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HERE are my posts that was called spam. I was blocked on the Cross Fox Facebook because I reported my research to other owners.
As mentioned above, I started my research on Dec. 18. On Dec. 30, I posted my conclusions, I made several posts after that to support my position. Here is that first post: No matter how this issue is finally resolved, I believe we should seek another insurance company. It is unconscionable for them to put this burden on the residents of Cross Fox during a COVID pandemic. There are many here who are in the high risk age group and don't want workmen going into every nook of their private living space. Worse still, the insurance company did not specify what penalty they would impose if everyone did not comply, and set a possible deadline in the worst part of winter when the spread of COVID will be at its worse. This is causing much distress for some of our neighbors. The fix they require is not a standard recognized by electrical contractors. Contractors use electrical code which is based on UL listed parts. Our insurance company is requiring that the fix be done to CPSC publication 516. There is disagreement between UL and CPSC. Pub 516 is just general guidance. It does not say how the contractor is to resolve conflicts with UL code. Our insurance company did not provide a written specification that could be passed to the contractors for a quote. The result is that contractors may perform incomplete work and may not even realize it. We should seek an insurance company that sticks to the code, and treats guides as guides, not as edicts from above.---
Our management and the insurance company told us to fix our wiring, but did not specify exactly which connections had to be fixed. On 1/5/21, I posted this on our Facebook:
We are getting widely different quotes from contractors partly because they have different opinions on which connections need to be fixed. The latest guidelines from our management are outlets, switches and light fixtures. Some contractors are only doing outlets and switches, not light fixtures. Our management told me that people who did not do their light fixtures need to call back their contractors.
I am not sure who told our management that was all that needed to be fixed. What about the ceiling fan fixture for the bathroom? That is why we need to demand exact written specifications from our insurer, Millers Mutual. We need to be able to hand that document to a contractor for a quote.
Every connection to our branch wiring may need to be treated. Here is an excerpt from CPSC Pub 516, which Millers is using as the sole justification for their demands. On page 4:
"Every connection of aluminum-to-aluminum or aluminum-to-copper wire should be repaired in order to obtain the maximum benefit from such repair work. All appliances connected directly to No.12 or No.10 AWG aluminum branch circuit wiring (e.g., dishwashers, cooling equipment, heaters, air conditioners, and light fixtures) must be repaired in addition to wall outlets, switches, junction boxes, and panel boxes."
Unless Millers Mutual provides explicit written instruction to override Pub 516, they could say we did not properly fix our wiring if we make a claim in the future. It is to Millers' advantage to be vague about the specification. That way they cannot be blamed if a contractor does an incomplete job.
If Millers continues to refuse to provide written specifications, we should refuse to do the fix and file a complaint with the Maryland Insurance Administration. There are other insurers that provide master condo insurance without demanding this fix. I know State Farm does. There may be more. People can check the policy for their HO6 insurers.
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I added this on 1/9/21:
Another reason we are getting widely different quotes from contractors is that some may not be doing inspections. Howard County requires that a permit be acquired for any electrical work. To close a permit you have to schedule an inspection. The cost of a permit is $55 or $105, which includes the cost of an inspection. But the real cost is what additional work the contractor has to do to pass inspection. When you make a modification to your wiring, you may be required to bring your wiring up to current electric code. Our wiring is 50 years old and is way behind current code, but it is grandfathered as long as you leave it alone. Pig-tailing with AlumiConn will require you to add at least AFCI breakers. I am not sure about COPALUM.
We are required to submit a scope of work and a paid receipt. But this does not say if you had and passed an inspection. I was told that an inspection affords a certain amount of liability protection with the county. So if there is a fire, the county can check its inspection records if there is a question of liability. If the county determines that the wiring was not inspected, the insurance company would probably deny the claim.
It would seem that we could use the inspection record to prove compliance. However, the insurance company is disallowing some fixes that are code compliant but not approved by the CPSC. Inspectors do not check for CPSC compliance; so we have to keep our own records. But hidden in these records may be proof that we did not comply. One contractor had in its scope of work that he fixed all connections with AlumiConn; so his work was accepted. But it also listed which connections were fixed, and it did not list light fixtures. The contractor told me that the light fixtures did not need to be fixed because they were rated for aluminum. So all the connections that needed to be fixed were fixed with AlumiConn. This is up to code and would have passed inspection, but is disallowed by CPSC. The insurance company could use this scope of work to prove non-compliance and deny a claim.
The problems don’t end after all the fixes are done. Years from now an owner may make an electrical addition, like a new outlet. The electrician may use an Ideal-65 purple twister to connect to the aluminum branch wiring. These purple twisters are popular with electricians, are up to code and will pass inspection. But they are specifically disallowed by CPSC. Even if there are no records, a purple twister found in the remains of a fire would prove non-compliance and provide grounds to deny a claim.
