In March, I attended a Central Arizona Chapter International Association of Electrical Inspectors (IAEI) meeting. A discussion ensued about the growing number of improperly installed and uncertified light-emitting diode (LED) retrofit lighting kits. In fact, Underwriters Laboratories (UL) just issued a public notice to warn of these dangers. The notice can be found in the newsroom at www.ul.com.


Article 410.6 in the 2014 National Electrical Code (NEC) requires LED retrofit kits to be listed for installation in luminaires. Article 600.3 requires fixed, mobile or portable electric signs, section signs, outline lighting and LED retrofit kits for signs, regardless of voltage, to be listed, provided with installation instructions and installed in conformance with that listing, unless otherwise approved by special permission in writing by the authority having jurisdiction. 


Having discussed the NEC installation and listing requirements, the IAEI group was then shown pictures of improper LED-retrofit-kit jobs. Many of these installations were an attempt to upgrade or retrofit existing luminaires to create more energy-efficient lighting. Instead, some of these installations resulted in potential fire or shock hazards.


How could an installation, meant to modernize and provide higher efficiency lighting, go so terribly wrong? Surely an electrical contractor (EC) would not knowingly create a fire or shock hazard. So where did the installers go wrong, and what happened to the electrical inspections designed to ensure electrical safety? 


Many of these installations may not have been installed by ECs. Instead, they may have been installed by big-box-store contractors who specialize in retrofits, and they may have occurred without the issuance of electrical permits.


Many electric utilities have pushed to replace incandescent and fluorescent luminaires with LED lighting. Rebates and tax incentives are often offered to commercial and industrial customers to encourage these changes. Unfortunately, the retrofit-kit installation is often done without permits or inspections. Electric utility companies should be encouraged to require permit information as part of the completed rebate and tax submittals to ensure proper inspection of the retrofits has occurred.


Many ECs may not know about listed retrofit kits for incandescent and fluorescent luminaires, recess cans, exit signs, emergency lights and others. A typical LED-retrofit-kit luminaire conversion consists of parts or assemblies intended for field installation in listed luminaires, office furnishing luminaires or portable luminaires. These products have been investigated to determine that, when installed in accordance with the manufacturer’s instructions, the conversion continues to comply with the listing requirements for a complete luminaire.


Conversion kits can include reflector kits and other devices to enhance luminaire operation after the installation of the LED units. Reflector kits are intended to add or replace the reflectors originally installed in fluorescent luminaires and may also involve relocation, removal or replacement of wiring, lampholders and ballasts. The wiring, lampholders, ballasts, LED units and power supplies must still be enclosed inside the luminaire housing in accordance with the manufacturer’s instructions as well as with the listing and labeling instructions.


The following information is located on page 228 in the 2016 UL White Book as it relates to LED luminaire retrofit kits in Category IFAR: “These kits consist of LED light sources, installation instructions, subassemblies (LED drivers, or other parts where appropriate), luminaire marking labels, and assembly aids (where appropriate) to facilitate the replacement of the existing light sources for complete luminaires. The kits may also consist of the replacement and/or upgrade of existing LED luminaire components, such as LED drivers, LED arrays, and other required parts, for complete luminaires. The retrofit installation may require modifications to the luminaire in accordance with the installation instructions provided with the retrofit kits.”


The retrofit kits may be intended for specific luminaire models identified in the installation instructions or one or more generic-type luminaires that meet specific criteria identified in the installation-kit instructions. In addition, the retrofit kits may be offered by the original equipment manufacturer (OEM), or by manufacturers engaged in producing retrofit kits for the general market.


A luminaire that is modified so it can no longer accept non-LED lamps has a label—provided by the retrofit kit manufacturer—affixed to the luminaire. It must be visible during relamping and indicate the luminaire has been modified and can no longer operate the originally intended lamp(s). In addition, the luminaire markings must identify the replacement LED lamp type and model to be used together with the manufacturer’s name and ordering information.


Remember, retrofit kits are required to be listed and must be installed based on the installation instructions included in the kit.