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The 2023 NEC and its Potential Impact on Lighting Equipment

Light bulbs hanging in cement room

December 14, 2020

By Michael Shulman, principal engineer, UL's Lighting division

The 2023 National Electrical Code (NEC) revision cycle is now in full swing. The deadline for submitting public inputs was Sept. 10, and the various Code Making Panels (CMPs) are now reviewing them and preparing for their first-ever virtual meetings due to COVID-19. These web-based conferences will occur from November 2020 through January 2021 and will result in a first draft to be published in July 2021.

Most NEC requirements for lighting equipment are found in Articles 410 (Luminaires), 411 (Low Voltage Lighting), and 600 (Signs), all of which are within the responsibility of CMP 18. Other requirements are in Article 680 (Swimming Pool and Fountain Luminaires, CMP 17) and 700 (Emergency Lighting, CMP 13). Some of the most impactful discussions are likely to be associated with Articles 410 and 700.

In Article 410, a new part has been proposed: Special Provisions for Germicidal Irradiation Luminaires. The proposal addresses both UV upper-air disinfection systems, in which UV is applied in the upper portion of a room above occupied space, and UV systems that apply direct surface and air UV disinfection only when the treated space is not occupied. The proposal makes reference to UL 1598, the Standard for Luminaires; UL 8750 the Standard for Light Emitting Diode (LED) Equipment for Use in Lighting Products; and the newly published UL 8802, Outline of Investigation for Germicidal Systems. The proposal notes the importance of proper system design and installation and thus the importance of installation instructions and markings prescribed by the referenced requirements and provided by the equipment manufacturer.

In Article 700, new definitions are proposed for emergency lighting control devices (ELCDs) and for battery-equipped emergency luminaires. These definitions are then leveraged in other proposals intended to clarify requirements for equipment installation and operation and system-level reliability. A new section for Class 2-powered emergency systems (including Power over Ethernet, PoE) is proposed to make selective adjustments from the Article 700 wiring requirements applicable to line voltage and higher powered systems. Another proposal is for PoE power sources to be treated as ELCDs. If adopted, these devices (typically certified as ITE/communications equipment under standard UL 62368-1, the Standard for Audio/Video, Information and Communication Technology Equipment, and commonly referred to as switches or routers) will need to be additionally listed per UL 924, the Standard for Emergency Lighting Equipment.

Article 700 also contains proposals to harden emergency systems against both electromagnetic pulses and cybersecurity attacks. Some may consider establishing regulatory-level safeguards against such events as extremely timely or overdue, while others might consider them unnecessary or premature. It will be interesting to see how the CMP responds. The upcoming Code Panel meetings will result in committee revisions based on the public input and panel discussions. This draft is then subject to further public comment (until Aug. 19, 2021), and then the CMPs will meet again to develop a second draft to be published in March 2022. A final series of processes then occur before the 2023 NEC gets published, typically in September. It’s important to recognize that the NEC is adopted at either the state or municipality level, rather than nationally. Most states are currently using the 2017 NEC. Several states have already adopted the 2020 NEC while a few are still using the 2014, 2011, and even the 2008 edition.  

By the time a new NEC edition has been published, UL’s principal engineers will already be in the process of identifying any related changes that may be needed to UL Standards or certification programs. This proactivity helps ensure that both UL Standards and UL Certified equipment will always meet NEC installation expectations. UL’s principal engineers will also develop educational material to cascade any necessary guidance throughout the engineering staff. That information is, in turn, shared with UL’s customers during new product design compliance reviews so those products are prepared for what’s awaiting them at the installation and approval site.

UL’s regulatory staff helps complete this circle of support, by being available to assist the involved code authorities if questions arise as to whether Listed equipment complies with the particular NEC in force in that jurisdiction.  

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