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Old 01-08-2021, 10:07 AM   #1
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DC electrical safety standards updates

For our ETI trailers, CSA Z240.6.2-14, Electrical requirements for recreational vehicles, is the Canadian RV electrical safety standard. In the US, NFPA 1192 prescribes NFPA 70, National Electrical Code, as the RV AC electrical safety standard. It also prescribes ANSI/RVIA LV, Standard for Low Voltage Systems in Conversion and Recreational Vehicles, as the RV DC electrical safety standard.

The recently released ANSI/RVIA LV 2020 edition contains new safety requirements the installation of solar panels and lithium battery systems. For example, the new §2-6 outlines minimum safety requirements for "Solar Prep Installations". Also, §2-3 requires lithium batters to be "listed", such as Battle Born LiFePO4 batteries being UL 2054 listed. Hopefully, all RV lithium battery manufacturers add UL 1692 and UL 1973 listings to their batteries.

If you are modifying any part of your DC electrical system, recommend consulting CSA Z240.6.2 or ANSI/RVIA LV as the life safety consensus body of knowledge. You might find the wiring sizing tables helpful, as well as guidance on how to properly protect, connect, and route DC wiring.

73/gus
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Old 01-08-2021, 10:12 AM   #2
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Quote:
Originally Posted by gklott View Post
For our ETI trailers, CSA Z240.6.2-14, Electrical requirements for recreational vehicles, is the Canadian RV electrical safety standard. In the US, NFPA 1192 prescribes NFPA 70, National Electrical Code, as the RV AC electrical safety standard. It also prescribes ANSI/RVIA LV, Standard for Low Voltage Systems in Conversion and Recreational Vehicles, as the RV DC electrical safety standard.

The recently released ANSI/RVIA LV 2020 edition contains new safety requirements the installation of solar panels and lithium battery systems. For example, the new §2-6 outlines minimum safety requirements for "Solar Prep Installations". Also, §2-3 requires lithium batters to be "listed", such as Battle Born LiFePO4 batteries being UL 2054 listed. Hopefully, all RV lithium battery manufacturers add UL 1692 and UL 1973 listings to their batteries.

If you are modifying any part of your DC electrical system, recommend consulting CSA Z240.6.2 or ANSI/RVIA LV as the life safety consensus body of knowledge. You might find the wiring sizing tables helpful, as well as guidance on how to properly protect, connect, and route DC wiring.

73/gus
You seem to be up on the relative codes for our trailers - would you take a look at these issues and see if they are within code?

US electrical code issues.

The transfer breaker panel should be UL approved - it's not. All electrical panels installed in the US since 1965 must accept only CTL breakers. Canada has allowed use of non-CTL breakers and is what Escape uses in the trailers.

An installed microwave must be powered by a dedicated circuit.

120vac and 12vdc wiring are not to be run together - a fault in the 120 wiring could feed into the adjacent 12v wiring and cause real problems. But that's the way all the wiring is run in the Escape. Code says that if all wiring is rated at or above the highest voltage, it can be done. Escape uses low voltage automotive primary wire zip cord for DC runs that is not rated for 120v.

Splices/wire junctions are not allowed inaccessible behind walls - take a look at your trailer and you will see them everywhere.

I could keep going but what's the point. Resolving these code questions would probably require rewiring most of the trailer anyway. I've already pulled over 300' of new wire in a 19' trailer to fix this stuff.

US Plumbing codes.

Air admittance valves are to be installed to allow access for maintenance. Escape installs one in the wall of the 21 bathroom that cannot be accessed without tearing out the wall.

Use of S traps are not allowed. The kitchen sink is installed with a S trap. The addition of an air admittance valve or replacement with a Hepvo valve is required to meet code.

ps. I really appreciate you being here to answer questions - I have been here all alone preaching code issues for too long.
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Old 01-08-2021, 11:19 AM   #3
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I wonder how they can comply with US standards to sell the bulk of their trailers here?

Thanks for the insight.
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Old 01-08-2021, 11:59 AM   #4
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I wonder how they can comply with US standards to sell the bulk of their trailers here?

Thanks for the insight.
It's not just Escape, most if not all trailer manufacturer's thumb their noses at meeting code with their trailers. If you really want to see a train wreck, take a look at a Keystone or similar trailer.

Escape must go by Canadian code which is different on a lot of points from US code.

