Please think twice about printing this matrix. You can it, along with your ballot to or

Transcription

1 Page Line Clause E/G Organization Comment (rationale) Proposed change (specific; add, delete. From-to) Resolution (SME ONLY)

2 6 1.2.(b) G AVCON, INC. (b) Qualified Persons. Only qualified persons as defined in the familiar with the construction and installation of electrical power systems and equipment should perform the technical work described in this publication. (b) Qualified Persons. Only qualified persons as defined in NFPA 70E-2015, Standard for Electrical Safety in the Workplace the familiar with the construction and installation of electrical power systems and equipment should perform the technical work described in this publication. Accepted in concept and incorporated provisions into revise text I 1.2(b). 1.2(c), 1.2(d) and 1.2(e). Rewritten text of section 1.2 is as follows: 1.2 Regulatory and Other Requirements (a) Regulatory. All information in this publication is intended to conform to the NFPA 780 Standard for the Installing Lightning Protection Systems and applicable requirements in the NFPA 70 National Electrical Code. Installers should always follow and apply the applicable requirements contained in NFPA 780 and NFPA 70, in addition to applicable state and local codes, and manufacturer's instructions when installing electrical equipment and systems. (b) Training and Experience. Installation of lightning protection systems requires special skills and training. Only trained and experienced personnel familiar with the construction and installation of lightning protection systems and associated equipment should perform the technical work described in this publication. Some regulatory bodies may require certification or licenses that demonstrate credentials and experience. Administrative functions and other tasks can be performed under the supervision of a trained and experienced person. See Annex A of NFPA 780. (c) Qualified Persons. Installations of surge protective devices (SPDs) and other portions of the lightning protection system that are covered by NFPA 70 National Electrical Code and NFPA 70E, Standard for Electrical Safety in the Workplace (ANSI). These portions of the system installation shall be performed by qualified persons and

3 6 1.3.(a) E AVCON, INC..instructions, or of Codes or other (b) E AVCON, INC..instructions, or of Codes or other. 9 2 T AVCON, INC. Master Label Certificate An Underwriters Laboratories inspection certificate which provides independent third party evidence that a lightning protection system installation was found to be in complete compliance with an inspection standard. 9 2 T AVCON, INC. Insert after listed and before master label LPI is a non-profit third party who competes with UL for inspection of lightning protection systems (b) T/E AVCON, INC. b) Observing warnings and stacking instructions information such as project destination, voltage, job tags, or labels for easy reference and access..instructions, or of in Codes or other..instructions, or of in Codes or other. Master Label Certificate UL Lightning Protection Inspection Certificate. An Underwriters Laboratories inspection certificate which provides independent third party evidence that a lightning protection system design and installation was found to be in complete compliance with an inspection standards. Lightning Protection Institute Inspection Program LPI-IP. Master installation certificate which provides independent third party evidence that a lightning protection system design and installation was found to be in complete compliance with an inspection standards. b) Observing warnings, and stacking instructions and information such as project destination, voltage, job tags, or labels for easy reference and access. Accepted Accept Accepted and incorporated into Section 2 to align with conformance provisions in Section 6. Accepted and incorporated into Section 2 to align with expanded LPI information and conformance provisions in Section 6. Accepted

4 (f) T AVCON, INC. Add new section f) Copper and stainless steel materials shall be protected from contact with ferrous metals and should be securely stored to prevent theft. Accepted in concept and incorporated into a new (f) as follows: (f) Copper and stainless steel materials shall be protected from contact with ferrous metals to reduce reactions between dissimilar metals. Where possible the above materials should be stored in locations not vulnerable to physical damage or not readily accessible to the public second paragraph E, T AVCON, INC. Lightning is an unpredictable force that is continuously being studied to understand. The purpose of NFPA 780 Standard for the Installation of Lightning Protection Systems is to provide safeguarding of persons and property from hazards arising from lightning exposure. Lightning protection systems do not prevent lightning strikes, nor do they attract lightning from distances greater than the conventional attractive area of a building or structure. Several concepts. Lightning is an unpredictable force that is continuously being studied. to understand. The purpose of NFPA 780 Standard for the Installation of Lightning Protection Systems is to provide safeguarding of persons and property from hazards arising from lightning exposure. Lightning protection systems do not prevent lightning strikes, nor do they attract lightning. from distances greater than the conventional attractive area of a building or structure. A lightning protection system simply provides a preferred low impedance path for shunting the lightning current to ground minimizing damage to the protected structure. Several concepts. Note: NFPA Codes and Standards and other applicable lightning protection system codes and standards such as NFPA 780, LPI 175, UL 96A and so forth are not equipped with installation and design rules that prevent damage from criminal activity such as theft. Accepted and incorporated into Section 4.1. See second draft for revised text as follows: Lightning is an unpredictable force that is continuously being studied. NFPA 780 Standard for the Installation of Lightning Protection Systems indicates the purpose of lightning protection is to provide safeguarding of persons and property from hazards arising from lightning exposure. Lightning protection systems do not prevent lightning strikes, nor do they attract lightning. A lightning protection system simply provides a preferred low impedance path for shunting the lightning to ground minimizing damage to the protected structure. Several concepts related