By providing no or poor requirements for work, inspection, record keeping and electrical additions, the insurance company is making it easy for us to be non-compliant and not know it until we file a claim. The owners of 244 units, with little knowledge of electric wiring, are searching for the cheapest price from contractors, who don’t know about CPSC, with a closing deadline during the worst part of a global pandemic. Do you think we are being setup to fail?
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On 1/12/21, I posted:
We need to be skeptical of the aluminum wiring safety guidance from CPSC, Consumer Product Safety Commission. I searched the CPSC website document database; Pub 516 is the only CPSC document covering aluminum branch wiring remediation. It is just an eight page pamphlet last updated in 2011, with no cross references for support. It was meant to be a standalone guide for homeowners managing risk on their own property. The homeowner is free to accept, modify or reject any part of the guidance found in the CPSC pamphlet.
As condo owners, we are in a different situation. Our insurance company is lumping our risk together saying that we must all be CPSC compliant. Our only choice is which CPSC option to follow. CPSC Pub 516 was never meant to dictate mandatory requirements for an entire community. For that you need something like the NEC, National Electric Code, used by all electrical contractors and inspectors, with only some modification at the county level. The NEC has a rigorous update process and a new NEC is published every three years; the latest is NEC 2020. Since the last CPSC Pub 516 update ten years ago, there have been three revisions of the NEC. None of them has incorporated any CPSC recommendation that was not already part of NEC from the start.
The NEC uses UL, Underwriters Laboratories, to evaluate the safety of electrical components. UL is a private company with revenues of about $2.5 billion. CPSC is a federal agency with a budget of about $130 million. They cannot afford the same level of product testing as UL. So who are we to believe when the guidance from CPSC is in direct conflict with UL?
Our condos were built in 1969 when the copper prices were high and aluminum was used as a substitute for branch wiring in buildings. The aluminum wire was a poor match for the steel terminal screws that had been used with copper wire. Due to differences in thermal expansion, air gaps formed over time leading to arcing and fire. To reduce the risk of fire, terminals and their screws have to be rated for aluminum (CO/ALR), or have a short copper wire pigtail between the terminal and the aluminum wire. The pigtails were connected to the aluminum branch wire with the same twist-on splicers that were used for all wire-to-wire connections. Our condos were fixed with a combination of CO/ALR and copper pigtails spliced with twist-ons. This approach is still allowed by NEC 2020.
UL found that in practice many twist-on splicers were installed without adding an anti-oxidant paste to the connection. So they then allowed only twist-ons that were pre-filled with anti-oxidant. Our old twist-ons were not pre-filled. Even though they lost their UL listing for new construction, they are still NEC compliant due to grandfathering. We can assume that they were installed properly, which makes them as safe as the pre-filled twist-ons that are still UL listed.
Contrary to UL, NEC and local code, the CPSC is saying that CO/ALR and twist-on splicers are dangerous when used with aluminum. Copper pigtails must be used for all terminal connections even on CO/ALR. All splices to aluminum branch wiring must be done with COPALUM or AlumiConn; twist-on splicers are forbidden. This includes aluminum-to-aluminum splices that are not in contact with copper. Even if you don’t have a junction box, there is probably an aluminum-to-aluminum wire splice near to, but not connected to, the terminals of each of your switches.
So why does CPSC and UL come to such different conclusions? It seems that all these connectors work fine when installed correctly. The failures in the field were attributed to improper installation. Both UL and CPSC felt the need to performed tests under typical installation conditions which may include common mistakes. You can make anything fail if you include enough mistakes; so lab tests are not entirely objective and may be a depend on the values of the testers. CPSC needs to report risks to justify their existence. Their recommendations, by themselves, are optional; they suffer no consequence if they exaggerate. UL needs to report risks honestly to maintain their public credibility. They need to be cautious because their analysis will affect their clients through mandatory standards.
Risks are interrelated; reducing the risk in one area, may increase the risk in another. Replacing our connectors, may damage our aluminum wires. Very old aluminum wires are brittle and if bent can form small internal cracks where hotspots can develop. To install COPALUM or AlumiConn on our 50 years old aluminum wire, the wire ends will have to be pulled clear from the wall and packed back in. The wire could be damaged without anyone knowing it. The reports from the CPSC are narrowly focused; Pub 516 just focused on connectors and said nothing about potential wire damage. On the other hand, reports from UL will be integrated in the NEC which has to consider the overall safety of electrical wiring.
