Last December we in the industry received some very exciting news.
After months of tireless advocation and huge grassroots support from our industry we were able to get the very questionable NFPA 70 551.71(F) amended. That is to say, we were able to get it back to where the NEC Technical Committee wanted it before various end runs to make GFCI protection in RV Pedestals a requirement. The process to amend the 2020 NEC is called a Tentative Interim Amendment (TIA). This TIA states:
551.71(F) GFCI Protection.
Ground-fault circuit-interrupter protection shall be provided as required in 210.8(B). GFCI protection shall not be required for other than 125-volt, 15- and 20-ampere receptacles used in recreational vehicle site equipment.
Informational Note No. 1: Appliances used within the recreational vehicle can create leakage current levels at the supply receptacle(s) that could exceed the limits of a Class A GFCI device.
Informational Note No. 2: The definition of Power-Supply Assembly in 551.2 and the definition of Feeder in Article 100 clarifies that the power supply cord to a recreational vehicle is considered a feeder.
You can read and download a copy of the TIA here:
What does that mean?
During the process to generate the 2017 NEC, a rather significant global change was made to a General Section of the NEC requiring that many (branch) circuits have ground fault circuit interrupter (GFCI) protection for personnel. The code reads:
“…all single-phase receptacles rated 150 volts or less, 100 amperes or less installed in the following locations…”. These locations include “outdoors”.
From this many AHJ’s and inspectors concluded that RV Site Electrical Equipment must have GFCI protection on the 30- and 50-amp receptacles in addition to the 20-amp receptacle where it is already required.
Flash forward to 2019…
The NEC Technical Committee (also called Code Panel 7) is made up of a number of RV industry partners as well as electrical equipment manufacturers, AHJ’s, safety and testing companies. This committee by overwhelming votes (80-92% on two votes) developed the draft 2020 NEC code RV pedestals to explicitly exclude from the need for 30 and 50-amp GFCI protection for the following reasons:
1. The 30- and 50-amp power on the RV pedestal are considered feeder circuits (those circuits that feed another panel) and not branch circuits. The changes made in 2017 applied to branch circuits such as the 20-amp receptacle on a RV Pedestal, not feeder circuits.
2. The leakage current allowed by UL for GFCI circuits when all the downstream GFCI receptacles are added together would be enough to constantly trip the pedestal GFCI circuit.
The end runs I mentioned above all came from one source trying to make it a requirement for GFCI protection on the 30- and 50-amp circuits. The TIA is not in any printed book, and the TIA is only for the 2020 code cycle. That means we will need to be vigilant and also go through the process for the 2023 code cycle as well.
If you find yourself trying to explain it to an electrical inspector or engineer, these two important facts should help your cause:
1. The RV pedestal provides power to an RV with a power supply assembly. The definition of a power supply assembly in NEC Article 551.2 and the definition of a feeder in NEC Article 100 clarifies that the power supply cord to an RV is a feeder.
2. NEC article 210.8(B) applies to branch circuits. The 30- and 50-amp service in RV site electrical equipment are feeder circuits and not branch circuits.”
The big take away is (at least for the foreseeable future) only 20A circuits need to be GFCI protected. However, we need to keep on top of this and other emerging issues in order to prevent negative impact on your industry.
As always – stay involved in the process .
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