third public review responses& resolutions bsr e1.51 ... · “the potential difference between...

Third Public Review Responses& ResolutionsBSR E1.51, Portable Power Cable in Canada

Referenced document:BSR E1.51 - 201x, The Selection, Installation, and Use of Single-Conductor Portable Power Feeder Cable Systems for Use at 600 Volts Nominal or Less for the Distribution of Electrical Energy in the Television, Film, Live Performance and Event Industries in Canada (document number EP/2012-7009r4a)

ANSI public review period: 19 June through 3 August 2015

Question: Do you recommend that the standards committee accept BSR E1.51-201X (document number EP/2012-7009r4a), as an American National Standard, that its requirements are reasonable, neither too lax nor onerous, and that it would not unreasonably negatively impact materially affected parties in the entertainment industry? Please indicate "Yes" (accept it), "Yes with comments," or "No with reasons" (don't accept it).

Responses:

Name Representing YesYes with

commentsNo with reasons

Roger Dean (RD) R. Dean Lighting Ltd. X

James Eade (JE) ABTT X

Robert P. Harris (RPH) Skookumchuck Electrics Ltd./IATSE 891 X

Ty Mellon Jr. (TM) Lex Products Corp. X

Keith Woods (KW) IATSE 891 X

Comments and reasons with resolutions in italics. (The resolutions were approved at the 23 October 2015 working group meeting.)

# Commenter Clause Comment or reason & resolution

1 KW general Firstly, I have discovered I was incorrect in previous comments, and proposed resolutions in that the CEC uses a hyphen between single and pole in all references; as well as with single and conductor. I propose that this be changed whenever these words are used to reflect the usage of the CEC.

Accept

2 KW Definitions Ampacity-this should only have the definition as stated in the CEC definitions. Therefore, the second sentence ”This rating changes with conditions of use.” Should be struck from the definitions. Language explaining these conditions should be added to later sections of the document.

Accept. Add an additional statement as an informative note.

3 KW Definitions Ampere-the second sentence “One ampere equals one coulomb per second.” Should be struck as we would then need to define coulomb. [TSM note: Both "ampere" and "coulomb" can be found in a standard dictionary with the meanings used in this document; neither needs to be defined in E1.51.]

Accept.

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4 KW Definitions AHJ-rewrite as follows: “The office, or individual, responsible for approving equipment; materials; and installations.” [TSM note: "and" would require an AHJ to do all three; "or" would be a more permissive conjunction.]

Accept as follows: The office or individual responsible for approving installations, and/or equipment and materials.

5 KW Definitions Authorized person-changes at the end as follows: “…authorized to do so by someone having the authority to give the such instruction or and authorization.”

Reject: Definition is per CEC, and can stand without change.

6 KW Definitions Conductor-rewrite as follows: “a wire; cable; or other form of metal material; installed for the purpose of conveying electric electrical current from one piece of electrical equipment to another, or to ground.”

Reject: The wording is the same as the CEC. C’est la meme chose de le CEC.

7 KW Definitions Connector-in the definition of wire connector add a comma between together and or

Reject: Comma not necessary; per CEC definition.

8 KW Definitions Discconect-rewrite as follows: “a device whereby the conductors of a circuit can be disconnected from their source of supply (power)” delete comma after device, and add power at the end.

Accept as the following change: re-write to include full CEC definition: Disconnecting Means”: A device, or group of devices, whereby the conductors of a circuit can be disconnected from their source of supply.

9 KW Definitions Feeder-add a comma after “system”, and before “or portable”.

Reject. No comma is needed. See Chicago Manual of Style, 6.18.

10 KW Definitions Grounding electrode-as there is an actual CEC definition, the true CEC definition should be used, not this hybrid version. Rewrite to CEC definition: “a buried metal water-piping system or metal object or device buried in, or driven into, the ground to which a grounding conductor is electrically and mechanically connected. a buried metal water-piping system or metal object or device buried in, or driven into, the ground to which a grounding conductor is electrically and mechanically connected.”

Accept.

11 KW Definitions Overcurrent device-rewrite with the proposed change: “….opening an electric electrical circuit…”

Reject: Also the same wording as the CEC Aussi la meme de le CEC.

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12 KW Definitions Single pin-first off add the hyphen between single and pin. Secondly, the word generally should be removed from a). this should be rewritten as follows:

a) a locking, one pin, outdoor usage approved connector rated up to 400 amperes, that is colour coded to designate phasing. (Refer to CEC Section 66); or [sic]

Reject use of hyphen in the bolded definition; referencing an item and a system.Accept removal of “generally”.

13 KW Definitions Tails-rewrite Load Tails as below:

Load Tails; single-conductor cables installed temporarily for the supply of power from a utility (power) source.

Accept in principle: Change to: single-conductor cables installed temporarily for the supply of power from a power source.

14 KW Definitions Volt-. I recommend a rewrite to the definition below as it is easier to understand, and we really do not need to get into the technical aspects of coulombs and joules as was in the original definition. “-unit of electromotive force, the difference of potential that would drive one ampere of current against one ohm resistance.”

Accept: Suggest add informative note: unit of emf (electromotive force); for grounded circuits, the measurement between any given live ungrounded part and any grounded part

15 KW Definitions Voltage-the original is a bit wordy, and confusing. Suggest rewrite to: “the potential difference between two points expressed in volts. Can be referred to as nominal, or actual voltage. Actual voltage is measured as root-mean square (RMS).”

Reject: Change last sentence to read: Also the potential difference required at the point of use for a system and/or equipment to operate as designed.

16 KW 1.2 1.2 suggest rewrite to: “All electrical equipment (including cordsets) shall must be approved, and bear an approval, or certification, mark of from:”

Accept in part. Keep "shall"but change "of" to "from."

17 KW 3.1 3.1-lose parenthesis at end of sentence

Accept removal of quotation mark at end of sentence.

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18 TM 3.2 The document as written has a construction requirement for equipment with single-pin connectors that require the installation of the connectors in a way contrary to the manufacturer’s instructions. The most common type of single pole connectors, cam-type connectors are evaluated according to to C22.2 No. 1691 and go through testing installed as manufacturer’s instructions specify.

From 3.2 of the document:3.2 Panel or chassis mount single pin connectors shall be installed from the inside of enclosures with attaching fasteners adequately clear of any possible contact with terminals or busses

The Leviton and Cooper cam-type connector installation instructions have the panel mount connectors installed on the outside of the panel. This document specifies that these connectors shall be installed on the inside of a panel, contrary to the instructions. Installing a cam-type connector in a manner not specified by manufacturer may compromise the rating of the device. For example, cam-type connectors are subject to environmental testing of Type 3R or greater. Installing them in a different manner may void the environmental rating of the device.

Any text asking for the installation of single pole needs to remove references to installing cam connectors on the inside or outside of the enclosure.

Alternate language that better falls in line with CSA C22.2 No. 1691 would be:

3.2 Panel or chassis mount single pin connectors shall be installed per manufacturer’s instructions. Verify that attaching fasteners adequately clear of any possible contact with terminals or busses during installation.

Accept in principle: Panel or chassis mount single pin connectors shall be installed per manufacturer’s instructions. Verify that attaching fasteners are adequately clear any contact with terminals or busses.

19 KW 3.4 3.4-suggest rewrite to: “All connection points that are not in use, shall must be covered with a an approved seal or cap. that is acceptable

Reject: use CEC wording 66 456 (2)(c)

20 RPH 3.5 "3.5 Feeder cables shall not penetrate walls, floors, windows, or ceilings, or be run through doors or traffic areas without additional protection from mechanical damage."

This must be removed as it states the opposite of the code. There is no provision for additional protection in the quoted rule.

Reject suggestion to remove the statement; requirement for additional protection is reasonable practice, and without this acceptance, utilization of sites or locations would be impossible. The code statement is directed at permanent installations.

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21 JE 3.5 Clause 3.5: I'm not sure about Canadian fire/building codes, but consider adding a requirement for fire sealing around penetrations to remain intact as follows:

3.5 Feeder cables shall not penetrate walls, floors, windows, or ceilings, or be run through doors or traffic areas without additional protection from mechanical damage. (CE Code 4-012 (3)). Any fire barriers or seals that are penetrated by such cables should be made good during use and after the cables are removed.

Reject: regardless of conditions, one cannot penetrate a fire barrier with cable.

22 KW 4.3 4.3 suggest new wording, change “Wrong” to incorrect in this section. Rewrite as follows: [sic. Nothing was written after "follows:" The next entry was for 5.2.]

Reject: uses code wording. Plug-in connectors for single-conductor cables shall(a) be of a locking type;(b) incorporate a mechanical interlock to prevent wrong connections or be colour-coded;

23 KW 5.2 5.2 Panel Assemblies-rewrite as follows: “Multiple connectors per pole phase shall be are permitted. But, Wwhere multiple connectors per pole phase are provided, the second and all additional sets of input, ( supply, or line ) ,and all or output (load) connectors shall have:”

Reject: pole is appropriate for the phraseology employed.

24 KW 6.1 6.1 Cable routing-shall is to be replaced by should. If it is not a direct reference to the Code, should is the word, not shall. No matter what is felt about this document, it cannot supersede, or put words in the mouth of the Code. On several occasions, just like this one, the word should has been used, not shall, and that should be the common denominator of this document. It is not the Code, and cannot, and never will carry the weight of the Code, and should therefore not pretend it can.

Reject: the statement is not in conflict with the code. As a standard, the statement can reflect the best practice.

25 RPH 6.1 "6.1 Cable routingCable routing shall be determined prior to commencement of any installation."

The word “shall” is inappropriate here. The only time "shall" is allowable is when a relevant section of the CEC is being cited, as this body does not have the authority or jurisdiction to apply the word “shall.” In all other instances the word "should" is the only allowable choice, as this body is only able to create voluntary standards on it’s own accord. This objection applies to the entire document, of which this clause is only one instance. As this document is riddled with the inappropriate use of the word “shall”, for brevity’s sake I will not document all the other cases. This change will necessitate the committee to identify them in a comprehensive review, asking the question in each case, “Is this citing the CEC or not?”. If so the relevant code rule should be cited, or if not the word “should” must be inserted instead.

Reject: see above (comment 24)

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26 KW 6.2.2 6.2.2-as I stated in the last comment review cycle, this is not what the Code states at all, and should be struck from the document. The section referenced, Sect 14-100 is an “and” section, not an “or” section meaning all pieces of the puzzle must be accepted to meet the Code. One cannot take the language one wants to do what one wishes. STRIKE THIS SECTION!

Accept in principle.Tap points used in a single conductor power distribution system that go from a higher ampacity conductor set to a lower ampacity conductor set shall have an appropriately sized overcurrent protective device at the tap point.

Drop the code reference at the end of the sentence.

27 KW 6.4.2.1 6.4.2.1-it feels safer to mark all frequencies in a system, no? suggest rewrite:

“When current is distributed at different supply frequencies in a portable power distribution system on one site, that system which is not 60Hz frequency shall bear prominent identification as to the supply frequency of the system. all branches of the system shall have the frequency identified.

Accept.

28 KW 6.4.3 6.4.3 Load-not very plainly written. Suggested rewrite: “Unless an overcurrent device is specifically marked as 100% rated, all calculated loads, on current conductors, must not exceed 80% of the maximum load rating of the overcurrent device in use.”

Reject: change is not substantive.

29 KW 6.5 6.5 Spare disconnects-replace shall with should. Not a requirement of the Code, and therefore does not need a “shall” designation.

Reject.We intend that this document or parts of it will become part of the CEC, so "shall" is the correct word to use.

