Engaging the Codes- and Standards-Making Process
Inside this Article
PV system safety rests on three pillars: responsible PV professionals dedicated to designing and installing safe systems; local AHJs entrusted to conduct third-party reviews and inspections verifying the safety of system design and installation practices; and the codes and standards that provide guidance to these parties by defining minimum safety requirements. Though it is a favorite pastime of PV professionals to complain about codes and standards, the process of developing and revising them is very much a volunteer effort. As such, the quality of these governing guidelines for PV systems and components depends directly on the knowledge and dedication of these volunteers.
In this article, I explore the practical differences between codes and standards and explain why both are necessary and important. I then provide an overview of the organizations responsible for codes and standards relevant to the North American solar industry and elaborate on their development processes and how you can get involved. Since the development process for the National Electrical Code is particularly accessible, I walk through this in detail. If you feel there is room for improvement in the codes and standards with which you must comply, the only way to bring about change is to engage in the development process. Though it is a significant commitment, becoming part of this process pays dividends in many ways. It brings you into contact with subject matter experts from all areas of the solar industry, enhances your understanding of applicable codes and standards, and ultimately improves the safety of fielded PV systems.
Understanding Codes and Standards
While codes and standards serve a common goal, they are not synonymous. A code, on the one hand, tells industry stakeholders what they need to do to meet minimum safeguards for a specific discipline, such as installing an electrical system or building a structure. A standard, on the other, tells them how to ensure that their designs meet these code requirements.
As an example, the stated purpose of the National Electrical Code is “the practical safeguarding of persons and property from hazards arising from the use of electricity.” The 2011 edition of the NEC introduced requirements for dc arc-fault circuit protection for PV systems, codified in NEC Section 690.11. Before system integrators could meet this new Code requirement, industry stakeholders had to develop a new standard specifically for PV dc arc-fault circuit protection. The resulting product safety standard, UL 1699B, details the manufacturing and testing requirements for this new class of equipment.
Codes and standards are essential to enhancing the safeness of PV systems because safety is not an easy sell in and of itself. Improving safety tends to increase costs without enhancing functionality, performance or reliability. All else being equal, equipment and service providers are most motivated by driving down costs. Codes and standards level the playing field by ensuring that all fielded PV systems have to meet the same basic safety requirements.
In North America, the National Fire Protection Association (NFPA) and UL are the primary entities responsible for codes and standards pertaining to PV systems. The Institute of Electrical and Electronics Engineers (IEEE) is also relevant since it is responsible for utility-interactive inverter interconnection standards.
NFPA. According to its website, the NFPA is “devoted to eliminating death, injury, property and economic loss due to fire, electrical and related hazards.” Established in 1896, the nonprofit organization has approximately 65,000 members today and more than 6,000 volunteer seats on the development committees responsible for its 300 codes and standards. The NFPA codes most pertinent to the PV industry are NFPA 70: National Electrical Code and NFPA 1: Fire Code. Other relevant standards include NFPA 70E: Standard for Electrical Safety in the Workplace and NFPA 780: Standard for the Installation of Lightning Protection Systems.
The NFPA uses a consensus-based process that is open to public input in developing and revising all of its codes and standards. While it releases new editions of some of its standards at variable intervals, the NFPA updates its most widely used codes at regular intervals. For example, every 3 years it publishes a new edition of the NEC, which AHJs eventually adopt in all 50 states. Though revision cycles and schedules vary from one publication to another, the NFPA uses the basic development process detailed in Figure 1 for all of its codes and standards.
Looking specifically at NFPA 70, you see two opportunities for solar industry stakeholders to engage in the development process. These are the public input stage and the public comment stage.
Public input: As soon as NFPA publishes NEC 2017 (late 2016), it will begin the process of developing the revised 2020 edition. The first step in this process is an official public notice, known as the Call for Public Input, whereby NFPA requests that interested parties submit proposals for Code changes. Everything in the NEC is open for revision at this stage: changes in wording, modifications to tables or figures, wholesale additions or deletions, and so forth.