Question 1. I am proposing to use Lucifer low-voltage strip lights with lens covers (see image 1 and image 2) within wardrobe cabinets (see attached drawing). Does 410-8 [NEC 1999] apply to this application as though it were a closet? Any assistance would be most appreciated. — Fred Fargetstein

Answer 1. This question is asking for a clarification on the application of NEC 410-8. To rephrase the question: Do the installation requirements of NEC 410-8, Fixtures in Clothes Closets, apply to wardrobe cabinets too? In general, the answer is no.

Article 410 covers lighting fixtures and lighting installations. Section 410-8 applies to the installation of lighting fixtures in clothes closets.” This section consists of several subsections, which provide a definition of storage space, information on the type of lighting fixtures permitted and not permitted in clothes closets, and the acceptable locations for the installation of lighting fixtures in clothes closets.

Although 410-8 is not specific to wardrobe cabinets, the answer to the question is within subsection 410-8(a) — definition of storage space. “Storage space shall be defined as a volume bounded by the sides and back closet walls and planes extending from the closet floor vertically to a height of 6 ft (1.83 m) or the highest clothes-hanging rod and parallel to the walls at a horizontal distance of 24 in. (610 mm) from the sides and back of the closet walls respectively, and continuing vertically to the closet ceiling parallel to the walls at a horizontal distance of 12 in. (305 mm) or the width of the shelf, whichever is greater.” This definition provides a reasonably good mental picture of a storage space. With some clarification, we can determine if this space applies to wardrobe cabinets too. To do this, a little reasoning is in order.

According to the definitions of “wardrobe” and “closet” in Webster's Dictionary, it is reasonable to conclude that a wardrobe and closet are one in the same. It is also reasonable to conclude, based on the information in the sketch submitted with this question, that the wardrobe cabinet is for hanging clothes. Therefore, it is reasonable to conclude that a wardrobe cabinet is indeed a clothes closet. Knowing this, how can the answer to the question be no?

The clothes closets that the NEC addresses are a permanent part of the building or structure. Clothes closets are constructed of the building or structure walls and ceiling. The walls are the sides of the building or room connecting the floor and ceiling; the ceiling is the overhead inside lining of the room; and, the closet is the space surrounded by the walls. Wardrobe cabinets are not part of the permanent building or structure. Wardrobe cabinets are household or commercial furnishings that may or may not be illuminated. Except for office furnishings, the NEC does not cover installation requirements for lighting fixtures in these furnishings.

Lighting fixtures installed in these furnishings fall under the purview of the appropriate product safety standard. Clothes closets that the NEC addresses and wardrobe cabinets are not one in the same. Wardrobe cabinets are simply furnishings for the building or structure. It may be wise to consult the cabinet manufacturer, the lighting fixture manufacture, and the appropriate product safety standard for the specific requirements of lighting fixtures in furnishings. This is especially important where the furnishing’s intended use is for hanging clothes. Fire is one of the major concerns with lighting fixtures in clothes closets. Obviously, lighting fixtures and combustibles confined within any small space can lead to a fire hazard.

Naturally, lighting fixtures get hot during operation. Many require adequate ventilation and installation locations where they are not confined. Some require installation on an insulated wall or ceiling, or on a noncombustible surface. Lighting fixtures are readily available that can be installed in these cabinets with ease. Knowing this, a warning of “let the buyer beware” may be in order. Many of these lighting fixtures are not intended for installation or use in enclosed spaces. Always read and follow the manufacturers' installation and use instructions included with lighting fixtures.

As a final note, keep in mind that the NEC does not address every installation scenario that may arise in the field. This would be impossible. In those instances, a judgment call by the authority having jurisdiction is usually necessary. I hope this response provides some clarification to the application requirements of 410-8. If not, it never hurts to use good common sense too! — Lanny McMahill, CMP-18

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Question 2. The following question has come up in local Code discussions and as an inspector, I do not have a clear answer. I have looked in the U. L. White book under “Incandescent Recessed Luminaires” (IEZX), but did not find an answer. May thermal protected (type T.P.) recessed can lights (luminaires) be installed in a cathedral (i.e. slanted) ceiling? If yes, should the thermal protection element be on the high or low side of the can? Your assistance with this would be appreciated. — A.N.

