In the late 1950s and early 1960s, Kodak, then the largest manufacturer of film and cameras, began a product promotion with a series of Christmas-themed advertisements with the tagline “Open me first.” The ad encouraged unwrapping the camera first in order to capture the rest of the merriment on film.
Paraphrasing their effective marketing concept, I titled this column “Read Me First,” because time is running short for my message about the 2023 NEC cycle. If you miss NFPA’s Sept. 10, 2020, deadline (yes, that is next month), you may be out of luck for three more years! So, read this first, unless you are an old hand at submitting proposals/public inputs for the NEC .
During my time at NFPA, I found that most of the proposals or comments on the NEC were submitted toward the end of the open period of submission. The good news is that no one will know when you submitted your idea.
I submitted two public inputs for 2023 and I will describe the process here.
Listed and labeled
My first input is about the combined term “listed and labeled.” Both terms are defined in Article 100. Both also have a unique status in the NEC and other NFPA documents because they are both the responsibility of the NFPA Standards Council. This means that only the council can make changes to them.
These two terms are defined as follows:
Listed: Equipment, materials or services included in a list published by an organization that is acceptable to the authority having jurisdiction and concerned with the evaluation of products or services, that maintains periodic inspection of production of listed equipment or materials or periodic evaluation of services and whose listing states that either the equipment, material or service meets appropriate designated standards or has been tested and found suitable for a specified purpose.
Informational note: The means for identifying listed equipment may vary for each organization concerned with product evaluation, some of which do not recognize equipment as listed unless it is also labeled. Use of the system employed by the listing organization allows the authority having jurisdiction to identify a listed product.
Labeled: Equipment or materials to which has been attached a label, symbol or other identifying mark of an organization that is acceptable to the authority having jurisdiction and concerned with product evaluation, that maintains periodic inspection of production of labeled equipment or materials, and by whose labeling the manufacturer indicates compliance with appropriate standards or performance in a specified manner.
Informational note: If a listed product is of such a size, shape, material or surface texture that it is not possible to apply legibly the complete label to the product, the complete label may appear on the smallest unit container in which the product is packaged.
It strikes me that when both terms are used together, the intent is that the product be labeled. On its own, that term would suffice. However, the term “labeled” is commonly used to denote a number of things that have nothing to do with product certification. Perhaps “labeled” isn’t needed in the NEC at all. Could the definition of listed be replaced with the definition of labeled? That would require action by the NFPA Standards Council, which isn’t an impossibility, but it is a higher peak to climb. The goal of combining both two terms is to require that products have certification markings, either on the product or on its smallest shipping container. An example of a small product requiring a listing mark on a small container is a wire nut. Since the NEC Style Manual and the NFPA Manual of Style both prohibit definitions from containing requirements, and the goal is to have the certification mark, that should be written in the form of a requirement. More on that later.
The next item deals with the organization of Chapter 5 of the NEC , “Special Occupancies.” Articles 500 through 516 address hazardous (classified) locations. Part IV of Article 517 on healthcare facilities covers flammable anesthetizing locations, which are also hazardous locations. However, the use of flammable anesthetics has been prohibited for decades. Article 500 covers general rules for hazardous locations. The traditional installation requirements for Class I, II and III locations are covered in Articles 501, 502 and 503 respectively.
In 1990, Article 504 was created for intrinsically safe systems, because the traditional requirements of articles 501–503 were not necessary for intrinsically safe equipment. In the 1996 Code , Article 505 was created as an alternative classification scheme using the zone classification system of the International Electrotechnical Commission (IEC). Article 505 introduced zones 0, 1 and 2 for Class I locations. Finally, in the 2005 Code , an IEC-based zone classification scheme was also created in Article 506 that consolidated Class II and III locations into zones 20, 21 and 22.
Articles 510 through 517 address specific occupancies. These articles are mostly extracted requirements of other NFPA standards. They have a unique status because the extracted requirements can’t be changed through the NEC -revision process; they must be changed through the revision process of the originating document. There have been no new articles in this grouping in more than 10 cycles. Yet, there are other occupancy standards that do not have extracted requirements in the NEC . Article 510 is the oddball in Chapter 5. Its very existence violates the NEC Style Manual. It only exists to introduce articles 511 through 517. Nowhere else in the Code do we have an article whose sole purpose is to introduce other articles without having any requirements of its own.
My recommendation will be to delete it. Its deletion will open a space where an additional occupancy article could be placed, if one is needed in the future.
Submit changes here
You can only submit suggested changes to the NEC online at www.nfpa.org/70next. In the middle of the page in red text is the note: “The next edition is now open for input.” Clicking “Submit a Public Input” takes you to a page to sign in or create an account. The link will also confirm when your public inputs have been entered into the system and when it has been submitted.
Once you sign in, you will see a NEC table of contents in the left-hand column, which begins with Article 90, and the titles of the nine chapters and annexes. It is not necessary to rekey existing text; you can simply modify or delete existing text. This is a real time-saver and minimizes errors. To get to the specific text in question, you can drill down in the table of contents by clicking on the plus sign. (Fig. 1) For my first public input, I would select “Chapter 1,” then “Article 110” and then “110.3” Since the subject is a requirement for listing, I selected 110.3(C), “Listing.” I decided to add my new text at the beginning of the sentence.
After selecting the first choice, the existing text is displayed with a background watermarked with the word “draft” (see Figure 2). This is the screen where I will add my new text. After the text is entered, select “next.” This shows the text in a legislative format. I then have the opportunity to upload additional related changes, if I have any.
Selecting “next” again brings me to a screen where I need to present my substantiation for the public input. This screen also presents an opportunity to submit additional supporting material. The following screen is where the submitter information is verified. This allows me to use the same information for all submissions. It also permits a submitter to have different affiliations for different public inputs.
The final step gives NFPA copyright permission to use the material submitted. It also certifies that you have the copyright permission to use what you submitted. Since many of us aren’t familiar with copyright law, if something you submitted looks like it might be copyrighted by someone else, NFPA staff may question whether or not you have permission. Red flags for copyright include tables, reports and articles authored by others.
My submission for Article 510 is much simpler. The first step is to open Chapter 5, expand it and then select Article 510. When the text box opens, choose the article title, which will select the entire article. When the draft screen appears, delete all of the text. All of other steps are the same, including substantiating the deletion and the copyright release.
Once you have submitted public inputs, you will see how simple the process is. Most of the screens allow you to save your work. You can start now and finish it later. After you have submitted a public input, you have until the document closing date to modify it or delete it.
A word of caution: If you open something that you have already submitted, you may change its status so that it is no longer a submitted public input. If you want it to remain a submitted public input, continue through all of the screens through the copyright release and click submit.