When the trailers are imported, they are "supposed" to be built to meet US code - but nobody checks so they don't.
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Old 01-08-2021, 12:28 PM   #5
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My luck, They will start that before I get mine delivered and registered next week.
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Old 01-08-2021, 12:58 PM   #6
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Quote:
Originally Posted by gklott View Post
....
If you are modifying any part of your DC electrical system, recommend consulting CSA Z240.6.2 or ANSI/RVIA LV as the life safety consensus body of knowledge. You might find the wiring sizing tables helpful, as well as guidance on how to properly protect, connect, and route DC wiring.

73/gus
Thank You for the heads-up, Gus. I note that as of this date the RVIA website still references the "2018 edition - ANSI/RVIA LV Standard" as their "Association Adopted Standard". I suppose it will take some time for the association to formally adopt the 2020 edition.

In any case, are you aware of any source for the text of these standards that's accessible to we mere trailer owners, lacking affiliation with any of the promulgating bodies? It sounds like they'd be interesting reading at the very least, and as you mention of particular interest to 'modifiers'.
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Old 01-08-2021, 04:31 PM   #7
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RVIA LV 2020 not available free on line

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Thank You for the heads-up, Gus. I note that as of this date the RVIA website still references the "2018 edition - ANSI/RVIA LV Standard" as their "Association Adopted Standard". I suppose it will take some time for the association to formally adopt the 2020 edition.
RVIA just released the 2020 edition. Got mine via UPS on Wednesday. My understanding is that RVIA release constitutes adoption, and they removed the 2018 edition from RVIA online store. Recommend confirming this with an RVIA member. Suspect RVIA lags updating the separate "adoption" website page.

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In any case, are you aware of any source for the text of these standards that's accessible to we mere trailer owners, lacking affiliation with any of the promulgating bodies? It sounds like they'd be interesting reading at the very least, and as you mention of particular interest to 'modifiers'.
Unfortunately, I do not know of a free location to read an ANSI/RVIA LV version. The standard is ©2020. The RVIA store cost is $45. Recommend asking your library if they can obtain a copy.

The basic NFPA 70 NEC text and the NFPA 1192 RV text are available free to read at the NFPA website. Every three years I get the updated NEC handbook when I take a professional continuing education course. Otherwise the 2020 NEC Handbook is $200.

Wish RVIA followed the NFPA free access initiative.

73/gus
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Old 01-08-2021, 04:42 PM   #8
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Technical standards are typically not distributed free of charge, even online, because selling access to standards documents is how the bodies which produce them fund their work. There are exceptions; at least at one point CSA Z240 was one of the selected CSA standards which was available online free of charge.

If your local library doesn't have and can't get a standard, my suggestion is to check with the appropriate library of a university, college, or technical school. I read SAE J684 (the towing equipment standard) by visiting the engineering library of our local university. Not being a current or even former student of that particular university wasn't an issue for me at the time, although of course in-person access by anyone is currently likely to be limited.
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Old 01-08-2021, 05:02 PM   #9
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US and Canadian standards???

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Originally Posted by Dcboyd View Post
I wonder how they can comply with US standards to sell the bulk of their trailers here?
Good question. ETI might meet both standards.

We have the Canadian QAI certification now under CSA Z240. ETI might want the RVIA certification if actually sold in the US. To achieve RVIA certification, the trailer must comply with NFPA 1192.

For everything I checked, ETI has done an excellent job. ETI's quality is much better than we found in our 30' Airstream.

73/gus
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Old 01-09-2021, 09:01 AM   #10
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I wonder how they can comply with US standards to sell the bulk of their trailers here?
.
So I thought ETI provides a letter for US customers that says they comply with all applicable US standards. Don’t you need it to import and especially when you go get trailer title tags at your state?
Could explain why some have had problems with their DMV

Should I be adding these into a build sheet? Thinking the dedicated circuits and accessible valves, etc.
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Old 01-09-2021, 09:07 AM   #11
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Also I thought CSA put out a 2020 update to bring most items into conformity with NFPA.
https://www.techstreet.com/standards...0-rv-series-14
Which leads to asking if ETI has updated their build practices
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Old 01-09-2021, 09:55 AM   #12
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Also I thought CSA put out a 2020 update to bring most items into conformity with NFPA.
https://www.techstreet.com/standards...0-rv-series-14
Which leads to asking if ETI has updated their build practices
Unfortunately your link leads to an error. I wonder if it's to your personal account?
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Old 01-09-2021, 09:56 AM   #13
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NHTSA FMVSS vs consensus standards

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So I thought ETI provides a letter for US customers that says they comply with all applicable US standards. Don’t you need it to import and especially when you go get trailer title tags at your state?
ETI provides an original form HS-7. On that form, ETI certifies that the trailer "...conforms to all applicable Federal Motor Vehicle Safety Standards...and Bumper and Theft Prevention Standards..." That's 49 CFR Subpart B - Federal Motor Vehicle Safety Standards.

