AFCI 2002 NEC ROP and ROC
The following is an explanation of the negative vote by one of the Code panel members on the issue of AFCI. This is in reference to Log #4348, Proposal #2-106, Page 129 of the Report of Proposals (ROP) for the 2002 NEC. (http://www.mikeholt.com/htmlnews/nec/pdf/AFCI_proposals.pdf).
EXPLANATION OF NEGATIVE: BROWN: This proposal should be accepted (that is to remove AFCI from the 2002 NEC).. It was wrong for the Panel to accept this requirement during the 1999 NEC ROC. To have a better understanding of the many basic problems, you need to read the negative comments on the original proposal. These can be found on pages 111 through 116 of the 1998 Annual Meeting, National Electrical Code Committee Report on Proposals. These comments, pointing out the fundamental problems with the device, still hold truth today.
The standard by which they are developed and tested, the CPSC and other studies used by the proponents to force this product into the NEC are still of concern. Though, most important is the fact that this device will NOT solve the problems the manufacturers stated was the real intent of pushing these devices into the marketplace through a mandate in the NEC.
It was the engineer from Underwriters Laboratories who showed the panel the basic technical problems with the device. It will not be able to detect all arcs that may produce a fire. Asked if the device will detect and trip all arcs between the breaker and the first outlet the answer was NO! The same held true for the area of the device, the area from the device to the appliance, and of the appliance itself.
Asked what percentage of arcs may be detected and the answer is they do not know. This could partly be caused by the inability for manufacturers to produce a product that solves all of the problems as shown in the UL study performed for CPSC. UL developed 14 test methods for the devices to pass to be reliable. These tests were developed based on identifiable causes of residential electrical wiring fires.
The UL standard used to manufacture and test this product is only over a year old. It was rushed through development only to satisfy the needs of the manufacturers as it relates to their specific product. As it turns out, the devices can pass only 4 of the tests. Not the full 14 test methods needed for this product to protect residential occupancies as outlined in the UL-CPSC study.
More to the point, the tests only use nonmetallic sheathed cable with a grounding conductor. Not the common single conductor concealed wiring method installed on older dwellings. Another problem with the CPSC study is the inability of the data to accurately ascertain the specific area of origin of the electrical fire. The study also did not indicate the actual type of wiring method, or the age of the dwelling. If all of this information is known, it would better indicate where the real problem exists.
It would be hard to believe that the nonmetallic sheathed cable -ROMEX - being installed today is the overwhelming cause of residential electrical fires. The CPSC study did reach the conclusion that further testing needed to be performed. So we now have a mandate for a product that is unreliable in its ability to protect. The high cost of this product is also a concern. The manufacturers repeatedly stated at the ROC meeting that the cost of this product would be the same as a GFCI device. This is not true. The manufacturer's catalog lists the devices at around $160.00 each. A check of the wholesale price was approximately $95.00. So now we have an unreliable product at a high price. Then we have the manufacturers statements on losses due to concealed electrical wiring.
Square-D in their product brochure states "CPSC estimates electrical equipment causes 155,100 or 34 percent of the 451,000 fires in residential structures." This is very misleading. Using current NFPA estimates based in the U.S. Fire Administration's National Fire Incident Reporting System (NFIRS), the total residential fire losses due to all electrical causes is only 13.75 percent of the total residential fire losses. Now, using the same data, the losses due to electrical wiring within the walls is only 5.49 percent of the total residential fire losses. This is not the 34 percent insinuated by the manufacturers.
Now, we have an unreliable product, at a very high price compared to the losses it may save. Using the NFPA data and the 1999 NEC requirements, if the devices were 100 percent reliable, consumers will spend $240,000,000 to cover losses of only $30,900,000. Well over seven (7) times the total losses. If this product is expanded to include all circuits in a dwelling, the public would spend over $2,400,000,000 to prevent losses of $253,600,000. This is approximately 9.5 times the actual loss. And, this is based on 100 percent effectiveness.
As noted, above, UL cannot determine the effectiveness of the product. Even more disturbing is a recently published article by UL stating property losses of over $1.5 billion. From the standpoint of cost-effective regulatory mandates, the requirement in the NEC for this product is unacceptable. This whole situation reminds one of the mandates for CO detectors. All studies have shown the location for installation of the detector to be reliably effective cannot be determined. Furthermore, there are numerous problems with the technology and the manufacturing of the detector.
Recalls and public announcements as to the problems are constant. It may be partly due to a rush by manufacturers to get the detectors into the marketplace. The AFCI is also a product that is untested in relationship to the actual problem that may exist, or its ability to effectively control them. Until a more complete study of the actual causes of residential electrical fire is available, and a product can be developed to meet those needs, mandates for AFCIs should not be included in the NEC. Society should not be mandated to spend 10-20 times the amount of money that may be saved without a solid basis for the expense.
Code Panel No. 2 Member, Mr. Brown
Mike Holts Comment: I dont know who Mr. Brown is and whos interest he represents. Other important AFCI files relating to the 2002 NEC to help you understand both sides to the story are included in the 2002 NEC Report on Comments (ROC) http://www.mikeholt.com/htmlnews/nec/pdf/AFCI_comments.pdf and the action on the ROC http://www.mikeholt.com/htmlnews/nec/pdf/AFCI comment action.pdf).
Copyright © 2002 Mike Holt Enterprises,Inc.