Where am I required to install light switches?

[stevemk]

I am not an electrician, nor a builder, but rather I am a low-voltage systems designer for an AV installation company. I am being told that there are requirements for light switch placement, but Google is vaguely telling me otherwise. I am revising an electrician's electrical floor plan with the intent of replacing proposed light switch locations with a smaller number of low-voltage keypads (in this case, Lutron Palladiom or Lutron Alisse keypads) that control the lighting loads in a centralized high-voltage panel in the mechanical room. I have been told by my boss that ingress / regress requirements dictate a light switch, or in this case keypad, be within reach of every doorway, but every Google search would seem to indicate that there is no requirement. Can anyone help me determine the actual requirement, as well as provide suggestions for best practices? My region is North Salt Lake / Bountiful in Salt Lake and Wasatch counties in Utah, USA. I am mainly interested in residential, but would be curious about commercial as well.

 

[e hilton]

So you’re doing motion sensors? I think you need an override switch in addition to the motion sensor.

 

[stevemk]

So you’re doing motion sensors? I think you need an override switch in addition to the motion sensor.

I am not currently including motion sensors in my design, but those would be wired separately from the lighting panels, and would trigger the lighting through programming and do not need to be taken into consideration at this time.

 

[e hilton]

“replacing proposed light switch locations with a smaller number of low-voltage keypads”

So no traditional light switches or motions? Everything is controlled by a remote keypad?

 

[Paul Sweet]

National Electrical Code 210.70 says where lighting outlets (or switched receptacles) are required, and that control devices (switches) shall be located on the wall near an entrance to the room.

 

[stevemk]

National Electrical Code 210.70 says where lighting outlets (or switched receptacles) are required, and that control devices (switches) shall be located on the wall near an entrance to the room.

I'm surprised, but that's all I've found either. Is there no requirement like "light switching receptacles must be located no higher than 48 inches to the top of the receptacle and no lower than 44 inches to the bottom of the receptacle on an interior wall of the room or area containing the associated light and must be within 4 feet of the framed edge of the doorway" or something like that. It also seems that on every set of electrical floor plans I encounter in my work there are entryways whose adjacent walls do not have light switches at all, and this is true for the homes I go into when inspecting my company's work. I see examples all the time of walk-in closets, bathrooms, single-purpose rooms, etc. where the proposed light switches are placed on a wall outside of the intended room, sometimes several feet away from the door, and there's no light switch in the room itself. Additionally, I see examples of large sliding glass doors that open from living rooms into back yards where no light switch is located near the sliding glass doors at all, but these rooms always contain light switches on a random wall near a hallway.

 

[stevemk]

“replacing proposed light switch locations with a smaller number of low-voltage keypads”

So no traditional light switches or motions? Everything is controlled by a remote keypad?

Yes, all low-voltage keypads. This is especially common in multi-property residences where the owner wants to be able to turn lights off remotely without having to go across the property into a home or building. To my knowledge, there are no residential rooms, such as mechanical rooms or bathrooms, where a bog standard light switch is required by code, although quite often our clients will opt not to do controlled keypads in every room to save on cost, so many rooms will still receive typical light switches. As for commercial, I do know there are requirements for safety lights that remain on.

 

[Joe.B]

You may find height and location requirements in accessibility guidelines, if your project is subject to ADA anyways.

 

[Mr. Inspector]

You never said what code your area uses. Here is the 2018 IRC. In commercial buildings you need to have switch's in the required reach zone for people with disabilities (IBC chapter 11) and the energy codes requires things too. most of the codes can be found at upCodes.com