5 13 Figures and E, T AVCON, INC. Figures are far too small to be of effective use. Please consider 11 X 17 size for figures E AVCON, INC. 4.3 Lightning Protection System Components. Lightning protection systems include several conductors and components that make up the entire system. Starting from the top of a structure and working toward the ground, the system includes a strike termination network (usually called air terminals, strike termination devices, or lightning rods), a down conductor network, a grounding terminal or grounding electrode network, an equipotential bonding network, and appropriate surge protection devices (SPDS) T AVCON, INC. Change reference in paragraph 1 from to G AVCON, INC. The grounding electrode network 2 nd para of the system is the largest contributor to the level of over voltage that will appear on the system if the ground connection not effective. 17 Fig E AVCON, INC. Figure does not print well, needs contrast 4.3 Lightning Protection System Components. Lightning protection systems include several many conductors and components that make up the entire system. Starting from the top of a structure and working toward the ground, the system includes a strike termination network (usually called air terminals, strike termination devices, or lightning rods), a down conductor network, a grounding terminal or grounding electrode network, an equipotential bonding network, and appropriate surge protection devices (SPDSs) Intent of sentence is not clear. Accepted in concept. To address the size issue, each figure and will be published on a full 8.5 in. x 11 in. page in landscape orientation. Also each of these sample installation and design drawings will be neutralized by removing any reference to a specific company or organization. Accepted and incorporated. Accepted and incorporated. Accepted and revised text as follows: The grounding electrode network of the lightning protection system is the largest contributor to increased levels of over voltage that could be present during system operation if the ground connection(s) are not effective. Accepted and graphic artist to increase contrast for clarity.

6 20 1 st par T AVCON, INC. Improper use of the term counterpoise, see definition NFPA and Chapter 11 Accepted and removed the reference to counterpoise. First sentence reads as follows: For buildings that exceed 18 m (60 ft) in height, these bonding connections shall be made to a ground loop conductor.

7 20 2 nd par T AVCON, INC. Section of the National Electrical Code (NEC) provides the restriction from using components of a lightning protection system as grounding electrodes for electrical power systems. The requirement to bond the two systems together must be adhered to as required in Section This rule specifies that the grounding electrode system of the lightning protection system be bonded to the electrical service grounding electrode system but does not specify a size of the bonding conductor. Section should be correct reference C provides sizing information, however, NFPA 780 sizing should probably be used in lieu of NFPA 70 since NFPA 780 conductors are sized for lighting protection not just for electrical systems. Accepted in Concept and Part. Reason: Section refers to minimum sizes of grounding electrode conductors. Section (C) addresses maximum sizes of grounding electrode conductors for an electrical power service when connected just to a ground ring electrode. Section and are provided in the NEC to indicate restrictions from using a power system grounding electrode as a lightning protection system ground loop. A new added sentence provides users with information about sizing conductors that are part of a lightning protection system. The text in this section is revised as follows to address the submitter s concerns and improve clarity: Section of the National Electrical Code (NEC) provides a restriction from using components of a lightning protection system as grounding electrodes for electrical power systems. The requirement to bond the two systems together must be adhered to as required in NEC Section This rule specifies that the grounding electrode system of the lightning protection system be bonded to the electrical service grounding electrode system but does not specify a size of the conductor that must be installed to bond the two systems together. Sizing requirements for lightning protection system conductors are provided in NFPA 780.

8 27 1 st par Second line E AVCON, INC. Change ant to and. Accepted 29 Fig T AVCON, INC. Side flash bonding distance appears to be violated at top of piping run and bend in LPS conductor nd par T AVCON, INC. The hardware shall not be located too close to an edge of the masonry unit to prevent cracking or spalling. The hardware shall not be located too close to an within two anchor lengths of the edge of the masonry unit to prevent cracking or spalling. Accepted and graphic will be revised accordingly. Accepted and incorporated into the sentence as follows: The hardware shall not within two anchor lengths of the edge of the masonry unit to prevent cracking or spalling T AVCON, INC. spatial shielding is not defined. Accepted and removed the term and revised the sentence as follows: Other means may need to be taken for protecting internal electrical and electronic systems from against lightning electromagnetic pulses. Potential equalization can be achieved at electrical service by bonding to down conductors and ground loop conductors as required, installing suitable listed surge protective devices and separation by space or distance T AVCON, INC. Add new sentence to end of Corrosion protection removed to make an electrical connection shall be repaired equivalent to the original corrosion protection Line 2 E AVCON, INC. Correct spelling of MASTER. Accepted Accepted and new sentence is added as follows: Any corrosion protection removed to make an electrical connection shall be repaired equivalent to the original corrosion protection.

