# Bonding CSST in Oregon



## Jim Katen (Nov 30, 2011)

Here's an interesting conundrum.

NEC 250.104(B) requires gas pipes to be bonded and allows us to use the EGC of the circuit that's likely to energize the piping as the bonding means.

CSST manufacturers, however, require a more robust bonding connection that involves a #6 copper bonding jumper. (For those who are not aware, this requirement came about as a result of a class action suit against Omegaflex. The manufacturer said that lightning damage to their product only occurred because the product wasn't adequately bonded. They ramped up the bonding requirements to protect it against lightning, a practice that, in the words of CMP 5 "has no basis in science.")

The state of Oregon has issued the following "Statewide Code Interpretation," which, basically, tells the CSST manufacturer's to go pound sand. http://www.cbs.state.or.us/external/bcd/programs/electrical/interps/electrical_CSST.pdf

This make for a nice clear cut line for code enforcement personnel, but it puts electrical contractors, plumbers, & home inspectors in a real bind. Do we use the code interp to ignore the manufacturer's instructions? Or do we go the extra mile and embrace the (silly and useless) manufacturer's instructions in an effort to contribute to the universal butt-cover-fest initiated by the CSST lobby?

I'm interested in hearing you-alls thoughts on the matter. If you were in Oregon, how would you install or inspect CSST with regard to bonding?


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## globe trekker (Nov 30, 2011)

Jim Katen,

As I understand the requirements, a jurisdiction cannot supercede / void the

requirements of the manufacturer.

If the bonding is not installed, and installed properly, then the manufacturer

can ( legally ) not honor the warranty in the event of, ..which "COULD"

leave the property owner holding the bag for any costs from damage received

from a lightning strike event.

In your case, who will be accountable / responsible for the damage costs

" IF " a lightning strike event occurs? Not the manufacturer, ..not the

installer of the CSST. Who then? And " IF " the property owner is to be

the weakest link in the chain ( i.e. - the bearer of the costs ), does the

state of Oregon also have language to legally require documentation

of notification to the property owner that a non-warranteed product has

been installed in the property they are purchasing? You know, so that

when they file an insurance claim for damages, they will know why

their insurance company says "No !".

"Silly and useless" *<----- ???*

If I were in Oregon and inspecting the bonding requirements, I would

inspect it according to the manufacturers requirements.

FWIW, the CSST manufacturers all have "well trained" technical

respresentatives who regularly travel all over the U.S., providing

"free-of-charge" training on their products, ..to those who actually

intend to install this product in the correct manner.

I'm also curious! When do you "not" cover the butt?   



.


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## Pcinspector1 (Nov 30, 2011)

Jim,

Interesting topic, this issue has been brought to my attention from a former electrical engineer as well, 250.104 (B) and table 250.122.  GAS furnace on a 20amp switched shut off circuit only requiring a #12 copper grounding wire, not the required #6 as the manufacture specs out.

The circuit that most likely would energize the piping system.(from NEC 250.104 (B).

This is a problem that needs to be addressed IMO.

pc1


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## north star (Nov 30, 2011)

*& & & &*





> "The circuit that most likely would energize the piping system.(from NEC 250.104 (B).This is a problem that needs to be addressed IMO."


Pcinspector1 and others, any suggestions on how to address this?.......In this case, shouldthe furnace, or all appliances have a larger sized grounding conductor?

*& & & &*


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## Francis Vineyard (Nov 30, 2011)

As stated the manufacturer’s electrical bonding requirement is specific for its CSST product and not a requirement found in the NEC (NFPA 70) or NFPA 780. It has recently been implemented into the NFPA 54 and IFGC (IRC) in conjunction with the manufacturer’s guidelines which Oregon deleted or does not enforce by reference. 



I can relate to Oregon's minimum requirement as Virginia deleted many code sections such as IRC sprinkler requirement and arc-fault breakers other than bedrooms. 

I was looking for a report published a couple of years ago and was delighted when I found another updated study linked below (file size 6.97 MB). 

From page 50.



An expert opinion: “While the current study of safety has been confined within the context of lightning strikes, safety must also be considered in the broader context of general usage. There are no known documented cases of loss of life related to any physical or operational failures of CSST product or systems, while the same cannot be said for other gas piping systems. CSST has already been demonstrated to be a safe product, and the objective of the research should only be focused on whether there is an incremental reduction of safety due to lightning strikes. In our opinion and based on actual statistical data from the NFPA, the damage to CSST caused by lightning strikes has been grossly overstated, and represents (at best) a marginal (if not statistically insignificant) reduction in safety compared to other gas piping products. … [this source] believes that many organizations are asking the wrong questions and/or looking to the wrong solutions to the problem. Let us state for the record that the lightning related problems of CSST has been incorrectly characterized while the prescribed bonding solution has been overly simplified … Although the bonding of the CSST system alone is considered “better than nothing,” it is not considered a complete solution to the threat of lightning damage to a building. Bonding CSST alone ignores the more conventional and comprehensive approach of equipotential bonding and/or the installation of a lightning protection system. Bonding represents a partial solution that is intended to provide passive resistance to any lightning energy that enters the premise from an indirect strike. It should also be understood that in the absence of a properly installed lightning protection system, a direct lightning strike to the structure is beyond the ability of any man-made system and/or equipment to absolutely protect the building and its contents from severe damage. Unless CSST bonding is examined and evaluated within the broader context of protecting the structure and all metallic systems within that structure, the outcome of this research will only confirm what is already known: bonding of CSST alone, without consideration of other metal systems in the building, is less than a complete solution.… The relative damage associated with CSST and lightning pales by comparison to other content within the home and/or to the wooden structure itself. This estimated annual number of CSST fires compared to all residential fires for all causes in the United States does not even register as a whole number and represents less than 0.01 of 1 percent of the total. There appears to be a gross misplacement of concern when one considers that over the same time period, the number of lightning caused fires within the electrical distribution system within residential structures was approximately double (240 incidents per year) the number of natural gas fires.”

