Bottle filling stations as appliances?

During the renovation of a new terminal in the local airport, we installed (hardwired) 12 bottle filling stations. An inspector failed each, stating that GFCI protection is required because a bottle filling station is an appliance. That just doesn’t make sense. How would we know that a bottle filling station, which is hardwired, is an appliance? Was the inspector correct?

The inspector is correct. Appliances come in all shapes and sizes, with some cord-and-plug-connected, and others hardwired. See the Article 100 definition of “appliance,” which explains that utilization equipment other than industrial appliances can be fastened in place (as they are in this case), stationary or portable, and they are typically built in standardized sizes or types to perform one or more functions. When in doubt, refer to Section 422.5 for ground-fault circuit interrupter (GFCI) protection of appliances. This requirement for GFCI protection applies to appliances supplied at 150V or less to ground and 60A or less single- or three-phase. 

Section 422.5(A) contains a prescriptive list of appliances that includes automotive vacuum machines, drinking water coolers and bottle filling stations, cord-and-plug-connected high-pressure spray washing machines, tire inflation machines, vending machines, sump pumps and dishwashers. Unfortunately, many installers miss the required GFCI protection in 422.5. 

It is important to note that the GFCI requirement for residential dishwashers existed in 210.8(D) in 2017 and was relocated into 422.5 in 2020. This was not just a simple relocation. As currently written, it now applies to all dishwashers, in all occupancies supplied at 150V or less to ground and 60A or less single- or three-phase.

What is a countertop?

In one housing development, there is an option to put shallow cabinets and a 14-inch countertop on one wall in the kitchen. The general contractor is claiming these are not countertops as addressed in the NEC, there are plenty of other counters and we do not need to comply with 210.52(C). Is that true?

No, Section 210.52(C) applies to all countertops and work surfaces in kitchens, pantries, breakfast rooms, dining rooms and similar areas of dwelling units. Receptacle outlets are required to comply with 210.52(C)(1) through (3). This applies to each countertop or work surface space that is 12 inches or wider. There is no minimum depth provided to qualify a countertop or work surface. Additionally, the Article 100 definition of “countertops and work surfaces” explains that they are a fixed or stationary surface typically intended for food preparation and serving, personal lavation, or laundering, or a similar surface that presents a routine risk of spilling larger quantities of liquids on outlets mounted directly on or in the surface.

Transitioning wiring methods

Is it a violation to use a rigid metal conduit coupling and an MC cable connector to transition from EMT to MC cable? Are special fittings required? If so, can you explain why? It seems to be exactly the same, electrically speaking. There is metal-to-metal contact. Does this apply only to Type MC cable?

Where Type MC cable, other cable assemblies and cables transition to a raceway, Section 300.15 requirements apply. This section mandates a box, conduit body or fitting be installed at each outlet point, switch point, conductor splice point, conductor junction point, conductor termination point, wiring method transition point or conductor pull point, unless otherwise permitted in the first-level subdivisions that follow. 

Section 300.15(F) addresses fittings that are identified for the use of transitioning between a raceway and a cable assembly, instead of using a box or conduit body, only where the conductors are not spliced or terminated within the fitting. The reason that a standard rigid coupling with a cable assembly connector is not permitted is due to how they are tested and listed by research and testing laboratories. Typically, the male threads on fittings such as EMT and Type MC cable connectors are tested for use with locknuts only, and the female threads on couplings, hubs and conduit bodies are tested only for use with threaded rigid conduit. 

Section 300.15(F) requires a fitting identified for the use of transitioning from a raceway to a cable assembly. The definition of “identified” in Article 100 means that the fitting would be recognized as suitable for the purpose of transitioning wiring methods. The informational note that follows explains that listing is one way to determine suitability. There are many listed products that are readily available to transition from EMT to Type MC cable, along with many other variations. 

PLFA power source

Are we required to purchase a red single-pole circuit breaker to supply a low-voltage fire alarm system? We are dealing with punch list items on a job, and we are not exactly sure what the engineer is looking for. Can you help?

Power source requirements for power-­limited fire alarm (PLFA) systems are in Section 760.121. There are multiple requirements for the branch circuit supplying the fire alarm equipment in 760.121(B). The branch circuit supplying the fire alarm system can supply no other loads and must not have AFCI or GFCI protection. The disconnecting means (typically a molded-case circuit breaker) must have red identification, be accessible only to qualified people and be marked “FIRE ALARM CIRCUIT.” The required red color marking must not damage the circuit breaker or obscure the manufacturer markings. The location of the branch circuit overcurrent protective device (OCPD) protecting the fire alarm system must be permanently identified at the fire alarm control panel.

The NEC permits the fire alarm branch circuit disconnecting means (typically a circuit breaker) to be secured in the “on” position, while NFPA 72 (see Section 10.6.5.4) requires an approved circuit breaker locking device be installed. There are many devices that are red, and properly marked, that secure the device in the closed position and are readily available to place over the circuit breaker to comply with these requirements.

Pools and gas-fired water heaters

Does a hardwired, gas-fired water heater, requiring a 120V, 15A circuit, for a residential swimming pool need GFCI protection where it is installed in a pool house? There is no receptacle, and it is not outdoors, so 210.8(F) would not apply. 

Yes, see Section 680.28, which requires all branch circuits supplying gas-fired water heaters associated with swimming pools and spas be provided with GFCI protection. This requirement is not limited to residential occupancies, nor does it address just indoors or outdoors. All circuits that serve gas-fired water heaters for pools and spas above the low-voltage contact limit must be GFCI-protected.

Does the NEC require replacement?

We are renovating an older apartment that is being converted to condominiums. The existing panelboards and circuit breakers are 30 years old, and the wiring method is Type AC cable. Does the Code require replacing all of the existing Type AC cable with Type MC cable, which would include an equipment grounding conductor? 

The NEC does not contain a blanket requirement to replace older equipment. In all cases, the owner, installer and designing engineer must make those decisions. During a complete renovation, it is always a good idea to replace everything, but it is not an NEC requirement. The scope of work in this installation will likely require new branch circuits, extensions of existing branch circuits, new devices and new lighting outlets. This will require AFCI protection in accordance with 210.2 and 210.12(E). This may require replacing all panelboards and existing OCPDs to achieve AFCI protection, as the older equipment may not be compatible with these devices. The jacket of Type AC cable is recognized as an EGC; see 250.118(A)(8).

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