National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 Fax: 617-770-0700 www.nfpa.org M E M O R A N D U M TO: NEC Code-Making Panel 1 FROM: Kimberly Shea, Administrator, Technical Projects DATE: April 3, 2015 SUBJECT: NFPA 70 First Draft TC Ballot Circulation (A2016) The April 1, 2015 date for receipt of the NEC First Draft Ballots has passed. The preliminary First Draft ballot results are shown on the attached report. 12 Members Eligible to Vote 0 Ballots Not Returned In accordance with the NFPA Regulations Governing the Development of NFPA Standards, attached are reasons for negative votes for review so you may change your ballot if you wish. Abstentions and affirmative comments are also included. Ballots received from alternate members are not included unless the ballot from the principal member was not received. If you wish to change your vote, the change must be received at NFPA on or before Friday, April 10, 2015. Members who have not returned a ballot may do so now. Changes must be submitted through the NFPA Vote.net Ballot site. The return of ballots is required by the Regulations Governing the Development of NFPA Standards.
FR 18, Global Input, See FR 18 FR 1, Section No. 90.2(A), See FR 1 Affirmative 9 Affirmative with Comment 1 Election NFPA 70 A16 This First revision should be revised to also include maintenance, testing and alteration. (A) Covered. This Code covers the installation, maintenance, alteration, testing, and removal of electrical conductors, equipment, and raceways; signaling and communications conductors, equipment, and raceways; and optical fiber cables and raceways for the following: Negative 2 While the Code covers the removal of wiring, these requirements are limited to only a few sections. The addition of "removal" to 90.2(A) may have unintended consequences and be misinterpreted to include more widespread removal of conductors, equipment and raceway than the sections specifically addressed. "Installation" is used in a broad sense and a laundry list of what aspects of installations the Code covers is not necessary. Kent A. Sayler NEC rules are primarily focused on electrical installations. Removal of electrical equipment is only required in a few specific sections therefore should not be included in 90.2(A). Removal of equipment that does not pose a hazard should not be covered by the NEC. 1 of 16
FR 2, Section No. 90.2(B), See FR 2 Affirmative 10 Negative 2 The term "energy storage" is not defined and therefore the breadth of this exclusion from the requirements of the NEC is unclear. In addition, the committee statement incorrectly states that "storage" was added when in fact "energy storage" was added. David L. Hittinger I am not in agreement that all "energy storage" should be exempt from the provisions in the NEC. Perhaps a definition would be an appropriate before excluding this from the NEC. FR 3, Section No. 90.3, See FR 3 FR 4, Section No. 90.8(B), See FR 4 2 of 16
FR 6, Article 100 [Excluding any Sub Sections], See FR 6 Affirmative 11 Affirmative with Comment 1 We are concerned that the proposed revisions are still not technically correct. For example, we wonder why there are definitions in part II that are used in 1,000 volt and less applications such a "fuse". It seems a number of these definitions are not unique to Part II. FR 8, Definition: Accessible, Readily (Readily Accessible)., See FR 8 Affirmative 10 Negative 2 Little to no justification was provided in the Committee statement for the change. Removal of the phrase "to whom ready access is requisite" is more than editorial in nature. Kent A. Sayler The panel statement does not cover all the changes made and their potential impacts. Removing the words "to those to whom ready access is requisite" was previously considered to permit equipment located behind locked doors to be considered readily accessible to qualified persons if they had the keys. Additionally the revised wording would prohibit locking doors or enclosures that limit access to any equipment that is required to be readily accessible such as panelboards in public spaces. Dictionaries indicate that a key is an instrument and an instrument is a tool. FR 9, Definition: Building., See FR 9 Affirmative 11 Affirmative with Comment 1 The Committee should have done more to improve the definition of "building" so that structures that stand alone, such as poles, are not considered buildings. 3 of 16
FR 10, Definition: Equipment., See FR 10 Affirmative 9 Negative 3 The addition of an Informational Note to the definition of "equipment" in order to provide additional examples to the existing laundry list of examples is not necessary. The definition already includes the phrase "and the like" to cover other examples. The proposed Informational Note adds no additional clarity to the existing examples and does not additionally clarify what is or what is not a structure. We are concerned that adding a laundry list in an informational note nearly as long as the laundry list already in the actual definition points to the fact that the definition is not correct. "And the like" seems to cover what is being prosed to be added as an informational note. Perhaps "such as" is more appropriate than "and the like". David L. Hittinger The added informational note adds a limited list of items that does not address mounting of AC equipment that FR 4732 was intended to correct. FR 13, Definition: Structure., See FR 13 Affirmative 10 Affirmative with Comment 2 David L. Hittinger We are concerned that the definition of equipment is unclear as indicated by the action on FR 10. We conclude that FR 13 will be difficult to apply as it may be unclear, vague and unenforceable. This revision does not correlate with revisions in FR 10 that adds a limited list of items in an informational note. FR 14, Definition: Voltage, Nominal., See FR 14 4 of 16