30 KW 7.1.3 7.1.3 Number of interconnections. This is not specifically mentioned in the Code, and is not a requirement of the Code, so “shall” needs to be replaced by “should”

Reject. We intend that this document or parts of it will become part of the CEC, so "shall" is the correct word to use.

31 KW 7.1.5.2.1 7.1.5.2.1-replace “shall” with “should”. This is a should statement, not a shall statement as the inference is that there is no exceptions to the rules, if one uses should, then you can move on and discuss cable mats and other protection equipment. Shall does not allow the use of protection as it basically says, do not allow it to happen. Should gives the technician the latitude he, or she, needs to do the work required.


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32 KW 7.2 7.2 System Ground-suggest the following rewrite: “Any new system, such as a generator or transformer, All power systems, shall have it’s the ….”

Accept

33 KW 7.2.2 7.2.2-new 2015 version of Sect 66-200 states what is in the a), although it is wrong, and onerous and should be removed.

Reject add Informative note: The purpose of grounding a generator in a remote location is to establish an equi-potential plane to eliminate step/touch potentials. The ground electrode should be installed as close as possible to the generator. In an existing building or urban environment the equi-potential plane has already been established because all system/service and equipment should already be bonded together and all system/service neutrals bonded to ground. In a rural setting, you are setting up the only equi-potential plane.

34 KW 7.2.3 7.2.3 suggest the following rewrite for clarity: “Where there is morn that one source of supply, such supply systems all power supplies in the system, shall have their grounds bonded together.”

Accept as follows: Where there is more than one source of supply, all systems shall be bonded together.

35 KW 7.2.4 7.2.4-suggest adding the sentence “Colloquially referred to as the ground line.”Accept

36 KW 7.3.1 7.3.1 suggest the following rewrites: “Connection and disconnection to/from a utility all power sources shall be…” FPN Different jurisdictions have different requirements, therefore the statement si intended to cover the variables it is suggested to check with the local AHJ.

Accept as rewritten.

37 KW 7.3.2 7.3.2-should we add..” , qualified, and where required, appropriately certified personnel” after authorized to bring this in line with our resolutions from the last public review?

Accept as rewritten: The authorized, qualified, and where required, appropriately certified personnel shall determine which loads will potentially create a safety hazard if shut down and shall take suitable precautionary actions.

38 KW 7.3.3 7.3.3 add the word the… “should notify other users of the power…”

Accept

39 KW 7.3.5 7.3.5 the words “non energized” should replace de-energized in the second paragraph as de energized infers one has turned off the power, and in this instance the system has yet to be energized.

Accept as follows: non-energized

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40 KW 7.4 7.4 replace shall with should. Remove “installed” after have. “each system shall should have installed…”


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Resolutions to 2nd Public Review ResponsesBSR E1.51, Portable Power Cable in Canada

Referenced document: BSR E1.51 - 201x, The Selection, Installation, and Use of Singleconductor Portable Power Feeder Cable Systems for Use at 600 Volts Nominal or Less for the Distribution of Electrical Energy in the Television, Film, Live Performance and Event Industries in Canada (document number EP/2012-7009r3)

ANSI public review period: 3 October through 17 November 2014

Question: Do you recommend that the standards committee accept BSR E1.51-201X (document number EP/2012-7009r3), as an American National Standard, that its requirements are reasonable, neither too lax nor onerous, and that it would not unreasonably negatively impact materially affected parties in the entertainment industry? Please indicate "Yes" (accept it), "Yes with comments," or "No with reasons" (don't accept it).

Name Company Yes Yes with comments No with reasons Comments only

Jeffrey Harvey (JH) KIS Electric Ltd. X

Tim Garrison (TG) IATSE 891 member X

Phil Klapwyk (PK) (none listed) X

Keith S Woods (KW) IATSE local 891 X

Robert Scurrah (RS) (none listed) X

Robert P. Harris (RH) IATSE local 891 X

Sean Bygrave (SB) (none listed) X

A note about duplicate comments and the work to resolve them:

Three comments resolution sessions were conducted, with the participants from Toronto and the participants from Vancouver collaborating in the comment review by conference call. The dates were: December 22, 2014; January 16, 2015; and February 9, 2015.

At the first meeting, Robert Harris and Keith Woods participated from Vancouver.

In the two subsequent meetings, Keith spoke for and collaborated with Robert Harris and the other Vancouver commenters. Robert Harris stated that he had authored the objection comments, which others had totally or partially duplicated, and it was agreed that the duplicate objection comments would be struck, and only those that he had written would be addressed. Where objections and supporting comments from both Robert Harris and Keith Woods were substantially similar, consensus was achieved on the appropriate disposition of the relevant comment.

Any substantial variants by the other Vancouver submitters were considered on their merits.

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Comments and reasons with proposed resolutions:Cmmnt

# Clause Commenter Comment Resolution

1 General JH In conclusion, I must recommend that this document not be adopted without being substantially altered. Most importantly, I find that many of the clauses are onerous, that they would unreasonably negatively impact film and television workers in the performance of their jobs, and could substantially increase the cost of production without any significant safety benefit.

I am also troubled by the way this document presents itself. First, while it quotes the CEC, it also paraphrases sections at it’s convenience and then chooses to ignore code when it’s inconvenient (as in the paralleling of cables). Second, while the ANSI standards that exceed the CEC are voluntary, the implication of the wording employed in this document is that they are compulsory (as in the frequent misuse of the word “Shall” instead of “Should”). To make it clear, there should be some method of identifying what is recommended and what is required, and the document should state in the preamble that ANSI standards are voluntary. Third, there seems to be some sections that are for training purposes, as they appear to just present general knowledge for the workers. The combination of these three aspects make for a confusing presentation. It would be much clearer if they were either separated into 3 sections (CEC, ANSI Standards, and Training), or marked throughout as to what type of clause is being presented. This document lacks a clarity of purpose and scope, and fails to provide a useful document for me in my work in the industry. I cannot recommend it’s adoption as it stands.

Finally, I would like to note my qualifications. I have been employed in the Film Industry for over 20 years in the Lighting Department with IATSE 891 as a Lamp Operator, Setwireman, Generator Operator, Rigging Best Boy, and Rigging Gaffer. I have an Interprovincial Certification as an Electrician, licence contractor from the BC Safety Authority, and I am an ETCP Certified Electrician.

Reject duplication of 2 while noting the work experience related does not offer any substantive comment to any technical content in the standard.

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2 general RH In conclusion, I must recommend that this document not be adopted without being substantially altered. Most importantly, I find that many of the clauses are onerous, that they would unreasonably negatively impact film and television workers in the performance of their jobs, and could substantially increase the cost of production without any significant safety benefit.


Finally, I would like to note my qualifications. I have been employed in the Film Industry for over 17 years in the Lighting Department with IATSE 891 as a Lamp Operator, Setwireman, Generator Operator, Rigging Best Boy, and Rigging Gaffer. I have an Interprovincial Certification as an Electrician, with a B Level Field Safety Representative and a Full Entertainment Certification from the BC Safety Authority, and I am an ETCP Certified Electrician.

accept: the document has been substantially altered.

Reject: we have addressed the specifics of the shall vs. should in subsequent relevant comments. Regarding the document lacking clarity etc. we have Robert Harris now on our subcommittee so he accepts the document exists and by agreeing to participate on achieving consensus on the comments resolution panel gives defacto acceptance of the standard.

3 general SB In conclusion, I must recommend that this document not be adopted without being substantially altered. Most importantly, I find that many of the clauses are onerous, that they would

Reject duplication of 2 while noting that the work experience related does not offer any substantive comment to any technical content in the standard.

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unreasonably negatively impact film and television workers in the performance of their jobs, and could substantially increase the cost of production without any significant safety benefit.


Finally, I would like to note my qualifications. I have been employed in the Film Industry for over 17 years in the Lighting Department with IATSE 891 as a Lamp Operator, Setwireman, Generator Operator, Rigging Best Boy, and Rigging Gaffer. I have an Interprovincial Certification as an Electrician, with a B Level Field Safety Representative and a Full Entertainment Certification from the BC Safety Authority, and I am an ETCP Certified Electrician.

4 general RS I could not get a copy of the actual Adobe document that would allow changes therefore I have to use Word.

This document, BSR E1.51 - 201x, is being purposed as a voluntary set of standards for all of North America however some of the purposed standards are directly contrary to or are directly

Accept in principal, this is to be a Canadian Standard and while there are no specifics given, the standard has been reviewed and revised as appropriate.

Reject: we have addressed the specifics of the

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affected by the Canadian Electrical Code (CEC). As the code is law or regulation in Canada, a voluntary standard that is against or directly affected by the CEC cannot be followed in Canada, therefore cannot be "A North American" standard.

I have attached my suggestions as a separate document and also included them below.

Because this is to be a North American standard, obviously the CEC cannot over ride local codes in other jurisdictions that may have direct conflicts with the CEC, however I have treated the document specifically as pertaining to Canada. Other jurisdictions need to have direct input on their specific situation to standards but direct contradiction to the CEC cannot be allowed in Canada.

I found that the use of the word "shall" is inappropriate in a voluntary document. ANSI standards may exceed the requirements of the CEC however there should be language or a method that shows what is recommended to exceed code and what is required by code.

There is also some issues I found with the specific instances where the proposed document actually contradicts the CEC.

I have over 100,000 hours of work in theatre as an Theatre Lighting Electrician/Lighting Designer/Operator and since 2005, have worked as a member of IATSE 891 as Lamp Operator and in other areas and currently hold a FE (Full Entertainment Certification) BC Electrical License. This is not recognized outside of British Columbia but is specific to the entertainment industry here and regulated by the provincial government specifically in accordance with the Canadian Electrical Code.

In conclusion, I must recommend the document not be adopted in its present form. Many of the clauses are onerous in the performance of work by film and television workers with no significant improvement in safety and are directly contrary to the Canadian Electrical Code. They will also negatively affect the cost of production. The document needs clarification and

‘shall vs. should’ in subsequent relevant comments. Been dealt with in subsequent comments.

Reject: Does not note specific instructions to code conflict. Specific issues have been dealt with in subsequent comments.

Reject: the work experience related does not offer any substantive comment to any technical content in the standard.

Reject: No specific comments however, we have dealt with the specific code comments in subsequent comments and the document has been altered from its initial form.

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correction from its present state.

5 general PK There are many more issues with the document as it presents. I believe that it needs substantial revision, more with an eye to practical application of the CEC across all jurisdictions in Canada.

Reject: No specific comments to address.

6 general KW There should be no hyphen between single and conductor at any time in this document, as it is unnecessary grammatically. The same would apply for hyphens found between live and event. [TSM note: PLASA North America uses the Chicago Manual of Style, 16th edition. In that, see clause 7.81 about compound modifiers.]

Reject: the document will reflect as it appears in the code book. single-conductor, Live Event

7 general KW Also, there is no standard as to whether the personnel are “certified”; “qualified”; or “authourized”. In my mind whenever discussing personnel, they should be “qualified, and authorized”. I suggest that this be done throughout the text wherever “certified” has been used, and to add “authorized” whenever adding, “qualified”.

Accept: Add 3 definitions as follows: Certified person: a holder of a valid certificate of qualification. Qualified person — one familiar with the construction and operation of the apparatus and the hazards involved, Authorized person — a qualified person who, in his or her duties or occupation, is obliged to approach or handle electrical equipment; or a person who, having been warned of the hazards involved, has been instructed or authorized to do so by someone having authority to give the instruction or authorization.

