PLEASE HELP! Need to change the SOPs, per NEMA

[Kate Tarasenko]

Howdy, Folks --

We've received a three-page letter from NEMA today calling us out on some language in our Residential SOP (and probably also our ComSOP) regarding a passage in our electrical section.

Here's the passage in question:

2.7 Electrical
I. The inspector shall inspect:

H. a representative number of switches, lighting fixtures and receptacles, including receptacles observed and deemed to be AFCI-protected during the inspection using an AFCI-tester, where possible.

The phrase that got NEMA's attention (and subsequent request for amendment) is "AFCI tester." They write:

The standard is unclear regarding the purpose of conducting a test using an "AFCI tester," officially listed as an AFCI indicator. Is it to determine if an AFCI circuit breaker has been installed on a circuit that would require AFCI protection in accordance with the NEC, or is it to determine if the AFCI function of the circuit breaker is functioning? Neither of these purposes can be definitively determined using an "AFCI tester." In fact, using an AFCI tester/indicator may yield confusing and conflicting results.

Here's the link to the entire letter, for those who want to get the full context: http://www.nachi.org/documents/nema-internachi-april-2010.pdf

We have some ideas about how to fix this, but WE WANT YOUR INPUT!

[Bruce A. King]

I agree, changes are needed but technically it says "where possible" and we are only required to "substantially" follow the nachi SOP. We do have to follow our state SOPs to the letter unless agreed otherwise with the client.


The SOP should indicate that arc fault breakers will be tested with the device test button when possible depending on the presence of tenant equipment in use.

[Michael Larson]

II. The inspector is not required to:
A. insert any tool, probe or device into the main panelboard, sub-panels, distribution panelboards, or electrical fixtures.

[Robert Meier]

Originally Posted by mlarson

II. The inspector is not required to:
A. insert any tool, probe or device into the main panelboard, sub-panels, distribution panelboards, or electrical fixtures.

Are you saying that you would call a receptacle an electrical fixture?

For AFCI and GFCI's the recommended testing procedure is to use the test button on the device and not any type of plugin tester. Here's what Ul says about listed testers:

OUTLET CIRCUIT TESTERS (QCYU)
GENERAL
This category covers portable devices with fixed attachment plug blades, or probes attached to flexible leads, used to indicate various wiring conditions in 15 or 20 A branch circuits by a pattern of lights or other similar means along with markings or instructions to identify the probable wiring conditions which cannot be determined by the tester. The devices may include provisions for checking the functions of a ground-fault circuit interrupter (GFCI) connected to the branch circuit, or for indicating that a branch circuit is connected to an arc-fault circuit interrupter
(AFCI).
AFCI indicators operate by producing a waveform similar to an arc fault. Since these devices cannot produce an actual arc fault, an AFCI indicator may not trip every AFCI. AFCI indicators are provided with markings or instructions that state the following or equivalent: ‘‘ CAUTION: AFCIs recognize characteristics unique to arcing, and AFCI indicators produce characteristics that mimic some forms of arcing. Therefore the indicator may provide a false indication that the AFCI is not functioning properly. If this occurs, recheck the operation of the AFCI using the test and reset buttons. The AFCI button test function will demonstrate proper operation.’’
These devices are not intended for use as comprehensive diagnostic instruments.
RELATED PRODUCTS Ground-continuity-indicating devices constructed integral with cord connector bodies for use on construction sites are covered under Attachment Plugs, Fuseless (AXUT) as ‘‘cord-connector bodies.’’

ADDITIONAL INFORMATION
For additional information, see Electrical Equipment for Use in Ordinary Locations (AALZ).
REQUIREMENTS
The basic standard used to investigate products in this category is UL 1436, ‘‘Outlet Circuit Testers.’’
UL MARK
The Listing Mark of Underwriters Laboratories Inc. on the product, or the UL symbol on the product and the Listing Mark on the smallest unit container in which the product is packaged, is the only method provided by UL to identify products manufactured under its Listing and Follow-Up Service.
The Listing Mark for these products includes the UL symbol (as illustrated in the Introduction of this Directory) together with the word ‘‘LISTED,’’ a control number, and the product name ‘‘Circuit Tester.’’

[Michael Larson]

Are you saying that you would call a receptacle an electrical fixture?

Technically no but the intent seems clear that no probes or test apparatus are required anywhere.

Do most of us use them? Yes. Does the SOP require it? No.

II. The inspector is not required to:
A. insert any tool, probe or device into the main panelboard, sub-panels, distribution panelboards, or electrical fixtures.

[James H. Bushart]

I suggest that future changes to the SOP, like this one, be coordinated with the ESOP Committee before adding it. Originally, there was no mention of AFCI testing. Where did this come from, anyway?

[Kate Tarasenko]

Thanks for the input, guys! We're looking for some very simple language, since NEMA's suggestion about referencing the UL's language is exhaustive and a bit off-point.

Including language that says something about using the TEST BUTTON is the suggestion I vote for.

In spite of the "disclaimer" language in II.a. (regarding what an inspector is NOT required to do), we'll still need to make some kind of amendment to the SOPs to appease NEMA, especially since we're glad they're actually reading our SOPs to begin with!

[Kate Tarasenko]

Here's another question for you:

Should we simply delete the language having to do with AFCIs? What are the pros and cons?

DISCUSS!

[Michael Larson]

Originally Posted by ktarasenko

Here's another question for you:

Should we simply delete the language having to do with AFCIs? What are the pros and cons?

DISCUSS!

Kate - who is making changes without going through the ESOP committee?

[Jeffrey R. Jonas]

Also curious who "IACHI" pizzed off this time, to prompt the letter???

[Kate Tarasenko]

Not sure who created the original language, so I don't have an answer for you there. ESOP is not in charge of making changes, but of reviewing and making suggestions.

But I'm the person in charge of final edits on all InterNACHI documents, and I want to figure out what we should do from here on out.

So, I vote to change "AFCI tester" to "test by depressing the AFCI test button," etc.

But should we dispense with the "testing AFCI" language altogether????

[Michael Larson]

This is why there is a ESOP committee if I am not mistaken.

There appears to have been changes that many were not aware of.

[Kate Tarasenko]

ESOP is welcome to weigh in, and we rely on their expertise for such questions and welcome the collaboration. The only genuine "change" here is that InterNACHI now has an editor (me).

I don't think we p-o'd anyone, either, JJ -- but somewhere along the way, NEMA read our SOP, and that's actually good news!

[Jeffrey R. Jonas]

Originally Posted by mlarson

This is why there is a ESOP committee if I am not mistaken.

There appears to have been changes that many were not aware of.

And since "most" of us are not aware, we are not inspecting to the SOP, and we all need to change our PIA's to reflect the change. As if we didn't have enough issues with liability!!!

That is, assuming that the changes made, were properly authorized.

[Jeffrey R. Jonas]

Originally Posted by ktarasenko

I don't think we p-o'd anyone, either, JJ -- but somewhere along the way, NEMA read our SOP, and that's actually good news!

Curious as to why? Seems awfully coincidental when reviewing some of the threads and non-member posts lately.

Feels like something a certain ex-member (JT) would stick his nose into.