http://www.google.com/url?sa=t&rct=j&q=nfpa csst piping final report&source=web&cd=1&ved=0CCsQFjAA&url=http%3A%2F%2Fwww.nfpa.org%2Fassets%2Ffiles%2F%2FPDF%2FResearch%2FCSST Gas Piping Ph.1 Final Report.pdf&ei=29zWTt2xEMS62wXZ8KydAQ&usg=AFQjCNHfadWmfmPRmYf8TO5PYDCdxOlKpA


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## Jim Katen (Nov 30, 2011)

globe trekker said:
			
		

> Jim Katen,As I understand the requirements, a jurisdiction cannot supercede / void the
> 
> requirements of the manufacturer.
> 
> ...


I'm not sure that the state of Oregon is superseding or voiding the manufacturer's requirements. They're just saying that they won't participate in enforcing them. If an installer wants to follow the requirement, that's fine, but the state isn't going to *make* him follow the requirement. It's a bold move -- essentially giving the manufacturers the finger.



> "Silly and useless" *<----- ???*


*If you follow the history of the bonding requirements for CSST, it quickly becomes obvious that they're silly and useless. The fatter bonding jumper won't make any difference when it comes to reducing voltage potentials between the CSST and other nearby conductive objects. I fully expect the manufacturer's to come out with some new technical bulletins next year that call for #4 wire. *





> *If I were in Oregon and inspecting the bonding requirements, I would**inspect it according to the manufacturers requirements.*


*That's where I'm at now. *





> *I'm also curious! When do you "not" cover the butt?   **. *


*I have a deep and profound philosophy regarding butt covering. I never try to cover my own butt, just my customers' butts. I believe that when I cover their butts, mine is covered automatically.*


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## Jim Katen (Nov 30, 2011)

Pcinspector1 said:
			
		

> Jim, Interesting topic, this issue has been brought to my attention from a former electrical engineer as well, 250.104 (B) and table 250.122.  GAS furnace on a 20amp switched shut off circuit only requiring a #12 copper grounding wire, not the required #6 as the manufacture specs out.
> 
> The circuit that most likely would energize the piping system.(from NEC 250.104 (B).
> 
> ...


The two standards are trying to address different things.

The NEC is concerned with clearing faults from the building's electrical system. For that purpose, a #12 jumper is just fine.

The manufacturers are, supposedly, trying to prevent their product from suffering arc damage that would occur as the result of the voltage potentials from a nearby lightning strike. Their fantasy is that a fat bonding jumper will dissipate these voltages better and, thus, protect the tubing. Of course, this isn't true. In order to prevent arcing from voltage potentials, you've got to bond everything, not just the gas pipe, and even then, with the huge potentials created by a lightning strike, there's no guarantee that you won't get an arc somewhere anyway.

The fact is that CSST is a bit vulnerable to nearby lightning strikes and the manufacturers know it. The #6 bonding requirement is just a distraction to get the lawyers off their backs until they can implement other improvements to the product, such as the new voltage dissapating jackets that are starting to come out now.


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## Jim Katen (Dec 1, 2011)

Francis Vineyard said:
			
		

> As stated the manufacturer’s electrical bonding requirement is specific for its CSST product and not a requirement found in the NEC (NFPA 70) or NFPA 780. It has recently been implemented into the NFPA 54 and IFGC (IRC) in conjunction with the manufacturer’s guidelines which Oregon deleted or does not enforce by reference.
> 
> I can relate to Oregon's minimum requirement as Virginia deleted many code sections such as IRC sprinkler requirement and arc-fault breakers other than bedrooms.
> 
> ...


Well, if you want to bring science and reason to the discussion . . .

The quotation above is correct. However, if a house burns down because of a failure with a piece of black iron pipe, there's no one to whom you can direct a class action suit. If, on the other hand, a house burns down because of a failure of CSST piping, that's lawyer heaven. Let the class actions begin.


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## Francis Vineyard (Dec 1, 2011)

Jim Katen said:
			
		

> Well, if you want to bring science and reason to the discussion . . . The quotation above is correct. However, if a house burns down because of a failure with a piece of black iron pipe, there's no one to whom you can direct a class action suit. If, on the other hand, a house burns down because of a failure of CSST piping, that's lawyer heaven. Let the class actions begin.


