Practically Speaking: Measurement Methods Need Clarification

When it comes to determining whether GFCI protection may be required for receptacles near sinks, bathtubs, shower stalls, and similar open aquatic vessels, containers, tanks, or bowls, Sec. 210.8 spells out exactly how we are supposed to take that measurement. For that section, it states, “the distance from receptacles shall be measured as the shortest path the power supply cord connected to the receptacle would follow without piercing a floor, wall, ceiling, or fixed barrier.” Now, when we look at Secs. 210.8(A)(9), and (A)(11) [Sec. 210.8(A)(8) and (A)(10) in the 2023 edition] for dwelling units as well as Secs. 210.8(B)(7), (B)(14), and (B)(16) [Sec.210.8(B)(7),(B)(13), and (B)(15) in the 2023 edition] it is pretty clear on how we should be measuring the 6 ft distance when it comes to receptacle placement and whether GFCI protection would be need for the receptacles. But how do we measure the distance of an appliance plugged into a receptacle near a sink as specified in Sec. 210.8(B)(7)?

Section 210.8 only tells us how to measure the distance for receptacles. It does not tell us how to determine if an appliance would be within 6 feet of a sink. Do we measure horizontally? Vertically? Every direction? Does the measurement continue through doorways, windows, walls, or other fixed barriers? The photo I used here is a commercial kitchen, so all of the receptacles would need GFCI protection. But for the sake of this discussion, let’s assume this is not a kitchen and the toasters and ovens are appliances other than cooking appliances. There is a sink on the far left of the photo. On the far right of the top shelf, there is an appliance plugged into a receptacle 8 feet away from the sink. Is that appliance within 6 feet of the sink? If it is, it needs GFCI protection. But how do we take this measurement? Is it taken from the closest edge of the appliance to the sink? Does the measurement continue around corners? Or is it only in a straight line? What if the appliance was plugged into a receptacle on the other side of the entrance door to this area? Do we measure from the appliance, through the doorway, and all the way to the edge of the sink? Or do we stop measuring at the doorway?

I think all of these questions will be great questions to discuss with your AHJ. Hopefully, the 2029 Code will provide some clarity on this topic.