9 G AVCON, INC. Need to include/address Lightning Protection Institute (LPI) inspection and labeling program and other 3 rd party inspection programs. UL and LPI are the two major players. Document currently sole sources the 3 rd party inspection. Accepted and incorporated LPI, LPI 175 and LPI-IP into Section 6 as follows: 6.2 Lightning Protection Institute The Lightning Protection Institute (LPI) is a nationwide not-for-profit organization founded in 1955 to promote lightning protection education, awareness and safety. LPI membership is comprised of manufacturers, contractors, scientists, architects, engineers and safety directors all interested in promoting lightning safety and improving the science of lightning protection. LPI members are dedicated to ensuring that today s lightning protection systems provide the best possible quality in both materials and installation practices for maximum safety. LPI has developed two standards related to installation and inspection of lightning protection systems. LPI 175 titled Standard of Practice for the Design Installation Inspection of Lightning Protection Systems is based on the design requirements of NFPA 780 and revised every three years according to the standards cycle. Information is added to LPI 175 to assist with the installation process from member experience. The publication LPI 177 is titled Inspection Guide for Certified Systems and is keyed to the paragraphs of the 175 document with additional information for those involved in system inspection and certification. The LPI individual certification is designed to educate and examine lightning protection professionals using a program which meets the national safety standards (LPI 175 Standard, NFPA 780 Standard, and UL 96 & 96A Standards). Through a battery of

10 G AVCON, INC. Need to include/address Lightning Protection Institute (LPI) inspection and labeling program and other 3 rd party inspection programs. UL and LPI are the two major players. Document currently sole sources the 3 rd party inspection. Accepted and revised paragraph 7.1 as follows: Installations should be inspected upon completion and shall be required if the UL Master Label Certificate or Lightning Protection Institute s Inspection and Labeling Program is specified. A maintenance manual should be provided to the building owner upon completion of the installation.

11 44 Annex A G AVCON, INC. Need to include/address Lightning Protection Institute (LPI) inspection and labeling program and other 3 rd party inspection programs. UL and LPI are the two major players. Document currently sole sources the 3 rd party inspection. Accepted and incorporated into Annex A revised and expanded text as follows: The installing contractor shall apply for inspection certificate of the completed lightning protection. Certificate programs recognized by this standard are UL Master Certificate Program and Lightning Protection Institute (LPI) Inspection Certificate and Labeling Program. Each of these program includes specific criteria that must be met in order to achieve conformance certification of the system. For compliance to the UL Master Label Certificate Program, the system is to be inspected by Underwriters Laboratories Inc., or other ANSI certified testing agency for compliance with NFPA 780. The system shall be without deviation and the UL field representative will issue a UL Master Label Certificate of Inspection for Lightning Protection Systems or Letter of Findings at completion of the installation, as indicated in section 3.04 below. For compliance to the Lightning Protection Institute (LPI) Inspection Certificate and Labeling Program the system must meet national safety standards (LPI 175 Standard, NFPA 780 Standard, and UL 96 & 96A Standards). Through a battery of exams, the LPI certification program assures participants are thoroughly tested in proper installation techniques and certified competent to provide quality workmanship and supervise complete system installation. See Section 6 for more detailed information.

12 45 Annex a 1.05 T AVCON, INC. Add new section 1.05 discussing Pre-installation conference Accepted and incorporated a new Section 1.05 that reads as follows: 1.05 Pre-Construction Conference Before beginning a lightning protection system installation, the installing contractor should meet with the building owner and all other trades and affected parties to coordinate the sequence of events for the entire project. All safety concerns and requirements must be addressed as well as coordination for access to areas within an existing building that would be required. Project timelines, material delivery and storage, and other related project installation activities should be reviewed and understood by all involved. Any unforeseen circumstances or problems should be addressed by subsequent project coordination meetings as necessary. 47 Annex a 2.06.d T AVCON, INC. The base of each steel column shall be connected to the LPS ground system. Accepted and incorporated additional sentence as follows: The base of each steel column shall be connected to the lightning protection ground system.

13 55 Annex c T AVCON, INC. Need to include/address Lightning Protection Institute (LPI) inspection and labeling program and other 3 rd party inspection programs. UL and LPI are the two major players. 63 Maint Proc T AVCON, INC. Re-tightening of all air terminals, bases, thru-roof assemblies, bonding lugs and plates, pipe clamps, connectors and conductor fasteners and cable holders Once terminations are properly torqued - is it advisable to go back and re-tighten? I was taught not to re-torque electrical connections (especially aluminum) once they have been properly torqued. Accepted and incorporated revised text as follows: This inspection will determine if the system installation is ready for final conformance assessment and certificate inspection. The latest revision of the shop drawing or customer provided AS-BUILT drawing will be used for this inspection to confirm that the installation of this system is in compliance with the specified lightning protection system installation standards. Accepted and revised clause (b) as follows: Verify tightness (torque values) of all air terminals, bases, thru-roof assemblies, bonding lugs and plates, pipe clamps, connectors and conductor fasteners and cable holders 66 Item 13 & 14 T AVCON, INC. Need to define affected area Should be greater distance of arc flash boundary of limited approach boundary Accepted and revised item 13. As follows: 66 Item 16 T AVCON, INC. No conductive hard hats or metal frames glasses shall be permitted with the affected area. No conductive jewelry is permitted when work is performed within the arcflash boundaries (limited approach boundary or the restricted approach boundary). Accepted and added a new item 16. As follows: No conductive hard hats or metal frame glasses are permitted when work is performed within the arc-flash boundaries (limited approach boundary or the restricted approach boundary).

