excluding “equipment” in the definition,
the grounding electrode requirement in
Section 250.32 will no longer apply to
power outlets, electric vehicle chargers
and other electrical equipment. There
are also potential revisions on the way to
specifically address this issue in Article
551 for Recreational Vehicle Parks.
Flexible metal conduit as an EGC?
During a recent renovation project that
involved a large amount of lighting, I had
an issue with the electrical inspection and
the reuse of some lighting tails that were
installed using flexible metal conduit
(FMC). The previous installation was only
a few years old, but the spaces changed
hands, and new tenants desired a new
ceiling and new lighting fixtures. The
previous lighting tails were each shorter
than 6 feet and protected at 20 amperes
(A). The lighting tails did not contain
equipment grounding conductors (EGCs)
because they met the requirements in
250.118. The electrical inspector asked
us for documentation to prove that the
existing FMC and fittings were listed. We
could not provide such documentation
and were forced to install EGCs. Was the
List item ( 5) in Section 250.118 permits
the use of “listed” FMC as an EGC, pro-
vided all four of the requirements listed
in 250.118( 5) are met. The first require-
ment is that the fittings are also listed.
This is obviously where the inspector
had an issue. During the initial instal-
lation, the installer apparently had
access to documentation that both the
FMC and fittings were listed. It should
be noted that, while 250.118( 5) requires
“listed” FMC and fittings under pre-
scribed conditions to be used as an
EGC, Section 348.6 contains a general
requirement that all FMC and asso-
ciated fittings are to be listed. The
problem that inspectors face here is
that nonlisted FMC and fittings are
readily available. It is for that reason,
an inspector should ask to see the coils
of FMC and boxes of fittings being used
to ensure that they are listed products.
However, in this particular case, the
inspector or one of his or her colleagues
had approved this job a few years earlier.
All of the tails were shorter than 6 feet
and protected at not more than 20A as
required. Short of listing documentation
for the FMC and fittings, the requirements of 250.118( 5) were met.
If you were adding FMC tails used
as an EGC, it would be your responsibility to prove the products were listed. In
my opinion, in this particular case, the
inspector should not have required you
to install EGCs. While you were unable
to provide listing documentation, the
same department previously approved
the installation, and the inspector did
not provide information to prove that
the products were not listed.
While discussing the use of FMC
as an EGC, it must be understood that
250.118( 5) does not permit FMC to be
used as an EGC under any circumstances
where the FMC is installed because flexibility is required due to vibration or
movement. In those situations, an EGC
must be installed.
What is a kitchen?
The NEC defines a kitchen as having
a permanent means of cooking. If a
cord-and-plug microwave is bolted
to the wall, do we have a kitchen?
Microwaves are used for reheating foods
and not for cooking. Shouldn’t the NEC
address a range or cooktop to be more
The Article 100 definition of “kitchen”
is, “An area with a sink and permanent
provisions for food preparation and
cooking.” To even consider whether
we have a kitchen based on permanent
provisions for cooking, a sink along
with a permanent countertop or table
must be installed for food preparation. Where a range or a cooktop are
installed, we obviously have permanent
provisions for cooking. Where a receptacle is installed on a countertop and
a portable microwave is placed on the
countertop, plugged in and used, that is
not considered permanent, and, therefore, a kitchen does not exist. Where a
microwave, cord-and-plug connected
or hardwired, is permanently installed,
along with a sink and permanent provisions for food preparation, it is by
the NEC definition, a kitchen. I agree
with you that, in many cases, such as
an office break room, a microwave
may be used to simply reheat foods.
However, the microwave can be used
to cook and is permanently installed,
so we have permanent provisions
for cooking, and thus a kitchen.
DOLLARD is the safety coordinator for IBEW Local No. 98 in Philadelphia and works closely
with contractors to ensure job-site safety and compliance with all installation codes and
standards. He is a member of the NEC Correlating Committee, NEC CMP- 10, NEC CMP- 13, NFPA
70E, NFPA 90A/B and the UL Electrical Council. He can be reached at firstname.lastname@example.org.
While discussing the use of flexible metal conduit as an
equipment grounding conductor, it must be understood
that 250.118( 5) does not permit FMC to be used as an EGC
under any circumstances where the FMC is installed because
flexibility is required due to vibration or movement.