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Does a light fixture replacement trigger AFCI?

Discussion in 'Commercial Electrical Codes' started by Yikes, Mar 22, 2018.

  1. Yikes

    Yikes Gold Member

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    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.
     
  2. conarb

    conarb Sawhorse

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

    mark handler Sawhorse

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    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.
     
  4. fatboy

    fatboy Administrator

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    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..............
     
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  5. ICE

    ICE Sawhorse

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    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
     
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  6. ICE

    ICE Sawhorse

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

    fatboy Administrator

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

    conarb Sawhorse

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

    Yikes Gold Member

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    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?
     
  10. tmurray

    tmurray Sawhorse

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    Did he provide a code section?
     
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  11. ICE

    ICE Sawhorse

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    210.12(B)

    Electrical plans would not be required here.
     
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  12. steveray

    steveray Sawhorse

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    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....
     
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  13. mark handler

    mark handler Sawhorse

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    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
    see exception 210.12b(2) Does not include additional fixtures
     
    #13 mark handler, Mar 23, 2018
    Last edited: Mar 23, 2018
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  14. steveray

    steveray Sawhorse

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

    mark handler Sawhorse

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    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
     
  16. mark handler

    mark handler Sawhorse

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    IRC R105 And IBC 105; specifically say replacement of Lamps, not fixtures
     
    #16 mark handler, Mar 23, 2018
    Last edited: Mar 23, 2018
  17. ADAguy

    ADAguy Sawhorse

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

    steveray Sawhorse

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

    mark handler Sawhorse

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    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
     
    #19 mark handler, Mar 23, 2018
    Last edited: Mar 23, 2018
  20. Pcinspector1

    Pcinspector1 Platinum Member

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    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?:confused:
     

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