For the first time in 34 years, I am participating in the National Electrical Code process as an active submitter of public input. For most of my career, I was unable to submit input or comments because my role was to remain a neutral arbiter of the Code. I set up the committee meetings and recruited staff to work with the panels. I oversaw balloting and arranged for correlating committee reviews of the reports. I worked with the editorial staff to implement Code changes and to identify inconsistencies and other problems.
Being a Code geek, I looked at proposals and comments as they came in to see what was coming up for the new cycle. This cycle, I relied entirely on the rumor mill as to what was happening until NFPA staff made the file public. While they would like to do this immediately after the closing date, they need to review the files to ensure that no submission violates copyright law. Specifically, they are looking for submissions that include tables, reports, photographs, trade journal articles or anything else that may be copyrighted by someone else.
Each submitter must electronically sign a statement that indicates that they have copyright permission for the submission and that NFPA is given permission to publish the material online. This is critical because once the material is published, it is available to everyone.
However, most of us are not experts in copyright law. It is easy to submit material to support a position that was published elsewhere, not realizing that it is a copyright violation. NFPA staff contacts the submitter of any material that appears to have originated elsewhere to ask that person to contact the copyright owner to see if they can obtain permission to publish the material online. The submitter has a limited amount of time to obtain permission. If it can’t be obtained, under normal conditions, the staff would bring one copy of the material to the committee meeting so that the members can review it. If it is a detailed 300-page report, the members of the panel would not have the time to review it. It is best to try to get permission ahead of time. This cycle, reviewing copyrighted material could be difficult.
Like so many things in 2020, this cycle will not be like any other. All of the meetings will be held virtually by video conference in two, three-week blocks. The first starts on Nov. 30. The second starts Jan. 4, 2021.
Here are some of the public inputs that I found interesting.
Article 100 has been the repository for definitions that are used in more than one article. Other definitions are located in the second section (xxx.2) of many of the articles. There are public inputs to move all of the definitions to Article 100. If a definition only applies to a single article, that article number will be shown parenthetically after the term. In addition, if there is an associated acronym, it will be included in the definition.
During the 2017 cycle, requirements for reconditioned electrical equipment were introduced. The NEC required such equipment to be identified with a label indicating who did the reconditioning and when. The 2020 Code greatly expanded the coverage of reconditioned equipment by specifically stating which equipment is permitted to be reconditioned and which is not. It also provided a definition of “reconditioned” that distinguishes reconditioned equipment from routine equipment maintenance. A task group did extensive work between cycles to fine-tune the requirements for reconditioned equipment for the 2023 cycle. The result is proposed changes to the definition for “reconditioned” and to the requirements in 110.21(A)(2).
Medium-voltage equipment has always been within the NEC’s scope. However, the requirements never appeared to be complete. One area in need was outside overhead distribution. Overhead distribution requires preventing hazards from icing, sag and wind. Many of these topics are dealt with in the National Electrical Safety Code. In the 2014 NEC, new article 399 was created to address some of the outdoor distribution that is covered by the NEC. Instead of trying to repeat all of that information, the article was written in performance-based language that allowed the use of existing standards.
For the 2023 cycle, a task group has worked to expand and clarify medium-voltage requirements. The principal deliverable will be to make it clear which requirements apply to medium voltage. The demarcation point will be 1,000V AC and 1,500V DC. Rather than having separate parts for medium- or high-voltage requirements, several new articles have been proposed, including Articles 255, 305 and 315.
For example, medium- or high-voltage services are proposed to be located in a new Article 235. Overcurrent and overvoltage requirements for medium- and high-voltage installations are proposed to be in a new Article 245. Medium- and high-voltage grounding and bonding requirements would be in Article 255.
A new wiring method, flexible bus systems, has been proposed as Article 371. Flexible bus systems are defined as: an assembly of flexible insulated bus, with a system of associated fittings used to support and terminate the bus. Each installation will be an engineered system. Supporting hardware will include components that are listed for support of flexible bus systems.
There are public inputs that address relocating and reorganizing requirements. The last major reorganization took place in the 2002 cycle, when Chapter 3 was reorganized. There were a lot of articles that did not cover wiring methods, including boxes, switches and switchgear. This equipment more closely aligned with the scope of Chapter 4, where it was moved in that cycle.
The articles remaining in Chapter 3 were reorganized and like wiring methods were located together. A standard format was adopted to simplify locating similar requirements. Prior to the reorganization, new articles went into the Code where we had room for them. The reorganization was built so that space was created for future expansion by ensuring that there were gaps in numbering. This cycle, there are a number of public inputs to reorganize the articles in Chapters 4, 6 and 7. The proposed order is:
- 689 On-Site Energy Sources (Currently Article 705)
- 690 Solar Photovoltaic (PV) Systems (Existing)
- 691 Large-Scale Photovoltaic (PV) Systems (Existing)
- 692 Fuel Cell Systems (Existing)
- 693 Generators (Currently Article 445)
- 694 Wind Electric Systems (Existing)
- 695 Energy Storage Systems (Currently Article 706)
- 696 Storage Batteries (Currently Article 480)
A task group has proposed removing the Class 1 requirements from Article 725 and creating a new Chapter 7 article for Class 1 circuits. Class 1 circuits have little in common with Class 2 and 3 circuits. Class 1 circuits are covered by Chapters 1 through 4. The public input notes that Class 1 circuits are not recognized by the IT industry as power-limited. They have little in common with Class 2 and 3 circuits.
Class 4 systems have been proposed for a new Article 726. A typical Class 4 system will be used to provide power for 5G high-speed internet transceivers.
A new article, “Cables for Power-Limited Circuits,” is proposed for Chapter 7, which will consolidate all the listing and installation requirements for wires, cables, cable routing assemblies and communications raceways from all of the articles in Chapters 7 and 8 that contain similar requirements. This will eliminate a lot of duplication.
A task group recommended relocation of Article 727, Instrument Tray Cable, into Chapter 3 as Article 341. When it was originally proposed as a new article, it was proposed in Chapter 3. The correlating committee decided at the time to assign it to CMP 16 and locate it in Chapter 7.
As I promised in a previous column, I submitted a public input to delete Article 510. It is my position that it doesn’t contain anything of value and eliminating it provides more space to add more helpful occupancy-specific hazardous location requirements. The occupancy-specific articles usually extract area classification information from other NFPA standards, that make it easier to apply the NEC.
I also submitted a public input to require all listed equipment to have a certification marking on the equipment or on the smallest shipping carton. This is in lieu of numerous requirements for equipment to be “listed and labeled.” These two terms overlap in meaning. I know of no circumstances under which the certification mark is not desirable.
These are just a few of the interesting ideas that have been proposed for the next edition. A lot can happen between this point and final publication of the next Code. Some of these concepts will undergo extensive fine-tuning between now and then, while some will not make it. Stay tuned to see what happens!