LIGHTING OUTLETS
E3903.1 General. Lighting outlets shall be provided in accordance
with Sections E3903.2 through E3903.4. [210.70(A)]
E3903.2 Habitable rooms. At least one wall switch-controlled
lighting outlet shall be installed in every habitable
room, kitchen and bathroom. [210.70(A)(1)]
Exceptions:
1. In other than kitchens and bathrooms, one or more
receptacles controlled by a wall switch shall be considered
equivalent to the required lighting outlet.
[210.70(A)(1) Exception No. 1]
2. Lighting outlets shall be permitted to be controlled by
occupancy sensors that are in addition to wall
switches, or that are located at a customary wall
switch location and equipped with a manual override
that will allow the sensor to function as a wall switch.
[210.70(A)(1) Exception No. 2]
E3903.3 Additional locations. At least one wall-switch-controlled
lighting outlet shall be installed in hallways, stairways,
attached garages, and detached garages with electric power. At
least one wall-switch-controlled lighting outlet shall be
installed to provide illumination on the exterior side of each
outdoor egress door having grade level access, including outdoor
egress doors for attached garages and detached garages
with electric power. A vehicle door in a garage shall not be considered
as an outdoor egress door.
E3903.3.1 Stairway lighting outlet control. Where one
or more lighting outlets are installed for interior stairways,
there shall be a wall switch at each floor level and landing
level that includes an entryway to control the lighting outlets
where the stairway between floor levels has six or
more risers. Lighting outlets installed to meet this requirement
shall not be controlled by the use of dimmer switches
except where the dimmer switches provide the full range
of dimming control at each switch location. [210.70(A)(2)]
Exception: In hallways, stairways, and at outdoor
egress doors, remote, central, or automatic control of
lighting shall be permitted. [210.70(A)(2) Exception]
E3903.4 Storage or equipment spaces. In attics, under-floor
spaces, utility rooms and basements, at least one lighting outlet
shall be installed where these spaces are used for storage
or contain equipment requiring servicing. Such lighting outlet
shall be controlled by a wall switch or shall have an integral
switch. At least one point of control shall be at the usual point
of entry to these spaces. The lighting outlet shall be provided
at or near the equipment requiring servicing. [210.70(A)(3)]

 

[BN4537]

National Electrical Code 210.70 says where lighting outlets (or switched receptacles) are required, and that control devices (switches) shall be located on the wall near an entrance to the room.

The requirement above is new in the 2020 NEC, so you will see many places where that has not been done, and there are many jurisdictions where it is still legal to put the switch wherever since they have not adopted the 2020 NEC yet and are still on an older code.

There are no height requirements except where the ADA applies, in which case the operable parts need to be between 15" and 48" of the floor.

 

[e hilton]

“This is especially common in multi-property residences where the owner wants to be able to turn lights off remotely without having to go across the property into a home or building.”

Ok. So the maintenance guy needs to do something in the building. Walks all the way over there lugging a heavy toolbox. Discovers the control module isn’t working right, no way to override, so he has to walk all the way back to the office.

With regard to heights, even if you are not subject to ADA, it’s a safe move to use those guidelines for installation.

 

[stevemk]

“This is especially common in multi-property residences where the owner wants to be able to turn lights off remotely without having to go across the property into a home or building.”

Ok. So the maintenance guy needs to do something in the building. Walks all the way over there lugging a heavy toolbox. Discovers the control module isn’t working right, no way to override, so he has to walk all the way back to the office.

With regard to heights, even if you are not subject to ADA, it’s a safe move to use those guidelines for installation.

Believe me, I agree with the scenario, but it's just not a consideration in many of these homes because such issues are extremely rare, especially when by default certain loads will always be switchable on / off by the control device if the control interface fails, and if the keypad fails, it's treated no differently than if a switch failed, and the most common problem that could occur is a breaker being tripped. I still agree with you because that scenario is in no way impossible, just very, very uncommon. Low-voltage keypads are common in automated homes and businesses, though.

 

[stevemk]

The requirement above is new in the 2020 NEC, so you will see many places where that has not been done, and there are many jurisdictions where it is still legal to put the switch wherever since they have not adopted the 2020 NEC yet and are still on an older code.

There are no height requirements except where the ADA applies, in which case the operable parts need to be between 15" and 48" of the floor.

Understood, I will look into the ADA and to see whether my area of Utah has adopted the current NEC. Thank you.

 

[stevemk]

I will clarify my post by mentioning that my company does not do any high-voltage work, but perhaps we will in the future. For now, I just want to make sure that whatever documents and products I deliver to the on-site electricians include clear instructions as to what needs to be installed, how to install it, and what we need to accomplish without ever breaking regulations and whilst also attempting to follow best practices. I certainly don't want to hand off tasks to electricians without even considering their requirements as that would be insulting. My goal is to raise the bar (internally) and provide the materials necessary for any electrician to be able to work with us on a project without causing any problems that could come up during inspections, and to make sure that everyone we work with has the confidence that we know what we're doing. Fake it 'till you make it, right?

 

[bill1952]

“replacing proposed light switch locations with a smaller number of low-voltage keypads”

So no traditional light switches or motions? Everything is controlled by a remote keypad?

By many remote keypads, with one located proximate to each light outlet. Like this, with custom labels and a whole host of options. These are very reliable systems.