8 title JH "THE SELECTION, INSTALLATION, AND USE OF SINGLECONDUCTOR PORTABLE POWER FEEDER CABLE SYSTEMS FOR USE AT 600 VOLTS NOMINAL OR LESS FOR THE DISTRIBUTION OF ELECTRICAL ENERGY IN THE TELEVISION, FILM, LIVE PERFORMANCE AND EVENT INDUSTRIES IN CANADA".

This should be changed to 750V from 600V, as that is the dividing line in the CEC between Low Voltage and High Voltage. “Section 0- Voltage definitions”

Reject Duplication of 9

9 title RH THE SELECTION, INSTALLATION, AND USE OF SINGLE- CONDUCTOR PORTABLE POWER FEEDER CABLE SYSTEMS FOR USE AT 600 VOLTS NOMINAL OR LESS FOR THE

Reject: Leave as originally stated, comments resolved. The cables and connectors involved are rated for 600V

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DISTRIBUTION OF ELECTRICAL ENERGY IN THE TELEVISION, FILM, LIVE PERFORMANCE AND EVENT INDUSTRIES IN CANADA". This should be changed to 750V from 600V, as that is the dividing line in the CEC between Low Voltage and High Voltage. “Section 0- Voltage definitions” also needs to be changed in the Scope on page 4.

10 title SB THE SELECTION, INSTALLATION, AND USE OF SINGLE- CONDUCTOR PORTABLE POWER FEEDER CABLE SYSTEMS FOR USE AT 600 VOLTS NOMINAL OR LESS FOR THE DISTRIBUTION OF ELECTRICAL ENERGY IN THE TELEVISION, FILM, LIVE PERFORMANCE AND EVENT INDUSTRIES IN CANADA". This should be changed to 750V from 600V, as that is the dividing line in the CEC between Low Voltage and High Voltage. “Section 0- Voltage definitions” also needs to be changed in the Scope on page 4.


11 title RS "….FEEDER CABLE SYSTEMS FOR USE AT 600 VOLTS NOMINAL….

Change to 750 V from 600 V as per the Canadian Electrical Code (CEC) Low Voltage versus High Voltage systems. Also Page 4 under scope – again 600 V should be 750 V


12 title KW Delete January 16, 2015 Reject Duplication of 9

13 title KW The first paragraph of the Scope, and the title page should better reflect the language of CEC Section 66. The Scope should be revised, and read as follows:

This standard covers the selection; installation; and safe use of single conductor portable power feeder cable systems used for amusement parks; midways; carnivals; and other events of a temporary nature held indoors; outdoors; or in tents; such as film and TV sets; TV remote broadcasting locations; home shows; live theatre; and travelling shows.

The second paragraph of the Scope is acceptable, but hyphens

Accepted Jan 16/15

This standard covers the selection; installation; and safe use of single conductor portable power feeder cable for events of a temporary nature. This includes but is not restricted to (a) amusement parks;(b) midways;(c) carnivals;(d) fairs;(e) film, television, and radio productions;(f) remote broadcasting and recording locations;(g) live performance and entertainment events;

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need to be removed for grammatical correctness.

The title page could be the same, with the words “this standard covers” removed.

(h) touring shows and productions;(i) concerts;(j) sporting events;(k) trade shows.

Accept comment excepting "single-conductor"

Reject: leave as stated

14 Scope JH This should be changed to 750V from 600V, as that is the dividing line in the CEC between Low Voltage and High Voltage. “Section 0- Voltage definitions” also needs to be changed in the Scope on page 4.


15 Scope SB This should be changed to 750V from 600V, as that is the dividing line in the CEC between Low Voltage and High Voltage. “Section 0- Voltage definitions” also needs to be changed in the Scope on page 4.


16 Scope RS "….FEEDER CABLE SYSTEMS FOR USE AT 600 VOLTS NOMINAL….

Change to 750 V from 600 V as per the Canadian Electrical Code (CEC) Low Voltage versus High Voltage systems. Also Page 4 under scope – again 600 V should be 750 V


17 Scope KW Scope, and title page should be revised to reflect the low voltage language of the CEC, plus meet the British Columbia Full Entertainment certification language, which places the voltage at 750v, not 600v.

In the definitions section of the CEC it describes low voltage as “any voltage exceeding 30 V but not exceeding 750 V”.


18 Scope KW The first paragraph of the Scope, and the title page should better reflect the language of CEC Section 66. The Scope should be revised, and read as follows:

This standard covers the selection; installation; and safe use of single conductor portable power feeder cable

Reject Jan 16/15 Keith Woods (resolutions task group member) withdrew his comment.

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systems used for amusement parks; midways; carnivals; and other events of a temporary nature held indoors; outdoors; or in tents; such as film and TV sets; TV remote broadcasting locations; home shows; live theatre; and travelling shows.

The second paragraph of the Scope is acceptable, but hyphens need to be removed for grammatical correctness.

The title page could be the same, with the words “this standard covers” removed.

19 Scope RH This should be changed to 750V from 600V, as that is the dividing line in the CEC between Low Voltage and High Voltage. “Section 0- Voltage definitions” also needs to be changed in the Scope on page 4.


20 DefinitionsAmpere

KW The second sentence is unnecessary language. All the worker needs to know is what an ampere is, the scientific language is unnecessary.

As we are dealing with some people who are new, or unknowing, of some of the ins and outs of the CEC and the work covered in this document, it might be good to add the following text from the CEC:


Reject. Leave as defined in the CE Code.

21 DefinitionsAuthorized

person

KW Authorized person — a qualified person who, in his or her duties or occupation, is obliged to approach or handle electrical equipment; or a person who, having been warned of the hazards involved, has been instructed or authorized to do so by someone having authority to give the instruction or authorization.

Add the above language below the definition of an AHJ.

See resolution for comment 7.

22 DefinitionsBond

(Bonded

KW Bond (Bonded): connect (connected) by bonding to grounding conductor and electrode.


23 DefinitionsCertified person

JH Definitions - "Certified person: a tradesperson, with a valid certificate of Qualification.”

This should be changed to! "Certified person: a person, with a


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valid certificate of qualification, recognized by the Appropriate Authority Having Jurisdiction".

The reasons for the two changes are that (1) a certified person may not necessarily be A tradesperson, and (2) a certification from one jurisdiction may not be recognized in Another area. For example, the Full Entertainment Certification from BC is not Recognized in other Canadian provinces, and is not a Trade certificate (i.e., there is no Registered apprenticeship program for this)


RH Definitions - "Certified person: a tradesperson, with a valid certificate of qualification." This should be changed to:"Certified person: a person, with a valid certificate of qualification, recognized by the appropriate Authority Having Jurisdiction". The reasons for the two changes are that (1) a certified person may not necessarily be a tradesperson, and (2) a certification from one jurisdiction may not be recognized in another area. For example, the Full Entertainment Certification from BC is not recognized in other Canadian provinces, and is not a Trade certificate (ie, there is no registered apprenticeship program for this).



SB Definitions - "Certified person: a tradesperson, with a valid certificate of qualification." This should be changed to:"Certified person: a person, with a valid certificate of qualification, recognized by the appropriate Authority Having Jurisdiction". The reasons for the two changes are that (1) a certified person may not necessarily be a tradesperson, and (2) a certification from one jurisdiction may not be recognized in another area. For example, the Full Entertainment Certification from BC is not recognized in other Canadian provinces, and is not a Trade certificate (ie, there is no registered apprenticeship program for this).



KW Certified person is not a term used in the CEC, and therefore one needs to be more specific as to what, or who “certifies” this person. It should be reworded as below:


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“Certified person: a person with a valid certificate of qualification recognized by the appropriate AHJ.”


RS Certified person may not be a tradesperson. I hold a Full Entertainment Certification recognized by and regulated by the British Columbia government. Therefore the definition should read similar to the below:"Certified person: a person with a valid certificate of qualification recognized by the Authority Having Jurisdiction (AHJ)."


28 DefinitionsCordset

KW Cordset-this needs to become 2 words Cord set, to meet the CEC text. [TSM note: See clause 7.79 of the Chicago Manual of Style. Possibly the CSA does not use the Chicago Manual of Style.]

Accept: "Cord set" as per CEC.

29 DefinitionsGrounded

KW Grounded (neutral, identified) conductor should be revised to the text below:

Grounded (neutral, identified) conductor: One current carrying conductor of a circuit that is intentionally bonded to the ground conductor at the power source to maintain a nominal voltage of 0 V to ground.

This needs to be added to note that the conductor is bonded, not grounded, at the source, and only at the source. Also, no hyphen between current and carrying.

Accept as follows:Grounded (neutral, identified) conductor: One current carrying conductor of a service entrance, transformer or generator service is intentionally bonded to the ground conductor at the power source to maintain a nominal voltage of 0 V to ground.

30 Definitions(System)

Grounding conductor

KW (System) Grounding conductor-lose the word system, and revise as below:

Grounding conductor: the conductor used to connect the service equipment; power system; or generator to the grounding electrode.

Accepted as follows: Grounded (neutral, identified) conductor: One current carrying conductor of a service entrance, transformer or generator service is intentionally bonded to the ground conductor at the power source to maintain a nominal voltage of 0 V to ground.

31 DefinitionsGrounding

system (new)

KW We can clear up some things in the revision by adding the language below from the CEC. Add this below the definition of grounding.

Grounding system — all conductors, clamps, ground clips, ground plates or pipes, and ground electrodes by means of which the electrical installation is grounded.

Accepted as follows: Grounding system — all conductors, clamps, ground plates or rods, and grounding electrodes used to ground the electrical installation.

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32 DefinitionsSingle pin

KW Single pin-the hyphen between single and conductor; locking and type; as well as colour and coded should be removed as they are not grammatically correct.

Accept Jan 16/15 (review doc)

33 DefinitionsUtility

Sources

KW Utility Sources- suggest rewrite to “Utility Source(s)” Accept Jan 16/15

34 DefinitionsMultiple

Connection Device

KW Special Terminology-Multiple Connection Device-I am unsure what this device is, but it sounds rather sketchy, and dangerous. Need an explanation of this device, and how it works.

Accept: relocate from special terminology to definitions. Follow multi-connection device with "Special Terminology"

35 Administrative

JH "The permit shall be prominently displayed in an area Accessible to the AHJ in the vicinity of the central power distribution point.”

This should be changed to: "The permit shall be prominently displayed on site in an area accessible to the AHJ."

The reason is that it is common for they’re to be more than one power distribution point. Common practice in British Columbia is that the Lighting Trailer or truck for film & Television productions are where the permits are stored. Availability for the AHJ on site Is the important factor, not a specific place.

Reject Jan 16/15 Comment withdrawn

36 Administrative

SB "The permit shall be prominently displayed in an area Accessible to the AHJ in the vicinity of the central power distribution point.”

This should be changed to: "The permit shall be prominently displayed on site in an area accessible to the AHJ."

The reason is that it is common for they’re to be more than one power distribution point. Common practice in British Columbia is that the Lighting Trailer or truck for film & Television productions are where the permits are stored. Availability for the AHJ on site Is the important factor, not a specific place.


37 Administrative

KW It seems to me that the second paragraph of the section needs revision. If one has several power sources on one site, it becomes onerous to have multiple copies attached to each power source, or genset. The AHJ will know if a permit has, or has not, been filed, so one can have a single copy in a safe, accessible


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place; the lighting truck on a film set would suffice. Suggest revision to the second paragraph to read as the following text:

“The permit shall be kept in an area that is easily accessible, on site, to present to the AHJ should he request it. The permit should be stored in a place that will protect it from environmental destruction.”

