International Association of Electrical Inspectors [RE-wrenches]
Mark Frye
markf at berkeleysolar.com
Fri Mar 7 09:57:53 PST 2008
Thanks Chris,
I hear what you are saying.
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 9:45 AM
To: RE-wrenches at topica.com
Subject: RE: International Association of Electrical Inspectors
[RE-wrenches]
The NEC refers to UL standards as the recognized standards for
testing components. Unfortunately I do not have the lines or the
reference to say he can not interpret UL standards in a way contrary to
the standards. But as known in other industries it is not the inspectors
place to open a piece of equipment and say a component of the equipment
can not be used if a testing organization has accepted and listed it as
meeting UL standard. What is out of my knowledge range is if he can pick
which standard he wants used for the testing. In my past experience it
was the testing lab that selected the proper standard and performed the
test not the inspectors. UL467 is the general testing standard for
grounding options baring the existence of a specific standard. Since
1703 does not have that standard then by default ETL has established the
467 standards as the only one that applies. The biggest issue here is
not whether the inspector has the right but does he understand the
standard he is trying to use does not cover alternate means of grounding
and I would hope he is open to expanding his view of the standards and
not just pulling the God card that some inspectors like to play. This
issue is also interesting because you do not use UL1703, conduit, lugs,
wire and racking. The appropriate standard is used for these items.
There is currently only two grounding lugs in existence that have been
tested to UL1703 but tons that have been tested to UL467 which lugs are
you using? If you are like me the ones you use whether they are test to
467 or 1703 I feel do the job safely.
I personally feel it is a bad day if we can not sit with an
inspector and explore the issues because we or they feel they have
ultimate power and that there is no room for open discussion. Nowhere in
the intent of any code was it meant do what I say because I said so. The
sprite of the codes is do what I say because code and the standards it
refers to says so and here it is.
Again these are my views and I am not set in stone that I am right just
bring up an argument to discuss and to learn from I may be 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
-----Original Message-----
From: Mark Frye [mailto:markf at berkeleysolar.com]
Sent: Friday, March 07, 2008 9:30 AM
To: RE-wrenches at topica.com
Subject: RE: International Association of Electrical Inspectors
[RE-wrenches]
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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