Texas initial registration requires an original HS-7. Suspect most US states are the same.

FMVSS is separate from the life-safety consensus standards published by CSA (new 2020 edition) and NFPA (new 2021 edition).

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Old 01-09-2021, 10:14 AM   #14
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So I thought ETI provides a letter for US customers that says they comply with all applicable US standards. Don’t you need it to import and especially when you go get trailer title tags at your state?
Could explain why some have had problems with their DMV

Should I be adding these into a build sheet? Thinking the dedicated circuits and accessible valves, etc.
Who is going to check if the trailer complies with all applicable US standards? Every authority assumes that the manufacturer is correct and the trailer has been built to standards.

Only after the owner starts digging into how the wiring and plumbing was done do the deficiencies show up.

Wiring splices that is hidden behind a solid wall are just that - hidden. No inspector is going to rip out walls to look for splices. Or for a air admittance valve that was buried in a wall.

The same on if the microwave is on a dedicated circuit. If an inspector pulled the installed microwave to check, he would see the sticker on the microwave outlet that says it's dedicated and assume that the builder wouldn't lie.

Oh, just so you understand that I'm not just bringing this up on the forum only. I have contacted Reace long ago about these problems and he made a point of ignoring them. Not worth his effort to correct - not when he's selling every Escape he can build. The new Escape is making changes - but they still have the Reace trained wiring people that keep doing it wrong.

And yes, I'm frustrated! These kind of issues should have been resolved long ago. There's no cost to Escape involved - just training on how it should be done and changing their wiring practices. Maybe if enough owners / buyers speak up, things will get changed. I would love to get a new Escape - there are a lot of improvements that I like. But I cringe when I think of all the wiring and plumbing issues that I would have to redo again.
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Old 01-09-2021, 10:25 AM   #15
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NFPA 1192 2021 edition

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You seem to be up on the relative codes for our trailers - would you take a look at these issues and see if they are within code?
NFPA shipped the 1192:2021 3 days ago. Should be here Monday. We are also updating our Canadian standards to the 2020 edition of CSA Z240-Series 14 and the new 2021 edition of CSA C22.1

Will wait to receive these, and then I will try to address your questions.

73/gus
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Old 01-09-2021, 10:36 AM   #16
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Contact QAI ???

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Who is going to check if the trailer complies with all applicable US standards? Every authority assumes that the manufacturer is correct and the trailer has been built to standards.
RVIA and QAI have programs to review or inspect designs, manufacturing process, completed product, and quality assurance program.

Seems you have addressed these with ETI. Did you raise your concerns with QAI? The QAI sticker by our door should mean something.

73/gus
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Old 01-09-2021, 10:43 AM   #17
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New standard versions are available

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Also I thought CSA put out a 2020 update to bring most items into conformity with NFPA.
Yes, the CSA Z240-14:2020 is out, and the NFPA 1192:2021 was just released. I too understand that CSA Group works closely with NFPA to harmonize the RV standards. Will be interesting to compare the new editions.

Would like to hear ETI's answer when asking about updating life-safety compliance.

73/gus
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Old 01-09-2021, 11:17 AM   #18
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RVIA and QAI have programs to review or inspect designs, manufacturing process, completed product, and quality assurance program.

Seems you have addressed these with ETI. Did you raise your concerns with QAI? The QAI sticker by our door should mean something.

73/gus
No, I never thought about it. But your right - that may be the thing to do if Escape doesn't want to correct these problems.

But since QAI certification is supposed to include random surprise inspections and the discrepancies I'm pointing out are obvious, I have to doubt if the QAI certification is worth much. Maybe I'm being too antagonistic.
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Old 01-09-2021, 11:48 AM   #19
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The same on if the microwave is on a dedicated circuit. If an inspector pulled the installed microwave to check, he would see the sticker on the microwave outlet that says it's dedicated and assume that the builder wouldn't lie..
Which specific code requires the Microwave be on a dedicated circuit?
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Old 01-09-2021, 12:27 PM   #20
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I had a dedicated outlet installed below the fridge for a portable floor heater.
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