14 68 In-service care and use 69 Training Orientation 3 rd para T AVCON, INC. Do an inflation test for gloves for possible tears or punctures. T AVCON, INC. All employees who work on 600 volts and above shall be trained and qualified for the tasks. Do an inflation test for gloves for possible tears or punctures. Perform dielectric testing in accordance with specific ASTM standard. See NFPA 70E Table 130.7(C)(7)(c). All employees who work on 600 volts and above shall be trained and qualified for the tasks. Accepted in concept and incorporated text as follows: Perform dielectric testing in accordance with applicable specific ASTM standard to meet the requirements contained in Article 130 of NFPA 70E Standard for Electrical Safety in the Workplace. Accepted in concept and incorporated revised text as follows: All employees who perform justified energized work shall be trained and qualified for the tasks. This includes new equipment and systems. The COMPANY shall provide the training or ensure that the employee receives the training necessary th par T AVCON, INC. Refresher training will be provided as necessary and shall consist of classroom and/or field training as deemed required by a qualified electrical foreman. 71 Annex F T AVCON, INC. Add Lightning Protection Institute standards. 1.2 Maxwell Lighting ) UL96A under Underwriters Laboratories and LPI 175 under Lightning Protection Institute should be added. The statement Electrical Equipment and System should be deleted. Lightning Protection and Grounding Systems should be used. Refresher training will be provided as necessary and shall consist of classroom and/or field training as deemed required by a qualified electrical foreman person. Accepted in concept and revised the section as follows: Refresher training will be provided as necessary and shall consist of classroom and/or field training as deemed required by a qualified person as defined in NFPA 70E. Accepted Accepted and revised accordingly.

15 1.2 Maxwell Lighting Of Electrical Power and Equipment should be revised. Lightning protection is not electrical power system. Recommend Of Lightning Protection Systems and Equipment and is listed by UL or LPI as such. Administrative Functions and other tasks can be performed under the supervision of a qualified person: should be deleted entirely. Accepted in concept and revised the text of this section as follows: 1.2 Regulatory and Other Requirements (a) Regulatory. All information in this publication is intended to conform to the NFPA 780 Standard for the Installing Lightning Protection Systems and applicable requirements in the NFPA 70 National Electrical Code. Installers should always follow and apply the applicable requirements contained in NFPA 780 and NFPA 70, in addition to applicable state and local codes, and manufacturer's instructions when installing electrical equipment and systems. (b) Training and Experience. Installation of lightning protection systems requires special skills and training. Only trained and experienced personnel familiar with the construction and installation of lightning protection systems and associated equipment should perform the technical work described in this publication. Some regulatory bodies may require certification or licenses that demonstrate credentials and experience. Administrative functions and other tasks can be performed under the supervision of a trained and experienced person. See Annex A of NFPA 780. (c) Qualified Persons. Installations of surge protective devices (SPDs) and other portions of the lightning protection system that are covered by NFPA 70 National Electrical Code and NFPA 70E, Standard for Electrical Safety in the Workplace (ANSI). These portions the system installation shall be performed by qualified persons and shall be in accordance with the applicable provisions of the NEC and

16 2. Definitions Maxwell Lighting 2. Definitions Maxwell Lighting 2. Definitions Maxwell Lighting (a) UL96A and LPI175 should be added to all locations NFPA is stated. Master label certificate. The LPI IP inspection and certification should be placed along with UL s program. Strike Termination Device. Recommend leaving NFPA out. Code location change eliminating constant updating for 3 year cycles. Accepted and incorporated LPI 175 and UL 96A accordingly. Accepted and incorporated LPI IP inspection certificate and labeling program in Section 6 and added references to LPI in locations where only UL was previously mentioned. Not accepted. SME and NECA agree with the submitter, but when including a definition from another standard, the definition should match what is contained in that standard. Maxwell Lighting 4.2 System Design Maxwell Lighting Maxwell Lighting Maxwell Lighting 4 Fundamentals and Design Procedures. Per NFPA780, Surge is required on electric, coax, and phone. Recommend adding UL and LPI and LPI has testing for Master Installer/Designer. Figure and Illegible, also Harger title block and part numbers are not general. 1.) Put each on its own page. 2.) Remove part numbers and title block. Figure Make this a full page. Accepted and incorporated an additional sentence in Section 4.3 as follows: Surge protection must be installed the power system or service, phone, coaxial cable for CATV systems, and so forth. Accepted and incorporated LPI 175 Standard of Practice for the Design Installation Inspection of Lightning Protection Systems into this section. Accepted in concept. To address the size issue, each figure and will be published on a full 8.5 in. x 11 in. page in landscape orientation. Also each of these sample installation and design drawings will be neutralized by removing any reference to a specific company or organization. Accepted

