International Association of Electrical Inspectors [RE-wrenches]

Mark Frye markf at berkeleysolar.com
Fri Mar 7 08:29:36 PST 2008


Chris,

"In short this inspector needs to read UL1703 and then make a case
for his position but he is going against what a national recognized lab
has defined and some people may make the argument he does not have that
authority to do so. I can not see his position since UL1703 clearly has
no wording on how to test alternative grounding options."

Unfortunately, based on my understanding of the regulator systems in the USA
(NEC and local building authority), this inspector does not have to do any
of the above.  The NEC gives him absolute discretion (my words) to approve
or disapprove any electrical system.

I have been interested in avenues for challenging the discretion, other that
the friendly talk to try and see eye to eye, for sometime now.  For a period
of time I thought I could hold a local building official accountable to the
State Fire Marshall, but really didn't have the unlimited energy that would
be required to pursue this on a practical basis.

Can you substantiate the statement that he has to "...make a case for his
position..." or that "...he does not have that authority..."?
 
Mark Frye
Berkeley Solar Electric Systems
271 Vistamont Dr
Grass Valley CA 95945
(530) 401-8024
www.berkeleysolar.com
 

-----Original Message-----
From: Chris Meier [mailto:chrism at unirac.com] 
Sent: Friday, March 07, 2008 8:10 AM
To: RE-wrenches at topica.com
Cc: Collin Rhodes
Subject: RE: International Association of Electrical Inspectors
[RE-wrenches]



 

I find the position of this inspector interesting. There seems to be
much misunderstanding of UL and ETL positions on the use of the WEEB or
our UGC. Below are some notes from a past discussion I have had. UL is
currently being pressed to review these issues by some manufacturers and
state organizations.

 

 

 

Here is my review of UL1703.

 

 I went through UL1703 section 11 Bonding and Grounding.  Section 11.1
refers you to section 10 connection means. But the exception in 11.1
says this. 

 

 When the grounding means is a module or panel mounting member intended
to contact an array or structural member, the module grounding means are
not required to comply with the requirements of section 10.

 

 Section 10 discuses the connection means like bolts, lugs to wiring.
This does not apply to the WEEB or UGC.

 

 

             I do not have the National Electric Code but in my
experience the Code normally refers to both UL listing and UL standards.
But never says you most be UL listed this would be legally unacceptable
because it would exclude other testing organizations and this is against
federal law. 

 

If I was a PV manufacturer I would suggest strongly to UL that 45.1.1a
says I need to describe my acceptable methods but what grounding
standard am I to refer to since section 10 does not apply?  UL467 or
what? ETL has reviewed this and made a decision but UL and some
inspectors have not.

 

             This is the issue:  UL 1703 does not address grounding with
exception of a bolt, lug and wire or outside of Section 10. I think we
need to push the partners and organization to push UL to give the
standard they want to use for other grounding methods.  I believe the
grounding reference in 1703 needs to be changed. It should say something
like other grounding solutions shall meet or exceed UL 467 or some
standard yet to be created. This is not a new issue.  Electrical
manufacturer have been grounding equipment long before solar came along
and this would bring us into the same playing field of other electrical
manufacturers.  Unfortunately people seem to loss the point. UL is
basically two different organizations. First they are a testing lab and
by law they are not the only lab if ETL has performed the due diligence
and finds that under UL Standards the only applicable standard that can
be applied is UL467 then the local inspectors have to recognize this as
acceptable in the same manor they recognize a UL interpretation of the
standards. UL tests to the same standard and hold no more weight legally
than an ETL test. The second position of UL is to write testing
standards this is completely separate than UL testing and listing.
Because this grounding option did not exist when UL1703 was written and
there is no section of UL1703 that covers this grounding option both UL
and ETL need to define what standard does apply and this is what ETL has
done. In short this inspector needs to read UL1703 and then make a case
for his position but he is going against what a national recognized lab
has defined and some people may make the argument he does not have that
authority to do so. I can not see his position since UL1703 clearly has
no wording on how to test alternative grounding options.  

 

 

 

Expand my thinking if you feel I am wrong. 

 

 

Chris Meier

Product Manager

UniRac, Inc.

 

1411 Broadway Blvd. NE

Albuquerque, NM   87102-1545

Ph:  505-242-6411 

Fx:  505-242-6412

Email:  chrism at unirac.com 

Web:   http://www.unirac.com


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