# AFCI in Manufactured Home



## Pete m. (Nov 19, 2011)

I would say no as long as you are only replacing the device. 210.12 deals with the *branch circuit(s)* not device replacement.

Now, if you had to modify, replace or extend the *branch circuit* as part of the device replacement you would have to comply with 210.12(B)

Pete


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## MDShunk (Jan 7, 2007)

x2. The NEC doesn't really address replacement of receptacles. That would be more under the IEBC, and that model code will not require you to retro-fit/add AFCI protection.


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## czars (Aug 20, 2008)

The 2011 NEC, Article 406.4(D)(4) says that a replacement receptacle on a branch circuit that is required to have AFCI protection shall be (1) an AFCI receptacle, (2) a receptacle protected by an AFCI receptacle or (3) protected by an AFCI breaker. Effective January 1, 2014.


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## MDShunk (Jan 7, 2007)

czars said:


> The 2011 NEC, Article 406.4(D)(4) says that a replacement receptacle on a branch circuit that is required to have AFCI protection shall be (1) an AFCI receptacle, (2) a receptacle protected by an AFCI receptacle or (3) protected by an AFCI breaker. Effective January 1, 2014.


The branch circuit is not required to have AFCI protection. It was installed 20 years ago! No such requirement existed.

That section basically reminds you to not remove AFCI protection on circuits new enough to have required it when you're replacing receptacles.


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## czars (Aug 20, 2008)

Thanks for the clarification!


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## MTW (Aug 28, 2013)

czars said:


> Many of the manufactured homes have Westinghouse, Challenger or Bryant service panels for which AFCI breakers are not available from anyone including Cutler Hammer.



I'm baffled by this statement. Eaton/ Cutler Hammer *is* the UL listed replacement for those obsolete brands. It says so right on every box of BR styler breakers. 

To go a step further, Eaton/CH makes "Type CL" Classified breakers for use in a wide variety of 1" panels.


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## czars (Aug 20, 2008)

My statement about Cutler Hammer AFCIs not being acceptable for use in Westinghouse, Challenger and Bryant panels is the result of information that I received from CH 1 1/2 years ago. Something may have changed since then, so I have sent a question to CH specifically asking if the BR AFCI breakers are or are not acceptable for use in the three panels. I will post the information when I get it in the next day or two. CH has a 48 hours response time to emails.


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## MTW (Aug 28, 2013)

czars said:


> My statement about Cutler Hammer AFCIs not being acceptable for use in Westinghouse, Challenger and Bryant panels is the result of information that I received from CH 1 1/2 years ago. Something may have changed since then, so I have sent a question to CH specifically asking if the BR AFCI breakers are or are not acceptable for use in the three panels. I will post the information when I get it in the next day or two. CH has a 48 hours response time to emails.


Interesting. Well, I would use a CH-BR AFCI in those panels without a second thought. In my book, if the regular breakers are acceptable, then the AFCI's are too.


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## papaotis (Jun 8, 2013)

or at least they SHOULD be!


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## MTW (Aug 28, 2013)

Does the 2014 NEC require AFCI when a receptacle is replaced regardless?


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## czars (Aug 20, 2008)

I received the information below from EATON stating that Cutler Hammer does not manufacture AFCI breakers for Challenger, Westinghouse or Bryant panels.



Sorry but Eaton does not have AFCIs for Challenger, Westinghouse and Bryant service panels. Please see the attached document which shows the compatible breakers.
Hope this will be helpful. If you need further help, please feel free to contact me. I will be glad to help you. Have a wonderful day !
Thank you for your inquiry,
Click here to answer 2 questions about the service you received today!

Kartik V S | EatonCare | Technical Resource Center | Technical Support Engineer
Eaton | 175 Vista Blvd | Arden, NC 28704 | 877-ETN-CARE Opt 2 | [email protected] 
TRC Phone Menu | Chat | Catalogs | ATU | How to Buy | New SL Series Stacklights


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## Pete m. (Nov 19, 2011)

MTW said:


> Does the 2014 NEC require AFCI when a receptacle is replaced regardless?


Unfortunately, yes.


