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NEON- Secondary Ground Fault Protection
Hello listers,
I am writing this posting regarding a very serious and important issue
facing all of us: the implementation of Secondary Ground Fault Protection
into the 1996 National Electrical Code. For virtually everyone working with
neon, there will be some impact. I hope that you will take the time to read
it. I will indulge your patience, it's a little long.
During 1994 and 1995, the National Electrical Code Article 600 was rewritten
by Code Panel 18. At the request of various electrical inspectors,
Authorities Having Jurisdiction, and other "experts", Secondary Ground Fault
Protection was included in the Code drafts. As of November 1995, the final
draft was published as the 1996NEC. The text stated as follows:
Section 600-23:
(a) Type. Transformers and electronic power supplies shall be
identified for use and shall be listed.
(b) Secondary Fault Protection. Transformers and electronic
power supplies shall have all secondary circuit components
isolated or have secondary fault protection.
That's all it says. Nothing about UL, nothing about their reasons for
wanting Secondary Fault Protection. Code says...there must be Secondary
Fault Protection.
Allanson manufactures a line of ferromagnetic transformers having Secondary
Fault Protection. We have marketed them since 1991. Before going further,
I don't mean this to be a commercial. I am not touting Allanson as "better"
or "exclusive". I am not writing this posting as an advocate for or against
Fault Protection. We were not included in Code Panel 18 decisions.
What I am writing about is a jurisdictional issue which may end up being a
legal issue. What I am writing about is whether it is possible to comply
with NEC. In fact, it is. If the AHJ implements 1996NEC, you need to
comply or else may be liable for prosecution.
Product exists that complies with NEC. Allanson happens to make it. This
is not hearsay, this is not fantasy, the product is real. It is UL Listed
(file #E39591). For those who would like to use it as part of their
specification, it is available. For those Authorities Having Jurisdiction
who want to implement 1996 ARticle 600, they have that choice.
Interestingly, some members of our industry do not want to see Fault
Protection implemented. Therefore, they are saying that product does not
exist. According to another section of the Code (Article 90-4) if a product
does not exist, Code is not enforceable. So, they'd like the Allanson
product to conveniently go away. If we don't keep our mouths shut, then
action will be taken in attempts to deal with us otherwise.
One such action came this week in the form of a letter to the editor
published in October Signs of the Times from Mr. Henry Brown of Transco Inc.
Mr. Brown took exception to a paragraph taken out of context of a technical
article by Tony Efantis published in July issue of Signs of the Times. Tony
is Allanson's Chief Design Engineer and is a recognized expert in our field.
I recommend you read the article if you haven't already done so.
Tony Efantis stated that Allanson's SGFP product meets applicable standards
for UL and the 1996 NEC requirements. Mr. Brown claims it doesn't.
Further, Mr. Brown takes exception to the text of a purchased placement in
September's Signs of the Times essentially saying the same thing.
What is frustrating is several of Mr. Brown's assumptions. On what
authority does Mr. Brown speak? First, on whose behalf does Mr. Brown
speak? He in no way represents the National Electrical Code. He in no way
has been involved in the National Fire Protection Association which oversees
NEC. He is not an electrical engineer nor does he employ any at Transco.
He is not a member of the International Association of Electrical Inspectors.
Mr Brown clearly accuses Allanson of misinforming the public. Mr. Brown
claims that Allanson has never had product tested by UL for the purpose of
Secondary Fault Protection. He states that our claim is "patently false".
In fact, he is wrong. The Fault Protection tests are part of our UL file
number and were completed in 1991. We stand by our statement: Allanson
manufactures a line of transformers offering Secondary Protection and they
have been tested by UL. Our listing was granted and the device was tested
separately from requirements of UL506 or UL1012.
Mr. Brown goes on to question Efantis' statement about conformance to UL
standards. He goes on to talk about the coming of UL2161. As I write this,
UL2161 DOES NOT EXIST. It has been talked about for over 2 years. It is
not yet finalized or published. Allanson cannot conform to a standard that
doesn't exist in the regulatory world. We comply with those that do. The
applicable transformer standards at UL are 506 and 1012.
Now on to Mr. Brown's statements about NEC. He questions why Allanson
states that our product meets all applicable standards of 1996 NEC. Can
anyone see anything written in that document which Allanson doesn't meet?
NEC asks for Fault Protection. NEC asks for a Listed Product. Nothing else.
Allanson complies with both those requirements. The Code does not talk
about compliance with a yet-to-be-published UL standard 2161. Actually, it
doesn't mention UL at all. So, what's the beef?
Mr. Brown goes on to beat his chest about Transco's intentions to comply
with NEC and UL2161. Good for them. If they want to sell transformers in
the USA, they had better.
That's not the point. Or maybe it is...Allanson product presently complies.
Transco's doesn't. So who is misleading whom?
Within the near future, all transformer manufacturers will have to comply
with NEC and, if UL gets 2161 finished, with that as well. Yes, Allanson is
the first of the North American transformer manufacturers to offer secondary
protection. Big deal. The Europeans already have similar technology on the
market.
That's not the point. What makes me mad is...who is Henry Brown to preclude
someone's ability to comply with Code? Just because Transco doesn't offer
an alternative? Yet. Come on, let's not talk about fairness nor "the
good of the industry" nor "rising above" or "presenting products in a
positive manner".
Henry states that he frankly knows why our industry has a bad reputation
with the AHJ. We agree with him on one point. The bad information has to
stop. Henry Brown should do a better job of gettting educated before
preaching about what's good for the industry.
If you can't help but sense my frustration and anger at this latest
development, well, good. That's important. What Mr. Brown has said and is
doing is not right. I've had enough of it to the point of making me say
something. Yes, if given the opportunity to debate the issues, Allanson has
never shirked from standing for what we felt was right. Popular or not.
That's not what Mr. Brown seems to want. Let the industry decide what's
good for the industry. Transco is certainly entitled to a point of view.
So are we. But, there's something else going on.... Electrical Code. Their
interests may not be 100% consistent with what the sign industry wants.
They are generally most interested in safety.
If they want secondary protection, we had better give it to them.
Thanks for your patience and attention,
Eric
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