Canadian Electrical Code Full Impact Assessment

Transcription

1 Canadian Electrical Code Full Impact Assessment Subject 3931 Update Section 26: Revisions to exceptions for AFCI protection

2 CONTENTS 1 INTRODUCTION TO THE FULL IMPACT ASSESSMENT PURPOSE OF THE FULL IMPACT ASSESSMENT BACKGROUND OF THE CHANGE THE NATURE OF THE CHANGE How is it different from the Status Quo? PURPOSE/ REASON FOR THE CHANGE What is the issue that the change is intended to address? How does the change accomplish the desired results? What are the implications/consequences if action is not taken? WHY IS ACTION REQUIRED AT THIS TIME? (14) PREVALENCE OF RULE USE IF ACCEPTED IMPACT ON KEY STAKEHOLDERS (16) Largest type of stakeholder who would benefit (24) Largest type of stakeholder who would be negatively affected (15) Other stakeholders affected on frequent basis Is the proposed change limited to a specific group/geographic area? What is the affected stakeholders readiness to act on the change(s) Recommended stakeholder management strategy Communication and implementation plan ANALYSIS OF ANTICIPATED ECONOMIC IMPACT (20) The jurisdiction or stakeholder s ability to compete based on incompatibility with other standards (21) Complexity of Implementation (is training required to be able to implement the rule?) (22) Total costs to implement (for example cost to install, educate, to manufacture/or inspect, purchase additional product, and of the increased use of electricity)... 6 IMPACT ON BUSINESS: LARGE AND SMALL (IF APPLICABLE)... 7 Page 1 16/01/2018

3 11 WHAT IS THE PRACTICE/EXPERIENCE IN OTHER JURISDICTIONS? Are standards consistent with (or lesser/greater than) other jurisdictions? (23) Conflict with other Ministries or Codes Consequence on other Departments/Ministries, e.g. apprentice training Consequence on other Codes from other jurisdictions (US, European standards) CONSULTATION PROCESS PROPOSED EFFECTIVE DATE OF CHANGES APPENDIX 1 CODE RANKING TOOL VALUES... 9 Page 2 16/01/2018

4 Subject 3931 Update Section 26: Revision to exceptions INTRODUCTION TO THE FULL IMPACT ASSESSMENT The Full Impact Assessment follows the rationale of the Canadian Electrical Code Ranking Tool (CRT) and provides supporting information to validate the rankings of the CRT. It includes all the questions of the CRT either verbatim or modified. However, the scope of the Full Impact Assessment extends beyond that of the CRT and therefore the document includes additional questions that may help to further substantiate the rankings. The CRT is referenced throughout the Full Impact Assessment. Questions contained in the CRT are included in the Full Impact Assessment and identified by numbers in parentheses. Whenever applicable, chapter titles also include references to sections of the CRT discussed in the chapter. While an effort has been made to follow the sequence of the CRT as closely as possible, risk related and benefits related questions have not been separated in the Full Impact Assessment to enhance the analytical function of the document. PURPOSE OF THE FULL IMPACT ASSESSMENT The purpose of the Full Impact Assessment is to provide the Provinces and Territories with an enhanced rationale and detailed assessment of a particular change to the Canadian Electrical Code (CEC). The following assessment is submitted for review to provincial and territorial regulatory authorities to aid with their adoption process of the Code. Jurisdictions may decide to conduct further analyses and hold additional consultations. Page 3 16/01/2018

5 1 BACKGROUND OF THE CHANGE The original intent of rule (f) was to allow a branch circuit that only feeds kitchen, washroom, or bathroom receptacles to be exempt from AFCI, however the literal wording of the accepted text created a loop hole. 2 THE NATURE OF THE CHANGE 2.1 How is it different from the Status Quo? Revise Item (f) as shown. (f) each branch circuit supplying 125 V receptacles rated 20 A or less shall be protected by a combination-type arc-fault circuit interrupter, except for branch circuits supplying (i) receptacles installed in accordance with (A) Rule 26-7(f) provided no other receptacles are connected to these circuits; or (B) Rule 26-7(d), (d)((i), (iii), (iv), and (v); and (ii) a single receptacle for a sump pump where (A) the receptacle is labelled in a conspicuous, legible, and permanent manner identifying it as a sump pump receptacle; and (B) the branch circuit does not supply any other receptacles; and 3 PURPOSE/ REASON FOR THE CHANGE 3.1 What is the issue that the change is intended to address? Based on the current wording of rule (f), as long as a washroom or bathroom receptacle was on a circuit, it would be exempt. For example, if a circuit contained 11 bedroom receptacles and one washroom receptacle the entire branch circuit would be exempt from the AFCI requirements. This implantation of the rule effectively lowers the level of protection to the public. 3.2 How does the change accomplish the desired results? Receptacles installed in accordance with rule 26-7(f) would be considered AFCI exempt only if no other receptacles are connected to the circuit. Page 4 16/01/2018

