Based on a new requirement in Section 210.8(B)(5) of the 2008 National Electrical Code (NEC), all 125-volt, single-phase, 15- and 20-ampere receptacles installed within 6 feet or 1.8 meters of the outside edge of a sink in a commercial or industrial facility must be covered by ground-fault circuit interrupter (GFCI) protection for personnel. The purpose of this new requirement is to provide much-needed GFCI protection for receptacles in areas close to floor sinks, hand-washing sinks, mop sinks, as well as sinks in lunchrooms, janitors’ closets, classrooms, and other similar locations. Two exceptions were added as part of the new requirement for the 2008 NEC; however, some industry people believe at least one of the new exceptions may lead to lack of GFCI protection in areas where that protection should still be provided.

The two exceptions, added as part of the new requirement for the 2008 NEC, apply to laboratories and healthcare facilities. The first new exception ensures that certain receptacles, located within 6 feet of sinks and used to supply equipment in industrial laboratories where removal of power would introduce a greater hazard, would not be required to have GFCI protection. For example, in an industrial laboratory, a receptacle, within 6 feet of a sink and supplying power to a refrigerator containing chemicals that could auto-ignite at room temperature, could be excluded from the GFCI requirement, since losing power could create a greater hazard.

Any 15- or 20-ampere, 125-volt receptacle located within 6 feet of the same sink, but not supplying power to a critical load, must be GFCI-protected. In applying this rule, the receptacle supplying power to the critical load, such as the refrigerator described in the example, must be a single receptacle, not a duplex receptacle, since only one of the receptacles of the duplex would be used for the refrigerator, leaving the other receptacle of the duplex without GFCI protection. The duplex receptacle could be split-wired with the connecting tabs on both sides of the receptacle removed, and two hots, each with their own neutral, could be installed. However, unless a GFCI receptacle was installed upstream protecting one of the circuits, compliance with 210.7(B), requiring both circuit breakers to be tied together with a tie bar, would not be possible.

The second new exception excludes GFCI protection for any 15- or 20-ampere, 125-volt, single-phase receptacles located within 6 feet of sinks in patient care areas of any healthcare facility. The new second exception reads as follows: “For receptacles located in patient care areas of healthcare facilities other than those covered under 210.8(B)(1), GFCI protection shall not be required.”

As noted in the text in the new exception, bathroom areas in healthcare facilities, covered by 210.8(B)(1) and not covered by 517.21 for critical care areas, must still comply with the GFCI requirement for protection of receptacles. The new exception would permit any 15- or 20-ampere, 125-volt single-phase receptacle installed within 6 feet of any sink within a healthcare facility to be installed without GFCI protection, including those receptacles within 6 feet of floor sinks, hand washing sinks in medical and dental doctor’s examining rooms, mop sinks, as well as sinks in lunchrooms, janitors’ closets, ambulatory healthcare facilities, nursing homes and similar locations.

During the 2008 NEC process, numerous comments from healthcare professionals expressed concerns with GFCI protection within 6 feet of hand washing sinks in patient areas, such as general care and critical-care bed locations. Substantiation in the comments expressed concern over GFCI protection for receptacles used for life support, monitoring and other critical loads where interruption of power might jeopardize the patient.

Receptacles located within 6 feet of sinks and not being used for “critical” power in patient bed locations, should be required to have GFCI protection so Code-Making Panel 2 has accepted proposals for the 2011 NEC to modify this broad application and provide more specific GFCI requirements for healthcare installations and facilities. The text that has been accepted at the proposal stage for the 2011 NEC process is as follows: “For receptacles located in patient care areas bed locations of general care or critical care areas of healthcare facilities other than those covered under 210.8(B)(1), GFCI protection shall not be required.”

As you can see, the words “care areas” have been struck and the words “bed locations of general care or critical care areas” have been added. If Code-Making Panel 2 continues to accept the revised text through the comment period, GFCI protection will be required for 15- and 20-ampere, 125-volt, single-phase receptacles within 6 feet of any sink in a healthcare facility, except those at general or critical patient care areas.

Ode is a staff engineering associate at Underwriters Laboratories Inc., in Research Triangle Park, N.C. He can be reached at 919.549.1726 and mark.c.ode@us.ul.com.