# Revisiting NEC 210.52(C): Defiining Similar Areas



## Papio Bldg Dept (Sep 13, 2011)

We are currently updating our NEC code editions to the 2011 edition and are revisiting Section 210.52©, for similar areas, and whether or not it is reasonable to consider a kitchenette/bar counters in finished basements as a similar areas as defined.  The following are two responses I received last time we visited this issue:

Code response #1: _ As for spacing I would consider it a "Similar Area" and it is intended to supplement the extension in theory of the kitchen type area. Now, I would not require GFCI but the required spacing is enforced because NEC 210.52© makes reference to the Similar Areas but in NEC 210.8(6) makes no reference other than to kitchens....so I would not require them to be GFCI protected however._

_You still have to meet the requirements of 210.52©(1) - ©(5). _

Code response # 2:  _There was a change from the 2005 and the 2008 code cycles in 210.52© where the words “pantries, breakfast rooms, and similar areas of dwelling units” was added._

_This change would now address the Butler Station as outlined in your question as to the installation spacing requirements of the counter top._

_As outlined in 210.8 only those receptacles over the kitchen counter top would require GFCI protection._

_As outlined in 210.12 Arc-Fault would be required as the Butler Station is not part of the kitchen._



In my opinion, the requirement is for areas where counter-top spaces are likely to be used with counter-top appliances, and in my experience this very much applies to basement finish kitchenette/bars where families and friends commonly gather on weekends and holidays loading up these counter-tops with blenders, crock-pots, and other appliances.  I have heard many arguments, mostly in favor of not requiring spacing and 20amp circuits.  The most common reasons have usually been voiced in "this is the way it has always been done," but clearly the NEC has made some changes in the language that might suggest they are not intending to continue this way.  Again this issue centers around the vagueness, or lack of definition, particularly the word "similar," and the intent of the code change versus the historical application of the code section.

Any thoughts or comments would be greatly appreciated.  Thank you.


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## BSSTG (Sep 13, 2011)

Greetings,

If you call it a kitchenette, then it's a kitchen, albeit a small one. If you call it a bar counter, then the 6 foot rule comes into play. Either way, GFCI required. As for spacing, I would use the same analogy. Check out the definition of "kitchen" in the NEC. It must have permanent provisions for food prep and cooking.

BS


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## Papio Bldg Dept (Sep 13, 2011)

BSSTG said:
			
		

> Greetings,If you call it a kitchenette, then it's a kitchen, albeit a small one. If you call it a bar counter, then the 6 foot rule comes into play. Either way, GFCI required. As for spacing, I would use the same analogy. Check out the definition of "kitchen" in the NEC. It must have permanent provisions for food prep and cooking.
> 
> BS


Thanks BSSTG, but the section is not limited to "kitchens" as it also adds pantries, breakfast rooms, and similar areas to the list, none of which are required to have permanent provisions for food prep and cooking.  Limiting it to kitchens is how the 2005 NEC and previous electrical codes handled it, and that mind set does not address the expanded code language.  Granted only kitchens is defined, but a bar counter is not all that different from a traditional pantry counter, that often times only has a single basin sink and counter.  How do permanent provisions for food prep and cooking affect the need/use of counter-top appliances?  In my opinion, they make the need for hot plates, toaster ovens, microwaves and crock-pots less likely, while increasing the need for other cooking appliances such as blenders, food processors, mixers, bread makers, etc.


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## north star (Sep 13, 2011)

*& & & &*

Papio,

Why not just add the language to amend the NEC, that your AHJ deems
applicable, ...such as the bar counter tops, and / or counter tops in
general......IMO, the use of any counter top, anywhere, would need to
adhere to the spacing & GFCI requirements......Also, the "less likely
need" for hot plates, toaster ovens, microwaves and crock pots
should not overlooked.....In my experience [ IME ], if there is a counter
top somewhere, ...someone will inevitably, use it for an appliance,
...gadget, ...thing-a-mah-dooey, or something that requires the use
of electricity......Now, add a sink or source of water to the "counter
top equation" and the need for GFCI protection, IMO, becomes critical.

Some on here will say that the various AHJ's are over-reaching their
legal authority to require GFCI receptacles in other than Kitchen area
applications, ...that extra costs are being imposed on the dwelling
owner / contractor.....Take that in to consideration when adding
language for your adoption of the 2011 NEC......I tend to err on the
side off safety and providing a safe environment for persons who
do not [ necessarily ] understand the need for GFCI protection in
these type areas.

Hope this helps!

*& & & &*


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## BSSTG (Sep 13, 2011)

Greetings again

I understand. I would say if the area does not meet the definition of a kitchen or bar area (that is it falls under the 6' rule) then I would treat all other countertop areas as "similar areas" and not require gfci protection per 210.8. As for spacing, you would have to go with 210.52 c 1-5 which I think is in agreement to the #1 above response to your original post and north star too. 210.52 is for convenience, 210.8 is for life safety IMHO and should not be confused. Also note that the requirements for gfci protection are made primarily where in close proximity to water or potentially wet or damp locations as north star reiterated.

I might add that I'm looking at the 2011 Code. Since it is the adopted code here I don't typically look at previous editions. I have gone to court on code issues before and nobody cares about the way it used to be insofar as code enforcement as a legal issue unless a grandfather type of situation exists.

I know opinions vary on this type of stuff but since I'm the AHJ in my little community that's my story and I'm sticking to it.

Have a Blessed Day!

BS


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## ronwampler (Sep 13, 2011)

Years ago when I proposed the Code revision kitchens, dining rooms, etc. were well defined within a room setting. Architecture began changing in the 80's to create open areas not easily defined as one use. I simply proposed that the requirements include those similar areas intended for use as a kitchen or dining area. This made it easier to enforce the intent of GFCI protection and 20 amp branch circuitry.

My opinion has always been not to create more Code but to efficiently enforce the existing Code to promote health, safety and welfare of the occupants.


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