Answer 2. Absolute “yes” or “no” answers to a question are great. Unfortunately, when working in codes and standards absolute answers are not always possible — caveats may need to be included with the answer. With this in mind, the answer to the question is “yes.” Now here are the caveats. First, NEC 110.3(b) requires that “listed or labeled equipment shall be installed and used in accordance with any instructions included in the listing or labeling.” The recessed incandescent luminaire should have no markings requiring that it be installed in a specific mounting position or orientation, such as “This End Up.” Any marking restricts the installation to the orientation noted. If there is no marking on the luminaire, the mounting position or orientation should be visually obvious. For most recessed luminaries, ceiling mounting is visually obvious. 

Second, the thermal protection has nothing to do with the mounting position or orientation of a recessed incandescent luminaire. Disregarding the exceptions to National Electrical Code (NEC) 410.65(c), all recessed incandescent luminaries, regardless of mounting position or orientation, shall have thermal protection. It makes no difference if the thermal protection element is “on the high or low side of the can.” If installed per the listing and labeling, the thermal protection element will perform properly.

Third, although this information is not readily available in “Underwriters Laboratories White book,” and unless there are restrictions by the manufacturer's installation instructions or marking on the luminaire, ceiling mounted luminaries can be wall mounted too. Luminaires identified for wall or ceiling mounting, conform to the test standard requirements for ceiling mounted luminaries. Luminaires tested for wall mount installation only, are marked “Wall Mount Only.” Again, with these caveats in mind, the answer to the question is yes. Feel comfortable installing a recessed incandescent luminaire in a slanted position in a cathedral ceiling. The recessed luminaire will perform properly whether mounted in the ceiling or wall or somewhere in between if installed per its listing or labeling. Where properly installed, there should be no concern with the orientation of the luminaire's thermal protection element. — Lanny McMahill, CMP-2

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Question 3. I am hoping that you can settle an ongoing debate that we are having in our office. Our controversy involves the placement of receptacle outlets in the area around bathtubs and showers.

NEC 410.4(D) [2002], Bathtub and Shower Areas, provides a specific area around tubs and showers that certain types of luminaries are not permitted to occupy.

NEC 406.8(C), Bathtub and Shower Space, restricts the installation of receptacles within a tub or shower space, but does not define the boundaries of this space.

This brings me to our question:   Based on the area referred to in 410.4(D) and the space referred to in 406.8(C), are both of these sections referring to the same physical space?  

In the Illustrated Guide to the National Electrical Code, 1999 edition, by Charles Miller, he treats both of these areas the same and states that no receptacle outlet is permitted in the space. What is your interpretation on this issue? — W.S.

Answer 3. I am not sure I can settle the debate, but I will attempt to provide some guidance for a reasonable conclusion

In the Manual of Style for NFPA Technical Committee Documents, Section 3.2.1.2 states, “Spelling and definitions of general words and terms shall follow Webster's Collegiate Dictionary, 10th edition.” Section 3.2.2.3 states, “When a standard definition is needed, Webster's shall be utilized where the meaning is correct and accurate as used in NFPA documents.”

Section 410.4(D), Bathtub and Shower Areas, addresses luminaires (fixtures) in specific locations. It states that “No parts of cord-connected luminaires (fixtures), hanging luminaires (fixtures), lighting track, pendants, or ceiling-suspended (paddle) fans shall be located within a zone measured 900 mm (3 ft) horizontally and 2.5 m (8 ft) vertically from the top of the bathtub rim or shower stall threshold. This zone is all encompassing and includes the zone directly over the tub or shower stall.”

Section 406.8(C), Bathtub and Shower Space, addresses receptacles in damp or wet locations. It states, “A receptacle shall not be installed within a bathtub or shower space.”

Webster's Dictionary defines space as “a limited extent in one, two, or three dimensions.” Working space is perhaps a good example of the use of the word space. Working space is given as a depth, width, and height — three dimensions. Webster's defines zone as,  “a region or area set off as distinct from surrounding or adjoining parts.”  Hazardous (classified) locations are a good example of the use of the word zone.  Zone is used extensively for classifying hazardous locations in distinct areas.

