Product Safety: Don’t Let Your Design Get Red-Flagged

Say the word “codes” and many lighting professionals quickly think of the 90.1 or IECC energy codes. But there are other codes that lighting designers must also be familiar with, such as the NEC (National Electrical Code) or the CEC (Canadian Electrical Code), or whatever electrical code is in force in the region where the design is to be installed. And to complicate the situation, lighting designers must have a working knowledge of the applicable safety standards that prevail for the products they specify. Jerry Plank, CEO/founder of Wilger Testing, takes a deeper dive into some of these product compliance questions.

In the U.S., ANSI/UL safety standards are used to determine whether a product is compliant or not, and eligible to bear an NRTL (Nationally Recognized Testing Laboratory) “Listed” mark. Failure to adhere to the applicable electrical code and safety standards will result in an unsuccessful project which will impact your reputation and your bottom line because you will be forced to spend valuable time trying to remove a violation (red flag) issued by an electrical inspector.

To help designers understand how a product or project could get red-flagged or derailed for non-compliance, Plank lists five key areas of concern:

1.Equipment selection. To be code-compliant, equipment selected must be listed by an NRTL and mounted as tested. Many times we see surface products that are semi-recessed in the field to reduce the exposure of the luminaire, which does not reflect upon how the product was tested by the NRTL. All municipal electrical inspectors have learned that when a luminaire listing, or its usage, is questionable, they will go directly to the NRTL that listed the product to ensure that what they are looking at was in fact tested and qualified. Make no mistake, if the lighting fixture was modified to suit your project, the modification needs to be qualified by the NRTL as an alternate construction or installation method and you should insist on getting a copy of the NRTL report to protect your interest.
2.Using newer technology. While it is not the intent of this article to prevent new technologies from being used, it is extremely important to receive objective evidence (i.e., a certification letter, or the like) from the manufacturer that the product selected is in fact listed by an NRTL, and meets with the intent of the NEC and the CEC. The revision cycle for each version of those two codes is three years, which means it’s possible that the new technology is not included in the prevailing version of the code. When a new technology is not addressed by the NEC or CEC, the decision whether to accept it or not is up to the municipal electrical inspectors and they are often reluctant to accept a new technology without a field inspection by a qualified NRTL. Field inspections by an NRTL to verify that the combination of the product and installation are compliant are costly and add significant delays to any project. The preferable path with a specified product is to ensure that the listing is up to date and addresses the new technology.
3.Equipment installation and wiring. The next item to address for potential red flags is the installation and wiring of lighting equipment in the field. On the surface it would seem logical that it’s the responsibility of the electrical contractor to follow local codes and practices to ensure that the installation is compliant and safe from reasonable risks. Potential problems occur whenever the product selected is not capable of mounting in a certain way to accommodate the project and requires a modification to accept conduit or the like, or special wiring is needed to facilitate the installation. Keep in mind that any modification of the NRTL-listed product for mounting and/or wiring requires a field inspection by an NRTL.

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4.Controls. Any use of controls must be addressed to prevent red flags. Simply put, controls must be listed by an NRTL and suitable for the product to which they are connected. Get copies of the relevant NRTL reports which will contain restrictions, if any, and how the wiring should be installed. While at times it seems expeditious to mix low-voltage and line-voltage in the same enclosure, know in advance what is allowed and what isn’t. Don’t leave the wiring decision up to the electrical contractor or assume that the claims made by the controls manufacturer are point of fact; investigate how the wiring shall be connected. An installation of low-voltage controls came under question recently by a municipal electrical inspector where line and low voltage were mixed in the wall junction electrical box. It took almost two weeks of investigation to determine that the wiring connected to the low-voltage circuit was acceptable as the rating was 300 volts; however, the project was red-flagged and stalled without cause.

5.Electrical codes and practices by region. Don’t assume which version of the NEC or CEC codes has been adopted in the region where the project will be installed. Every municipality has the right to adopt the current edition of the NEC or CEC, a previous edition of the NEC or CEC, create their own electrical code, or adopt a nationally published code with regional variances. Too many projects get rejected because the NRTL listing applied to an ANSI/UL safety standard which did not address local practices. Always verify what electrical code has been adopted in the region where the project is installed and what local variances, if any, should be addressed.