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.
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.
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:
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?
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!
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???
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!
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.
If you leave it in, make sure there is also an out so that we are not necessarily required to test them. There could be very good reasons for NOT testing one if it is there.
Since our SOPs are posted online, it’s a pretty easy thing for NEMA, et al., to check out what’s out there with a Google search or a Google alert. I don’t think this is necessarily a coincidence, but since they are NEMA, again, we’re grateful to have their input, as we are YOURS.
So, although I don’t devise the language per se (I’m not an electrician), I’m striving to make it accurate and clear. Our SOPs are also “living documents,” in that they may change, as they will for this point about AFCIs.
We will usually (if not always) make some sort of announcement on the Forum about changes to our SOPs – or anything else regarding best practices for inspectors. (By the way, in this case, we are speaking strictly about the Residential SOP, and not ComSop, which will remain the same, as its language will not be affected.)
I’ll be finalizing the language for this question by tonight, so please keep your comments coming regarding replacing language or deleting language regarding AFCI testing.