*406.4(D)(4) Arc-Fault Circuit-Interrupter Protection.* 

Where a receptacle outlet is supplied by a branch circuit that requires arc-fault circuit-interrupter protection as specified elsewhere in this Code, a replacement receptacle at this outlet shall be one of the following:

(1) A listed outlet branch-circuit type arc-fault circuit-
interrupter receptacle
(2) A receptacle protected by a listed outlet branch-circuit
type arc-fault circuit-interrupter type receptacle
(3) A receptacle protected by a listed combination type
arc-fault circuit-interrupter type circuit breaker

_This requirement becomes effective January 1, 2014._

Pete


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## czars (Aug 20, 2008)

Good news. It turns out that not all Eaton Technical Reps have the same information. I called Eaton this morning at 877-386-2273, option 2 and got the most recent information about Eaton AFCI breakers which is dated January 24, 2012. They are acceptable for use in Westinghouse, Bryant and Challenger panels. They sent me a PDF file showing the breaker compatibilities. I tried to put the table here, but couldn't figure out how to copy it. Call Eaton and get your own chart.


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## MTW (Aug 28, 2013)

Pete m. said:


> Unfortunately, yes.
> 
> 
> *406.4(D)(4) Arc-Fault Circuit-Interrupter Protection.*
> ...



What am I missing here? The language is basically the same. :confused1:


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## MDShunk (Jan 7, 2007)

MTW said:


> What am I missing here? The language is basically the same. :confused1:


Right. I submit that a branch circuit installed before AFCI protection existed are, clearly, not required to have AFCI protection. The technology and the requirement didn't exist at the time. Therefore these branch circuits do not fall into the category of branch circuits requiring AFCI protection, thus you can replace the receptacle with the style of your choice.


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## Pete m. (Nov 19, 2011)

MTW said:


> What am I missing here? The language is basically the same. :confused1:


It is the same verbiage as the 2011 NEC. The catch is that in the 2011 the effective date for the requirement wasn't until January 1 of 2014.



MDShunk said:


> Right. I submit that a branch circuit installed before AFCI protection existed are, clearly, not required to have AFCI protection. The technology and the requirement didn't exist at the time. Therefore these branch circuits do not fall into the category of branch circuits requiring AFCI protection, thus you can replace the receptacle with the style of your choice.


I agree with you that 406.4(D)(4) has nothing to do with the branch circuit and does not require the branch circuit be AFCI protected.

The way I see it is that the requirement only applies to the device* IF* the existing non-AFCI branch circuit serves an area that would normally require the branch circuit to have AFCI protection. 

I have had conversations with a couple different contractors that were replacing smoke damaged receptacles in apartments and they were not aware of this stupid requirement... luckily we had the conversation prior to them giving a quote!

Pete


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## MDShunk (Jan 7, 2007)

Pete m. said:


> The way I see it is that the requirement only applies to the device* IF* the existing non-AFCI branch circuit serves an area that would normally require the branch circuit to have AFCI protection.


No such language exists.


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## Pete m. (Nov 19, 2011)

MDShunk said:


> No such language exists.


Are we reading the same thing?

How are you seeing this? What do you believe that 406.4(D)(4) requires?

Pete


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## MDShunk (Jan 7, 2007)

Pete m. said:


> Are we reading the same thing?
> 
> How are you seeing this? What do you believe that 406.4(D)(4) requires?
> 
> Pete


It requires replacement receptacle outlets on branch circuits that require AFCI protection to remain AFCI protected by one of several means. A branch circuit installed before AFCI's existed is not a branch circuit that requires AFCI protection, therefore none of these replacement receptacle requirements apply.


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## MDShunk (Jan 7, 2007)

If your answer to "does this branch circuit require AFCI protection" is NO, then you stop reading. It's only if the branch circuit requires AFCI protection that the replacement receptacle requirements at "this outlet [of that branch circuit]" applies.


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## MDShunk (Jan 7, 2007)

Is a dryer circuit required to have AFCI protection? No. Therefore you can replace it with the replacement device of your choice.
Is a convenience receptacle circuit in your toolshed required to have AFCI protection? No. Replace the receptacle with the device of your choice.
Is a 20 year old branch circuit required to have AFCI protection? No. Replace the receptacle outlets with the type of your choice.


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## Pete m. (Nov 19, 2011)

I can see why you read it this way. The verbiage is poorly written and somewhat unclear on it's intent.

Below is a copy of the text from the 2011 ROC and it shows that the intent was that replacement receptacles either be of AFCI type or be AFCI protected by an upstream device. The trigger is if the existing branch circuit feeds an area where AFCI protection would be required for a new installation.