17 4.4 System Classes. Maxwell Lighting 5.2 Maxwell Lighting I & II. More information is needed. The height of roof equipment, antennas, and light poles can put a structure less than 75 tall into a class II lightning protection classification. A.) a) NFPA Is incorrect. Currently it is 4.15 & Recommend not putting the number. Use title NFPA780 potential equalization. b) Would also note UL96A bonding distance is 6 ft. c) a note should be added: metal objects can affect the bonding distances. Accepted and incorporated a new sentence as follows: The height of roof equipment, antennas, and light poles can put a structure less than 75 tall into a class II lightning protection classification. Accepted in concept and revised the clause to not include a specific section. The section refers to both NFPA 780 and LPI Ground Ring Electrodes Figure Figure Maxwell Lighting Maxwell Lighting Maxwell Lighting a) This is a little confusing. Recommend rewording: If the ground ring electrode is also being installed for the purposes of electrical ground, as permitted by NFPA780. B) Add ground ring or counterpoise is required for structures 60 ft. in height by NFPA780 and LPI 175. Confusing. Recommend eliminating one of the ground ring cables and ground rods leaving just the ballooned in statements. Bonding electrical services and other metal parts. A) Add gas line bonds on owner s side. B) Bonds should be visible or accessible. Accepted in concept and added a new first sentence as follows: A ground ring is required by both NFPA 780 and LPI 175 for structures 60 feet or taller. Accepted and graphic revised. Accepted and Graphic revised. Add text about bonding connections being accessible.

18 Figure Maxwell Lighting Not numbered. A) Microwave antenna bonding with full size cable, and air terminal if not in zone of protection. B) The grounding electrode cable need to indicate its own separate ground. Lightning protection and electric systems have separate grounds that must be bonded together. Accepted and add more detail to graphic and text as needed Maxwell Lighting Figure Figure Maxwell Lighting Maxwell Lighting Straps and fasteners need to be defined as listed by UL96. Cable straps, copper or aluminum to match cable, fasteners noncorrosive and compatible with straps and structure. b) For PVC conduit straps, recommend stainless steel or PVC Label cable as copper down conductor. NEC requires exposed nonmetallic raceway to be schedule 80 and has no provisions for cable guard Accepted in concept and revised accordingly. Accepted and revised graphic to include text Down Conductor with arrow. Accepted in concept and incorporated text about schedule 80 PVC use as follows: Schedule 80 PVC provides protection against physical damage and shall be secured and support in accordance with the requirements in Chapter 3 of the NEC. Accepted and inserted new graphic of incorrect method of through the roof penetration for sample only. Use a circle with a line through it for clarity. Accepted and added revised graphic Figure Figure Maxwell Lighting Maxwell Lighting a) Add picture of incorrect thru roof U pocket. B) Also add exothermic weld detail. Is the same as fig.( ). Should be revised showing a down cable in PVC with bond to steel top and bottom.

19 5.5.2 Bonding Maxwell Lighting Maxwell Lighting Maxwell Lighting 5.95 Maxwell Lighting When building is taller than 200 ft. This should have its own number with additional information. This is an NFPA780 and LPI requirement for concrete structures possibly requiring mid loops. Add statement after last paragraph. Adhering to metal roofing will require bonding to the roofing seams at a minimum of each down lead. thru wall show caulking or sealant. Add statement. Some roof systems TPO, or modified may require primer prior to adhesion Accepted and incorporated additional text in a new Add another graphic showing mid-loop bonding as indicated in the text. Accepted and added text in the 9 th paragraph of this section as follows: Adhering to metal roofing will require bonding to the roofing seams at a minimum of each down lead. Accepted and revised graphic to include caulking with arrows.

20 6 Maxwell Lighting Acquisition of Master Label Certification. This should be retitled: Acquisition of Certification. A) 6.1 should be renamed UL Master Label Certification. b) 6.2 should be renumbered Inspection Procedure. c) 6.3 should be renumbered submitting Application for Master Label. d).6.4 should be renumbered Post UL Inspection Documents. e) 6.5 should be renumbered Letter of Findings. g) 6.2 Newly names: LPI-IP Master certification with sub numbers as required Accepted and incorporated LPI, LPI 175 and LPI-IP into Section 6 as follows: 6.2 Lightning Protection Institute The Lightning Protection Institute (LPI) is a nationwide not-for-profit organization founded in 1955 to promote lightning protection education, awareness and safety. LPI membership is comprised of manufacturers, contractors, scientists, architects, engineers and safety directors all interested in promoting lightning safety and improving the science of lightning protection. LPI members are dedicated to ensuring that today s lightning protection systems provide the best possible quality in both materials and installation practices for maximum safety. LPI has developed two standards related to installation and inspection of lightning protection systems. LPI 175 titled Standard of Practice for the Design Installation Inspection of Lightning Protection Systems is based on the design requirements of NFPA 780 and revised every three years according to the standards cycle. Information is added to LPI 175 to assist with the installation process from member experience. The publication LPI 177 is titled Inspection Guide for Certified Systems and is keyed to the paragraphs of the 175 document with additional information for those involved in system inspection and certification. The LPI individual certification is designed to educate and examine lightning protection professionals using a program which meets the national safety standards (LPI 175 Standard, NFPA 780 Standard, and UL 96 & 96A Standards). Through a battery of