FR 31, Section No. 110.3(A), See FR 31 Affirmative 9 Negative 3 The committee statement provides no substantiation for the change. The addition of this Informational Note may have unintended consequences and be misinterpreted to indicate that the Code is retroactive to reconditioned, refurbished and remanufacturered equipment. We conclude that "equipment" already includes the information in this FR. We further conclude that the action on FR 10 and the action of this FR adding an additional informational note raises concern that the definition of "equipment" is unclear. David L. Hittinger The definition of "equipment" does not include refurbished, remanufactured or reconditioned as described in the informational note. The definition may need to be revised if that is the intent. FR 39, Section No. 110.5, See FR 39 FR 37, Section No. 110.9, See FR 37 5 of 16
FR 35, Section No. 110.11, See FR 35 FR 38, Section No. 110.12 [Excluding any Sub Sections], See FR 38 FR 41, Section No. 110.14 [Excluding any Sub Sections], See FR 41 FR 40, New Section after 110.14(C), See FR 40 Affirmative 10 Affirmative with Comment 1 Mohinder P. Sood This may be an enforcement issue for the AHJs as when inspectors go for inspections an electrician may or may not be present at the job site. Even when they have the proper tool, inspectors are not going to be present when actual work is being done (early morning, late night etc.). It will be the same issue when preventive maintenance is performed on the switchgear in large buildings. Negative 1 This change has the potential of having a significant impact on the electrical industry. Emphasis and priority should be given to properly torquing bolted connections before implementing mandatory requirements for smaller gauge wire and connections on terminal strips. 6 of 16
FR 55, Section No. 110.16, See FR 55 Affirmative 7 Affirmative with Comment 3 This is a logical addition of installation requirements into an enforceable Code. Mohinder P. Sood David L. Hittinger Negative 2 Harry J. Sassaman Too many labels on any piece of equipment may not have the desired effect. It will also be an enforcement issue as the installers may not pay attention when they see so many labels. Correct the editorial error where the first strike through of "are" to "is' should be changed to "at". The second use of "is" was correct. NECA is mindful of the obligations to provide safe work environments for employees and understands requirements contained within both NFPA 70 National Electrical Code and NFPA 70E Standard for Electrical Safety in the Workplace. Section 110.16 of the NEC is titled Arc Flash Hazard Warning. The information contained in this section should relate to a generic warning for qualified persons. As resolved by NEC CMP 1 in previous NEC development cycles, the warning should remain general in nature and should not include information about how to protect using PPE, because this section is not about how to protect. The NEC is an installation Code that provides information and requirements for electrical installations that essentially protect persons and property from hazards arising from use of electricity. It should not include workplace safety requirements related to how to protect against electric shock, arc flash and arc blast events that could occur when workers are performing energized work, justified or not justified. The label requirements proposed in FD 55 are currently addressed in NFPA 70E, as they should be. The proposed NEC revision would be inconsistent with the requirements in 70E and would introduce confusion for installers and inspectors, and would not be practical or enforceable. It also creates problems for manufacturers that current provide generic arc flash hazard warning labels at the factory, which is current provision in this section. The responsibility for this type of marking detail rests with owners, as indicated in NFPA 70E. With no date and time included in the proposed marking, there are serious concerns about the validity and accuracy of such information after the service equipment is initially marked. Another problem is that there are two clearing times (lines side of service OCPD and load side of service OCPD) upon which the values on such a mark or label should be based, further complicating the proposed marking requirement. NECA is also concerned that a false sense of security that might be created, and that the values of energy provided on such marks would not be accurate and compromise worker and owner safety. These proposed requirements appear to be beyond the NEC scope and should be provided only in NFPA 70E, and it is the responsibility of an owner to maintain their accuracy and validity. They should not become an installation requirement in the NEC. NECA emphasizes that compliance with NFPA 70E is a requirement, not an option. Roland E. Deike, Jr. EEI votes against the FR 55 revisions to 110.16, since these are prescriptive related practices already covered in NFPA 70E about incident energy, arc flash boundary, and PPE. Installation related requirements having dated provisions for markings similar to 110.24 would be more appropriate for the NEC. 7 of 16
FR 42, Section No. 110.21(A), See FR 42 Affirmative 9 Affirmative with Comment 1 Donald R. Iverson With the following sentence added as the second sentence of the Informational Note: Following the original equipment manufacture s guidance on permitted refurbishing and reconditioning activity is critical to the operational performance of the equipment. Negative 2 It appears the primary intent of this change is to provide traceability of refurbished or remanufactured equipment resold by 3rd parties and used to replace existing equipment. Providing company name and trademark labels on equipment that is regularly maintained and/or refurbished by the owner/operator as part of a regular equipment maintenance program does not enhance the traceability of the work. An industrial exemption should be included that states the following: "In industrial occupancies, where conditions of maintenance and supervision ensure that only qualfied persons service the equipment, the markings indicated in 110.21(B)are not required." Kent A. Sayler The proposed text creates an infeasible requirement for all reconditioned equipment to be marked, without defining what types of equipment maintenance, alterations, or adjustments constitute reconditioning. This is the user s responsibility to ensure the equipment as installed complies with all applicable requirements and is suitable for service FR 43, Section No. 110.21(B), See FR 43 FR 44, Section No. 110.22(C), See FR 44 Affirmative 11 Affirmative with Comment 1 We are concerned that this FR was made referencing a recommended practice that was not published at the time the Panel met. 8 of 16
