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Tables 11 and 19 in the CE Code — are they necessary guides to the Code users or obstacles of using approved equipment?

Posted By Ark Tsisserev, Thursday, July 01, 2010
Updated: Thursday, January 24, 2013

Let’s acknowledge a few undisputed facts:

1. All electrical equipment used in installations under provisions of the CE Code, Part I must be approved, and it must be of a kind or type and rating approved for specific purpose for which it is intended to be utilized (Re: Rule 2-024).

2. Word "approved” (in respect to electrical equipment) is defined in the CE Code, and it means by this definition that approved equipment is:

"(a) equipment that has been certified by a certification organization accredited by the Standards Council of Canada in accordance with the requirements of

(i) CSA standards; or
(ii) other recognized documents, where such CSA standards do not exist or are not
applicable; or

"(b) equipment that conforms to the requirements of the regulatory authority.”

It should be noted that the vast majority of electrical equipment is made "approved” by its certification to an applicable CSA safety standard forelectrical equipment. All such current product standards (known by the industry experts as "Part II” standards) are referenced in Appendix A to the CE Code, Part I. In fact, the installation Code is called the "CEC, Part I,” as the CSA safety standards for electrical productsrepresent the "CE Code, Part II.”

It should be also noted that for the purpose of item (a)(ii) of definition "approved,” equipment certified to the ULC standards is deemed to be "approved” (i.e., for the equipment comprising a fire alarm system), as there are no CSA standards for such equipment.

3. All "approved” electrical equipment must be marked to ensure that it is suitable for the particular installation. Such markings must consist of a certification monogram and other relevant means of equipment identification as described in Rule 2-100 of the CE Code, Part I.

As we have established the above three undisputed facts, we can with a full certainty state that if a piece of electrical equipment is "approved” for the specific purpose of its use in accordance with the applicable product standard, such piece of electrical equipment should be installed under rules of the CE Code, Part I.

This statement is accurate for the majority of electrical products.

However, in case of electrical conductors (in addition to this generic requirement), another criteria must be met. Thiscriteria is compliance with condition ofconductors use as per Table 11, when such conductors are flexible cords, heating cords, equipment wires, festoon and elevator cables or portable power cables; and compliance with condition of use listed in Table 19, when such insulated conductors are intended for a permanent installation in accordance withSection 12 of the CE Code, Part I.

How do we know about a need to comply with such additional criteria? The answer could be found in two sections of the Code: Section 4 and Section 12.Rule 4-010, which governs installation of flexible cords, mandates compliance of "approved” flexible cordswith Table 11. Rule 4-038 covers use of portable power cables. This rulerequires that condition of the applicable use must meet provisions ofTable 11 for any portable power cable installed under the Code.

Rule 4-006 covers all insulated conductors, and it references Table 19 for condition of use for all types of these conductors.

It is interesting to note that although Rule 12-100 re-enforces the requirementalready existing in Rule 4-006 bymandating use ofTable 19 for installation of conductors in suitablelocations, this Rule also outlines the objective criteria for use of these conductors.

These criteria are outlined in respect to:
"(a) moisture, if any;
(b) corrosive action, if any;
(c) temperature;
(d) degree of enclosure; and
(e) exposure to mechanical injury.”

There are some Code users that consider these objective criteria of Rule 12-100 as the main condition for selection of "approved” wiring products for installation under provisions of the Code.

These code users are of the opinion that such criteria should be expanded into Rules of Section 4 that cover installation of flexible cords and portable power cables. They are adamant that Tables 11 and 19 have become an obstacle to trade, particularly in those cases when the Code has not caught up with a new approved wiring product. These electrical practitioners feel that Tables 11 and 19 should be moved from the mandatory body of the Code to the informative appendix. They argue that Tables 11 and 19 may be unnecessarily restrictive and may not accurately and efficiently reflectnew technologies in wiring products.

However, there are numerous Code users who rely on guidance provided by these Tables in respect of condition of use for specific wiring, and these electrical safety stakeholdershave no doubts about advantages of retaining these Tables as a mandatory part of the Code.

Of course, technical experts who participate in the development of the code are dealing with this issue at their respective S/C’s (section 4 and Section 12) via a consensus process. But a public input is always welcome, and the CSA has established a mechanism for a comprehensive public review of every technical subject.

I’m not going to express my view point on the subject in this article (I expressed it in the consensus process at the technical S/C’s level), but in light of this discussion I’d like to pose to the readers just anexample of two questions to illustrate the fact that Table 19 is certainly not perfect and should be improved, if it is to stay in the body of the Code.

So, my first example relates to installation of armoured cables in raceways. Everyone is aware that power utilities request that their supply service cables be installed in the customer-owned raceways, and that such requests are routinely satisfied by the designers and installers, and such installations are accepted by the regulators. But what does the CE Code tell us on this subject? Rule 12-902 states that the conductors for use in raceways must be of types specified in Table 19. Table 19 does not appear to allow use of armoured cables in raceways. Does this mean that the designers, installers and regulators routinely violate the Code? Does it mean that Rules of the Code need improvement?

I’ll answer to the latter question with a confident, "Yes.” And such improvement is taking place.

My second example relates to use of a fire alarm and signal cable, FAS 90 in Class 2 circuits intended for security systems installations. Table 19 appears to permit only extra-low-voltage ELC Type cable for such installation. Does it mean thatTable 19 restricts use of the FAS for this purpose?

My answer is: "The FAS cable is allowed for this application. However, to recognize this fact—Table 19 should be improved accordingly.”

Although I have many more examples on this subject (and I also have an answer to the last question), I will advise the readers to communicate these issues with the electrical inspection authorities responsible for the enforcement of the adopted CE Code in their respective jurisdictions.


Read more by Ark Tsisserev

Tags:  Canadian Perspective  July-August 2010 

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