Does a light fixture replacement trigger AFCI?

[Yikes]

Talked with a building official today about an apartment property manager who wants to simply replace existing incandescent light fixtures with high efficacy fixtures in the bedrooms and hallways of about 50 units.
(typical fixtures, with typical ceiling junction box.)

The building official says that every outlet that is changed must be upgraded to Arc Fault Circuit Interrupters, and he says that since the light fixture's junction box meets NEC definition of "outlet", therefore the light circuit needs protection, and since the only place to do that on our lighting-only circuit is back at the load center, we need an AFCI circuit breaker. But the load center is too old to support that kind of breaker, so now we have to replace the load centers and submit engineered electrical plans for approval.

I asked, "so do you mean to say that if someone goes to Home depot to put in a new light fixture in their old house, they need to effectively replace the entire panelboard?"
"Yes."

Question: where in the NEC does it say, or infer, that replacing a light fixture triggers AFIC for the lighting circuit?
I can understand it for NEW construction per NEC 210.12(A)
I can understand it for EXISTING "wiring modifications" per NEC 210(B)
I can understand it for replacement of EXISTING "receptacle outlets" (not J-boxes) per NEC 406.4(D)4
But I don't see anything about replacing a light, when you are not touching the wiring (other than the connect the light in the existing J-box).

***

• NEC 100 definition of outlet: A point on the wiring system at which current is taken to supply utilization equipment.
• NEC 100 definition of "receptacle": A contact device installed at the outlet for connection of an attachment plug.
• NEC 100 definition of "receptacle outlet": An outlet where one or more receptacles are installed.

 

[conarb]

Yikes, if that's the only work being done how does the building official even get involved?

 

[mark handler]

The NEC’s requirements emphasize that AFCIs are important for existing homes where older wiring and outdated electrical work may increase the threat of an electrical fire.
Add a separate subpanel, arc-fault protect it, adjacent to existing panel. All altered circuits will be protected.

 

[fatboy]

Sorry........not adding/changing circuits..........fixtures can be changed out, as long the demand does not increase......at least in my neck of the woods..............

 

[ICE]

It is rare that the scope of work is restricted to fixture for fixture at the exact location with no additional fixtures.....but if that is the actual situation then AFCI wouldn’t be required

 

[ICE]

Yikes, if that's the only work being done how does the building official even get involved?

An electrical permit would be the first clue that work is being done.

 

[fatboy]

It is rare that the scope of work is restricted to fixture for fixture at the exact location with no additional fixtures.....but if that is the actual situation then AFCI wouldn’t be required

That was the premise I was replying to........same location, no additional fixtures/loading.

 

[conarb]

That was the premise I was replying to........same location, no additional fixtures/loading.

With high-efficiency replacing incandescent, theoretically the loads should be lower, if other work is contemplated change the fixtures first, then pull the permit.

 

[Yikes]

We are doing other work, such as changing cabinets, putting in energy efficient windows, etc. It's affordable housing and it qualifies for tax credit rehab funds. However, the tax credit investors want to see permits for everything. We went to submit plans, and the plans list all work being done, including swapping the fixtures for efficacy. That's when the building officil said he wanted to see separate "electrical plans" for the light swap. When I talked to him on the phone he said it was about the whole AFCI issue.
Again I ask, what code citation in the NEC would compel this?

 

[tmurray]

Did he provide a code section?

 

[ICE]

210.12(B)

Electrical plans would not be required here.

 

[steveray]

Our amended IRC.....(Amd) E3902.13 Arc-fault circuit interrupter protection for branch circuit extensions or
modifications. Where branch-circuit wiring is modified, replaced, or extended in any of the areas
specified in Section E3902.12, the branch circuit shall be protected by one of the following:
1. A combination-type AFCI located at the origin of the branch circuit.
2. An outlet branch-circuit type AFCI located at the first receptacle outlet of the existing
branch circuit.
Exception: AFCI protection shall not be required where the extension of the existing
conductors is not more than 6 feet (1.8 m) in length and does not include any additional
outlets or devices.

I would not call it a modification....

 

[mark handler]

I would not call it a modification....