38 Administrative

RH Administrative - "The permit shall be prominently displayed in an area accessible to the AHJ in the vicinity of the central power distribution point." This should be changed to:"The permit shall be prominently displayed on site in an area accessible to the AHJ." The reason is that it is common for there to be more than one power distribution point. Common practice in British Columbia is that the Lighting Trailer or truck for film & television productions are where the permits are stored. Availability for the AHJ on site is the important factor, not a specific place.


39 Administrative

RS Administrative Section referencing where the permit is displayed. Here in BC, there is often be more than one power distribution point on one set. The availability for the AHJ to access it is an important factor and the AHJ requests that it be available in a central location, usually the Lighting Truck or Trailer where it is properly protected from the elements and easily available.


40 1.1 KW suggest rewrite to: 1.1 Electrical equipment used in electrical in all installations shall be approved…..

Accept and reword as follows: 1.1 Electrical equipment used in all installations shall be approved…..

41 1.2 KW suggest rewrite to: 1.2 All electrical equipment (including cord sets) shall be approved, by and bear the mark of approval, or certification of from:

accept as follows: 1.2 All electrical equipment (including cord sets) shall be approved, and bear the mark of approval, or certification from:b) a special inspection (field approval) agency under SPE1000; and(c) such labels shall be affixed to the electrical equipment.

42 1.2 KW 1.2 Single pin connectors should be renumbered to 1.3, and the word pin should not be capitalized.

accept: Single-pin connectors shall only be used on approved single conductor cables as per Table 11 and section 66 of the CE Code.

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43 2.2.6 KW The language regarding single setscrews, while the safer option should be rewritten as the CEC does allow their use in cam loc style connectors. Suggest the following rewrite:

“Single pole conductors should be terminated only to single conductor cable via crimp or double setscrew, as per the manufacturer’s instructions. Although allowed by the CEC, single setscrew connectors do not create as secure a connection, and should not be used, if at all possible.”

“Single pole connectors should be terminated only to single conductor cable via crimp or double setscrew, as per manufacturer’s instructions. Although allowed by some other standards, single setscrew connectors do not create as secure a connection, and should not be used, if at all possible.”

44 3.1 KW suggest rewrite to better reflect actual on the ground practices. Snow and ice do not present the same issues as submersion in water, and require other methods.

“3.1 Appropriate methods should be taken to when standing water; snow; or icy conditions are present. If standing water is present connectors should be elevated to not allow submersion.”

Accept as follows: “3.1 Where water, snow, or icy conditions are present, appropriate methods shall be used to prevent submersion of electrical equipment.”

45 3.1 JH "Appropriate methods should be taken when standing water, snow, or Icy conditions are present. If these conditions are present, all cable connections should Be elevated to not allow submersion or exposure to these conditions.”

This should be changed to: "3.1 Appropriate methods and caution should be taken when pooling water, snow, or icy Conditions are present. If pooling water is present, all cable connections should be Elevated to not allow submersion.”

The reason for this is that the original statement would cause onerous working Conditions that are not warranted. While pooling water is an active hazard, snow and ice In and of them do not present the same level of hazard.

Reject Duplicate of 44

46 3.1 RH "Appropriate methods should be taken when standing water, snow, or icy conditions are present. If these conditions are present, all cable connections should be elevated to not allow submersion or exposure to these conditions."

This should be changed to: "3.1 Appropriate methods and caution should be taken when pooling water, snow, or icy conditions are present. If pooling water is present, all cable connections should


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be elevated to not allow submersion."

The reason for this is that the original statement would cause onerous working conditions that are not warranted. While pooling water is an active hazard, snow and ice in and of themselves do not present the same level of hazard.

47 3.1 SB "Appropriate methods should be taken when standing water, snow, or Icy conditions are present. If these conditions are present, all cable connections should Be elevated to not allow submersion or exposure to these conditions.”

This should be changed to: "3.1 Appropriate methods and caution should be taken when pooling water, snow, or icy Conditions are present. If pooling water is present, all cable connections should be Elevated to not allow submersion.”

The reason for this is that the original statement would cause onerous working Conditions that are not warranted. While pooling water is an active hazard, snow and ice In and of them do not present the same level of hazard.


48 3.1 PK There is a difference in the hazard levels of water, snow and ice. As such, standing water is really the only active danger to interconnections. Current practice is to elevate and isolate from pooling water, but to allow contact with ice and snow. I concur that all three are hazards and must be monitored, however the methods appropriate for dealing with these dangers are different.


49 3.1 RS Section 3.1 referencing elevating cable connections. This statement would not have a noticeable improvement in safety and would be excessive and onerous for little gain. Snow and ice doesn't present the same level of hazard as standing water.

Change to read: 3.1 When standing water, snow and icy conditions are

present, appropriate methods and caution should be taken. When standing water is or could become present, cable connections should be elevated to not allow submersion


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This would then refer specifically to water being present but caution to if the snow could melt as an example.

50 3.5 JH "Feeder cables shall not penetrate walls, floors, or ceilings, or be run through Doors or traffic areas without additional protection from mechanical damage. (CE Code 4-012 (3))."

This should be changed to: "3.5 Feeder cables shall not penetrate walls, floors, or ceilings, or be run through doors or traffic areas (CE Code 4-012 (3)).”

The last part of the original statement "without additional protection from mechanical damage" is not in the code. While it is a common practice and I believe it should be in Section 66, it is not there currently and is in direct contravention to the code as it is currently written. Exceptions to the CEC cannot be made in this document.


51 3.5 RH "Feeder cables shall not penetrate walls, floors, or ceilings, or be run through doors or traffic areas without additional protection from mechanical damage. (CE Code 4-012 (3))."

This should be changed to: "3.5 Feeder cables shall not penetrate walls, floors, or ceilings, or be run through doors or traffic areas (CE Code 4-012 (3)).”

The last part of the original statement "without additional protection from mechanical damage" is not in the code. While it is a common practice and I believe it should be in Section 66, it is not there currently and is in direct contravention to the code as it is currently written. Exceptions to the CEC cannot be made in this document.

Accept as follows:"Feeder cables shall not penetrate walls, floors, windows, or ceilings, or be run through doors or traffic areas without additional protection from mechanical damage."

52 3.5 KW RECOMMEND removal of this section. Allow the worker to sort this out with his/her local AHJ.

In the last round of public review I stated that this should be removed, as feeder cables are not allowed to do this as per the CEC. Although the response was correct that the CEC does not deal with cable ports; which I too discussed in my review comments, I still feel this should be struck, as the new language


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is not allowed by the CEC any more than the original language.

53 4.1 JH “4.1 Feeder cable assembliesFeeder cable assemblies shall consist of lengths of cable with a male connector on one end and a female connector on the other end, and configured as(a) a single conductor;!(b) a two-conductor bundle (red, blue);!(c) a three-conductor bundle (green, white, black or red) or (green, red, black/blue);(d) a four-conductor bundle (green, white, red, blue); or(e) a five-conductor bundle (green, white, red, black, blue).”

This clearly contradicts the code.

"4-038 Colour of conductors(3) Where colour-coded circuits are required, the following colour coding shall be used, except in the case of service entrance cable and when Rules 4-032, 4-034, and 6-308 may modify these requirements:(a) 1-phase ac or dc (2-wire) — 1 black and 1 red or 1 black and 1 white*† (where identified conductor is required);(b) 1-phase ac or dc (3-wire) — 1 black, 1 red, and 1 white*†; and(c) 3-phase ac — 1 red (phase A), 1 black (phase B), 1 blue (phase C), and 1 white* (where neutral is required).*Or grey†Or white with coloured stripe (see Rule 4-030)"

By this code rule Blue can only be used to identify Phase C. This rule needs to be amended to reflect that requirement. It should read;

"Feeder cable assemblies shall consist of lengths of cable with a male connector on one end and a female connector on the other end, and configured as(a) a single conductor;!(b) a two-conductor bundle (black, white) or (red, black)(c) a three-conductor bundle (green, white, black) or (green, red, black); (d) a four-conductor bundle (green, white, red, black); or


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(e) a five-conductor bundle (green, white, red, black, blue)."

54 4.1 RH “4.1 Feeder cable assembliesFeeder cable assemblies shall consist of lengths of cable with a male connector on one end and a female connector on the other end, and configured as(a) a single conductor;(b) a two-conductor bundle (red, blue);(c) a three-conductor bundle (green, white, black or red) or (green, red, black/blue); (d) a four-conductor bundle (green, white, red, blue); or(e) a five-conductor bundle (green, white, red, black, blue).” This clearly contradicts the code."4-038 Colour of conductors (3) Where colour-coded circuits are required, the following colour coding shall be used, except in the case ofservice entrance cable and when Rules 4-032, 4-034, and 6-308 may modify these requirements:(a) 1-phase ac or dc (2-wire) — 1 black and 1 red or 1 black and 1 white*† (where identified conductoris required);(b) 1-phase ac or dc (3-wire) — 1 black, 1 red, and 1 white*†; and(c) 3-phase ac — 1 red (phase A), 1 black (phase B), 1 blue (phase C), and 1 white* (where neutral isrequired).*Or grey†Or white with coloured stripe (see Rule 4-030)"

By this code rule Blue can only be used to identify Phase C. This rule needs to be amended to reflect that requirement. It should read;"Feeder cable assemblies shall consist of lengths of cable with a male connector on one end and a female connector on the other end, and configured as(a) a single conductor;(b) a two-conductor bundle (black, white) or (red, black)(c) a three-conductor bundle (green, white, black) or (green, red, black); (d) a four-conductor bundle (green, white, red, black); or

Accept with the "b" modification as follows:(b) a two-conductor bundle for two wire DC (black, white) or (red, black)

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(e) a five-conductor bundle (green, white, red, black, blue)."

55 4.1 KW This entire section runs counter to the CEC section 4-038, and should be rewritten to the following:

“4.1 Feeder cable assembliesFeeder cable assembles shall consist of lengths of cable with a male connector on one end and a female connector on the other, and configured as follows:

(a) a single conductor(b) a two conductor bundle (black, white) or (red,

black)(c) a three conductor bundle (green, white, black) or

(green, red, black)(d) a four conductor bundle (green, white, red, black)

or(e) a five conductor bundle (green, white, red, black,

blue)”

I realize that what is written is the system used in Toronto and other jurisdictions in Ontario, but as it runs counter to the CEC, it cannot be a system that is both written into this document, and expected to be put into use in other jurisdictions. This practice does not occur in all jurisdictions in Canada, as it is not the language of the CEC.

Reject duplicate of 54

56 4.7.3 JH “4.7.3 Load tails shall be installed and removed by qualified personnel.”

This should be changed to read: "4.7.3 Load tails shall be installed and removed only by qualified and authorized personnel.”

The reason for this is that only an authorized, as well as qualified, person should be performing this work as permission from the venue is required. Both are required.


57 4.7.3 RH “4.7.3 Load tails shall be installed and removed by qualified personnel.”

This should be changed to read: “ 4.7.3 Load tails shall be

Accepted as follows:“4.7.3 Load tails shall be installed and removed by qualified, authorized, and where required appropriately certified personnel.”

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installed and removed only by qualified and authorized personnel.”


58 4.7.3 SB “4.7.3 Load tails shall be installed and removed by qualified personnel.”

This should be changed to read: “ 4.7.3 Load tails shall be installed and removed only by qualified and authorized personnel.”



59 4.7.3 RS Section 4.7.3 referencing Load tails being installed/removed by qualified personnel.

Add the word "Authorized" as permission from the company, rental or owner or venue will be required in addition to just qualified. The venue may have some specific reason or requirement for this to be done a certain way


60 4.7.3 KW suggest rewrite to the following:

“4.7.3 Load tails shall be installed and removed by certified qualified and authourized personnel.”