FR 45, Section No. 110.24(A), See FR 45 FR 46, Section No. 110.25, See FR 46 FR 15, Section No. 110.26(A), See FR 15 FR 17, Section No. 110.26(B), See FR 17 Affirmative 11 Negative 1 Additional signage has not been shown to solve the stated problem. 9 of 16
FR 19, Section No. 110.26(D), See FR 19 FR 20, Section No. 110.26(E)(2), See FR 20 Affirmative 9 Affirmative with Comment 2 In is unclear what "structural overhangs" and "roof extensions" are. These appear to be vague and unenforceable. David L. Hittinger Negative 1 Michael A. Anthony Editorial: Change the wording in (2) (a) to the following. (a) Installation Requirements. Outdoor electrical equipment shall comply with (a)(1)(2) and (3) Although the cases will be rare, to convey the same interior working space conditions into exterior working space conditions is unwise in many campus power systems. FR 21, Section No. 110.26(F), See FR 21 Affirmative 10 Negative 1 This requirement does not need to be carried over from 110.34(C). Suitable guarding of LV parts is already required in 110.27 and addressed directly in 110.27(A). Relocating this requirement and creating an intermediate voltage level of 601 1000V is redundant and may create confusion. This intermediate voltage does not exist in global standards, whith which the COde is attempting to correlate. The NEC should make a "clean distinction" that LV is < =1000V and HV is >1000V. Abstain 1 Michael A. Anthony In some cases, though not all, locked electrical closets present a new safety hazard. The difficulty will be most likely in existing facilities so some retroactive clauses would be helpful. New power systems should be designed with this safety condition up front. 10 of 16
FR 48, Section No. 110.27(A), See FR 48 FR 49, Section No. 110.27(C), See FR 49 Affirmative 11 Affirmative with Comment 1 FR 50, Section No. 110.28, See FR 50 FR 52, Section No. 110.30, See FR 52 We are concerned whether the FR incorporates the correct action word. As written, rooms with exposed live parts are to be marked with warning signs rather than signs with a different action word such as danger. 11 of 16
FR 32, Section No. 110.31 [Excluding any Sub Sections], See FR 32 FR 22, Section No. 110.31(A) [Excluding any Sub Sections], See FR 22 FR 23, Section No. 110.31(B)(1), See FR 23 FR 33, Section No. 110.31(D), See FR 33 Affirmative 11 Affirmative with Comment 1 We recommend adding a definition of "unqualified person" to Article 100 or 110 to correlate with the addition of "unqualified person" in this FR. We propose the following definition from NFPA 70E: "Unqualified Person. A person who is not a qualified person." 12 of 16
FR 24, Section No. 110.33(A)(2), See FR 24 Affirmative 10 Negative 2 We are concerned with "to ground" being removed without substantiation or explanation in the panel statement. David L. Hittinger The wording "to ground" was removed. FR 24 did not include this revision. FR 25, Section No. 110.34(A), See FR 25 FR 26, Section No. 110.34(B), See FR 26 FR 27, Section No. 110.34(C), See FR 27 13 of 16
FR 28, Section No. 110.34(D), See FR 28 FR 34, Section No. 110.34(E), See FR 34 FR 36, New Section after 110.40, See FR 36 Affirmative 10 Negative 2 The proposed new section 110.41 is broad, overly restrictive and falls outside the scope of 90.1(A). There are many elements of a "complete electrical system design" that are not relevant to the practical safeguarding of persons and property from hazards arising from the use of electricity. The proposed text is also unenforceable. Is it the responsibility of the AHJ to review and approve "the complete electrical system design"? The new section also requires the "complete electrical system design" to be tested "when first installed on site". There are many tests conducted on electrical installations that are not relevant to practical safeguarding of persons and property. Also, testing installations "when first installed" may not be practical, or verify the safety of the installation, especially in the case of large projects that may take several years to install and energize. Michael A. Anthony I do not disagree that this kind of information is necessary for a ready to energize system but in many cases the as built condition of the wiring system is not available when the system is needed to continue construction. We should work on this language in the next stage so we retain the safety spirit of the PI without building in complicating inspection conditions for electrical contractors. 14 of 16
FR 30, Section No. 110.73, See FR 30 FR 54, Section No. 110.74, See FR 54 FR 11, Annex A, See FR 11 FR 47, Part II., See FR 47 15 of 16
FR 7, Part II., See FR 7 FR 51, Part III., See FR 51 Affirmative 10 Affirmative with Comment 2 We are concerned that it is not clear that this FR is applicable to Part III of Article 110. David L. Hittinger There may be an error in the the committee statement that refers to Part!! and III. The action on FR 51 is for part III. See statement This revision from 600 Volts to 1000 volts correlates with first revision relative to Article 110 Parts II and III. FR 53, Part IV., See FR 53 FR 29, Part V., See FR 29 For Simple majority and also two third majority election; the simple affirmative votes needed are 7 and the two third affirmative votes needed are 8 16 of 16