21 7.0 Inspection, Maintenance and Testing Maxwell Lighting a) 7.1 should reference NFPA780 inspection and maintenance of lightning protection systems. b) The statement If the Master Label Certification is specified should be removed. c) Should be added that LPI certification expires in 3 years coinciding with the NFPA780 cycle. Accepted in concept. LPI and Master Label certificate programs are covered in Section 6 as revised.

22 Testing Maxwell Lighting Section 6.2 is not correct. Recommend stating use NFPA780 (annex) grounding and measurement techniques. Accepted and incorporated revised and expanded text as follows: General IEEE Standard 81 describes several different methods in which to test the resistance of a grounding electrode or a grounding electrode system, among those methods are the three-point fall of potential method and the clamp-on test. NFPA 780 Annex E describes the principals involved with the three point fall of potential test and how it can be used with small and complex grounding electrode systems. The Clamp-on test method is used predominantly to test individual electrodes but it has limitations Fall of Potential Method This method requires that the grounding electrode or grounding electrode system be isolated from the electrical power system if the utility uses a multigrounded neutral system. It must also be isolated from the telecommunications ground as well as any other building grounds. Tests should be performed on individual grounding electrodes and the results recorded over time. Any increase of resistance from the original test reading may indicate deterioration of the grounding electrode. When using grounding electrodes in conjunction with a ground ring, it may not be possible to test the individual electrode. In this case the entire system should be tested while isolating it from other building grounds Clamp-On Method The clampon method requires that the grounding electrode or grounding electrode system be connected to the electrical power system using a multi-grounded neutral system or another zero reference source. Proper placement of the unit is essential in order to obtain a correct reading. The grounding

23 8. Project Management Maxwell Lighting Maxwell Lighting 8.5 Maxwell Lighting Specification Review. In addition to NFPA 780, UL96A and LPI 175 requirements, there may be other government, state, or local code requirements. Normally located in bid documents. LPI needs to be listed. Lightning.org Accepted and incorporated. Add new text as follows: Specification Review. In addition to NFPA 780, UL96A and LPI 175 requirements, there may be other government, state, or local code requirements. Normally located in bid documents. Accepted and incorporated LPI into the text as follows: For more complete information about lightning protection system installations and the requirements for such systems refer to the Electrical Training Alliance (ETA) Lightning Protection Systems training program, NFPA 780 Standard for the Installation of Lightning Protection System and LPI 175 Standard of Practice for the DESIGN-INSTALLATION- INSPECTION of lightening protection systems, LPI-177 Inspection Guide for Certified System. For information about listed products suitable for use in lightning protection systems refer to UL 96 Lightning Protection Components

24 Maxwell Lighting Annex A Lightning Protection Specification. This needs to be eliminated. NECA 781 is not a lightning protection system design document. If not removed, then reworded. Accepted Only in Part As the scope of NECA 781 indicates this standard is intended to provide quality and performance criteria and best practices for lightning protection system design and installation for both new construction and existing structures. The basic components of lightning protection systems are covered as well as basic information related to lightning protection system design and system maintenance. Information about quality design of such systems is included in this standard. The title of Annex A is revised as Lightning Protection System Specification Example Maxwell Lighting Annex A is intended as an example of a specification that can be used. It provides essential information for specifiers to assist in development of specifications. Annex A as well as the other Annexes in this standard are information rather than Normative and thus are not part of the standard and not mandatory, even where adopted by a jurisdiction.

25 6 1.2 (a) E Rebane Edit to make compliance with NFPA 70 mandatory. Further, as written, it is not clear whether compliance with NFPA 780 is mandatory. If you decide to leave NFPA 780 as a recommendation, then note that some of the certifications might not be available for that installation, and is in conflict with Clause 4.2. I recommend that you include a statement requiring that materials used for lighting protection system be listed and labeled. N/A Accepted in Concept and revised text as follows: (a)regulatory. All information in this publication is intended to conform to the NFPA 780 Standard for the Installing Lightning Protection Systems, LPI-175 Standard of Practice for the DESIGN-INSTALLATION- INSPECTION of lightening protection systems, and any applicable requirements in the NFPA 70 National Electrical Code. Installers shall follow and apply the applicable requirements contained in lightning protection standards such as those mentioned above and NFPA 70, in addition to any applicable state and local codes, and manufacturer's instructions when installing electrical equipment and systems. NOTE: All NEIS are voluntary and only mandatory where adopted through legal adoption processes by jurisdictions. NEIS documents can bb mandatory where incorporated by reference from a project specification or other legal document. NEIS are not intended for mandatory application but serve to fill the gap related to what constitutes good workmanship related to lightning protection system installation and design. Included a provision in 4.3 requiring lightning protection conductors and components to be listed (certified) to appropriate product standards. This requirement is also provided in Clause