As one is doing this in an existing facility, one needs permission from the facility, thus being authourized, to do the work, plus only qualified personnel can do the work.


61 5.3 JH “5.3 Neutral conductors - A neutral (identified conductor) supplying phase control dimmers may be provided with a higher ampacity than that of the circuit.”

This should be deleted. In the BSR E1.51 First Public Review Comments with Resolutions the statement is made in rejection to a previous comment “Reject: doubling the neutral to dimmers is


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an industry standard practice to deal with harmonics.” This may be the mis-practice of some individuals in Canada, but that does not mean that it is permissible. This is clearly illegal and against the CEC;

“66-456 Single-conductor cable connections 3) Single-conductor cables shall not be connected in parallel except as a means of reducing voltage drop, and cables so connected shall have overcurrent protection sized to protect the cable having the smallest ampacity as though it were used alone”.

This must be deleted for use in Canada, as this document cannot supersede the CEC.

62 5.3 RH “5.3 Neutral conductors - A neutral (identified conductor) supplying phase control dimmers may be provided with a higher ampacity than that of the circuit.”

This should be deleted. In the BSR E1.51 First Public Review Comments with Resolutions the statement is made in rejection to a previous comment “Reject: doubling the neutral to dimmers is an industry standard practice to deal with harmonics.” This may be the mis-practice of some individuals in Canada, but that does not mean that it is permissible. This is clearly illegal and against the CEC;



Accept: Agreed to delete 5.3 from the standard

63 5.3 SB “5.3 Neutral conductors - A neutral (identified conductor) supplying phase control dimmers may be provided with a higher ampacity than that of the circuit.”

This should be deleted. In the BSR E1.51 First Public Review Comments with Resolutions the statement is made in rejection to

Rejected Duplication see 62

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a previous comment “Reject: doubling the neutral to dimmers is an industry standard practice to deal with harmonics.” This may be the mis-practice of some individuals in Canada, but that does not mean that it is permissible. This is clearly illegal and against the CEC;



64 5.3 PK It is not permissible in the CEC to increase the ampacity of the neutral conductor. This should be deleted.


65 5.3 RS Section 5.3 Neutral connectors

Delete. This is illegal and against the CEC in Canada as per section 66-456.


66 5.3 KW RECOMMEND-removal of this section as it is not an industry standard to parrallel neutral conductors, or add a larger neutral conductor in the load tail sets used for power connections for dimmer systems and portable power distribution devices.

I say this, as there are 2 things in play with this concept; the first being using a larger conductor than the one necessary, and how to do this with a system that draws a full 400A of power.

1) As there is no cable larger than 4/0 available to the entertainment technician to connect to the power source, and as we cannot parallel run any cables other than for line loss, there is no way that this is an “industry standard practice”. Yes, one could use a larger neutral conductor for a 24x2.4k dimmer pack, which requires nothing larger than a #2 conductor, but what does it solve? The probability of actually over amping the cable via imbalance of load, or harmonics, is small, if at all given the nature of the power consumed. Plus it creates a system in which the


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vendor is now needed to create more products than is necessary.

2) When using a device that has the potential to draw a full 400A, there is no way to oversize the cable other than by parallel running conductors, which is expressly forbidden by CEC section 66-456 (3), which is also stated by section 6.4.4 of this very document, which states “Parrallel conductors shall only be used for reducing voltage drop. (CE Code 66-456(3))”

Given we cannot, by law, parallel run conductors for anything but line loss, there is no way this procedure can be accomplished for 90% of the work done in the entertainment industry.

I have spoken to all the major national lighting vendors in Canada, and not one of them sends out a dropdown set (load tails) with their dimmers, or power distribution racks that has 2 neutral conductors; one said that is against the Code, so I cannot do that. None of their dimming, or power distros have more than one neutral conductor on them; the only exception is on their ETC 96x2.4k “Broadway” dimmer racks.

I made some site visits to local venues in my jurisdiction BC, and none of the venues, theatre and film, in Vancouver have multiple neutral conductors; and if they do, they are bussed to the same conductor feeder cable that is no larger in ampacity capability than the 4/0 conductor on most dimming racks, and power distros.

As it stands right now, I am unsure what industry practices this in Canada, for I have spoken to no entertainment lighting, or power technician in the Canadian entertainment industry that follows this practice.

As well, the Editorial note: “A neutral (identified conductor) supplying phase control dimmers may be provided with a higher ampacity than that of the circuit” runs counter to the CEC and section 66-456 (3) no matter how you try and phrase it, as we have no higher ampacity on offer other than that of 4/0 in temporary installations.

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67 6.2 KW RECOMMEND-removal of all of section 6.2 Rejected. This is in 2015 CE Code

68 6.2.1 TG Please reexamine your new rule about not having more then one tee per connection on a tee tower. We , at Iatse lighting dept. , local 891 , Vancouver BC think things are just perfect the way they are. Multiple tees on T - towers are fine ( film industry ).

Rejected Duplication of 67

69 6.2.1 RS Section 6.2.1 Tee connections. This is onerous and confining with no safety gain. This section should be deleted


70 6.2.1 PK The limitation of one tapping tee per conductor at any point in the system is unworkable in the current practice in Vancouver. There is no enhanced safety by this restriction, and it is unnecessary. This clause should be deleted.


71 6.2.1 JH “6.2.1 No more than one tapping or parallel tee per conductor shall be used at any one point in a power distribution system. Any distribution splitting or combining devices requiring more than two load connections per conductor shall use a single approved multiple connection device at that point.”

This is an onerous condition that is being imposed for no safety gain. In my experience working in power configurations in BC, this has never been a safety issue. It should be deleted.


72 6.2.1 RH “6.2.1 No more than one tapping or parallel tee per conductor shall be used at any one point in a power distribution system.

Any distribution splitting or combining devices requiring more than two load connections per conductor shall use a single approved multiple connection device at that point.”


Rejected in 2015 CE Code

73 6.2.1 SB “6.2.1 No more than one tapping or parallel tee per conductor shall be used at any one point in a power distribution system.

Any distribution splitting or combining devices requiring more than two load connections per conductor shall use a single approved multiple connection device at that point.”


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74 6.2.1 KW I do not accept that this section makes things safer than the CEC does, and as at this is not in the CEC at this time, although it is apparently going to be added to the new 2015 code. Until that time this section needs to be removed.


75 6.2.2 JH “6.2.2 Tap points used in a single conductor power distribution system, which go from a higher ampacity conductor set to a lower ampacity conductor set and extend beyond 3 meters in total length (distance being calculated from the tap point to the downstream device bus), shall have an appropriately sized overcurrent protection at the tap point. (CE Code 14-100(b)(ii)).

"Single conductor jumper sets, of no less than #2 AWG – PPC, may be utilized to facilitate connection of distribution devices to the tap point, without the addition of overcurrent protection, providing that their length, combined with any supply tail or lead on the downstream device does not exceed the 3 meter total.”

The second paragraph of this clause makes a specific allowance that is not in the code. With no definition of distribution device this creates an ambiguous clause. As such, it must be deleted, or restated to come within compliance of not just the spirit, but the letter of the code.


76 6.2.2 RH “6.2.2 Tap points used in a single conductor power distribution system, which go from a higher ampacity conductor set to a lower ampacity conductor set and extend beyond 3 meters in total length (distance being calculated from the tap point to the downstream device bus), shall have an appropriately sized overcurrent protection at the tap point. (CE Code 14-100(b)(ii)).

Single conductor jumper sets, of no less than #2 AWG – PPC, may be utilized to facilitate connection of distribution devices to the tap point, without the addition of overcurrent protection, providing that their length, combined with any supply tail or lead on the downstream device does not exceed the 3 meter total.”

Accept as follows: “6.2.2 Tap points used in a single conductor power distribution system, which go from a higher ampacity conductor set to a lower ampacity conductor set and extend beyond 3 meters in total length, shall have an appropriately sized overcurrent protective device at the tap point.

Accepted Jan 16/15

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77 6.2.2 SB “6.2.2 Tap points used in a single conductor power distribution system, which go from a higher ampacity conductor set to a lower ampacity conductor set and extend beyond 3 meters in total length (distance being calculated from the tap point to the downstream device bus), shall have an appropriately sized overcurrent protection at the tap point. (CE Code 14-100(b)(ii)).

Single conductor jumper sets, of no less than #2 AWG – PPC, may be utilized to facilitate connection of distribution devices to the tap point, without the addition of overcurrent protection, providing that their length, combined with any supply tail or lead on the downstream device does not exceed the 3 meter total.”



78 6.2.2 RS Section 6.2.2 – second paragraph, makes a specific allowance that is not in compliance with the CEC. It must be deleted or be made compliant to the code.


79 6.2.2 KW As with 6.2.1, I do not accept your rejection as the CEC section quoted, 14-100 (b) is an “and” section, not an “or” section, and as such cannot be used in any way but as a whole. One needs to meet all the criteria of the section, and not cherry pick the pieces one wishes to use. Plus, this section deals with gutter box installations, and that is not what we are doing in the entertainment industry. I am flummoxed by the language in the resolution to my prior comments, what exactly is meant by:

“The spirit of the rule is the point of consideration. There is no valid safe argument to take exposed unrestrained cable,


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(which is accessible to entertainment professionals, trained or otherwise), and expose it to conditions beyond which cable that is “restrained” in one form or another is exposed to.”

The language is the language it has no spirit. All cable that is a downsize from it’s source cable systems needs an overcurrent protection device unless there is an overcurrent device built into the equipment that is connected. This would preclude devices such as 6x60A boxes; small dimmer packs; and any equipment that does not have an overcurrent device installed; being connected to a larger cable feeder system without a current protection device in place before the equipment.

80 6.4.1 JH “6.4.1 Voltage Any power distribution system, utilizing single pin connectors, operating at any voltage above 150 volts to ground, shall: a)have all inline connectors made inaccessible by enclosing the joint or connector(s) in a secured, nonconductive box or enclosure;”

My objection to this is that it creates an unnecessary and onerous working condition. I frequently run 600V distribution systems. Our common practice is to isolate the cable from the general public with use of delineators to the cable, secure the joints with electrical tape and further identifying each conductor with markings to indicate the voltage. We have never had a problem with this level of security. I would reword this to: “a( have all inline connectors made secure by enclosing the joint of the connectors with the identifying phase tape with marking the voltage on the connection, and reasonable effort shall be made to prevent public access to the cable”


81 6.4.1 RH “6.4.1 Voltage Any power distribution system, utilizing single pin connectors, operating at any voltage above 150 volts to ground, shall: a)have all inline connectors made inaccessible by enclosing the joint or connector(s) in a secured, non-conductive box or enclosure;”

My objection to this is that it creates an unnecessary and onerous working condition. I frequently run 600V distribution systems. Our common practice is to isolate the cable from the general public with use of delineators to the cable, secure the joints with

Rejected in 2015 CE Code

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electrical tape and further identifying each conductor with markings to indicate the voltage. We have never had a problem with this level of security. I would reword this to: a( have all inline connectors made secure by enclosing the joint of the connectors with the identifying phase tape with marking the voltage on the connection, and reasonable effort shall be made to prevent public access to the cable”

82 6.4.1 SB “6.4.1 Voltage Any power distribution system, utilizing single pin connectors, operating at any voltage above 150 volts to ground, shall: a)have all inline connectors made inaccessible by enclosing the joint or connector(s) in a secured, non-conductive box or enclosure;”

My objection to this is that it creates an unnecessary and onerous working condition. I frequently run 600V distribution systems. Our common practice is to isolate the cable from the general public with use of delineators to the cable, secure the joints with electrical tape and further identifying each conductor with markings to indicate the voltage. We have never had a problem with this level of security. I would reword this to: a( have all inline connectors made secure by enclosing the joint of the connectors with the identifying phase tape with marking the voltage on the connection, and reasonable effort shall be made to prevent public access to the cable”


83 6.4.1 PK The locking off of all 600V inline connections creates an undue burden to the creation and maintenance of temporary 600V systems. Each connection can usually be isolated from the general public and can be made inaccessible in other methods than a lockbox. This clause does not describe a more safe method for the creation of these systems. This clause should read something along the lines of: Reasonable effort shall be made to ensure all 600V inline connectors are inaccessible to the general public. Connectors shall be enclosed with the appropriate phase tape and identified as to the appropriate voltage.