Knowing this, a reasonable conclusion is that the words space and zone do not have the same meaning. Space is less defined and zone is more defined. However, if we refer to 225.19(E), Zone for Fire Ladders, it would appear that space and zone are one in the same. Section 225.19(E) states in part that, “. . . overhead lines shall be arranged, where practicable, so that a clear space (or zone) at least 1.8 m (6 ft) wide will be left either adjacent to the buildings . . .” In this case, a reasonable conclusion is that space and zone have the same meaning.

Where does this lead us? Where the word space is used in the Code, it allows for some flexibility and judgment in code enforcement (i.e., receptacles along the floor line of a wall space); it is less stringent.  Where the word zone is used in the Code, it does not allow for the same flexibility and judgment in code enforcement (i.e., hazardous (classified) locations); it is more stringent.

I hope this provides some guidance for a reasonable conclusion.  If you would like to debate this issue further, I would suggest throwing the word area into the mix too! — Lanny McMahill, CMP-18

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Question 4. I am employed with the Maryland State Fire Marshals Office and I do the electrical testing for them.  The University of Maryland called me with a question regarding the 2002 NEC.  The question dealt with 110.31(A).  They were inquiring if this applies to all electrical rooms or new installations.  They were also wondering why this code change came about. The concern that they have is partially due to an incident in the fall at their facility. There was a fault in some switchgear in one of their electrical rooms that resulted in a fire, and a fatality occurred.  Now they are going back and evaluating all of their equipment and electrical closets and researching the Code on it and finding that most of the areas do not have the three-hour rating required by the 2002 NEC. Can you shed some light on this for me as I am under the impression that it applies to new construction and any major modifications? — M. C.    

Answer 4. First, I am sad to hear that an electrical incident resulted in a fatality. Since you did not indicate the type of electrical testing you perform for the Fire Marshall’s office, I will begin with a note of caution. It is imperative that one be familiar with NFPA Standard 70E and that one have the appropriate safety training on the hazards involved when performing any type of electrical testing. It is also necessary to have the required skills and knowledge in the installation, use and maintenance of the electrical system. These factors are important when working on any electrical system, but they are especially important when working on equipment over 600 volts. Only qualified persons should service such systems!

Second, to address your questions, a minor clarification is in order. National Electrical Code Article 110 provides the general requirements for electrical installations, and Part III applies to electrical installations over 600 volts, nominal. Subsection 110.31(A) addresses the fire resistivity of electrical vaults. This subsection provides specific information on the construction requirements for an electrical vault. Subsection 110.31(A) only applies where a vault is required for the electrical installation. If the electrical equipment is enclosed, such as in metal-enclosed switchgear, unit substations, pull boxes, raceways, etc., a vault may not be required.

Your question is asking if 110.31(A) applies to all electrical rooms or new installations, and why this code change came about in 110.31(A).

Does 110.31(A) apply to all electrical rooms? No. The word "room" typically means a room within a building or structure. Subsection 110.31(A) only applies where an electrical vault (room) is required within a building or structure. For installations over 600 volts, an electrical vault is required where live parts must be guarded against accidental contact or where exposed service-entrance conductors are installed within a building or structure. The electrical vault is the enclosure for the live parts and conductors. A good example of this is an outdoor substation and switching yard. Outdoor substations and switching yards are installed in enclosed fenced-in areas. There is no need for a fire resistive electrical vault as there is no potential fire or explosion hazard to a building or structure. The live parts require protection from accidental contact — a fence or other suitable enclosure accomplishes this. If this substation and switching yard were in a building or structure, a fire resistive electrical vault would be required.

Does 110.31(A) apply to all new installations? Generally, yes. Subsection 110.31(A) applies to over 600 volt installations where an electrical vault is required. An electrical vault is required for specific installations, such as where live parts must be guarded or exposed service entrance conductors are installed in a building or structure.