 

[stevemk]

You never said what code your area uses. Here is the 2018 IRC. In commercial buildings you need to have switch's in the required reach zone for people with disabilities (IBC chapter 11) and the energy codes requires things too. most of the codes can be found at upCodes.com

LIGHTING OUTLETS
E3903.1 General. Lighting outlets shall be provided in accordance
with Sections E3903.2 through E3903.4. [210.70(A)]
E3903.2 Habitable rooms. At least one wall switch-controlled
lighting outlet shall be installed in every habitable
room, kitchen and bathroom. [210.70(A)(1)]
Exceptions:
1. In other than kitchens and bathrooms, one or more
receptacles controlled by a wall switch shall be considered
equivalent to the required lighting outlet.
[210.70(A)(1) Exception No. 1]
2. Lighting outlets shall be permitted to be controlled by
occupancy sensors that are in addition to wall
switches, or that are located at a customary wall
switch location and equipped with a manual override
that will allow the sensor to function as a wall switch.
[210.70(A)(1) Exception No. 2]
E3903.3 Additional locations. At least one wall-switch-controlled
lighting outlet shall be installed in hallways, stairways,
attached garages, and detached garages with electric power. At
least one wall-switch-controlled lighting outlet shall be
installed to provide illumination on the exterior side of each
outdoor egress door having grade level access, including outdoor
egress doors for attached garages and detached garages
with electric power. A vehicle door in a garage shall not be considered
as an outdoor egress door.
E3903.3.1 Stairway lighting outlet control. Where one
or more lighting outlets are installed for interior stairways,
there shall be a wall switch at each floor level and landing
level that includes an entryway to control the lighting outlets
where the stairway between floor levels has six or
more risers. Lighting outlets installed to meet this requirement
shall not be controlled by the use of dimmer switches
except where the dimmer switches provide the full range
of dimming control at each switch location. [210.70(A)(2)]
Exception: In hallways, stairways, and at outdoor
egress doors, remote, central, or automatic control of
lighting shall be permitted. [210.70(A)(2) Exception]
E3903.4 Storage or equipment spaces. In attics, under-floor
spaces, utility rooms and basements, at least one lighting outlet
shall be installed where these spaces are used for storage
or contain equipment requiring servicing. Such lighting outlet
shall be controlled by a wall switch or shall have an integral
switch. At least one point of control shall be at the usual point
of entry to these spaces. The lighting outlet shall be provided
at or near the equipment requiring servicing. [210.70(A)(3)]

I don't know what code my area uses, but I will try to find out. Meanwhile, I've spoken to two electricians who just shrugged off my question as though there were no codes for what I was asking about, yet here you are presenting those very regulations. Thank you, I knew there must be something! Makes me wonder why the other guys didn't even try to point me to these. Even if they had said "there are rules, I just don't know them," that would have been more honest and more helpful.

It took me a few minutes of rereading the specific codes you provided before I understood them, but I think I've got. There was one I failed to understand, however...

E3903.2, Exception.1 seems to indicate that (in any room that is not a kitchen or bathroom) there shall be at least one switch per light? I'm definitely fuzzy on what this one is trying to say.

Also, when reading E903.3.3, it mentions that dimmers in these locations must be full range. It occurs to me, if we install these keypads and later provide programmed automation (which allows us to completely repurpose the buttons), and considering that we often set scenes where multiple lights are controlled and multiple lights do not exceed 80% power, these being common practices in our industry, is it possible that we are we breaking regulations in some cases? What do you think?

Also, if "regulation" is not the correct word, please correct me.

 

[stevemk]

By many remote keypads, with one located proximate to each light outlet. Like this, with custom labels and a whole host of options. These are very reliable systems.

View attachment 9834

Yep, that's the one! And these ones from the same manufacturer are expensive, but so sexy. I've got a $100K Lutron bid out to a client who wanted some steampunk light switches with programming. It's like $800+ per switch before labor, yikes!

 

[bill1952]

E3903.2, Exception.1 seems to indicate that (in any room that is not a kitchen or bathroom) there shall be at least one switch per light? I'm definitely fuzzy on what this one is trying to say.

In those rooms requiring a switched light other than kitchens and bathrooms, you may instead switch an outlet. The concept being a floor or table light can be connected to that outlet, thereby allowing someone entering to illuminate the room.

ps: I meant to add the location is based mostly on common sense. You want the ability to illuminate a dark room upon entering.

 

[Yikes]

LIGHTING OUTLETS

E3903.2 Habitable rooms. At least one wall switch-controlled
lighting outlet shall be installed in every habitable
room, kitchen and bathroom. [210.70(A)(1)]

I see examples all the time of walk-in closets, bathrooms, single-purpose rooms, etc. where the proposed light switches are placed on a wall outside of the intended room, sometimes several feet away from the door, and there's no light switch in the room itself.

