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90-3. Code Arrangement
This Code is divided into the introduction and nine chapters. Chapters 1, 2, 3, and 4 apply generally; and Chapters 5, 6, and 7 apply to special occupancies, special equipment, or other special conditions. These latter chapters supplement or modify the general rules. Chapters 1 through 4 apply except as amended by Chapters 5, 6, and 7 for the particular conditions.
Chapter 8 covers communications systems and is independent of the other chapters except where they are specifically referenced therein.
Prior to the start of the 2002 National Electrical Code (NEC) cycle, a task group was formed under the direction of the Technical Correlating Committee to review the history of the “independent” status that has existed in the arrangement of the Code for Chapter 8.
Specifically, the task group was asked to consider whether such status should continue for the communication systems contained within Chapter 8 or if other measures should be taken to ensure that all applicable provisions of the Code are adequately addressed in Chapter 8. The basis for this review was three comments, which were held by Code Making Panel 1 (CMP-1) during the 1999 NEC cycle.
Background
The Task Group on Communication Systems was able to trace the origins of the independent status back to 1937. Unfor-tunately, there was no Technical Committee Report or Technical Committee Documen-tation available to review regarding the original substantiation for the provision. During the Task Group’s deliberations, it became apparent that there was not sufficient technical substantiation, at the present time, to warrant removing the independent status for Chapter 8 as provided for in Section 90-3.
The Task Group did, however, reach a broad consensus that there were significant concerns about the lack of understanding of how communication systems fit within the broader context of the Code. Specifically, the Task Group identified that this lack of understanding led to a significant problem with enforcement of existing Code provisions for communications systems.
Findings
The Task Group on Communications Systems’ discussions identified three areas of Article 90 that they believed resulted in an inadequate enforcement of the provisions of Chapter 8 of the Code.
90-2. Some users of the Code do not identify signaling and communications conductors and equipment as part of the electrical installation. Specifically, the Task Group has determined that some communications systems installations may not be subject to inspection because of this confusion.
90-3. The word “independent” has been misinterpreted to imply that communications systems are not covered by the Code and, therefore, not subject to inspection by the authority having jurisdiction.
90-4 There may be users of the Code who fail to understand that signaling and communications conductors and equipment are included in the scope of enforcement as stated in Section 90-4.
2002 NEC Proposals
The Task Group submitted three proposals specifically addressing these areas of concern.
The first resulted in a revision to Section 90-2(a), which now reads in part; 90-2(a) Covered. This Code covers the installation of electric conductors, electric equipment, signaling and communications conductors and equipment, and fiber optic cables and raceways for the following:
This revision was meant to clarify that signaling and communication conductors and equipment are in fact and have always been intended to be within the scope of the Code. A close reading of the five specific items mentioned in 90-2(a) of the 1999 Code led some to incorrectly believe that these conductors and associated equipment were never intended to be covered by the Code.
Secondly, 90-3 was revised by deleting the word “independent.” The proposed revision now reads, “Chapter 8 covers communications systems and is not subject to the requirements of Chapters 1 through 7 except where they are specifically referenced in Chapter 8.”
The deletion of the word independent was intended to merely change a perception, without altering the provision. While such a change may appear to be insignificant, it was made to clarify that Chapter 8 is not an entity in and of itself. In other words, there are specific references to these provisions that must be followed, even though the conductors or equipment are covered by the scope of Chapter 8.
Lastly, 90-4 was revised to clarify that Chapter 8 systems are subject to the same enforcement provisions in 90-4 of any other electrical systems. The proposed wording in the first sentence of 90-4 is as follows, “(T)his code is intended to be suitable for mandatory application by governmental bodies that exercise legal jurisdiction over electrical installations, including signaling and communications systems, and for use by insurance inspectors.”
Once again, the intent was merely to clarify that the installation of communication system conductors and equipment must be subjected to inspection, which is inspected again by the Authority Having Jurisdiction.
Analysis and conclusion
Taken together, these three proposals should remove all doubt that the independent status that was afforded to Chapter 8 over 60 years ago was never intended to remove them from scope of the Code and the subsequent inspection and enforcement. Unfortunately, during the past 60 years, some have mistakenly believed that “anything goes” with these systems. This has led to the unfortunate practice, at least in some parts of the country, of allowing unqualified electrical contractors using unqualified persons to install these systems.
It is not uncommon to find that these “contractors” appear mysteriously on job sites and install these systems unbeknownst to anyone but the owner. This often results in installations that do not meet the minimum provisions of the NEC and ultimately installations that, as far as the AHJ is concerned, never see the light of the day and are never inspected.
These proposals are merely a first step, but an important one. As communication systems evolve and become more complex, the need for independent status for Chapter 8 may have to be re-evaluated. In the meantime, the future of these systems and equipment lies with the members of CMP-16 of the Code. Clearly, they have the expertise and ability to ensure that all the necessary rules and provisions for these systems are included within the appropriate article in Chapter 8.
Specifically, two outcomes must be sought. First, if the Code arrangement provided for in 90-3 is to remain unchanged, CMP-16 needs to ensure that as these communication systems evolve and emerge, the requisite provisions are self-contained within the article.
Second, the electrical industry must educate our customers that these systems fall within the scope of the Code. Therefore, they must ensure that these systems are installed by qualified electrical contractors, using qualified personnel and ultimately, inspected by qualified electrical inspectors.
CALLANAN is director of Safety, Codes, & Standards at the National Joint Apprenticeship & Training Committee. He can be reached at [email protected].