I agree, however a smooth lawyer and a "bad" judge could result in enough monetary damages to settle out allege fault with any product. Hence the notice of todays manuals results in twice as many pages with cautions and warnings included in multiple languages; this wasn't done for convenience.

Jim, my approach is take an obligation to help and note the correct installation procedures on the inspection report and approve the inspection per code.


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## globe trekker (Dec 1, 2011)

> *"I'm not sure that the state of Oregon is superseding or voiding the manufacturer's**requirements. They're just saying that they won't participate in enforcing them. If an*
> 
> *installer wants to follow the requirement, that's fine, but the state isn't going to *make**
> 
> ...


Jim K.,

Perhaps I was a bit overzealous in my response to your request for information. I apologize

if I was disrespectful to you! It seems that the homeowner or purchaser of the this

product, as well as, a lot of others products are left with absorbing the costs of a

( potentially ) defective, / less than optimally performing product.

How can homeowners & Commercial property owners protect themselves from this

product?



> *"The #6 bonding requirement is just a distraction to get the lawyers**off their backs until they can implement other improvements to the product,*
> 
> *such as the new voltage dissapating jackets that are starting to come out*
> 
> *now."*


The Tracpipe brand of CSST no longer manufacturers their original CSST product,

but now offers the Tracpipe Counterstrike "voltage dissapating jacketed" CSST.

There is still a lot of the original CSST warehoused everywhere, so it will still

be installed for a long time to come.

.


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## jar546 (Dec 1, 2011)

As stated, the IRC addressed this is the 2009.  I am assuming that the State in question does not use the 2009 IRC.

*SECTION G2411 (310)*

*ELECTRICAL BONDING*

*G2411.1 (310.1) Pipe and **tubing **other than CSST. *Each

above-ground portion of a _gas piping system _other than corrugated

stainless steel tubing (CSST), that is likely to becomeenergized

shall be electrically continuous and bonded to an effective

ground-fault current path. _Gas piping_, other than CSST, shall be

considered to be bondedwhere it is connected to _appliances _that

are connected to the equipment grounding conductor of the circuit

supplying that _appliance_.

*G2411.1.1 (310.1.1) CSST. *Corrugated stainless steel tubing

(CSST) _gas piping systems _shall be bonded to the electrical

service grounding electrode system at the point where

the gas service enters the building. The _bonding jumper_

shall be not smaller than 6AWGcopper wire or equivalent.


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## gbhammer (Dec 1, 2011)

:cheers



			
				Jim Katen said:
			
		

> I have a deep and profound philosophy regarding butt covering. I never try to cover my own butt, just my customers' butts. I believe that when I cover their butts, mine is covered automatically.


Very fine philosophy.


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## Jim Katen (Dec 1, 2011)

jar546 said:
			
		

> As stated, the IRC addressed this is the 2009.  I am assuming that the State in question does not use the 2009 IRC.


We use the 2009 IRC but we got rid of that section. Oregon's amended version of the IRC has always been highly "customized." I used to buy the standard loose leaf version and insert the Oregon amendments. By 2003, the amended pages were so numerous that there were only 42 unamended pages in the entire code. Nowadays, it's probably closer to zero. (I don't know because I just buy the pre-amended versions now.)


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## Inspector Gift (Dec 1, 2011)

Oregon's amended code states:

*G2411.1 Gas pipe bonding.* Electrical bonding of gas piping systems shall be in accordance with the _Electrical Code._


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## righter101 (Dec 1, 2011)

Not in Oregon, but the IFGC has

_310.1.1 CSST. Corrugated stainless steel tubing (CSST)_

_gas piping systems shall be bonded to the electrical service_

_grounding electrode system at the point where the gas service_

_enters the building. The bonding jumper shall be not_

_smaller than 6 AWG copper wire or equivalent._

In this discussion, I think the State of Oregon is wrong in ignoring the Mfg. specifications.

I would enforce the more restrictive of either the NEC, res.code or mfg listing.

Just my $0.02  worth ($0.03 in washington with our sales tax)


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## righter101 (Dec 1, 2011)

I have re read the state of Oregon interpretation or opinion of this and I have to re affirm my poistion that they are dead wrong.  2408.1 is not ambigious at all.

_Where a code provision is less restrictive than the conditions of_

_the listing of the equipment or appliance or the manufacturer’s_

_installation instructions, the conditions of the listing and the_

_manufacturer’s installation instructions shall apply._

I think they are dead wrong on this.  The issue shouldn't be whether we agree with the mfg's specs or the reasons behind it, this decision goes contrary to very explicit language in the code.

I would appeal this decision if I were in a poistion to do so.  Even if I agreed with the ruling they issued, the logic and process is flawed.

This opens the door for subsequent decisions that would go against the intent of the code.

From reading the interpretation by the Oregon code folks, it seems to boil down to "because we said so".  They just seemed to brush aside 2408.1 as "not really applicable in this case".

JMHO


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