The IBC definition of "Habitable":
[BG] HABITABLE SPACE. A space in a building for living, sleeping, eating or cooking. Bathrooms, toilet rooms, closets, halls, storage or utility spaces and similar areas are not considered habitable spaces.

So, other than the bathroom, there's not a requirement to have the switch inside many non-habitable spaces such as closets, etc.

 

[stevemk]

You guys are awesome! Thanks so much, and if you have other advice you wish to share, please keep it coming.

 

[e hilton]

I suggested that you set the mounting heights to comply with ADA just in case the project might someday fall under those guidelines. And … be conservative. BTDT. ADA sets the max height of switches as 48”, so my electricians installed the centerline of the j-box at 48”. We failed the audit, because we used standard toggle switches, and the top of the toggle was at 48-1/4” in the up position. Petty? Yes, but technically correct. So now we set the centerline of the box at 46” or 47”. You might ask why they wouldn’t allow 1/4” tolerance … the justification was the the switch could be anywhere between 15” and 48” so we already had an huge range to hit.

 

[Mr. Inspector]

Also, when reading E903.3.3, it mentions that dimmers in these locations must be full range. It occurs to me, if we install these keypads and later provide programmed automation (which allows us to completely repurpose the buttons), and considering that we often set scenes where multiple lights are controlled and multiple lights do not exceed 80% power, these being common practices in our industry, is it possible that we are we breaking regulations in some cases? What do you think?

As long as you can get the required 6 footcandles over the area of the room at 30" above the floor of the room or 8% minimum glazing I would think it would be OK. Read IRC section R303.

 

[stevemk]

You never said what code your area uses. Here is the 2018 IRC. In commercial buildings you need to have switch's in the required reach zone for people with disabilities (IBC chapter 11) and the energy codes requires things too. most of the codes can be found at upCodes.com

LIGHTING OUTLETS
E3903.1 General. Lighting outlets shall be provided in accordance
with Sections E3903.2 through E3903.4. [210.70(A)]
E3903.2 Habitable rooms. At least one wall switch-controlled
lighting outlet shall be installed in every habitable
room, kitchen and bathroom. [210.70(A)(1)]
Exceptions:
1. In other than kitchens and bathrooms, one or more
receptacles controlled by a wall switch shall be considered
equivalent to the required lighting outlet.
[210.70(A)(1) Exception No. 1]
2. Lighting outlets shall be permitted to be controlled by
occupancy sensors that are in addition to wall
switches, or that are located at a customary wall
switch location and equipped with a manual override
that will allow the sensor to function as a wall switch.
[210.70(A)(1) Exception No. 2]
E3903.3 Additional locations. At least one wall-switch-controlled
lighting outlet shall be installed in hallways, stairways,
attached garages, and detached garages with electric power. At
least one wall-switch-controlled lighting outlet shall be
installed to provide illumination on the exterior side of each
outdoor egress door having grade level access, including outdoor
egress doors for attached garages and detached garages
with electric power. A vehicle door in a garage shall not be considered
as an outdoor egress door.
E3903.3.1 Stairway lighting outlet control. Where one
or more lighting outlets are installed for interior stairways,
there shall be a wall switch at each floor level and landing
level that includes an entryway to control the lighting outlets
where the stairway between floor levels has six or
more risers. Lighting outlets installed to meet this requirement
shall not be controlled by the use of dimmer switches
except where the dimmer switches provide the full range
of dimming control at each switch location. [210.70(A)(2)]
Exception: In hallways, stairways, and at outdoor
egress doors, remote, central, or automatic control of
lighting shall be permitted. [210.70(A)(2) Exception]
E3903.4 Storage or equipment spaces. In attics, under-floor
spaces, utility rooms and basements, at least one lighting outlet
shall be installed where these spaces are used for storage
or contain equipment requiring servicing. Such lighting outlet
shall be controlled by a wall switch or shall have an integral
switch. At least one point of control shall be at the usual point
of entry to these spaces. The lighting outlet shall be provided
at or near the equipment requiring servicing. [210.70(A)(3)]

I've been rereading NEC 210.70 and Utah's IRC 2015 (most current version), and I've learned that "wall switch-controlled lighting outlet" refers only to the lighting outlet, not to the wall switch itself. In fact, the Utah IRC 2015 makes a mistake and omits an important line found in NEC 2015 (and beyond), bolded and italicized below:

210.70 Lighting Outlets Required

Lighting outlets shall be installed where specified in 210.70(A), (B), and (C).

(A) Dwelling Units

In dwelling units, lighting outlets shall be installed in accordance with 210.70(A)(1), (A)(2), and (A)(3).