26 6 1.2 (b) E Rebane As a minimum, all tasks shall be performed under the supervision of a qualified person. IMHO, that requirement should be extended to include persons that perform technical tasks as well, but that is your decision N/A Accepted in concept. See the revised and expanded text that deals with training and experience and also requirements for qualified persons as defined in NFPA 70 and NFPA 70E. Requirements (a) Regulatory. All information in this publication is intended to conform to the NFPA 780 Standard for the Installing Lightning Protection Systems and applicable requirements in the NFPA 70 National Electrical Code. Installers should always follow and apply the applicable requirements contained in NFPA 780 and NFPA 70, in addition to applicable state and local codes, and manufacturer's instructions when installing electrical equipment and systems. (b) Training and Experience. Installation of lightning protection systems requires special skills and training. Only trained and experienced personnel familiar with the construction and installation of lightning protection systems and associated equipment should perform the technical work described in this publication. Some regulatory bodies may require certification or licenses that demonstrate credentials and experience. Administrative functions and other tasks can be performed under the supervision of a trained and experienced person. See Annex A of NFPA 780. (c) Qualified Persons. Installations of surge protective devices (SPDs) and other portions of the lightning protection system that are covered by NFPA 70 National Electrical Code and NFPA 70E, Standard for Electrical Safety in the Workplace (ANSI). These portions the system installation shall be performed by qualified persons and shall be in accordance with the applicable provisions of the NEC and

27 6 1.2 (c) E Rebane I recommend that compliance with NECA 1 be mandatory, see Clause 5.1 Accepted and incorporated revised text as follows in Section 1.2: (d) Workmanship. General requirements for installing electrical products and systems are described in NECA 1, Standard for Good Workmanship in Electrical Construction (ANSI) and not all provisions in NECA 1 would apply to lightning protection system installations. Other National Electrical Installation Standards provide additional guidance for installing particular types of electrical products and systems. NECA 781 provides workmanship provisions for lightning protection systems including system design, maintenance, quality, and performance criteria. A complete list of NEIS is provided in Annex E E Rebane This Clause should carry a warning that changes to construction documents (is that what is meant by "original drawings?" may not be made without approval of the contracting agency. Accepted and added text to 4.2 as follows: Often changes in the field result in system installations that will differ slightly than as shown in the original plans and specifications. Any changes to an original system design must be coordinated with the original designer or engineering firm E Rebane Correct spelling Replace "(SPDS)" with (SPDs)" Accepted , the last paragraph on that page T Rebane Moisture and water intrusion through walls and floors warrants additional directions and cautions, similar to that offered for roofs. See the first paragraph of Clause 5.6 and the last paragraph on page 34 (Clause ) E Rebane Correct spelling Replace OHSA with OSHA Accepted Accepted and added text in as follows: Moisture and water intrusion through walls and floors warrants additional directions and cautions, similar to that offered for roofs.

28 44 Annex A E Rebane Correct Division number Replace 2600 with 26 Accepted N/A Annex A E Rebane Review sample specification for conformance with CSI MasterFormatTM for sections. 53 and 58 Annex B E Rebane Update SPD standard reference to UL 1449, 4th edition. Correct abbreviation for kilo-amperes Relocate paragraphs in Part 2 describing execution to Part 3. Samples of paragraphs that should be relocated include: 2.03a.2.03b, 2.03c, a through e, g and h,2.05, etc. Relocate paragraph in Part 3 to Part 1: 3.01b and c, 3.03, 3.04d. Replace 20KA with 20kA Accepted and reorganized as suggested. Renumbered the section accordingly. Accepted and revised text as follows: Confirm surge protection devices on electrical service(s) are compliant with the current edition of UL 1449, with 20KA In ALL E HLP Systems Page numbers need to be added. It is very difficult to comment on a certain page number when none are listed. Page numbers we are using in this comment matrix are based on when these document pages fall in their presented order. Add Page Numbers to the entire document including the table of contents. Accepted. Page numbers will be added in the final publishing of the standard. ALL G HLP Systems Proposed NECA x is not needed. NFPA 780 is already an ANSI standard and attempting to have a second ANSI standard that is less technical that the current recognized ANSI standard would cause conflicts. Concentrate on making this a maintenance standard or document and not an installation standard. As presented it is in conflict with NFPA 780 in many places and is more of a handbook and not a technical document. This document is editorial in nature. Not accepted. NFPA 780 is intended to be a recommended practice that requires that conductors and equipment for lightning protection systems be installed in a neat and workmanlike manner, however, nothing in 780 describes what constitutes neat and workmanlike. That is the whole inspiration behind the National Electrical Installation Standards (NEIS) program. NECA 781 is intended to address quality, performance, workmanship and more specific and detailed maintenance information than NFPA 780 or PLI 175.

