Practically Speaking: A Trifecta of GFCI Protection
When it comes to horse racing, hitting the trifecta means you have placed winning bets on the first three horses to cross the finish line in the correct order. When it comes to providing GFCI protection for certain appliances, such as the drinking water cooler/bottle fill station in the Photo below, a trifecta of GFCI protection may be needed for a Code-compliant installation.
Section 210.8(D) was extensively revised for the 2020 Code, but something seems to have gotten lost in translation during these revisions, unfortunately.
The wording in the first paragraph of Sec. 210.8(D) presently requires GFCI protection within the branch circuit overcurrent device, or GFCI protection in a device or outlet within the supply circuit for any outlets supplying the appliances specified in Sec. 422.5(A), “unless GFCI protection is provided in accordance with Sec. 422.5(B)(3) through (B)(5).” Section 422.5(B)(3) specifies GFCI protection as an integral part of the attachment plug of the appliance. Section 422.5(B)(4) specifies GFCI protection within the appliance supply cord no further than 12 in. from the attachment plug. Section 422.5(B)(5) specifies GFCI protection factory-installed within the appliance. So, the literal wording of that first paragraph in Sec. 210.8(D) requires GFCI protection integral to the attachment plug, GFCI protection within the supply cord, and GFCI protection otherwise factory-installed within the appliance to omit GFCI protection for the appliance branch circuit or outlet.
I don’t think the intent was to require this trifecta of GFCI protection, but the wording of the first paragraph of Sec. 210.8(D) lends itself to that interpretation. It does not say, “in accordance with Sec. 422.5(B)(3), (B)(4), or (B)(5)”, instead it states, “in accordance with Sec. 422.5(B)(3) through (B)(5),” with my emphasis on the word “through.” For vending machines, the second paragraph of Sec. 210.8(D) does permit GFCI protection integral to the attachment plug or within the supply cord of the vending machine in place of providing GFCI protection for the branch circuit.
Why do you think such a difference exists in the wording of these two paragraphs? After reading some of the Public Input submitted to revise Sec. 210.8(D) for 2023, I expect some major changes may be happening again to these requirements. I think some clarifications are certainly needed here. And as a reminder, I think it’s always a good idea to have a discussion with the AHJ regarding his or her interpretation before you perform an installation when you have uncertainties trying to decipher the meaning of the Code.
About the Author
Russ LeBlanc
Owner
Russ started in the electrical trade as an apprentice in 1985. He worked his way up to become a Journeyman Electrician and then eventually became a Master Electrician and Licensed Construction Supervisor. In 1999 Russ become an Electrical Instructor for The Peterson School of Engineering in Massachusetts where he developed his passion for teaching, and quickly became Department Head of Electrical Instruction. Russ has taught thousands of apprentices, electricians, engineers, inspectors, and other electrical professionals during his career as an instructor. He continues to provide electrical professionals with Electrical Code seminars, Arc-Flash Awareness training seminars and educational material through his LeBlanc Consulting Services in North Reading, MA whose specialty is educating electricians. He has been an active member of the NFPA Electrical Section and has authored hundreds of National Electrical Code proposals and comments which have become Code rules to improve the safety for the electrical industry. Russ is also an IAEI certified Electrical Inspector.
Please visit www.russleblanc.net for more information.