84 6.4.1 RS Section 6.4.1 Any power distribution system, etc. security and marking joints.This is onerous and excessive as in general this system in our industry, is usually temporary and is NOT accessible to the public.


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Reword it to something like your wording of Section 6.4.2.1 AC. See below for my suggestion:

A) Have all inline connectors made secure by enclosing the joint of the connectors with identifying phase tape and marking the connections with the voltage on the connectors and reasonable effort shall be made to prevent public access to the cable

85 6.4.2.2.1 JH "6.4.2.2.1 DC (direct current) shall be identified by red and blue for the "hots", and white for the "common." It shall be permissible to use red and black for a 120 VDC system.”

This contravenes the CEC “4-038 Colour of conductors (3) Where colour-coded circuits are required, the following colour coding shall be used, except in the case of service entrance cable and when Rules 4-032, 4-034, and 6-308 may modify these requirements:.(a) 1-phase ac or dc (2-wire) — 1 black and 1 red or 1 black and 1 white*† (where identified conductor is required);(b) 1-phase ac or dc (3-wire) — 1 black, 1 red, and 1 white*†; “

Blue is not permissible for use, as previously noted above. This must be amended appropriately.


86 6.4.2.2.1 RH “6.4.2.2.1 DC (direct current) shall be identified by red and blue for the "hots", and white for the "common." It shall be permissible to use red and black for a 120 VDC system.”This contravenes the CEC “4-038 Colour of conductors (3) Where colour-coded circuits are required, the following colour coding shall be used, except in the case of service entrance cable and when Rules 4-032, 4-034, and 6-308 may modify these requirements:

(a) 1-phase ac or dc (2-wire) — 1 black and 1 red or 1 black and 1 white*† (where identified conductor is required); (b) 1-phase ac or dc (3-wire) — 1 black, 1 red, and 1 white*†; “Blue is not permissible for use, as previously noted above. This must be amended appropriately.

Accept as follows:“6.4.2.2.1 DC (direct current) It shall be permissible to use red and black for a 120 VDC system.”

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87 6.4.2.2.1 SB “6.4.2.2.1 DC (direct current) shall be identified by red and blue for the "hots", and white for the "common." It shall be permissible to use red and black for a 120 VDC system.”This contravenes the CEC “4-038 Colour of conductors (3) Where colour-coded circuits are required, the following colour coding shall be used, except in the case of service entrance cable and when Rules 4-032, 4-034, and 6-308 may modify these requirements:

(a) 1-phase ac or dc (2-wire) — 1 black and 1 red or 1 black and 1 white*† (where identified conductor is required); (b) 1-phase ac or dc (3-wire) — 1 black, 1 red, and 1 white*†; “Blue is not permissible for use, as previously noted above. This must be amended appropriately.


88 6.4.2.2.1 PK The color coding of all cables is prescribed in the CEC 4-038. Rejected Duplication of 86

89 6.4.2.2.1 RS Section 6.4.2.2.1 is in contravention to the CEC Section 4-038 regarding colour coded circuits. Blue is not permissible for use


90 6.4.2.2.3 JH "6.4.2.2.3 All DC connections in a portable power distribution system shall be clearly labeled DC."

6.4.2.2.3 is an excellent example in this document where the word shall should be substituted for the word should. “Shall” should be used when referring to code requirements, should “should” be used in this document where not required by the CEC, but is a recommended practice by this body. To do otherwise is creates confusion about the voluntary nature of this document, since nowhere in this document is this noted.


91 6.4.2.2.3 RH “6.4.2.2.3 All DC connections in a portable power distribution system shall be clearly labeled DC.


Reject Comment:discussed and agreed that it is a requirement therefore, "shall"

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92 6.4.2.2.3 SB “6.4.2.2.3 All DC connections in a portable power distribution system shall be clearly labeled DC.



93 6.4.2.2.3 RS Section 6.4.2.2.3 – This is a voluntary document and because it is not Code, the word "should" should be used here rather than "shall." There are other places where the word "shall" is used possibly incorrectly but this specific place pops out as not specifically being required by the CEC


94 6.5 JH "When designing the system, provision shall be made for a spare disconnect(s) (generaluse or isolation switch) to allow for expansion while the system is energized.”

This clause once again misuses the word shall instead of should. Also it is redundant to 7.4, and should appear only once in the document. If adopted it should read like this: “When designing the system, where alteration or expansion is foreseen and desired, each system should have installed a disconnect (general-use or isolation switch) to allow for expansion while the system is energized.”

Accept in principle. We adopt the revised wording from the 2015 CEC.

Leave as "shall." Per 2-304 (1) and Appendix B of the 2015 CEC, live work is to be avoided. Telling the reader to provide for the safe expansion of the system in both the planning and the installation of the system promotes this policy.

95 6.5 RH "When designing the system, provision shall be made for a spare disconnect(s) (general-use or isolation switch) to allow for expansion while the system is energized.”


Accept in principle. We adopt the revised wording from the 2015 CEC.


96 6.5 SB "When designing the system, provision shall be made for a spare Accept in principle. We adopt the revised wording

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disconnect(s) (general-use or isolation switch) to allow for expansion while the system is energized.”


from the 2015 CEC.


97 6.5 RS Section 6.5 – again "shall" is used where "should" is appropriate. Accept in principle. We adopt the revised wording from the 2015 CEC.


98 7.1.4 KW 7.1.4 Excess length-the wording of this is rather onerous, and should have the language added below to make it a bit more palatable:

7.1.4 Excess lengthExcess runs should be avoided or eliminated whenever possible by the use of jumpers or (25 feet foot ) cable sets.

Accept in principle. Change to read, "Excess runs should be avoided whenever possible."

99 7.1.5.1 through 7.1.5.2.1

JH “7.1.5.1 Crossing walkways and paths "It shall be permissible to cross walkways or paths where there is no vehicular traffic and the cable(s) shall be protected by use of cable mats manufactured for the purpose and arranged so as not to present a tripping hazard."7.1.5.2 Vehicular traffic"7.1.5.2.1 Cables shall not be subjected to vehicular traffic. When vehicular traffic must travel over cables, cable mats of conductive or non-conductive material, rated for the weight of the vehicle and manufactured for the purpose, shall be used to protect the cables.”

Once again this section from 7.1.5.1 to 7.1.5.2.1 creates the


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impression that these are standards that must be adhered to. The CEC states that “66-450 Single-conductor cables Single conductor cables shall be permitted in sizes No. 4AWG and larger provided that they are (c) covered or guarded so as not to present a tripping hazard in pedestrian walkways or roadways.”

This not only specifically allows cable mats in roadways, it make no prohibition on the crossing of vehicles. This prohibition is unworkable and onerous to our industry. Either these sections should be deleted, or the relevant code should be cited. I do think that it would be acceptable to state that “reasonable care should be taken when vehicular traffic is present, and means to control that traffic should be employed when necessary”.

100 7.1.5.1 through 7.1.5.2.1

RH “7.1.5.1 Crossing walkways and paths It shall be permissible to cross walkways or paths where there is no vehicular traffic and the cable(s) shall be protected by use of cable mats manufactured for the purpose and arranged so as not to present a tripping hazard."7.1.5.2 Vehicular traffic"7.1.5.2.1 Cables shall not be subjected to vehicular traffic. When vehicular traffic must travel over cables, cable mats of conductive or non-conductive material, rated for the weight of the vehicle and manufactured for the purpose, shall be used to protect the cables.”

Once again this section from 7.1.5.1 to 7.1.5.2.1 creates the impression that these are standards that must be adhered to. The CEC states that “66-450 Single-conductor cables Single conductor cables shall be permitted in sizes No. 4AWG and larger provided that they are (c) covered or guarded so as not to present a tripping hazard in pedestrian walkways or roadways.”


Reject. Existing wording represents safe practise

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101 7.1.5.1 through 7.1.5.2.1

SB “7.1.5.1 Crossing walkways and paths It shall be permissible to cross walkways or paths where there is no vehicular traffic and the cable(s) shall be protected by use of cable mats manufactured for the purpose and arranged so as not to present a tripping hazard."7.1.5.2 Vehicular traffic"7.1.5.2.1 Cables shall not be subjected to vehicular traffic. When vehicular traffic must travel over cables, cable mats of conductive or non-conductive material, rated for the weight of the vehicle and manufactured for the purpose, shall be used to protect the cables.”

Once again this section from 7.1.5.1 to 7.1.5.2.1 creates the impression that these are standards that must be adhered to. The CEC states that “66-450 Single-conductor cables Single conductor cables shall be permitted in sizes No. 4AWG and larger provided that they are (c) covered or guarded so as not to present a tripping hazard in pedestrian walkways or roadways.”



102 7.1.5.1 through 7.1.5.2.1

RS Sections 7.1.5.1 to 7.1.5.21 regarding the use of cable mats. This is restrictive and unworkable to put in place standards that would not allow traffic and make it impossible to work on set. The CEC section 66-450 covers this area and supersedes any voluntary standard.


103 7.1.5.2.2 KW I am unsure of any instance when cable protectors should be made of a conductible material, and I feel this clause should be removed entirely to ensure someone does not think it is a good idea. If they are foolish enough to make a protector out of metal, they will know what to do.


104 7.1.5.2.4 JH “7.1.5.2.4 Cables elevated over vehicular traffic shall be permissible. When elevated, the lowest point of the sag of the


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cable shall be 5.5 metres above grade. Signs shall be posted informing traffic of the maximum safe height.”

This is reinventing the wheel. Why not just quote the CEC? It states “66-100 Supporting of conductors . (3) Overhead conductors shall have a vertical clearance to finished grade of not less than the following:(a) across highways, streets, l anes, and alleys: 5.5 m;(b) across areas accessible to vehicles: 5 m; and(c) across areas accessible to pedestrians: 3.5 m. “

105 7.1.5.2.4 RH “7.1.5.2.4 Cables elevated over vehicular traffic shall be permissible.When elevated, the lowest point of the sag of the cable shall be 5.5 metres above grade. Signs shall be posted informing traffic of the maximum safe height.”

This is reinventing the wheel. Why not just quote the CEC? It states“66-100 Supporting of conductors (3) Overhead conductors shall have a vertical clearance to finished grade of not less than the following: (a) across highways, streets, lanes, and alleys: 5.5 m; (b) across areas accessible to vehicles: 5 m; and (c) across areas accessible to pedestrians: 3.5 m. “

Reject. Existing wording should remain.

106 7.1.5.2.4 SB “7.1.5.2.4 Cables elevated over vehicular traffic shall be permissible.When elevated, the lowest point of the sag of the cable shall be 5.5 metres above grade. Signs shall be posted informing traffic of the maximum safe height.”

