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Why Voltage Drop Is Required In The NEC

jar546

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If there’s one NEC article that gets overlooked far too often, it’s 110.3(B). It is a single sentence with massive implications, and the 2023 edition of the NEC makes it even more explicit. It now states that equipment that is listed, labeled, or identified for a use shall be installed and used in accordance with any instructions included in the listing, labeling, or identification. An informational note was added to clarify that these instructions may be printed, delivered by QR code, or hosted online. Whether a sticker is slapped on the product or the manual is buried in a PDF, the bottom line is this: if the manufacturer says it must be installed a certain way as part of the listing, then that becomes enforceable code.

This is not new. The 2020 NEC already required listed or labeled equipment to be installed according to its instructions. The 2023 version expands the scope to include equipment “identified for a use,” which matters when dealing with custom or application-specific equipment. The code panel also clarified how installation instructions are delivered, which reflects how the industry actually works today. Digital documentation is common but does not reduce the legal obligation to follow it.

What gets missed is how this ties into something like voltage drop. While the NEC has an informational note in 210.19 suggesting a maximum of 5 percent combined voltage drop, that is not a code requirement.

Informational Note:
Conductors for branch circuits as defined in Article 100, sized to prevent a voltage drop exceeding 3 percent at the farthest outlet of power, heating, and lighting loads, or combinations of such loads, and where the maximum total voltage drop on both feeders and branch circuits to the farthest outlet does not exceed 5 percent, provide reasonable efficiency of operation. See 215.2(A)(2), Informational Note No. 2, for information on voltage drop on feeder conductors.

However, when a manufacturer sets a minimum voltage or states a maximum allowable voltage drop in its listing, 110.3(B) makes it mandatory. It does not matter if the rest of the code treats voltage drop as a recommendation. If the listed equipment requires a minimum voltage at its terminals, you enforce it. That is the law. And that means the installer has to do the math before they pull the wire, not after the inspector calls them out on it.

This plays out in real-world scenarios all the time. Think about long feeder runs to manufacturing equipment or remote installations where the voltage at the load could easily fall below spec. If the equipment documentation says “minimum operating voltage: 208 volts,” and the engineer’s calculation puts it at 204 volts under full load, that is a problem. As the AHJ, you can and should require proof that the installation complies with the listing. That is what 110.3(B) demands. The same principle applies to transformers, EV chargers, HVAC equipment, or anything else where the operating voltage is part of the listing criteria.

Manufacturers put those instructions there for a reason. They are part of the safety testing and evaluation process. Whether the equipment is listed by UL, ETL, or another NRTL, the performance parameters are not suggestions. If the label says “do not install above a receptacle,” then that’s code. If it says the product must maintain a minimum spacing from combustible material, that’s code. And if it says the voltage must be within a specific range, that’s code too.

Too many installers treat listing instructions like optional reading material, and too many inspectors fail to enforce them. That has to change. The industry needs to stop thinking of listing labels as fine print and start recognizing them as code language. If a product is listed and part of that listing includes installation criteria, then 110.3(B) gives you the authority and the responsibility to hold people to it.

Some people like to argue about what the NEC does or does not explicitly require. But 110.3(B) closes that door. It is one of the most powerful tools an AHJ has, and yet it is often misunderstood or ignored. It is time to stop overlooking it.
 
It now states that equipment that is listed, labeled, or identified for a use shall be installed and used in accordance with any instructions included in the listing, labeling, or identification.
What isn't clear to me, and I gather to many users of the NEC, is whether the entire installation manual for a listed piece of equipment is "included in the listing," or whether instructions "included in the listing" are limited to what appears in the listing standard itself.

For example, does a manufacturer have to submit the installation manual along with the product to the NRTL, and does the NRTL evaluate those instructions? Does a manufacturer have to get a NRTL to sign off on each revision of the installation manual?

If not, it seem to me that it is not the case that the entire installation manual is "included in the listing", meaning it's not so simple as saying that 110.3(B) requires compliance with everything manufacturers put in their instructions.

If you've read many instruction manuals, you know manufacturers often use terms that differ from NEC terms and/or provide instructions that are contrary to the NEC. E.g. requiring a "dedicated" branch circuit--does that mean an "individual branch circuit," or just a branch circuit where each of outlets is for a specific load? Or the instructions with many EVSEs that say "do not install a GFCI breaker on the supply to the EVSE", while the NEC has started requiring (misguidedly, in my opinion) GFCIs for many EVSE installations.