29 1 G HLP Systems 781 is a poor choice of a Standard number. I 2 E HLP Systems Page numbers missing from the Table of Contents. NECA 780 should be used since the attempt here is to somewhat align with NFPA will lead to confusion with the long proposed but never adopted NFPA 781. Add Page Numbers. This designation was accepted by ANSI and is included in the PINS submitted to ANSI. The scopes of NFPA 780 and 781 differ and each are specific to the information covered within each. The standard designation 781 has been cleared with NFPA. Accepted. Page numbers will be added in the final publishing of the standard E HLP Systems Lightning is spelled lighting Correct spelling error Accepted and corrected.

30 6 1.2 B G HLP Systems Paragraph requires the installer to be familiar with the construction and installation of electrical power systems What does this have to do with the installation of Lightning Protection Systems? Change: Only qualified installers under the employ of contractors Listed by Underwriters Laboratories for the purpose of installation of Lightning Protection Systems should perform all work described in this publication. Accepted the comment and completely revised this section to include more detail about required training and experience as well as when qualified persons are required to perform certain portions of some work related to installing a lightning protection systems (such as installing a surge protection unit or system at an electrical service). Test is revised as follows: 1.2 Regulatory and Other Requirements (a) Regulatory. All information in this publication is intended to conform to the NFPA 780 Standard for the Installing Lightning Protection Systems and applicable requirements in the NFPA 70 National Electrical Code. Installers should always follow and apply the applicable requirements contained in NFPA 780 and NFPA 70, in addition to applicable state and local codes, and manufacturer's instructions when installing electrical equipment and systems. (b) Training and Experience. Installation of lightning protection systems requires special skills and training. Only trained and experienced personnel familiar with the construction and installation of lightning protection systems and associated equipment should perform the technical work described in this publication. Some regulatory bodies may require certification or licenses that demonstrate credentials and experience. Administrative functions and other tasks can be performed under the supervision of a trained and experienced person. See Annex A of NFPA 780. (c) Qualified Persons. Installations of surge protective devices (SPDs) and

31 E HLP Systems There are two Sections numbered E HLP Systems In the first section 4.1 Lightning is & misspelled. Figures G HLP Systems The listing of a specific manufacturer implies that this document is an endorsement of that product. This document should be free of any implied product endorsement. Renumber paragraphs in section 4. Correct spelling error. Remove all references to the manufacturer. Figures E HLP Systems Figure numbers are inconsistent. Change numbers to be consistent though the document. Some have dashes some have dots. Accepted and revised the second instance of 4.1 as Accepted and corrected. Accepted and corrected. The sample shop drawings figures and have been neutralized to remove company names. Accepted. SME and NECA will ensure that the figure numbers receive the appropriate number designations and they appear in sequence Figure E HLP Systems Figure number is inconsistent. Change numbers to be consistent though the document. Some have dashes some have dots. Accepted. SME and NECA will ensure that the figure numbers receive the appropriate number designations and they appear in sequence E HLP Systems Lightning is spelled lighting Correct spelling error Accepted and corrected T HLP Systems Section in NFPA 780 does Change to correct section number or Accepted removed specific reference. not exist. remove reference Figure E HLP Systems A material manufacturer s name is visible on the ground access well. The listing of a specific manufacturer implies that this document is an endorsement of that product. This document should be free of any implied product endorsement. Remove all references to the manufacturer. Accepted and corrected. The sample shop drawings figures and and Figure have been neutralized to remove company names.

32 T HLP Systems The ground ring electrodes, rods and so forth shall be installed.. Define and so forth Accepted and revised as follows: The ground ring electrodes, rods, and other installed electrodes permitted by the standard(s) shall be installed so that it is not affected by freezingthawing cycles of the earth, (if present). See figure E HLP Systems See Figure should be Change numbers to be consistent though the document. Some have dashes some have dots T HLP Systems In the second line of the paragraph the term, there may be confusion is correct. This paragraph as written is very confusing and is not consistent with NFPA 780 Rewrite to be consistent with NFPA 780 ground ring electrode requirements. Accepted and corrected. Accepted and revised as follows: A ground ring is required by both NFPA 780 and LPI 175 for structures 60 feet or taller. If required, a ground ring electrode for the lightning protection system shall be installed at least 450 mm (18 in.) below the earth unless ground conditions prevent this. There may be confusion as to whether the ground ring electrode is for the lightning protection system ground or for a supplemental electrical ground. If the ground ring electrode is being installed for the purposes of electrical grounding, it shall be installed to a depth of at least 750 mm (30 in.). Ground ring electrodes shall be continuous around the structure and connect to all down conductors. The ground ring electrodes, rods, and other installed electrodes permitted by the standard(s) shall be installed so that it is not affected by freezing-thawing cycles of the earth, (if present). See figure E HLP Systems structure should be structure s Correct typo. Accepted and corrected.