New TIA for 2020 NEC Addresses Receptacles Near Bathtub and Shower Spaces

A new Tentative Interim Amendment (TIA) was recently issued by the National Fire Protection Association in regard to the 2020 edition of the National Electrical Code. Open for comment until August 23, TIA 1598, which was submitted by Kerry Stackpole, Plumbing Manufacturers International (PMI), is proposing adding a new Exception No. 2 to Section 406.9(C) to read as follows (new text is underlined):

406.9 Receptacles in Damp or Wet Locations. …

(C) Bathtub and Shower Space. Receptacles shall not be installed within a zone measured 900 mm (3 ft) horizontally and 2.5 m (8 ft) vertically from the top of the bathtub rim or shower stall threshold. The identified zone is all-encompassing and shall include the space directly over the tub or shower stall.

Exception No. 1: In bathrooms with less than the required zone the receptacle(s) shall be permitted to be installed opposite the bathtub rim or shower stall threshold on the farthest wall within the room.

Exception No. 2: In a dwelling unit, a single receptacle shall be permitted for an electronic toilet or personal hygiene device such as an electronic bidet seat. The receptacle shall be readily accessible and located on one of the following:

(1) The wall behind the toilet but not behind the tank

(2) The opposite side of the toilet from the bathtub or shower

Substantiation: It is quite common for a toilet to be located next to a bathtub or shower in a residential bathroom. The existing text in NFPA 70 could prevent the installation of a receptacle that is necessary for the operation of an electronic toilet (also known as a “smart toilet”) or personal hygiene device (e.g., electronic bidet seat) where a toilet is located within 3 feet horizontally of a bathtub or shower. Application of the receptacle placement requirements has the potential to place an undue burden on the consumer whereby additional cost may be incurred to position the receptacle in an acceptable location without considering potential structural barriers behind the wall that may further restrict installation. Therefore, the proposed exception is necessary to ensure that such plumbing products are permitted to be installed while not jeopardizing the level of electrical safety that the standard seeks [see below photo(s)/diagram(s) that provide clarity for the proposed exception]. As such, due to the proximity of the individual receptacle to the bathtub or shower, it would be required by NEC Section 210.8(A)(9) to be protected by a Class A GFCI device minimizing any potential shock hazard. Moreover, it is our understanding that products like electronic toilets and personal hygiene devices were not taken into consideration during the discussion of the proposal prior to adoption into the current standard.

Emergency Nature: The proposed TIA intends to correct a circumstance in which the revised NFPA Standard has resulted in an adverse impact on a product or method that was inadvertently overlooked in the total revision process or was without adequate technical (safety) justification of the action.

Read the entire TIA 1598 for specific reasons why making an allowance for these listed products (which are permitted in all major plumbing codes) is necessary for safeguarding public health and safety. According to the submitter, the bottom line is these products are necessary for many individuals around the United States for maintaining their health, and “the existing text in NFPA 70 would prevent the installation of such products in many residential bathrooms.”

Anyone may submit a comment by the closing date of August 23. Please identify the TIA number, and forward to the Secretary, Standards Council.