REQUEST FOR CLARIFICATION BY THE MANUFACTURED BUILDINGS PROGRAM MANAGER ON GFCI PROTECTION IN SHEDS

SITUATION: Mr. Kevin Crowley, Esq. representing the Florida Portable Building Manufacturers Association, has requested an exemption to the NEC to install non-GFCI outlets in sheds and defer the protection required in s. 210.8 (A)(2) NEC, to a site requirement, with a statement on the plans to the effect: "Electrical power to this shed must be installed in accordance with methods consistent with the National Electrical Code, Article 210.8"

HISTORY: Germane to this issue is that fact that SB 442 provided [in ch 553.80 FS] an exemption for storage sheds that do not exceed 400 sq. ft. from the requirement of installation by a licensed contractor. As a result, a majority of the jurisdictions no longer require building permits for sheds, notwithstanding the statutory requirement to do so. In absence of a building permit, the responsibility for the correct installation of a shed falls to the owner, who may or may not secure the services of a licensed contractor.

DISCUSSION: The above bolded language could certainly apply to sheds that are not wired for electrical receptacles in the factory; however, under the proposed scenario, the owner would presumably have to read the plans and hire an electrician to install a circuit breaker box with a much more expensive GFCI circuit breaker (not outlet), that would provide GFCI protection to the factory installed, non-GFCI outlets, at a cost of at least $100. The likelihood of this occurring is not considered very high; especially, in those jurisdictions where with no building permits are required for sheds.

From a Manufactured Buildings Program programmatic perspective, this approach appears irresponsible by not providing adequate safety protection in the shed when it leaves the factory; notwithstanding the violation, as depicted in the following NEC language.

S. 210.8(A) NEC, states: "All 125-volt, single phase, 15- and 20- ampere receptacles installed in the locations specified in (1) through (8) shall have ground-fault circuit-interrupter protection for personnel".......

(1) Bathrooms

(2) Garages and also accessory buildings that have a floor located at or below grade level not intended as habitable rooms and limited to storage areas and work areas, and areas of similar use" .......

Exemption No. 1: Receptacles that are not readily accessible.

Exemption No. 2: A single receptacle ................. located within dedicated space..........

It goes on to state: The requirement for GFCI receptacles in garages and sheds, as illustrated in Exhibit 210.10, improves safety for persons using portable, hand-held tools, gardening appliances, lawnmowers, string trimmers, snow blowers, and so on, that might be connected to these receptacles, which are often the closest ones available."

One argument that Exception # 1 (above) would seemingly allow this installation, is based on a questionable interpretation that "not readily accessible" could include receptacles inside the shed.

Another argument that sheds that are mounted on skids, do not constitute "on grade", is also a questionable interpretation. Neither of these arguments is considered viable by the program manager.

RECOMMENDATION: (1) Manufactured storage sheds should comply with the NEC and require GFCI protection before leaving the factory, and not defer this requirement to the owner. (2) Additionally, changes should be made to Rule 9B-1 FAC to prohibit certain items from deferment to site installed, albeit, already implied, but not so stated in rule. Supplemental to that change would be to list specific items allowed to be deferred to site installed, e.g., HVAC, foundation, gable end siding, etc., and/or prohibit all others.