Why the code change to Section 110.31? The 1999 NEC, Section 110-31, Enclosures for Electrical Installations, mentioned "electrical installations in a vault." A fine print note (FPN) after the section referred the user to Article 450 for construction requirements for transformer vaults. The reference to transformer vaults was confusing and the FPN was unenforceable. To eliminate this confusion, it became obvious that the construction requirements for electrical vaults needed to be included in Article 110. Therefore, 2002 NEC, Section 110.31(A), Fire Resistivity of Electrical Vaults, came about. The requirements in 110.31(A) simply mirror the requirements in Article 450 for a transformer vault. Realistically, the intent of the code did not change, only the usability.

I hope my comments will assist you in evaluating the electrical system for the facility and that they provide reasonable guidance and clarification regarding 110.31(A). I also encourage you to be careful around over 600-volt systems and see that only qualified persons service these systems! — Lanny McMahill, CMP-18

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Question 5. I have seen many electricians using their side-cutting Klein pliers as strippers even though they do not have a manufactured stripping hole. Is this considered a legal or safe practice?  If you want to stir up a hornet’s nest, just challenge a group of them on this. — P.H.

Answer 5. It is common knowledge that most electricians have been guilty of stripping conductor insulation with their side cutters at one time or another, and some are good at it too. Is this considered a legal or safe practice? Since a "yes" or "no" response is out of the question, a little deliberation is in order.

Is this a legal practice? Section 110.12, Mechanical Execution of Work, requires that electrical equipment be installed in a neat and workmanlike manner. Workmanlike is not defined in the NEC; however, Webster’s defines it as "worthy of a good workman" or "skillful." The word "craftsman" comes to mind too. Based on Webster’s definition, it leads one to surmise that workmanlike is in the eyes of the beholder. In other words, what looks good to one person may be atrocious to another.

It should also be understood that the proper use of any tool is a work practice issue. Work practice issues are not addressed in the NEC. Therefore, the use of an incorrect tool for any job has nothing to do with being a legal practice. It has everything to do with being a good work practice. Obviously, using side cutters for stripping conductor insulation is not a good work practice. Is it a legal practice? Only a craftsman can answer this question.

Is this a safe practice? Section 110.12(C) states, "There shall be no damaged parts that may adversely affect safe operation or mechanical strength of the equipment.…" Using an improper tool on any part or equipment could easily affect safe operation. A damaged conductor has the potential of creating a high impedance current path; damaged conductor insulation could easily subject a person to exposed live parts. Either situation is undesirable and may adversely affect the safe operation of the equipment.

In addition, it is fair to note that not too many tool manufacturers or training organizations would recommend using side-cutting pliers as a stripping tool. Most would train and advise to use the correct tool for the job at hand. An analogy of this is asking a carpenter to do trim work using a chain saw. Sure, the chain saw will do the job, but the outcome may not be what was expected. So, is using side-cutters as a stripper a safe practice? Definitely not!

Always use the proper tools for the installation or application and continue to learn and grow as it can only lead to a safe and code compliant installation! For those electricians good at stripping conductor insulation with their side-cutters, keep-in-mind that bad habits are hard to break. That should stir up a hornet’s nest too. — Lanny McMahill, CMP-18

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Question 6. I have a question regarding 410.8(C). Is it permissible to use a fluorescent bulb in a recessed can and still meet the Code? I see no exceptions for this. — W. A.

Answer 6. In response to your question, a fluorescent lamp in an incandescent luminaire does not make the incandescent luminaire fluorescent.

Looking at 410.8(D), the Code uses wording to help the reader realize that the intent is to limit the proximity of an incandescent fixture to 12 inches from the storage space. Notice the use of the word fixture in this section.

The problem is that while the inspector is on scene the fixture contains a fluorescent lamp; after the bulb runs its course of life and ceases to illuminate, there is no guarantee that an incandescent bulb could not be placed in the fixture causing a code violation.

Note that there are fluorescent luminaires of the recessed type on the market that could be used here as the design of the fixtures precludes the use of an incandescent bulb. — Amos D. Lowrance Jr., CMP-18
(January/February 2007)

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The views expressed are not the official position of NFPA, the NEC Correlating Committee or any of its panels, IAEI, IAEI News, or the author's employers. Nor are they intended to represent a formal or informal interpretation of the NEC. 

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