Minor Labels

Q. Can I use a minor label to replace a defective ballast?

A. Yes, up to 5 under one label, limited to 120-240V.
(June 19 Tri-County Electrical Code Forum)

Q. What is the definition of "device" under the minor label rules?

A. There are many devices named specifically in the rules (see OAR 918-309-0220 (D) including (but not limited to ) alarm contacts, smoke detectors, heat detectors, and central vacuum clean control devices.
(June 19 Tri-County Electrical Code Forum)

Q. I would like clarification on the scope of work allowed under the minor label rule, OAR 918-309-0220(3)(d)(I), which allows the installation of up to five thermostats under one label. Does this mean that a contractor can install only five thermostats and nothing else? Thermostats can control furnaces, which in turn can run in conjunction with air conditioners or other items such as VAV boxes in commercial buildings. If the contractor can wire anything downstream from a thermostat and still be under the approved rule, this could lead to hours of inspection labor for one minor label. With the new technology of HVAC controls, it would be possible to have one thermostat control hundreds of VAV boxes that may have Class II transformers.

A. The minor label rules allow for the installation of five thermostats only, not for any accessories to the thermostats.
(August 8,2002 Tri-County Electrical Code Forum)

Q. We are confused about doing installations in rowhouses. In some jurisdictions, we find it is OK to post a minor label for vacuum systems in each unit. In others we are told to get a restricted-energy permit for installations in each unit. Is this up to the jurisdiction to decide?

A No, it is not up to the jurisdiction to decide. Each rowhouse is considered a separate property, so a minor label can be used at each address. See the question about thermostats, above.
(August 8,2002 Tri-County Electrical Code Forum)

Q. We are planning to post a minor label on a commercial installation and we have one installer who has a restricted energy license. He will be supervising the work of two other vacuum installers. Is there a problem with this?

A. Yes, there is a problem. For commercial work, licensing and apprenticeship rules need to be followed.
(August 8,2002 Tri-County Electrical Code Forum)

Q. If we hire a subcontractor who has a restricted energy license to install our wire in a commercial application, can we post the minor label and have this person do this work?

A. No. See OAR 918-309-0000(4).
(August 8,2002 Tri-County Electrical Code Forum)

Q. On vacuum system installations, if the electrical panel is not on site is it correct to post minor labels on the furnace?

A. If no electrical panel is available, you can post the label on the installation itself or on the furnace, if it is visible and accessible. You must note the location of the label on the back of the label log sheet if you do not post it on the electrical panel. See 918-309-0000(4)
(August 8,2002 Tri-County Electrical Code Forum)

Q. If we post a minor label on a job and start the job, but completion gets delayed for three weeks, and the minor label sheet is mailed anyway, what are the ramifications for the installing contractor if the job is inspected?

A. The contractor should log the job as incomplete on the minor-label sheet and contact the Tri-County Service Center and the jurisdiction to advise them that the job was not complete.
(August 8,2002 Tri-County Electrical Code Forum)

Q. If we post a minor label or an installer log on a job, and it disappears from the site because the builder or another contractor removes it, it blows away, or it is covered by paint or plasterboard, are we responsible for posting a new minor label or installer log? How does one prove whether a minor was posted in the first place?

A. The installer is responsible for proving that the sheet was posted. Communication and trust between the contractor and inspector is crucial in this scenario.
(August 8,2002 Tri-County Electrical Code Forum)

Q. I understand that you can extend up to two circuits under one minor label. Is there a limit to the number of receptacles or switches I can add to the circuit?

A. The limitation of the number of receptacles on a circuit is based on the load characteristics and whether they are residential or commercial, not the number of receptacles. (Tri-County Code Forum, May 9, 2002)

Q. Where (on or in commercial high-rise buildings ) in commercial high rise building should contractors place minor labels when the electrical rooms are typically locked and it's difficult to determine from which electrical room and which floor the circuits are fed?

A. Contractors should place labels on the panels feeding the circuit or the equipment or on the installation when they have no access to the panel. Contractors should record in the "notes" section on the minor label hard-cards where the label was placed so that the inspector can easily find it. (Tri-County Code Forum, November 7, 2002-Approved by the state code chief for statewide application)

Q. Are there any limits on square footage for using minor labels on commercial jobs?

A. No. See OAR 918-309-0220. (Tri-County Code Forum, November 7, 2002-Approved by the state code chief for statewide application)

Q. Does installing a security system in a large commercial building fall within minor-label work for a contractor who has a limited-energy license?

