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January 31, 2024 Kathi Markan

HUD NSPIRE January Newsletter: NSPIRE STANDARD: Electrical – GFCI or AFCI Outlet or Breaker

NSPIRE STANDARD:
Electrical – GFCI or AFCI Outlet or Breaker
Deficiency #3:
An unprotected outlet is present within 6 feet of a water source.

NSPIRE TRAINING ANNOUNCEMENT!
‘HUD-NSPIRE Demystified: A Deep Dive into the New Inspection Process’
Training begins February 2024 with multiple options to choose from!
Click here to learn more: HUD-NSPIRE Full Training!
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Click here to see free, downloadable REAC Resources

January’s Newsletter discusses the brand-new deficiency, “An unprotected outlet is present within 6 feet of a water source.”  This is deficiency #3 under the Electrical – GFCI or AFCI Outlet or Breaker Standard.
This deficiency will be scored starting October 1st, so it’s important to understand where you need them and how many you’ll have to purchase!
This Newsletter will focus on the following 3 primary areas of confusion amongst PHAs/POAs and inspectors:

  1. Where exactly are GFCI’s (Ground Fault Circuit Interrupter) required?
  2. Are there any outlet receptacles that are exempt from the requirement?
  3. What does “wired in a series” or “protected by a GFCI upstream” mean?

Where exactly are GFCI’s required?
As you’re reading the NSPIRE Standards, it’s of the utmost importance to understand the difference between i.e. and e.g. HUD has repeatedly defined them during their inspector trainings as:
i.e. = Exactly these and nothing else
e.g. = Examples – could be more than what is shown

So why does this matter?!

Example 1:

Answer: Per HUD….NO!  It is not one of the 5 water sources identified by HUD requiring outlets within 6 feet to be GFCI protected.
Per National Electric Code? No, not for dwelling units.  Per common sense?  Absolutely.

Example 2:

Answer: Per HUD…YES!  A drinking fountain is considered a “water faucet.”

Are there any outlet receptacles that are exempt from the requirement?
Yes – and this one is complicated…
Per HUD:

Also…

What does ‘dedicated’ mean? Unfortunately, it means different things to different people.

  1. HUD defines a ‘dedicated outlet’ as:


This is a terrible definition – even the QA’s (Quality Assurance) that were conducting the inspector training did not like this definition…because it does not make sense industry-wise or otherwise!

  1. The National Electric Code defines a dedicated outlet as a dedicated circuit – “A single circuit that provides power to one appliance. It has its own circuit breaker, which is usually labeled in the electrical box.”
  2. Many inspectors define “dedicated” as a single outlet receptacle…not a duplex.  They want to see major appliances plugged into something like this:

How many refrigerators have you seen plugged into a single receptacle like the image above?!

Bottom line?
“Dedicated” should mean the CLOSEST OUTLET TO THE MAJOR APPLIANCE but, if we want to win an appeal, that outlet receptacle WILL HAVE TO BE ON A DEDICATED CIRCUIT (meaning, if the breaker is shut off, only that outlet will lose power).
Example:

Answer: Per HUD…NO!  This is the only outlet that the washing machine can be plugged into – it also happens to be on a dedicated circuit! Outlets in laundry rooms were not required to be GFCI-protected by code until 2014!!!  So if your property was built prior to that date, and has never been rehabilitated, then chances are your outlet’s are NOT GFCI protected and that is within NSPIRE’s guidelines. To remind you, PER HUD:

What does “wired in a series” or “protected by a GFCI upstream” mean?

Nothing drives me crazier than when a property gets remodeled and EVERY outlet receptacle in the kitchen has its own GFCI and the breaker is ALSO GFCI’d (talk about overkill) – this is an easy way for contractors to add serious money to a construction project…and the poor borrower never knows to question this.
Both phrases essentially mean the same thing…one GFCI receptacle is protecting all the standard outlet receptacles “downstream” from it.

Many inspectors see the standard outlet receptacle within 6 feet of a water source and cite it as “unprotected” when all they had to do was push the little button on the circuit tester!


Side note: This button on the circuit tester will NOT work if there is an open ground…you will have to MANUALLY press the test button on the GFCI upstream (or at the breaker panel) to determine whether the outlet is GFCI protected!

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