Focus: Fire-Life Safety / Column


Regulations, Codes & Standards Q&A: GFCI receptacles

By Brad Keyes / Special to Healthcare Facilities Today
April 22, 2020

Q: We were just surveyed (healthcare occupancy) and were cited for not having GFCI outlets installed within 6 inches of a sink location. At the time of construction this was not a requirement. I cannot find anywhere that states we must update upon change of the codes. I would prefer to find something that says upgrades are not required unless there are modifications/changes to the electrical system. What are your thoughts on this, please?

A: Article 210.8(B)(5) of NFPA 70-2011 does require GFCI outlets within six feet of a sink, but it does depend when the outlets were originally installed. According to section 9.1.2 of the 2012 LSC, it says electrical wiring and equipment shall be in accordance with NFPA 70 unless such installations are approved existing installations, which shall be permitted to be continued in service. When those outlets were originally installed, were they required to be GFCI outlets? If yes, then you’re still required to install them today because they were not approved when they were originally installed. According to the records I have, GFCI outlets were required within six feet of a sink back in the NFPA 70-1999 edition which was referenced by the 2000 LSC.

But there is another concern to deal with and that is the word ‘approved’. According to section 4.6.1.1 of the 2012 Life Safety Code the authority having jurisdiction shall determine whether the provisions of the LSC are met. This means, the AHJ determines whether or not the outlets were originally approved. This means if you were cited by your accreditation organization (AO) for not having GFCI outlets within 6-feet of a sink you cannot use the argument that the non- GFCI outlets were approved by your state or local AHJ. The AO is an AHJ and they get to determine what is approved or not, and they are under no obligation to accept the approval of a different AHJ.

So, the bottom line is this: If you can prove the outlets were not required to be GFCI at the time they were installed, you can submit this response to the AHJ as part of your plan of correction and see if they accept that. However, be prepared for the AHJ to decline that argument and still require you to install GFCI outlets. They have that authority according to section 4.6.1.1 of the 2012 LSC

Brad Keyes, CHSP, is the owner of KEYES Life Safety Compliance, and his expertise is in the management of the Life Safety Program, including the Environment of Care and Emergency Management programs.

See the latest posts on our homepage


Share

Topic Area: Regulations, Codes & Standards


Recent Posts
Recent Posts

Stabbing of Physician Leads to Lawsuit


Doctor’s lawyers say no one on staff alerted hospital security or seemed to know how to respond to incident

6/21/2021

Hospital's Renovation, Expansion Focus on Patients and Families


New facility will feature behavioral health design

6/21/2021

Case Study: Revamped Hospital Meets Space Needs


Solution involved relocating and enlarging main entrance, reconfiguring hospital’s interior and adding a parking garage

6/21/2021

Twice as Nice: Hospital To Double Bed Count


Expansion will add 200,000 square feet, more than double number of beds, and renovate and expand surgical and other facilities

6/18/2021

Rethinking Emergency Preparedness in Assisted Living


Research findings underscore importance of understanding ‘unique challenges’ communities face

6/18/2021





Post Comment




FREE
NEWSLETTER

News & Updates • Webcast Alerts • Building Technologies

All fields are required.

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.