submersible sump pump

Practically Speaking: Clarification Needed on GFCI Requirements

Dec. 5, 2022
Some patience may be needed while waiting for this rule to evolve.

Based on the 2020 NEC.

Patience is a virtue, or so I’ve been told. Some patience may be needed while waiting for this rule to evolve into something easier to decipher.

Section 422.5(A) requires GFCI protection to be provided for seven specific appliances. This requirement is based solely on the voltage rating and amperage rating of the appliance. The branch circuit voltage rating is irrelevant because there is no mention of the branch circuit voltage in this rule. There are also no exceptions to this rule. What about low-voltage appliances? Will a 12V sump pump need GFCI protection too? I’m hopeful that some changes may come to this rule to provide some much-needed clarification.

Presently, the requirement only applies to appliances with a voltage rating of 150V or less to ground and an amperage rating of 60A or less. This includes single-phase or 3-phase appliances. A 230V sump pump would be excluded from needing GFCI protection, but a 115V pump would need it. Looking at other appliances, neither a 3-phase, 208V nor a single-phase, 230V commercial dishwasher installed in the kitchen of a restaurant is required to have GFCI protection, but a 115V dishwasher is required to have GFCI protection. The branch circuit for each of those dishwashers may be operating at less than 150V to ground, but the voltage rating of the branch circuit seems to be irrelevant for applying this rule. Was the intent to specifically exclude the branch circuit voltage rating from this requirement? Or was it merely overlooked unintentionally? That is the one-million-dollar question.

You may remember that something similar happened in the 2017 Code with Sec. 210.8(B) GFCI protection requirements for receptacles. The branch circuit voltage was not mentioned in Sec. 210.8(B) for 2017, and only the voltage rating and amperage rating of the receptacle mattered. Thankfully, that error of omission was corrected in the 2020 NEC. The wording now includes the branch circuit voltage rating in addition to the receptacle ratings.

Clarifications didn’t happen in Sec. 422.5(A) for 2023. Maybe we will need to wait until 2026 for some exceptions and branch circuit voltage ratings to be added to this requirement. Until then, I think some discussion with your AHJ would be a good idea for this one.

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.

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