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AFCIs at a Limited-Care Facility: Navigating Code terminology and applications

By Kyle Krueger | Jul 15, 2024
AFCIs at a Limited-Care Facility: Navigating Code terminology and applications

In the realm of electrical safety, the arc-fault circuit interrupter (AFCI) stands as a crucial defense mechanism against potential fire hazards. However, misconceptions and errors persist in applying AFCI requirements.

In the realm of electrical safety, the arc-fault circuit interrupter (AFCI) stands as a crucial defense mechanism against potential fire hazards. However, misconceptions and errors persist in applying AFCI requirements.

With various states adopting different versions of the National Electrical Code (NEC), evolving AFCI requirements can pose challenges for contractors and authorities having jurisdiction (AHJs). This case study explores a contractor’s experience grappling with AFCI protection mistakes and highlights the importance of correctly applying Code requirements.

AFCI protection first appeared in the 2002 NEC and was limited to dwelling unit bedroom outlets rated 125V, single-phase, 15A and 20A. In the 2023 NEC, nearly every outlet rated 120V, single-phase, 10A, 15A and 20A in a dwelling unit is required to have AFCI protection. These requirements have expanded to occupancies such as dormitories, hotel and motel guest rooms/suites, patient sleeping rooms in nursing homes and limited-care facilities and sleeping quarters in fire and police stations.

A midsize electrical contractor’s crew progressed smoothly through the rough wiring stages of a 150-unit limited-care facility without any Code or inspection-related issues. With the units nearly finished, the foreman called the AHJ in for the first round of unit final inspections. As they walked through, the AHJ asked about AFCI protection. The foreman explained that the project bid did not include this additional cost. They believed it wasn’t necessary, citing the state’s adoption of the 2017 NEC, which did not mandate AFCI protection in limited-care facilities. This gave the inspector pause, triggering a request for more information on the layout and use of each unit. The inspector would then provide a decision.

Each unit consisted of a sitting area with a TV, sleeping room, food prep area with cooktop and microwave and a bathroom. Upon receiving detailed unit layouts, the inspector clarified that AFCI protection wasn’t required because the units were part of a limited-care facility, but because they met the NEC definition of a dwelling unit: “A single unit, providing completed and independent living facilities for one or more persons, including permanent provisions for living, sleeping, cooking, and sanitation.”

The inspector explained that Section 210.12(A) requires AFCI protection for all 120V, single-phase, 15A and 20A branch circuits supplying outlets in kitchens, family rooms, dining rooms, living rooms, parlors, libraries, dens, bedrooms or similar areas in dwelling units. The foreman had to come up with a solution to provide AFCI protection for these rooms/areas for all 150 units.

Several weeks later, the foreman was ready for reinspection of the initial stage of completed units to confirm the necessary AFCI protection was in place. The inspector discovered that certain electrical equipment—including luminaires and the in-wall heating unit installed in the living room space—lacked AFCI protection. The foreman questioned the findings, as AFCI protection was in place in accordance with what was discussed after the first inspection. Once again, this discrepancy came down to a misunderstanding of defined terms in the NEC. While many used the term “outlet” to refer to receptacle devices, the NEC defines it as “a point on the wiring system at which current is taken to supply utilization equipment.” This can be a receptacle outlet, lighting outlet or any equipment outlet supplied by a 125V, 15A or 20A, single-phase branch circuit in the areas specified in Section 210.12(A).

The foreman now had to strategize how to provide protection for these initial units and plan for compliance in the remaining ones. Rectifying the oversight proved costly, with the contractor bearing the expenses for materials and labor to implement corrections. Considering the resulting time delays, absorbing these costs was a prudent measure to maintain credibility with the general contractor and client. The financial impact was substantial, with the expense for materials alone ranging from $40,000 to $50,000 for 150 units.

Lessons learned

How can this expensive oversight be prevented? Several key factors from a Code application standpoint offer valuable lessons:

  • Not all states or jurisdictions enforce the same NEC edition. If you are a contractor working across multiple states, be aware of this. Going with the most recent edition of the Code is not always the safest play. Newer versions of the Code may be less restrictive than previous ones. In addition, many states, cities and municipalities will adopt rules or ordinances that amend the NEC. Contact the local AHJ when working in an unfamiliar area. Visit NFPA’s NEC enforcement maps to see NEC adoption by state.
  • Know your definitions! The use of “trade names” for equipment or devices can lead to habitual use of incorrect terminology. It seems routine, but enforcement of requirements often comes down to defined terms. Getting in the habit of using the correct terms can go a long way in preventing expensive mistakes.
  • Training. The aforementioned items are reinforced with regular Code update training. Many local inspector associations, JATCs and technical colleges provide state-specific Code update training.

Ensuring the proper application of AFCI requirements is paramount for electrical safety. While the costs of AFCI protection are quantifiable, the consequences of neglecting it are immeasurable.

CC BY-SA 4.0, via Wikimedia Commons

About The Author

Kyle Krueger headshot

Kyle Krueger

Executive Director of Codes and Standards

KRUEGER is NECA’s executive director of codes and standards. He has worked in the electrical industry for over 25 years as an inside wireman, authority having jurisdiction and educator. Kyle currently represents NECA on the NEC Correlating Committee, Code-Making Panel 3, NFPA 72 Correlating Committee, NFPA’s Electrical Section Executive Board and the UL Electrical Council. Reach him at kkrueger@ necanet.org.

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