In July’s edition of our HUD-REAC Monthly Newsletter, I am going to discuss Ground Fault Circuit Interrupters (GFCIs) and Arc Fault Circuit Interrupters (AFCIs) in both Units and Common Areas for 2 reasons:
1. They are high-scoring and often overlooked as a priority item
2. There has been some confusion on their requirements.
CLICK HERE for the updated COVID-19 protocols:
GFCI/AFCI Scoring
- An inoperable GFCI/AFCI is worth approximately 50% of the total unit points. Thus, if your Units are worth 2 points each – an inoperable GFCI/AFCI is about 1 point
- To put it in perspective using the example above, 1 inoperable GFCI/AFCI in every single unit would take off approximately 20 points from your overall score!
- GFCI’s on the exterior are recorded as H&S: Hazards: Other …no points!
- GFCI’s can be recorded in every single common area but are only scored against you, if defective, in the following areas:
o Laundry
o Kitchen
o Bathrooms
What are GFCI’s and AFCI’s?
- AFCI
- Arc Fault Circuit Interrupter
- Prevent fires caused by electrical arcing
- The 2020 NEC (National Electric Code) requires that for dwellingunits, all 120-volt, single-phase, 15- and 20-ampere branch circuitssupplying outlets or devices installed in dwelling unit kitchens, family rooms, dining rooms, living rooms, parlors, libraries, dens, bedrooms, sunrooms, recreation rooms, closets, hallways, laundry areas, or similar rooms or areas shall be protected by AFCIs.
- GFCI
- Ground Fault Circuit Interrupter
- Prevent shocks
- The 2020 NEC requires that all 125-volt through 250-volt receptacles installed in the following locations: Bathrooms, Garages, and accessory buildings, Outdoors, Crawl spaces, Basements, Kitchen Countertops, Sinks, where the receptacles are within 6-feet from the top inside edge of the sink bowl, Boathouses, Bathtubs and shower stalls, where the receptacles are within 6-feet of the outside edge of the tub or shower stall, Laundry areas, Indoor damp and wet locations
Do I need to upgrade all my existing outlets to GFCI/AFCI?
- Updating receptacles to current code (in this case, installing GFCI/AFCI’s) is only required with new construction, alterations, modifications, repairs – typically, if you pull a permit, you will have to conform to the current code requirements but in the case of electric repairs/replacements you must upgrade per NEC 406.4.
- For REAC, the only requirement is, “If it’s there…it’s gotta work!” There is currently no requirement to conform to current code.
Current REAC Protocol on GFCI’s and AFCI’s
- I’ve been hearing some REAC inspectors use circuit testers – this is prohibited.
- On Page 7 of the Compilation Bulletin, it states:
- A tape measure, flashlight, and a means to test inspectable devices up to 8 Feet, are the minimal tools required during all REAC inspections. The inspector will not carry any type of testing equipment such as: GFCI tester, Canned Smoke, etc.
- On Pages 83-84 of the Compilation Bulletin, it states:
- GFI and Arc Fault Circuit Interrupter (AFCI) circuit breakers in electrical panel boxes must be tested by pushing the test button to trip the breaker and resetting it; which is to be only done by the inspector. It is strongly recommended that the inspector notify the POA’s (Participant/Owner/Administration) that these circuits are going to be interrupted and effect devices such as: computers, oxygen pumps, televisions, etc.
Proposed Guidelines for NSPIRE (not yet set in stone – your feedback could help)!
- An inoperable GFCI/AFCI is considered a “Severe Non-Life-Threatening” deficiency and is required to be repaired in 24 hours.
- For Units, Common Areas and Building Exteriors – under the Standard, “Electrical – Outlet and Switch”
- “A GFCI is required within 6 feet of a water source that is located in the same room”
- The measurement required is not to Code – the requirement for HUD’s NSPIRE is to measure from the “center of each water source to the center of each outlet.” Code is “top inside edge of sinks” and “Outside edge of tubs/showers.”
- “An outlet designated for a major appliance (water heater, HVAC, refrigerator, washing machine, dishwasher, garbage disposal, microwave, etc.) should NOT be evaluated under this standard, regardless of its distance from the water source.” This is interesting – a bit of a break for you as it’s also not to Code which is much more strict.
- The GFCI can be part of a series (receptacles located downstream from a GFCI receptacle)
- “An outlet located below a countertop and within an enclosed cabinet should not be evaluated under this standard regardless of its distance from the water source.” This is also a break because the 2020 NEC Code removed the language about doors from their requirements!