Cheers, Wayne
 
Let's not forget another important section that says:

695.7 Voltage Drop.
(A) Motor Starting.
Unless the requirements of 695.7(B) or (C) are met, the voltage at the fire pump controller line terminals shall not drop more than 15 percent below normal (controller-rated voltage) under motor starting conditions. [20:9.4.1]
 
What isn't clear to me, and I gather to many users of the NEC, is whether the entire installation manual for a listed piece of equipment is "included in the listing," or whether instructions "included in the listing" are limited to what appears in the listing standard itself.
Still very much interested in this question. Can an inspector properly cite 110.3(B) after just reading the instruction manual and finding a deviation? Or is it necessary to somehow check "the listing" to see what instructions are "included in the listing?"

Cheers, Wayne
 
Still very much interested in this question. Can an inspector properly cite 110.3(B) after just reading the instruction manual and finding a deviation? Or is it necessary to somehow check "the listing" to see what instructions are "included in the listing?"

Cheers, Wayne
Historically, the manufacturer's installation instructions have always been enough.
 
Historically, the manufacturer's installation instructions have always been enough.
You mean as a matter of practice? I.e. if you as inspector cite 110.3(B) and point to something in the installation instructions, the inspectee has never responded to you "those particular instructions are not included in the listing, so do not have the force of 110.3(B) behind them."

Cheers, Wayne
 
You mean as a matter of practice? I.e. if you as inspector cite 110.3(B) and point to something in the installation instructions, the inspectee has never responded to you "those particular instructions are not included in the listing, so do not have the force of 110.3(B) behind them."

Cheers, Wayne
Neither the inspector nor the inspectee will have the requisite knowledge about the contents of the Listing. The manufacturer will most likely defer to the NRTL. The NRTL will most likely respond that the Listing is the proprietary property of the manufacturer. That dog can see the tail but it's out of reach.
 
You mean as a matter of practice? I.e. if you as inspector cite 110.3(B) and point to something in the installation instructions, the inspectee has never responded to you "those particular instructions are not included in the listing, so do not have the force of 110.3(B) behind them."

Cheers, Wayne
(B) Installation and Use.
Equipment that is listed, labeled, or both, or identified for a use shall be installed and used in accordance with any instructions included in the listing, labeling, or identification.

Informational Note:
The installation and use instructions may be provided in the form of printed material, quick response (QR) code, or the address on the internet where users can download the required instructions.
 
Manufacturers’ listing and labeling installation instructions must be followed, even if the equipment itself is not required to be listed. For example, 210.52 permits permanently installed electric baseboard heaters to be equipped with receptacle outlets that meet the requirements for the wall space utilized by such heaters. The installation instructions for permanent baseboard heaters indicate that the heaters should not be mounted beneath a receptacle. In dwelling units, the use of low-density heating units more than 12 feet in length is common. Therefore, to meet the requirements of 210.52(A) and the installation instructions, a receptacle must either be part of the heating unit or be installed in the floor close to the wall but not above the heating unit. The Informational Note to 210.52 https://link.nfpa.org/publications/70/2023/chapters/2/articles/210#ID000700000509https://link.nfpa.org/publications/70/2023/chapters/2/articles/210#ID000700000509provides specific details.

Listing and labeling are the most common methods of establishing suitability. This section does not require listing or labeling of equipment. Before approving the installation, the AHJ may require evidence of compliance with 110.3.

Some sections do require listed or labeled equipment. For example, 250.8 specifies “listed pressure connectors . . . pressure connectors listed as grounding and bonding equipment [or] . . . other listed means” as connection methods for grounding and bonding conductors.

Listing organizations typically require the use of their listing mark on the equipment as the means of determining if the product is listed. Where it is impractical to have the listing mark on the equipment, the listing organization usually requires that the listing mark be on the smallest unit container in which the product is packaged. Since 110.3(B) requires compliance with the listing requirements, the appropriate certification mark is required if that is a requirement of the listing entity.
 
You mean as a matter of practice? I.e. if you as inspector cite 110.3(B) and point to something in the installation instructions, the inspectee has never responded to you "those particular instructions are not included in the listing, so do not have the force of 110.3(B) behind them."

Cheers, Wayne
Installation instructions are considered to be a part of the UL Listing.The UL Standards for Safety used to investigate products contain specific requirements regarding the content and appearance of the instructions. Installation instructions are not required to be marked with the UL Mark, but they are required to be provided with the product bearing the UL Mark. Some products are not required to have installation instructions when the National Electrical Code contains all the necessary installation requirements, such as outlet boxes.UL staff reviews the instructions, both during the initial evaluation of the product as well as during the continual Follow-Up Service at the factories. The clarity of the instructions is also reviewed.
 
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