This is reinventing the wheel. Why not just quote the CEC? It states“66-100 Supporting of conductors (3) Overhead conductors shall have a vertical clearance to finished grade of not less than the following: (a) across highways, streets, lanes, and alleys: 5.5 m; (b) across areas accessible to vehicles: 5 m; and (c) across areas accessible to pedestrians: 3.5 m. “


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107 7.1.5.2.4 RS Section 7.1.5.2.4 covers elevated cables. Just quote the CEC Section 66-100


108 7.1.5.3 JH "When used outdoors, single-pole separable connectors shall not come in contact with damp earth or water.”

This is totally unworkable in British Columbia. We specialize in filming in the rain here. As long as the connectors are appropriately rated for the environmental conditions as per the CEC, there is no problem with damp earth or rain. The hazard of pooling water was already dealt with in 3.1, so this should be deleted.


109 7.1.5.3 RH “When used outdoors, single-pole separable connectors shall not come in contact with damp earth or water.”


Accept in principle. Text to read: “When used outdoors, single-pole separable connectors shall not come in contact with standing or running water.”

110 7.1.5.3 SB “When used outdoors, single-pole separable connectors shall not come in contact with damp earth or water.”



111 7.1.5.3 RS Section 7.1.5.3 is redundant and covered in your earlier Section 3.1 and pooling of water. It is also covered in the appropriate section of the CEC regarding environmental conditions


112 7.2 KW the “&” should be replaced by the word “and” accept title change: Grounding and Bonding

113 7.2.2 I disagree with the resolution to reject the comment from the previous comment review, just because the CEC is silent does not mean one can add any language care to. I recommend the

Reject in 2015 CE Code

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following language revision:

“a) the number of interconnections between the ground electrode, and the ground point of the power source shall be kept to a minimum.”

114 7.3.1 JH “7.3.1 Authorized personnel"Connection and disconnection to a utility power source shall be performed only by authorized personnel."

This should be amended to:“7.3.1 Authorized personnel"Connection and disconnection to a utility power source shall be performed only by authorized, qualified, and where required, certified personnel.”

That should cover all the bases for who is allowed to perform that work.

Reject in 2015 CE Code

115 7.3.1 RH "7.3.1 Authorized personnel"Connection and disconnection to a utility power source shall be performed only by authorized personnel."

This should be amended to: “7.3.1 Authorized personnelConnection and disconnection to a utility power source shall be performed only by authorized, qualified, and where required, certified personnel.”


Accept. Wording shall be: “Connection and disconnection to a utility power source shall be performed by authorized, qualified, and where required, appropriately certified personnel.”

"FPN: Different jurisdictions have different requirements therefore the statement is intended to cover the variables, check with AHJ."

116 7.3.1 SB "7.3.1 Authorized personnel"Connection and disconnection to a utility power source shall be performed only by authorized personnel."

This should be amended to: “7.3.1 Authorized personnelConnection and disconnection to a utility power source shall be performed only by authorized, qualified, and where required, certified personnel.”


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117 7.3.1 RS Section 7.3.1 Authorized personnel – Connection/disconnection to a utility. This is vague because the Utility will have a lot to say about who does this work. Reword to the below:

Connection and disconnection to a utility power source shall be performed only by Authorized, Qualified and where required, Certified personnel


118 7.3.1 KW suggest rewrite to the following as only certified :

Connection and disconnection to a utility power source shall be performed only by certified, qualified and authourized personnel.


119 7.3.3 KW suggest rewrite to clarify personnel qualifications:

When connecting to utility power on existing distribution panels, the qualified, and authorized,

Accept: When connecting to utility power on existing distribution panels, an authorized, qualified, and where required, appropriately certified personnel.

120 7.3.5 JH “7.3.5 Connection and disconnection to distribution equipment "Connection and disconnection to portable power distribution equipment shall be performed only by certified personnel.

"The last connection(s) shall be to the power source and shall be done in a de-energized condition.

"The individual connections shall be made beginning with the bond first, then the neutral (identified conductor), with the phase conductors last.”

This should be amended to read:

“7.3.5 Connection and disconnection to distribution equipment"Connection and disconnection to portable power distribution equipment shall be performed only by qualified personnel. Where possible the last connection(s) shall be to the power source and shall be done in a de-energized condition. The individual connections shall be made beginning with the bond first, then the neutral (identified conductor), with the phase conductors last.”


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The reason for the changes are that the CEC does not require an individual to be certified, only qualified to perform the connections. Also, while it is always preferable to not perform live work, sometimes it is unavoidable. There is nothing in the code that forbids this, and the use of the word shall implies once again that this is a requirement, not a suggestion.

121 7.3.5 RH “7.3.5 Connection and disconnection to distribution equipment"Connection and disconnection to portable power distribution equipment shall be performed only by certified personnel.



This should be amended to read:“7.3.5 Connection and disconnection to distribution equipmentConnection and disconnection to portable power distribution equipment shall be performed only by qualified personnel. Where possible the last connection(s) shall be to the power source and shall be done in a de-energized condition. The individual connections shall be made beginning with the bond first, then the neutral (identified conductor), with the phase conductors last.”


Accept: "Connection and disconnection to portable power distribution equipment shall be performed by authorized, qualified and where required appropriately certified personnel.”

122 7.3.5 SB “7.3.5 Connection and disconnection to distribution equipment"Connection and disconnection to portable power distribution equipment shall be performed only by certified personnel.




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This should be amended to read:“7.3.5 Connection and disconnection to distribution equipmentConnection and disconnection to portable power distribution equipment shall be performed only by qualified personnel. Where possible the last connection(s) shall be to the power source and shall be done in a de-energized condition. The individual connections shall be made beginning with the bond first, then the neutral (identified conductor), with the phase conductors last.”


123 7.3.5 RS Section 7.3.5 regarding connection to distribution equipment. The CEC does not require an individual to be certified only qualified to perform the connection. Nor does it forbid performing work on a live connection and sometimes this is unavoidable. Here is where a voluntary suggestion would be appropriate with the correct use of the word "should." It would also be best if personnel involved be actually certified by the AHJ. See below for my suggestion:

Connection and disconnection to portable power distribution equipment should be performed only by qualified and certified personnel.Where possible the last connection(s) should be made to the power source and should be done in de-energized condition.The individual connections shall be made beginning with the bond first, then the neutral(identified conductor), with the phase conductors last


124 7.3.5 KW This should be rewritten as below:

Connection and disconnection to portable power distribution equipment shall be performed only by certified qualified, and authourized personnel.


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The last connection(s) shall be to the power source, and shall should be done in a de-energized condition whenever possible.

The individual connections shall be made beginning with the bond (ground) first, then neutral (identified conductor), with the followed by the phase conductors last. I suggest these changes as it makes it much clearer as to the personnel who can do the work, and the procedures to follow. The personnel can be qualified, rather than certified, and should be authourized to do the work if it is to a utility source, rather than a genset source.

125 7.4 JH "While laying out the feeder cable, where there is a likelihood of alteration or expansion, each system shall have installed a disconnect (general-use or isolation switch) to allow for expansion while the system is energized.”

This a redundant clause, as 6.5 makes the same point. It should be deleted or amended as previously noted.

Reject. Leave 7.4 intact. The text is in accord with the CEC.

126 7.4 RH “While laying out the feeder cable, where there is a likelihood of alteration or expansion, each system shall have installed a disconnect (general-use or isolation switch) to allow for expansion while the system is energized.”



127 7.4 SB “While laying out the feeder cable, where there is a likelihood of alteration or expansion, each system shall have installed a disconnect (general-use or isolation switch) to allow for expansion while the system is energized.”



128 7.4 RS Section 7.4 is redundant as 6.5 makes the same points. Delete this section.


129 8.1 KW suggest rewrite to the below to properly identify personnel:

The system shall be inspected by a certified, and qualified

accepted as agreed8.1 System InspectionThe system shall be inspected by a qualified and

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person… authorized person to confirm that all distribution equipment is off, that there are no exposed current-carrying components, that the voltage has been checked, and that all circuits are bonded.

130 8.2 JH "Upon completion of the system inspection, the system may be energized only by authorized personnel.”


“8.2 Energizing the System"Upon completion of the system inspection, the system may be energized only by authorized and qualified personnel.”


131 8.2 RH “Upon completion of the system inspection, the system may be energized only by authorized personnel.”


“8.2 Energizing the SystemUpon completion of the system inspection, the system may be energized only by authorized and qualified personnel.”

Accept as follows: “Upon completion of the system inspection, the system may be energized only by authorized, qualified, and where required appropriately certified personnel.”

132 8.2 SB “Upon completion of the system inspection, the system may be energized only by authorized personnel.”


“8.2 Energizing the SystemUpon completion of the system inspection, the system may be energized only by authorized and qualified personnel.”


133 8.2 RS Section 8.1 [sic]– the energizing should be done by authorized and qualified personnel


134 8.2 KW suggest rewrite to the below to properly identify personnel:

Upon completion of the system inspection, the system may be energized only by certified, and authorized personnel.


135 9 JH "Any portable power distribution system or connected equipment shall only be energized when qualified personnel are present.”


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“9 Energized Systems"Any portable power distribution system or connected equipment shall only be energized when qualified and authorized personnel are present.”

136 9 RH “Any portable power distribution system or connected equipment shall only be energized when qualified personnel are present.”


“9 Energized SystemsAny portable power distribution system or connected equipment shall only be energized when qualified and authorized personnel are present.”


137 9 SB “Any portable power distribution system or connected equipment shall only be energized when qualified personnel are present.”


“9 Energized SystemsAny portable power distribution system or connected equipment shall only be energized when qualified and authorized personnel are present.”


138 9 RS Section 9 – similarly use the wording authorized and qualified personnel


139 9 KW suggest rewrite to again properly identify personnel:

Any portable power distribution system, or connected equipment, shall only be energized when qualified, and certified personnel are present.

Accept as revised: Any portable power distribution system, or connected equipment, shall be energized only while qualified, authorized and where required, appropriately certified personnel are present.

140 10 KW To start with de-energization is not a word. Most of the language in this section is good, and all that needs to be rewritten is the headings.

10 Powering down the system

Accept as revised February 9 201510 Powering down the system (de-energizing)

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10.1 Prior to powering down the system 10.2 Powering down the system

141 10.2 KW I do suggest a rewrite of the second paragraph of this section to the following:

Only qualified, and certified personnel shall perform the powering down of a system.

Accept as revised: Only qualified, authorized and where required, appropriately certified personnel shall de-energize the system.

142 11.1 JH "Removal of any of the systems components shall commence only after system de-energization."

For all the reasons stated above (plus some grammatical clarity), this should be amended to read:

“11.1 De-energizing Systems"Where possible, removal of any of the systems components should commence only after systems are de-energized.”


143 11.1 RH “Removal of any of the systems components shall commence only after system de-energization.



Accept as revised: “Removal of any of the systems components shall commence after systems are de-energized"

Reject: "where possible" (constitutes working live) accept the rest.

144 11.1 RS “Removal of any of the systems components shall commence only after system de-energization.




145 11.1 RS Section 11.1 De-energization should reflect previously stated points about the use of "shall" and other grammar issues such as the word "De-energization" is not a proper word. See below:


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11.1 De-energizing a systemWhere possible, removal of any of the system components should commence only after systems are de-energized.

146 11.1 KW See 10 regarding comment on de-energization. This should be rewritten as below:

11.1 Decommissioning

Removal of any of the systems components shall should be done only after the system has been de-enrgized, whenever possible.

I suggest this, as there are times when it is not possible to shut down the system to do the work of removing the installation, there may be a portion that it is necessary to give in a live state.

Accept new heading as revised:"11 Decommissioning" February 9 2015

Reject: this is a “shell” as per 143 and we reject working live.