And then there is the cost. People always want more safety as long as they are not paying it. Well, we are paying for this wiring change, and we should take the time to understand what we are paying for. If we are rushed into making this change, without proper analysis and discussion, we could end up with a costly repair that is less safe than what we had originally.
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On 1/14/21:
Even though the CPSC warnings are not supported by UL, there must be some risk involved. The issue isn’t if there is any risk, but how much risk. There so little information given in CPSC Pub 516 that it is hard for us to judge. But there are some clues. On page 7, CPSC says this about twist-on connectors, “In CPSC-sponsored laboratory testing and life tests, substantial numbers of these connectors overheated severely”. The key word is “overheated”. That means that the problem is dependent on the amount of current flowing through the connector. Overheating is a problem for the wires, not just the connectors; that is why we have circuit breakers. The danger is if too much current flows through a connector without tripping the breaker. For that we need to know the lowest current for which there is problem; that number is missing from Pub 516.
There is information on the web that could set the number to 17 amps. On the InspecAPedia website, there a 1995 presentation to CPSC by Dr. Jess Aronstein. Dr. Aronstein was not mentioned in Pub 516, but it is well known that he had a major influence on CPSC’s warnings for twist-on connectors. Dr. Aronstein had been a long opponent of twist-ons and presented his self-funded research to CPSC in that 1995 presentation. His slides did not show much data except on slide 5, here is the caption, “The fire hazard posed by these splices when they fail is easily seen when the ‘burnouts’ are observed while passing current. At about 17 amps, less than the 20 Amp rating of the (#10 aluminum wire) circuit, the connector spring is red hot. The voltage drop is about 2 volts, so downstream loads operate normally”. (https://inspectapedia.com/aluminum/Copper_Pigtail_Aluminum_Wire_Failures.php).
In his presentation, Dr. Aronstein was trying to convince CPSC of the dangers of twist-on connectors; so he had every reason to show the lowest current where there was a problem, 17 amps. Aronstein was correct to say that 17 amps will not trip a 20 amp breaker, but most of the wiring in a home use 15 amp breakers and they should trip before they get to this level. In my one bedroom apartment, there are three 20 amp breakers, for the dishwasher and outlets in the kitchen and dining room. There is a 30 amp breaker for the AC which is safe because its wiring was designed for high currents. All the rest of the wiring, including the switches and fixtures in the kitchen and dining room, are on 15 amp breakers.
We could make the case that we would comply with CPSC if we just fixed the wire branches on 20 amp breakers. Our breaker panel is between the kitchen and the dining room; so the 20 amp branch wiring is short and the easiest to replace. We should be able to do full copper rewiring just on our 20 amp branches cheaper than putting AlumiConns on all of our wiring, and it would be probably safer as well. An even cheaper fix, if allowed, would be to replace our 20 amp breakers with 15 amp.
We may already have copper wiring on our 20 amp branches. That is the case in my apartment, but I am not sure if the previous owner had it installed or if they were there from the start. The builders of our condo would have good reason to use copper on 20 amp branches and aluminum on 15 amp branches. Aluminum was cheaper but its reliability was unproven for high currents. The 20 amp branches were short, so the cost of using copper only for high currents was reasonable. If anybody wants to check the wiring their condo, just let me know in the comment section and I can provide guidance.
If our insurance company is truly only concern with reducing fire hazards, they should welcome this compromise. If they continue to insist that we follow CPSC Pub 516 exactly as written, I would have to question their motives. They have given us so little guidance, that it would be easy for us to make the fix incorrectly. Thinking that we complied, we would continue to make premium payments year after year. The insurance company will gladly pay small claims to continue to collect those premiums. But if there was a big fire, a little digging will show that we did not comply with this required fix, and the insurance company will have the grounds to deny the claim or use it as a bargaining chip. Even if that big fire never happens, they know they have less risk exposure and will be able to take more risk leading to more profits.
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On 1/16/21:
The requirements of our wiring fix comes from our insurance company, not from CPSC. I emailed CPSC to determine what exactly Pub 516 required. In essence, Pub 516 was written as a consumer guide, not to serve as a supplement to local electric codes. An HOA or insurance company may use Pub 516 to guide the formation of their own mandatory policy. But their mandatory policy must clearly state what is required. Pub 516, by itself, was not meant to be a requirements document.
This means that our insurance company must document exactly what the requirements are, how they are verified, what records must be kept and how the requirements are enforced in future electrical work. The insurance company could simply declare Pub 516 as the requirement document, but the language of a guide is different from a requirements document. The suggestions in a guide are optional. They may be accepted, modified or rejected as you weigh the risks and the cost. A guide tells you the maximum that you should consider, while a requirements document defines the minimum that must be done.