Modification...the making of a change in something ...Changing Light fixtures is making a Modification.
Replaced....to put something new in the place of...Replacing Light fixtures is the making of a change to the circuit. (Fixtures are the outlet of the circuit.)

that being said i do agree with ICE

..... fixture for fixture at the exact location with no additional fixtures..... then AFCI wouldn’t be required

see exception 210.12b(2) Does not include additional fixtures

 

[steveray]

Where branch-circuit wiring is modified

OK...in that case the fixture is not "wiring"...Better?

 

[mark handler]

If the project is in CA, if Lighting is modified:
You also need to meet the CA Energy Code, per 6.7 of the Residential compliance standards

 

[mark handler]

OK...in that case the fixture is not "wiring"...Better?

IRC R105 And IBC 105; specifically say replacement of Lamps, not fixtures

 

[ADAguy]

There you go, "muddying" the waters (smiling).

 

[steveray]

2017 NEC 210.12(D) says branch circuit "wiring"....Not sure what code you use....

 

[mark handler]

You are altering the branch circuit by modifying the "...outlets or devices..." attached to it.
Are you modifying a car by replacing the tires, yes.
Are you modifying a house by adding a bedroom, yes.

IRC R105 And IBC 105; specifically say replacement of Lamps, not fixtures

 

[SCBO1]

It is rare that the scope of work is restricted to fixture for fixture at the exact location with no additional fixtures.....but if that is the actual situation then AFCI wouldn’t be required

That's how understand it, same for a switch & receptacle, we call it the maintenance man rule. Also we amended our code to not requiring any AFCI's.

Conarb would like us...I think??? Not sure?

 

[conarb]

That's how understand it, same for a switch & receptacle, we call it the maintenance man rule. Also we amended our code to not requiring any AFCI's.

Conarb would like us...I think??? Not sure?

Yeah, you are making sense, requiring permits for any modification is tyranny at it's worst. This morning I was reading an article about people escaping the inner cities, some comments:

Escaping overtaxation and ever increasing densities sought by City Planners.



Sales taxes

Property taxes

Unlimited regulations

We are not stupid. We'd like a bit of the freedom we thought we were born with.

" Instead they are targeting EVERY commercial area for redevelopment into Mid-rise live work play areas... "

Straight out of the Agenda 21 play book.

California is putting a NETZERO energy law applying to ALL housing.

Think you've paid off your home and only have prop taxes and upkeep - think again - because NO homes are net zero energy you will be required to pay at least $60,000 for upgrades - and i'm sure that's just the start. And what California does the libtards and repulicucks bring elsewhere. Debt Slave Heaven Hotel California

get on youtube STOPTHECRIME.net new channel to see what the planned destruction in California

Even better is that our plan must be approved by the ARC. The ARC is a body of individuals that are NOT elected and have no direct accountability to the residents.

As far as I am concerned they are part of the local Deep State pushing us towards an objective most of us simply do not want.

I don't know where that last guy is located but his ARC is like our One Bay Area, that's the
"NOT SO NICE" United Nations Agenda 2030 for the New World Order.

 

[steveray]

Not arguing that a permit is not required, just when to go all arcfault crazy....To further argue my point, I can replace 6' of wiring w/o going arcfault....Correct? if that wiring is connected to a device, I can still do it w/o arcfault...Correct? (because you would normally splice at a device)......Soooooo I can disconnect and reconnect a device w/o Arcfault ...Correct?

 

[Yikes]

IRC R105 And IBC 105; specifically say replacement of Lamps, not fixtures

Mark, you are correct, replacing of lamps (e.g. what we colloquially used to call the "light bulb") is considered maintenance, exempt from permit.
Fixtures are different: in theory, Joe Homeowner needs to pull a permit to replace the whole light fixture, because he's getting into the terminating wires at the junction box. (In reality, Joe Homeowner has no time or inclination to pull permits, and this is one of those things that flies under the radar of the inspector.) For a large project with "deep pockets", we pull permits to replace with high efficacy light fixtures so that no one can complain from an owner's liability/insurance standpoint.
None of this triggers AFCI in my opinion.

 

[Yikes]

conarb, I don't want to officially "out" him here, but let's just say it's a large So Cal city close to the Mexican border... a city large enough where he ought to know better.
Regarding your theory about tyranny, there's nothing more tyrannical than an ego of a code official who is already so convinced he's right he can't even bother to cite the code reference lest he be proven wrong.