147 11.2 KW Rewrite as below:

11.2 DisconnectionAfter the system is de-energized, t The connections closest to the power source shall should be disconnected first, whenever possible.

Done for the same reasons listed for 11.1

Reject: would allow working live

148 11.3 KW The words that follow should be added after bond …(grounded) conductor.

Reject: referencing wrong part of the circuit

149 11.4 KW Suggest following rewrite:

Whenever possible, before commencing disconnection of equipment, one should de-energize downstream equipment first, by use of an isolation switch disconnect, to ensure the system is no longer live.

We always need to note, that it is not always possible to de-energize all parts of a system while removing equipment and cable from the system.

Reject: would allow working live

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BSR E1.51 First Public Review Comments with Resolutions

Referenced document:BSR E1.51 - 201x, The Selection, Installation, and Use of Singleconductor Portable Power Feeder Cable Systems for Use at 600 Volts Nominal or Less for the Distribution of Electrical Energy in the Television, Film, Live Performance and Event Industries in Canada (document number EP/2012-7009r2)

ANSI public review period: 18 April through 2 June 2014

Question: Do you recommend that the standards committee accept BSR E1.51-201X (document number EP/2012-7009r2), as an American National Standard, that its requirements are not too lax, too onerous, or too vague, nor that it would unreasonably negatively impact materially affected parties in the entertainment industry? Please indicate "Yes" (accept it), "Yes with comments," or "No with reasons" (don't accept it).

Responses:

Name Representing Yes Yes with comments No with reasons

Chad Croteau CPC Lighting Design (CPCLD) X

Richard Holden PS Production Services Ltd. (PSPS) X

Keith S. Woods I.A.T.S.E. Local 891 (891) X

The following resolutions were approved at the 25 July 2014 Electrical Power Working Group meeting.

Clause Commenter Comment Resolution

Administrative PSPS ADMINISTRATIVE: Permitting is a matter of local regulations and should be left out of a national document. At the most say something along the lines of "Electrical permits and inspections must be obtained in accordance with local regulations".

Rejected Rationale: CEC 2-004 Permit: Electrical con-tractors or others responsible for carrying out the work shall obtain a permit from the inspection department before commencing work with respect to installation, alteration, repair, or extension of any electrical equip-ment.

The permit requirement is clearly spelled out in the CEC

Electrical Power Working Group 1 EP/2014-7011r1


Definitions 891 Definitions:Qualified person: this person is a certified person in the eyes of the code, and should be removed at it is redundant. One could just send the reader back to the earlier "Certified Person".

Reject Rationale: The CEC defines a “qualified per-son. “Certified” is not defined in the code, and certifica-tion is a jurisdictional labour requirement.

CEC Section 0 Qualified person — one familiar with the construction and operation of the apparatus and the hazards involved.

General CPCLD Lastly, there is no mention of any language indicating that system voltage should be read and confirmed prior to energizing a temporary power system. This should be done by qualified personnel only.

Accept: there has been an editorial change made “qualified”, “a qualified person.”The system shall be inspected by a qualified person toconfirm that all distribution equipment is off, that there are no exposed current-carrying components, that the voltage has been checked and that all circuits are bonded.

General CPCLD As a general note, there should also be language indicating that users should refer to the version of the Code that applies in their Province or Territory. For instance, Ontario has supplementary code language that exceeds the requirements set out by the CEC. Inspectors in Ontario expect compliance with the OEC whenever its requirements are more stringent than those in the CEC. A clause reading "personnel involved in the installation of temporary power systems should refer to the electrical codes enforced in the province where the work is being performed".

Rejected, any personnel qualified to do the work should be cognizant of the applicable code in their jurisdiction.

Scope PSPS SCOPE: How is this different from CEC Section 66? It's not beenexplained to me why this document exists and why we need it. Given that 66 exists as part of the Code, is E1.51 even enforceable? As a set electrician, I'd be inclined to ignore E1.51 and just use Section 66 and its associated CEC Sections.

Rejected: ANSI standards are voluntary, and this is intended to provide a more comprehensive approach in terms of industry requirements and practices

2.2.1 PSPS 2.2.1 CERTIFIED: This is redundant. If the cable assembly complies with the requirements of Section 1 "Equipment Approval", the connectors have already been deemed acceptable.

Rejected: this document may not be read in chronological order. This identifies an important requirement.



2.2.6 PSPS 2.2.6 Termination of Conductors to Connectors: While I don't use single set screw camloks myself, the fact remains that they are CSA approved for the application. This document has no authority to overrule that.

Reject. We have found that single set screw connectors are not appropriate for entertainment applications. Long experience in the early days of single-pole connectors proved that they work loose. We cannot in good conscience recommend single-set screw connectors in series 16 and 18 connectors.

We will also add a note to 2.2.6 that states, "For information on series 15, 16, and 18 connectors, see C22.2 No.1691."

3.5 891 3.5 Feeder cables This is a tough one to deal with as we all run cable out of "port" in the wall in sound stages all over the continent. As well, how does one get cable into a building if not through a wall; door; or cable port.

I think the best way to deal with this is to not have it here at all. Crew members are trained in how to do it properly, one hopes, and will know how to discuss this issue with the AHJ.

Reject: this doesn’t refer to “ports” Modification: Feeder cables shall not penetrate walls, floors, or ceilings or be run through doors or traffic areas without additional protection from mechanical damage



3.5 PSPS 3.5 Feeder cables shall not penetrate walls, floors, or ceilings or be run through doors or traffic areas.(CE Code 4-012 (3)): This one's been a problem for quite some time.

Most sound stages and studios here in Vancouver have openings in the walls specifically to allow feeders and dimmer load side cables to be passed through for dimmer shacks, base camps, etc.

This rule leaves the set electrician in an impossible situation. How is he to achieve connections between the outdoor and indoor elements of the system without passing through some sort of wall opening?

While I understand the intent of 4-012, it's impractical to comply in the case of temporary wiring. Wires gotta get from inside to outside and vice versa.

I suggest leaving it out of this document and trying for an exception to 4-012 in Section 66.

Reject: see above.



5.3 PSPS 5.3 Neutral conductors: This is also a problem. Take the case of a portable dimmer rack being fed at 400A 3phase: Given that we are unable to double up conductors for ampacity (Rule 66-456 (3)) and the largest commonly available size of PPC cable is 4/0 with an ampacity of 405A per Table 12A, how do you propose we achieve an ampacity of 800A on the neutral? Once again, you leave the set electrician in an impossible situation. I'm not sure of a solution to this one as I fully understand the theoretical possibility of harmonic overloading on the neutral. However, we've always just used a single 4/0 neutral on those racks and never had a problem.

Reject: doubling the neutral to dimmers is an industry standard practice to deal with harmonics.Editorial: A neutral (identified conductor) supplying phase control dimmers may be provided with a higher ampacity than that of the circuit.

6.2 891 6.2 This whole sections needs to be deleted from the document. Reject: new addition to the 2015 edition of the CEC.



6.2.1 891 6.2.1 This exceeds the Code, and as such should be removed from the document. There is nowhere in the Code where one is told to do this, and it is an onerous practice for crew on the ground on film sets and such like. All the Code states 66-456 [4] is:

(4) Tapping tees, paralleling tees, or rigid turnarounds shall(a) not be directly connected to any single-pin plug or connector rigidly housed or mounted in a multiple connection device;(b) not be directly connected to a panel mount inlet or outlet or toa multiple connection device with a cable less than 2 n in length; and(c) be arranged so that no mechanical strain is imposed on the connection.

As one can see, there is no mention that one must use a different connector device if one needs to connect more than onetapping tee. A multiple connection device is, referred to as a "Tapping Block", or "Crowsfoot Tower" in my jurisdiction. A "Crowsfoot Tower" being a device made up of 5 stacked crowsfoot, threefer, tees.

Reject: the code is a minimum standard and this rule makes the work safer. Further this is a new addition to the 2015 edition of the CEC.



6.2.2 891 6.2.2 This section is a misreading of the code. Section 14-1,00 (b) states:

(b) where the smaller conductor .(i) has an ampacity not less than the combined cornputed loads of the circuits supplied by the smaller conductor and not less than the ampere rating of the switchboard, panelboard, or controldevice supplied by the smaller conductor;(ii) is not over 3 m long;(iii) does not extend beyond the switchboard, panelboard, or control device that it supplies; and(iv) is enclosed in non-ventilated raceways, armoured cable. or metal-sheathed cable when not part ofthe wiring in the switchboard, panelboard, or other control devices;

This part of the section is an "and" section, not an " or" section. To comply, the system has to meet all criteria of sub section B, not just one part. As well, it is intended for gutter boxes, of which 6x60A boxes; 6xl2k dimmers;12x2.4k dimmers; and 24x2.4k dimmers do not adhere to. One also has to have an overcurrent device before the breakers of each of these devices, which does not exist. Therefore, all of these devices, in theory, need to have some form of breaker before the breakers they possess, just like one has after you leave the gutter box. In a gutter box system, there is the feed coming in, a section of feeder, and then a breaker before the smaller breakers are connected to the main.

This section of the document needs to be deleted.

Reject:

CEC Appendix B 14-100This Rule applies only to conductors interconnecting electrical equipment. It does not apply to overcurrent protection of electrical equipment as required by other Rules of the Code.

CEC 14-100 (b)This part of the code tells you when overcurrent protection is required and where it must be located.Sub-rule (b) refers to any unprotected conductor such as a small cable tapped off of a larger supply or feedercable. Where the overcurrent protection protecting the larger feeder cable does not fully protect the smaller cable. The spirit of the rule is the point of consideration. There is no valid safe argument to take exposed unrestrained cable, (which is accessible to entertainment professionals, trained or otherwise), andexpose it to conditions beyond which cable that is “restrained” in one form or another is exposed to. Insert: “Single conductor jumper sets, of no less than #2 AWG– PPC, may be utilized to facilitate connection of distribution devices to the tap point, without the addition of overcurrent protection, providing that their length, combined with any supply tail or lead on the downstream device does not exceed the 3 meter total.



7.1.4 CPCLD In Section 7.1.4, where you discuss excess cable length, the suggestion of the use of jumpers or 25' cable lengths seems oddand somewhat arbitrary. I would suggest instead that the language should read more like "cable lengths shall be selected to minimize excess length". It would also be wise to include some language about how to properly stack excess length, such as "excess cable shall be coiled in a figure eight pattern so as to minimize EMF and cable heating."

Accept: Cable should be selected to minimize excess length.

7.1.3 891 7.1.3 This section should be deleted. There is nowhere in the code, or common practice, that this is required. With this requirement, one could not run out feeder run of 100'; followed by 50'; followed by another 100'line of feeder. It is restrictive, andcould put a crew member in trouble when miles from the cable vendor and having only 25' cable left, and needing to run 1"00' more of feeder.

Accept in principle: Modification: The number of interconnections between the source of supply and theutilization equipment shall be kept to a minimum.

7.1.4 891 7.1.4 This is redundant based on the previous section, and should also be deleted.

Reject: see above.

7.2.2 891 7.2.2 a) This should be deleted as I am not sure where this rule came from as the wording below is the exact language from the section of the Code that is quoted:

66-200 Grounding(1) The service and electrical distribution shall be grounded in accordance with Section 10.(2) Notwithstanding Rule 10-908[1)[a), grounding electrodes for mobile generators shall be permitted to be connected using single-conductor plug-in locking-type connectors.

Points B and c are acceptable and can be kept, and relabled.

Reject: the existing CEC code rule [66-200 (2)] is silent regarding the use of any inline connections. The proposed wording is expected to be a new rule in the 2015 CEC.


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