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New TIA for 2020 NEC and Proposed 2023 NEC Addresses Portable Luminaires

Sept. 13, 2021
Proposal seeks to return Sec. 250.114(3)(e) and (4)(e) to their 2017 edition status to eliminate conflict related to grounding requirements

A new Tentative Interim Amendment (TIA) was recently issued by the National Fire Protection Association in regard to the 2020 edition and proposed 2023 edition of the National Electrical Code. Open for comment until October 14, TIA 1608, which was submitted by Michael Shulman of UL, is proposing that language for Sec. 250.114(3)e and Sec. 250.114(4)e be revised to read as follows:

250.114 Equipment Connected by Cord and Plug. Exposed, normally non-current-carrying metal parts of cord-and-plug-connected equipment shall be connected to the equipment grounding conductor under any of the following conditions:

(3) In residential occupancies:

e. Portable handlamps and portable luminaires

(4) In other than residential occupancies:

e. Portable handlamps and portable luminaires

Substantiation: The phrase “and portable luminaires” was added during the 2020 cycle (FR 8040, based on PI 1200) to both Sec. 250.114(3)(e) and (4)(e). The FR substantiation (carried forward from the PI) states:

“Portable handlamps were originally covered by UL 298, titled "Portable Electric Hand Lamps". UL 298 was withdrawn in 2004, and has been superseded by UL 153, titled "Portable Electric Luminaires". Devices that were once called "Portable Handlamp" on their label are now being labeled as "Portable Luminaire", but are the same product. Therefore, 3(e) and 4(e) should include "portable luminaires" to continue to cover the grounding need for these products.”

The substantiation conflated the certification organization label designation (“Portable Luminaire”) with the requirements in the standard that apply to the specific product type (a portable hand light). UL 153 (clause 138.6.1) explicitly requires portable hand lights, which are typically used in garages and similar environments, to use a grounding-type attachment plug when they have accessible metal that may become energized. UL 153 applies a similar grounding plug requirement on other types of portable luminaires, such as those for wet locations. But there are many indoor use (residential and commercial) portable luminaire types that have always been permitted, by UL 153 and NEC 410.82, to use a polarized, 2-wire supply plug. Polarized portable luminaires compliant with UL 153 have a well-established acceptable field record of adequately managing the associated risks. The substantiation for FR 8040 did not claim otherwise but appears to have inadvertently removed this longstanding design option.

During the 2020 cycle, NEC 410.42 was revised (PI 2473, FR 8426) to reinforce the longstanding permission (in 410.82) for portable luminaires to use a polarized plug.

The result is that NEC 250.114(3) and (4), which now require all portable luminaires with accessible metal (and without double insulation) to be grounded, is in conflict with 410.82, which permits a polarized plug, and 410.42, which says those with a polarized plug do not require grounding. This TIA, therefore, proposes that 250.114(3)(e) and (4)(e) be returned to their 2017 edition status to eliminate this conflict. The objective of PI 1200 / FR 8040, to maintain the grounding requirement for portable hand lights (despite their requirements shifting from UL 298 to UL 153), was never in jeopardy so the PI / FR was never needed.

Emergency Nature: The NFPA Standard contains a conflict within the NFPA Standard or within another NFPA Standard.

Portable luminaires listed in accordance with UL 153 and with a polarized plug should not be rejected due to non-compliance with 250.114. The conflict between this section and 410.42 was found too late in the 2023 cycle for public input, and it should not be left to linger until the 2026 revision cycle opens.

Anyone may submit a comment by the closing date of October 14. Please identify the TIA number and forward to the Secretary, Standards Council.

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