Mike Dolt Enterprises Logo Mike Dolt Enterprises

Topic: UL 1838 and NEC 680

User: Jesse Livingston, Location: Grand Cayman

Asked on: Monday, August 11, 2025 at 2:53 pm EDT
Answered on: Monday, August 11, 2025 at 2:53 pm EDT

Question: Looking for some help on this one. We have specified a fixture with a UL 1838 listing to be installed within 5' of the pool edge. 680.23 (A) (6) would appear to allow this as long as the power supply is listed for swimming pool use. The inspector is arguing that it needs to be UL 676 listed, however; this listing refers specifically to "underwater fixtures" and the code only refers to "listed low-voltage fixtures".The inspector has also argued that 680.26 (7) requires all "fixed metal parts" to be bonded, however; I do not think a "light fixture", is a "fixed metal part". While the fixture is metal, 680.23 (A) (6) states "not requiring grounding".Love for some opinions on this one. Thanks in advance.

Okay, let's break this down and address the inspector's arguments. You're encountering a common situation where interpretation differences arise, so clarity and code references are key.

Regarding the Fixture Listing (UL 1838 vs. UL 676)



Your Interpretation is likely correct.
The inspector is probably overreaching by demanding a UL 676 listing. Here's why: UL 676 explicitly covers underwater lighting fixtures. Your fixture is not underwater. It's within 5 feet of the pool edge, which is a different scenario. NEC 680.23(A)(6) speaks specifically to "listed low-voltage lighting systems, not requiring grounding." The key here is listing. If the fixture is UL 1838 listed (Low Voltage Landscape Lighting Systems) and the power supply is listed for swimming pool use, you likely meet the requirement. UL 1838 is a very common listing for landscape lighting, and it addresses safety concerns like waterproofing and low-voltage operation. Your fixture is not in the water. UL 676 is for lighting in the water itself. The Key Argument to the Inspector

Show them the UL 1838 listing on the fixture. Emphasize that 680.23(A)(6) requires a listed fixture and a power supply listed for pool use, and that you've met those criteria with UL 1838 and a suitable power supply. Ask the inspector to provide the specific section of the NEC that requires a UL 676 listing for
above-ground fixtures within 5 feet of the pool.

Regarding Bonding (680.26(B)(7) and "Fixed Metal Parts")



Your Interpretation is likely correct again.
The inspector's argument about "fixed metal parts" is likely flawed in this context. Context is Crucial

680.26(B) deals with equipotential bonding in the pool area. It aims to minimize voltage gradients in the water and surrounding areas to prevent shock hazards.


"Fixed Metal Parts" is not a catch-all term.
It generally refers to things like: Metal reinforcing structures in the pool shell (rebar) Metal piping Metal fences or railings close to the pool Metal parts of pump motors A Light Fixture is a manufactured product, not site fabricated. 680.23(A)(6) is the overriding section here. It explicitly states "not requiring grounding" for listed low-voltage lighting systems near pools. Bonding and grounding are closely related concepts for electrical safety. If the code exempts you from grounding, it's highly unlikely it also requires bonding. The exception exists for a reason - safety is already achieved by the low voltage and the listing requirements of the fixture and power supply. The intent is to prevent shock between different sources The Key Argument to the Inspector

Reference 680.23(A)(6) and its "not requiring grounding" clause. Explain that the fixture is a manufactured product with a listing designed to ensure safety without grounding or bonding. Ask the inspector to specifically explain how bonding this listed low-voltage fixture achieves a safety goal that isn't already met by the listing and low-voltage operation.

In Summary & Recommendations


Documentation is Key

Gather all documentation about your fixture:
The UL 1838 listing information. The listing information for the power supply showing it is listed for swimming pool use. The manufacturer's installation instructions. A copy of NEC 680.23(A)(6).
2.


Diplomacy First

Start by calmly and respectfully discussing your interpretation with the inspector. Point out the relevant code sections and the fixture listings. Ask for clarification on
why the inspector believes UL 676 and bonding are necessary, given the specific language of 680.23(A)(6).
3.


Escalation (if necessary)

If you can't reach an agreement, escalate the issue.
Talk to the inspector's supervisor.* Contact the local electrical code authority for an official interpretation.4.

Get a Second Opinion:
If the local authority sides with the inspector, consider getting an opinion from a qualified electrical engineer familiar with pool codes. A written opinion from a PE can carry weight.Good luck! You appear to be on solid ground with your interpretation. The key is clear communication, documentation, and a willingness to discuss the code rationally. Flag for review

Previous Question View on the official Mike Holt Forum Next Question