_* 18-10 Log #488 NEC-P18 Final Action: Accept in Principle 
(406.3(D))* 
_______________________________________________________________ 
Submitter: James T. Dollard, Jr., IBEW Local Union 98 
Comment on Proposal No: 18-30 
Recommendation: Continue to accept Proposal 18-30 in Principal, but make 
changes to address the comments in the voting. 
Revise the existing 2008 NEC text in 406.3(D) as follows: 
(D) Replacements. Replacements of receptacles shall comply with 406.3(D)(1) 
through (D)(6) as applicable. 
(4) Arc-Fault Circuit Interrupter Protection. Where a receptacle outlet is 
supplied by a branch circuit that requires arc-fault circuit interrupter protection as specified elsewhere in this code, a replacement receptacle shall be: 
(a) a listed outlet branch circuit type arc-fault circuit interrupter receptacle, or 
(b) protected by a listed outlet branch circuit type arc-fault circuit interrupter 
receptacle, or 
(c) protected by a listed combination type arc-fault circuit interrupter. 
Substantiation: The panel’s continued acceptance of this proposal will provide 
much needed arc fault protection in older homes. This comment is intended to address some of the concerns expressed by panel members. The proposed 
wording in this comment will allow AFCI protection to be provided by either a 
circuit breaker AFCI or by a receptacle AFCI when a receptacle is replaced. 
Both the receptacle and circuit breaker AFCI will provide protection for all 
receptacles and other outlets that are downstream on the branch circuit. The UL standard for AFCI’s, UL1699, covers outlet branch circuit (OBC) type for 
receptacles. An OBC type AFCI receptacle provides series arcing protection 
upstream and downstream from its point of installation and parallel arc 
protection downstream of that point. 
As noted in the proposal substantiation, AFCI protection in older homes is 
likely to be provided only when circuit breakers are replaced or when the 
service is upgraded. Continued acceptance of this proposal is necessary due to the fact that the replacement of circuit breakers individually or in a complete replacement as in a service upgrade does not require the use of AFCI type circuit breakers. *The proposed text provides significant flexibility due to the fact that this addresses only receptacle replacements not the entire branch circuit.* For example, receptacles installed on a multiwire branch circuit could easily be protected with a single outlet branch circuit (OBC) type at the first outlet. 
Adopting the requirement to provide replacement receptacles with AFCI 
protection will greatly expand the use of AFCI’s in older homes where there is a clear need for AFCI protection. As stated in the substantiation submitted with proposal 18-30 there is no practical reason to limit the level of safety provided by an AFCI to new homes only. 
NFPA has published a report titled Home Electrical Fires, by John R. Hall Jr., dated March 2009. The report describes how the age of a dwelling is related to the increased risk of electrical fires. A table in the NFPA report states that the risk ratio for electrical fires is 0.5 for dwellings 11-20 years old, 1.0 for dwellings 21-40 years old and 1.6 for dwellings more than 40 years old. It is apparent that many older homes are at significantly greater risk and would benefit most from additional AFCI protection. There have been a number of reports submitted to CMP 2 in support of the requirement for AFCI protection. 
Many of these reports also identify a clear correlation between older homes and the increased occurrence of electrical fires. (The NFPA report is available at http://www.nfpa.org/itemDetail.asp?categoryID=423&itemID=18255&URL=R
esearch/Fire%20reports/Major%20causes) 
Panel Meeting Action: Accept in Principle 
Revise text to read as follows: 
(4) Arc-Fault Circuit Interrupter Protection. Where a receptacle outlet is 
supplied by a branch circuit that requires arc-fault circuit interrupter protection 
as specified elsewhere in this code, a replacement receptacle at this outlet shall 
be one of the following. 
(1) a listed outlet branch circuit type arc-fault circuit interrupter receptacle. 
(2) a receptacle protected by a listed outlet branch circuit type arc-fault circuit 
interrupter type receptacle. 
(3) a receptacle protected by a listed combination type arc-fault circuit 
interrupter type circuit breaker. 
This requirement becomes effective January 1, 2014. 
Panel Statement: The panel editorially revised the recommendation to comply 
with the NEC Style Manual and added the effective date per their action on 
Comment 18-19. The panel added “type circuit breaker” to (3) to clarify the 
type of device that is permitted under this option. 
Number Eligible to Vote: 11 
Ballot Results: Affirmative: 11
_
Pete


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## MDShunk (Jan 7, 2007)

Quite aware of the original intent. Also quite aware how the section is often interpreted. However, that's not what they actually wrote. All that matters is what they wrote. If the branch circuit is not one that requires AFCI protection, than neither does the replacement receptacle outlet. Simple as that. If they intended otherwise, they should have wrote that. They did not. A 20 year old branch circuit does not require AFCI protection, therefore neither do the replacement receptacle outlets on that circuit. There is no place "elsewhere in the code" that applies retroactively to an old branch circuit.


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## Pete m. (Nov 19, 2011)

Wasn't attempting to infer that you did not know the intent of the section. I was just giving the information on why it is interpreted the way it is.