Since Pub 516 is just a guide, it did not have to warn us that changing the connections could damage our brittle 50 years old aluminum wire, making it more dangerous than the original connections. A properly written requirements document would let some of those affected review them and make suggestions. The brittle wire problem would be identified and the requirements adjusted.
In our case, the aging problem of aluminum wiring should be the primary focus. Any remediation of just the connectors should be considered a temporary fix. Eventually, the insurance company may come back and demand we change our aluminum wiring. The expense of the connector fix would be wasted.
A better approach would be to use the 80/20 rule; 80% of the problem can be address with 20% of the cost. Lab tests have shown that the overheating problem occurs at 17 amps. We can easily replace the wiring in the short 20 amp branches and leave the longer less risky 15 amp branches alone for now. They can be replaced when a condo unit changes ownership.
We can work with our insurance company to help them refine their requirements. A company interested in good customer relations should welcome this win-win opportunity. But our insurer has not been customer friendly. They insisted on this evasive wiring change during the worst part of a global pandemic. We do have other options; I contacted State Farm. They offer a master condo insurance policy, even with our wiring the way it is. They are willing to talk to our management.
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This was the post that I was unable to post on 1/17/21:
Does everybody know the difference between SHOULD and SHALL. SHOULD means that it is a recommendation, while SHALL means that it is mandatory. CPSC Pub 516 never uses SHALL and uses SHOULD in several places, including the quote I cited on my 1/5/21 post, "Every connection of aluminum-to-aluminum or aluminum-to-copper wire SHOULD be repaired”. Here is something I found on the web, “SHOULD is equivalent to RECOMMENDED means that there are valid reasons to ignore a particular requirement, but the implications need to be weighed”. That is why it is dangerous to blindly convert a recommendation to a requirement. That may be why our insurance company is so reluctant to provide written specifications that we can use to shop for services. If we are the ones to specify what must be done, then we are liable for any negative consequences.
What kind of negative consequence? The possibility of a fire is very low; so even if your fire risk has increased, there is a good chance that a fire would never happen. But the reliability of your electric wiring may suffer. Consider AlumiConn. CPSC Pub 516 has this caveat on page 6, ”The AlumiConn connector has performed well in initial tests, but is too new to have developed a significant long-term safe performance history”. Because AlumiConn did not have a long use history back in 2011 when Pub 516 was written, AlumiConn’s evaluation was based on proper installation. The other connectors were tested on common use, including common installation mistakes.
While there was no long term use history, you can make a judgement on possible mistakes by how AlumiConn is installed. The AlumiConn installation instructions can be found at https://www.kinginnovation.com/pics/db/docs/59-5010046AWAlumiConnREVM.pdf. You see that it is primarily a screw based connector and looks easy. Anybody can get an AlumiConn connector from Amazon for less that $4 apiece. A person not heeding the instructions would just tighten the screws with a good hard twist, easy and fast. But the instructions give specific torques that must be used on each kind of wire; it is a different torque setting for aluminum wire than for copper wire. The instructions warns, “Not following recommended torque instructions can result in failure”. The kind of failure they are referring to is probably metal creep, also called cold flow, which is a problem for aluminum but not copper. Aluminum under stress, like beneath an over-torqued screw, will slowly flow away from the stress. In an electrical connector, a gap could develop under the screw and lead to arcing. The problem could take a long time to manifest, possibly years; I don’t know about decades.
That is why CPSC Pub 516 say, “repair should be conducted by a qualified electrician because careful, professional workmanship and thoroughness are required to make the AlumiConn connector repair safe and permanent”. A skilled electrician will use a torque screwdriver and make sure to use the correct torque setting for every screw. Easy for a few connectors, but difficult if there are a large amount of connectors and a limited time, as would be the case for a low bidder. For my one bedroom I calculated 432 screws (asks me in the comments if you want a breakdown).
There is no way to determine if the screws were tightened to the right torque by just looking them. The screw actually cuts into the wire and over torquing will damage the wire. So if an electrician knows he over-torqued, he cannot simply loosen the screw. It would be easier just to close the lid covering the screws; no one will ever know. It takes time for air gaps to develop; so screws tighten to the wrong torque will probably still work okay during the warranty period.
Possibly years after installation, an incorrectly torqued AlumiConn may arc, sporadically at first. The arcing will probably not start a fire, but they can trip the AFCI breaker that we were required to install. We will have to reset the breaker every time this happens to restore power. So we will be safe but sorry. We traded a small overheating risk on just our 20 amp branches, for an arcing risk which could happen anywhere even where there is very low current. There is no one to sue, since we were the ones to specify what must be done to our contractors. We must insist that the insurance company provide written instruction to the contractor on what work must be done. If they are potentially liable, then they will have to be more careful when they issue these mandates.