6 3.3 What are the implications/consequences if action is not taken? If not action is taken at this time AFCI exemptions will continue to be misinterpreted and applied incorrectly. The change to rule (f) is intended to clearly state the requirements for exemption. 4 WHY IS ACTION REQUIRED AT THIS TIME? It is important to improve the wording of the code when known confusion exists. Such revisions will not only clarify the objective of these rules, but will improve consistency in their application, which will result in improvement of electrical safety. 5 (14) PREVALENCE OF RULE USE IF ACCEPTED AFCI exception rules are applied frequently. It is expected that these rules will see daily use. 6 IMPACT ON KEY STAKEHOLDERS 6.1 (16) Largest type of stakeholder who would benefit Clarity introduced by these changes will benefit installers, trainers and others who reference the code frequently. The general public is also considered a stakeholder who will benefit from the increased safety introduced by the clarity added with the code change. 6.2 (24) Largest type of stakeholder who would be negatively affected Installers/designers will be required to implement these changes. Exemptions will no longer be applied the way they currently are. AFCI exemption will now be dependent upon the existence or non-existence of other receptacles present in the circuit. 6.3 (15) Other stakeholders affected on frequent basis The revision will affect a broad range of stakeholder groups, namely: Other standard development organizations (SDO). All references to the part of the CEC being modified will need to be updated in the relevant documents published by other SDOs. Provincial /territorial electrical regulatory authorities. This group of stakeholders will be responsible for enforcement of new requirements and will therefore need to be informed of recent amendments. Insurance. Insurance policies contingent on following the CEC will need to be updated. Page 5 16/01/2018

7 Builders. Need to be informed of the changes since they will have to be incorporated into constructions. Inspectors. This group of stakeholders is accountable for enforcing compliance with the Code, and should therefore stay informed about recent amendments. It is the responsibility of a particular province or territory to make the information on recent Code amendments available to electrical inspectors. Depending on the practice of a particular jurisdiction, the changes can be communicated through training (provided by the jurisdiction or a third party), or through jurisdiction-specific or national industry literature. 6.4 Is the proposed change limited to a specific group/geographic area? The change will have a nationwide application. 6.5 What is the affected stakeholders readiness to act on the change(s) Research has not revealed any evidence of market not being ready to implement the changes discussed in the revision. 6.6 Recommended stakeholder management strategy Not applicable. 6.7 Communication and implementation plan Not applicable. 7 ANALYSIS OF ANTICIPATED ECONOMIC IMPACT 7.1 (20) The jurisdiction or stakeholder s ability to compete based on incompatibility with other standards The revision should not affect a jurisdiction s competitive position. 7.2 (21) Complexity of Implementation (is training required to be able to implement the rule?) This clarity provided by this change is intended to eliminate confusion of a somewhat complex requirement and may require formal training. It is also intended to provide clear and safe exemptions. 7.3 (22) Total costs to implement (for example cost to install, educate, to manufacture/or inspect, purchase additional product, and of the increased use of electricity) Page 6 16/01/2018

8 The cost to implement this change will be dependent on the number of circuits requiring AFCI protection. It is anticipated that this change will have a moderate increase in overall costs as more branch circuits will require AFCI protection. 8 IMPACT ON BUSINESS: LARGE AND SMALL (IF APPLICABLE) Compliance costs. Initial compliance will increase the anticipated project costs, but there are several options available to optimize costs. Change of investment. Not applicable. Job creation / job loss. Not applicable. Labour mobility. Not applicable. Impact on import/export of goods. Not applicable. Certification and licensing. Not applicable. Insurance. Not applicable. 9 WHAT IS THE PRACTICE/EXPERIENCE IN OTHER JURISDICTIONS? 9.1 Are standards consistent with (or lesser/greater than) other jurisdictions? Currently there are no deviations from the national CEC on this item in provincial electrical codes. 9.2 (23) Conflict with other Ministries or Codes Not applicable. 9.3 Consequence on other Departments/Ministries, e.g. apprentice training Not applicable. 9.4 Consequence on other Codes from other jurisdictions (US, European standards) Not applicable. CONSULTATION PROCESS The following groups of stakeholders were involved in the consensus approval of this change as part of CSA s standards development process. For details please refer to Appendix C of the Canadian Electrical Code. Groups that have been involved in accepting this change include: Page 7 16/01/2018

9 Regulatory authorities selected from various provincial, territorial and municipal electrical inspection authorities. Owners/Operators/Producers selected from groups with national stature, representing the viewpoints of electrical equipment manufacturers, electrical installation designers and installers and electrical installation users. General interest representatives selected from groups with national stature, representing the viewpoints of : (a) fire chiefs (b) electric utilities (c) committees responsible for related electrical codes and standards (d) fire insurers (e) labour (f) issuers of building codes, and (g) educators A regulatory/legislative body may want to hold additional consultations with all or some of these groups within their jurisdiction to clarify issues specific to the jurisdiction. 11 PROPOSED EFFECTIVE DATE OF CHANGES The change will be included in the CEC 2018 edition published January, Page 8 16/01/2018

10 12 APPENDIX 1 CODE RANKING TOOL VALUES Page 9 16/01/2018

11 Reason for Change Safety consideration (Severity) Safety consideration (Frequency) Subject # 3931 For clarity Crucial to harmonize Purely administrative Community's desire to change - Environment, Health, Safety Technological change/new Rule 0 Total Score for Reason for Change Extent of Use & Value Add Prevalence of rule use if accepted 60 8 Number of stakeholders affected on frequent basis Largest type of stakeholder who would benefit Benefit to society Total Score for Extent of Use Risk for Changing Rule/Staying Status The jurisdiction or stakeholder's ability to compete based on incompatibility with other standards 38 0 Complexity of implementation 1 Total costs to implement, e.g. cost to install, to educate, to manufacture,or inspect, increased product cost, increased cost of electricity. 5 Conflict with other Ministries or Code 1 Largest type of stakeholder who would be negatively affected 9 Total Score for Risk of Changing Rule/ Staying Status Quo 16 Total 114 Page 16/01/2018