobrowsky; and Neil F. La8rake , Jr.
Panel Meeting Action: Reject
Panel Statement: No action is necessary on 530. 64(8) as it already refers to an equipment grounding conductor and
makes no reference to Part VI and Part VII of Article 250,
See Comment 15- 74a (Log #CC 1501).
Printed on 12/13/2006