(1) Habitable Rooms

At least one lighting outlet controlled by a listed wall-mounted control device shall be installed in every habitable room, kitchen, and bathroom. The wall-mounted control device shall be located near an entrance to the room on a wall.
Exception No. 1: In other than kitchens and bathrooms, one or more receptacles controlled by a listed wall-mounted control device shall be permitted in lieu of lighting outlets.

Exception No. 2: Lighting outlets shall be permitted to be controlled by occupancy sensors that are (1) in addition to listed wall-mounted control devices or (2) located at a customary wall switch location and equipped with a manual override that will allow the sensor to function as a wall switch.

This makes clear that the language used differentiates lights and switches quite clearly, and when you reread the entire sections of NEC 210.70, and Utah IRC 2015 E3903, very little refers to the switch, and instead only implies that the light is controlled via wall switch, but it does specifically call out the wall switch when talking about stairways, for example, which you bolded originally. Furthermore, section E4001.15, points 5 and 6 below, seem relevant in some circumstances. Maybe I'm wrong on this, but point 6 could be interpreted such that an "automatic means" might include programmed automation, as well as default control of the lighting load without programming by means of the low-voltage keypad. I assume this is the exception to the rule that makes it possible for me to not wire the high-voltage lighting conductor to the keypad location and to just wire the lighting load direct to the lighting panel where control takes place, but where (per 210.70(A)(1) above) having the "wall-mounted control device ... located near an entrance to the room on a wall" is absolutely fine. I could certainly be wrong on this one, but it seemed interesting as a possible interpretation.

E4001.15 Switches Controlling Lighting Loads

The grounded circuit conductor for the controlled lighting circuit shall be provided at the location where switches control lighting loads that are supplied by a grounded general-purpose branch circuit for other than the following:

1. Where conductors enter the box enclosing the switch through a raceway, provided that the raceway is large enough for all contained conductors, including a grounded conductor.
2. Where the box enclosing the switch is accessible for the installation of an additional or replacement cable without removing finish materials.
3. Where snap switches with integral enclosures comply with E3905.1.3.
4. Where the switch does not serve a habitable room or bathroom.
5. Where multiple switch locations control the same lighting load such that the entire floor area of the room or space is visible from the single or combined switch locations.
6. Where lighting in the area is controlled by automatic means.
7. Where the switch controls a receptacle load. [404.2(C)]

 

[stevemk]

I've been rereading NEC 210.70 and Utah's IRC 2015 (most current version), and I've learned that "wall switch-controlled lighting outlet" refers only to the lighting outlet, not to the wall switch itself. In fact, the Utah IRC 2015 makes a mistake and omits an important line found in NEC 2015 (and beyond), bolded and italicized below:



This makes clear that the language used differentiates lights and switches quite clearly, and when you reread the entire sections of NEC 210.70, and Utah IRC 2015 E3903, very little refers to the switch, and instead only implies that the light is controlled via wall switch, but it does specifically call out the wall switch when talking about stairways, for example, which you bolded originally. Furthermore, section E4001.15, points 5 and 6 below, seem relevant in some circumstances. Maybe I'm wrong on this, but point 6 could be interpreted such that an "automatic means" might include programmed automation, as well as default control of the lighting load without programming by means of the low-voltage keypad. I assume this is the exception to the rule that makes it possible for me to not wire the high-voltage lighting conductor to the keypad location and to just wire the lighting load direct to the lighting panel where control takes place, but where (per 210.70(A)(1) above) having the "wall-mounted control device ... located near an entrance to the room on a wall" is absolutely fine. I could certainly be wrong on this one, but it seemed interesting as a possible interpretation.

Correction: Beniah Naylor already pointed out the that the line I saw in NEC 2020 is not yet included in Utah's IRC. For now, I can do whatever I please! ... Well, within reason. If I really want to, I can place a keypad for the upstairs master bath chandelier in the basement equipment closet, but that's assuming there are no occupancy regulations that dictate where lighting control devices must be located.

What I assume all of this means, however, is that I can install a single, multi-button keypad in a reasonable location at a reasonable height where a hallway, living room, foyer, and mudroom intersect (for example), rather than have to install 4 keypads all within 3 feet of each other for no reason. This cleans up my design greatly, and means that I don't have to unreasonably install extra low-voltage keypad wires and boxes that must then be covered up by ugly blank cover plates. THANK GOD. Now I can just put keypads wherever the customer wants them as long as I provide switched control of each lighting load individually. I still need to check if there are occupancy regulations. I heard someone say that light switches need to be within 6 feet of the entryway according to an occupancy regulation, but I have no idea if that's true.