You've correctly identified the basic requirements of NEC 210.8(B)(2), which mandates GFCI protection for 3-phase branch circuits rated 150 volts to ground or less, not exceeding 100 amps. The fact that it's a commercial kitchen reinforces this.

Here's a breakdown of why you're likely correct and what, if any, potential "outs" might exist, although they are unlikely in your specific scenario



NEC 210.8(B)(2) is Clear

This is the primary rule requiring GFCI protection. Your understanding is correct. 208V 3-phase systems typically have 120V to ground (208V / √3 = 120V), and a 30A circuit falls well under the 100A limit.

Commercial Kitchens

Commercial kitchens are subject to increased scrutiny and generally have stringent safety requirements, making GFCI protection even more important.

Possible (but unlikely) "Ways Around" (and why they probably don't apply)


Voltage Above 150V to Ground

This is the only real direct workaround in the code. If the voltage to ground exceeded 150V, GFCI wouldn't be required by 210.8(B)(2). However, you're describing a 208V system, which, as stated above, has 120V to ground.
2.

Dedicated Circuit Exception (Very Unlikely)

In rare circumstances, some jurisdictions might allow an exception for "critical processes" where GFCI tripping would create a greater hazard. However, this is extremely unlikely for a grill in a commercial kitchen. This exception is generally reserved for things like life-safety equipment or very specialized industrial processes, and requires very strong justification and AHJ approval.3.

AHJ (Authority Having Jurisdiction) Approval

The AHJ always has the final say. You could present a well-reasoned argument as to why GFCI protection is not necessary in this specific case, but it's a long shot. You'd need to demonstrate that it's impossible or impractical to implement GFCI without creating a greater hazard. Furthermore, most AHJ's won't accept this in a commercial kitchen.4.

Older Code Interpretations

If the building was permitted under a significantly older version of the NEC, the GFCI requirements might have been different or non-existent. However, any new work is typically required to meet the current code, and this option would not be valid.

Why GFCI is Important for Commercial Kitchens



Wet Environment

Kitchens are inherently wet environments, increasing the risk of electrical shock.

Contact with Metal Surfaces

Employees frequently come into contact with grounded metal surfaces (sinks, counters, equipment).

Increased Usage

Commercial kitchens see much heavier usage than residential kitchens, increasing the likelihood of equipment wear and potential faults.

Recommended Action


Assume GFCI is Required

Start with the assumption that GFCI protection is required. This is the safest and most compliant approach.2.

Consult the AHJ

Before proceeding with any installation, directly* consult with the local AHJ (electrical inspector). Get their specific interpretation of the code and whether any local amendments or exceptions apply. Document their guidance in writing.3.

Explore GFCI Breakers/Receptacles

Investigate available GFCI breakers or receptacles that are compatible with your 3-phase 208V system. GFCI breakers are typically the preferred solution for new circuits. Be sure to choose a product that is UL listed and suitable for the application.4.

Thoroughly Test

After installation, thoroughly test the GFCI protection to ensure it functions correctly.5.

Document Everything

Keep records of all communications with the AHJ, product specifications, and testing results.

In Summary:

While technically possible to argue against GFCI protection in some cases, it's extremely unlikely to be successful in your commercial kitchen scenario, given the current NEC and the inherent safety considerations. Focus on proper GFCI implementation after discussion and approval from the AHJ. Trying to avoid it is generally not worth the risk or potential code violations. Flag for review