I suppose you and I see it differently. 

Pete


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## MTW (Aug 28, 2013)

This was clearly a backdoor attempt by the NEC to require AFCI protection on existing circuits but I agree with Marc that the language simply does not support that intent at all.


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## Pete m. (Nov 19, 2011)

MDShunk said:


> It requires replacement receptacle outlets on branch circuits that require AFCI protection to remain AFCI protected by one of several means. A branch circuit installed before AFCI's existed is not a branch circuit that requires AFCI protection, therefore none of these replacement receptacle requirements apply.


To expand on your train of thought would you make the same argument for replacement devices such as GFCI, tamper resistant and weather resistant receptacles?

_*(3) Ground-Fault Circuit Interrupters.* Ground-fault
circuit-interrupter protected receptacles shall be provided
where replacements are made at receptacle outlets that are
required to be so protected elsewhere in this Code._

_*(5) Tamper-Resistant Receptacles.* Listed tamper-resistant
receptacles shall be provided where replacements are made at
receptacle outlets that are required to be tamper-resistant elsewhere in this Code._

_*(6) Weather-Resistant Receptacles.* Weather-resistant receptacles shall be provided where replacements are made at
receptacle outlets that are required to be so protected elsewhere in this Code._

Pete


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## MTW (Aug 28, 2013)

Pete m. said:


> To expand on your train of thought would you make the same argument for replacement devices such as GFCI, tamper resistant and weather resistant receptacles?


The language simply does not imply or require retroactive upgrading. I know that's what is intended, but it's not what is communicated. 

Once again, as Marc pointed out, all the wording does is ensure that replacements made in areas that already require TR, GFCI, or WR receptacles remain TR, GFCI, or WR.


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## Contractor Joe (Jun 7, 2015)

czars said:


> The 2011 NEC will be in effect in Florida on June 30, 2015. I do a lot of repair work for older folks who live in manufactured homes and receptacle replacement is common.
> 
> The 2011 NEC, Article 550.13(A)(2) specifically requires that receptacles in manufactured homes be installed IAW Article 406.4. 406.4 requires that when receptacles are replaced patio covers where AFCI protection is required by the 2011 NEC, AFCI protection must be provided by AFCI breakers or receptacles. However, 406.4 does not refer to Article 210.12(A) which requires a metal raceway or cable between the standard breaker and an AFCI receptacle at the beginning of the circuit.
> 
> ...


As Pete was saying "I would say no as long as you are only replacing the device. 210.12 deals with the branch circuit(s) not device replacement.

Now, if you had to modify, replace or extend the branch circuit as part of the device replacement you would have to comply with 210.12(B)"

Just make sure you are careful.


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## MDShunk (Jan 7, 2007)

Contractor Joe said:


> As Pete was saying "I would say no as long as you are only replacing the device. 210.12 deals with the branch circuit(s) not device replacement.
> 
> Now, if you had to modify, replace or extend the branch circuit as part of the device replacement you would have to comply with 210.12(B)"
> 
> Just make sure you are careful.


Exactly. Intent or not, no matter what is discussed in the ROP, the code says what it says.


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## MTW (Aug 28, 2013)

I was just reading the 2014 Handbook today and the author's commentary supported the common view which is that existing receptacles on existing branch circuits (pre AFCI) must be brought up to the current code if they are replaced. It was a good reminder why I don't waste money on NEC products any more.


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## RIVETER (Sep 26, 2009)

czars said:


> The 2011 NEC will be in effect in Florida on June 30, 2015. I do a lot of repair work for older folks who live in manufactured homes and receptacle replacement is common.
> 
> The 2011 NEC, Article 550.13(A)(2) specifically requires that receptacles in manufactured homes be installed IAW Article 406.4. 406.4 requires that when receptacles are replaced where AFCI protection is required by the 2011 NEC, AFCI protection must be provided by AFCI breakers or receptacles. However, 406.4 does not refer to Article 210.12(A) which requires a metal raceway or cable between the standard breaker and an AFCI receptacle at the beginning of the circuit.
> 
> ...


I believe...yes.


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## Meadow (Jan 14, 2011)

MTW said:


> I was just reading the 2014 Handbook today and the author's commentary supported the common view which is that existing receptacles on existing branch circuits (pre AFCI) must be brought up to the current code if they are replaced. It was a good reminder why I don't waste money on NEC products any more.


Important to note the commentary is just an opinion, albeit one heavily influenced by funding.


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## Lantern Electric (Jan 29, 2014)

Any reason you didn't share the PDF with us?


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