A. No, See OAR 918-309-0220.
(Tri-County Code Forum, November 7, 2002-Approved by the state code chief for statewide application)

Q. I am installing a low-voltage security alarm in a, commercial building divided into three businesses. Each suite has its own suite number. Can I use a minor label for each installation? As this is new construction and the suites are unoccupied, the contractor wants us to re-address this question.

A. No, minor labels cannot be used for new construction. (Tri-County Code Forum, November 7, 2002-Approved by the state code chief for statewide application)

Q.A new house has been pre-wired for a future air conditioner. The disconnect, feeder, and breaker are in place. All work was permitted and approved at construction. One or two years later, the homeowner has a 40-amp a/c installed. Can a minor label be used for the final whip between the previously approved system (disconnect) and the new a/c?

A. No. See OAR 918-309-0220(1)(b). (May 1, 2003 Tri-County Code Forum; approved by state electrical code chief for statewide application)

Q. Can you use a minor label to install a GFCI?

A. Yes. 918-309-0220
(May 1, 2003 Tri-County Code Forum; approved by state electrical code chief for statewide application)

Q.When installing a single circuit in a newly constructed bedroom, can a minor label be used to set a sub panel with a single 20-amp arc-fault breaker feeding the bedroom?

A. No, the minor labels may not be used for such an installation in new construction. However, in a remodeled bedroom, where the existing panel box is not compatible with AFCI breakers, a small sub panel, limited to 30 amps and two circuits, that will accept an AFCI breaker, can be installed using a minor label. (May 1, 2003 Tri-County Code Forum; approved by state electrical code chief for statewide application)

Q: Scope of Work Minor Label: 918-309-0220 states that a door or gate control, monitor, or up to five access devices can be installed under one label. Does this mean we can install a double swing gate operator system under one label?

A. Yes, it is allowed if it is a single circuit.
(Tri-County Electrical Code Forum September 11, 2003)

Q. There is electrical work being done using a minor label on a remodel or addition where it will be covered with wallboard. Is this permitted under the present code? The electrical contractor says it is done all the time.

A. No, if installed after April 1, 2004 for electrical systems, except for One- and Two-Family Dwelling limited energy systems. The intent is that if the walls are opened up an inspection should occur. If the walls are not opened up, "fishing" the cable in the wall is still allowed.
(Tri-County Electrical Code Forum April 28, 2004)

Q. Minor Labels: Under (1) (a) contractors are allowed the extension of two branch circuits and the connection of an appliance. Does that mean the connection of an appliance to each of the repaired circuits? Or may we only connect one appliance -and if we need to connect two, will that require a full permit?

A. Yes, two appliances can be connected.
(Tri-County Electrical Code Forum April 28, 2004)

Q: I was recently failed on a minor label inspection in which I had extended two circuits (adding a number of light switches and receptacles) and pulled the mud rings and pull strings for the low voltage that the homeowner will have installed by another contractor. Does this installation exceed the scope of a minor label installation?

A. The scope of work allowed by a minor label is found in OAR 918-309-0220.The quick answer is "No. " If you needed to contest your inspection results, contact the senior inspector or the building official. However, more information is needed than what is presented in the question. In order to answer the question fairly, input from the jurisdiction is needed. Other extenuating circumstances could have caused that minor label to be failed.
(Tri-County Electrical Code Forum November 20, 2003)

Q. I respectfully request a clarification of work allowed under minor label regarding (1)(c): repair or replace damaged components of existing electrical equipment including services not to exceed 200 amps.

I understand this to mean that a main breaker, meter jaw, bus bar or similar component can be repaired or replaced in an existing installation under 200 amps. Would this definition include a riser damaged by weather or vehicular traffic or a burnt meter jaw for which there are no replacement parts or panels that are not available any longer?

A. If a reconnect by the utility company is required, a reconnect permit, not a minor label, is required. See 918-309-0040(10). Additionally, ORS 479.570 requires an inspection before equipment is re-energized, unless a letter to energize is used by the supervising electrician. (Tri-County Electrical Code Forum September 11, 2003)