This is a common question with some nuances. Here's a breakdown to help determine if GFCI protection is required for the branch circuit breakers feeding those washroom (bathroom) electrical loads

Key Considerations:
Article 210.8(B) - GFCI Protection for Personnel - Other Than Dwelling Units

This section is the core requirement to review. It lists specific locations and equipment requiring GFCI protection in non-dwelling units.

Analysis


Is it a "Bathroom"? The NEC defines a bathroom as: "An area containing a sink, as well as one or more of the following: a toilet, a urinal, a tub, a shower, a bidet, or similar plumbing fixture."2. Application of 210.8(B)

Assuming your washrooms do meet the definition of a bathroom, here's how 210.8(B) applies:

Receptacles

GFCI protection is

required for all 125V through 250V receptacles rated 50A or less supplied by single-phase. Specific Equipment



Sinks GFCI protection is required for receptacles within 6 feet (1.8 m) of the outside edge of the sink. Electric Drinking Fountains GFCI protection is required for electric drinking fountains. Electric Vehicle Charging GFCI protection is required for electric vehicle charging equipment. Hardwired Equipment

210.8(B) now requires GFCI protection for specific hardwired equipment in bathrooms. Note that the list of equipment below is for other than dwelling units only: Electric water heaters.

HVAC equipment.Answer



Lighting

Lighting circuits in a commercial bathroom generally do not require GFCI protection under 210.8(B) unless your local jurisdiction amends the NEC.

Hand Dryer

Hand dryer circuits in a commercial bathroom generally do not require GFCI protection under 210.8(B) unless your local jurisdiction amends the NEC.

Water Heater

GFCI protection

is required for the branch circuit(s) feeding the electric water heater.

Unit Heater

GFCI protection

is required for the branch circuit(s) feeding the unit heater.

Important Considerations



Local Amendments

Always check with your local Authority Having Jurisdiction (AHJ) for any local amendments or interpretations of the NEC. Some jurisdictions may have stricter requirements and require GFCI protection for additional circuits.

Dedicated Circuits

Even if GFCI isn't strictly required for lighting or hand dryers, using dedicated circuits can improve reliability and reduce the chances of nuisance tripping if other equipment has a ground fault.

Good Practice

While not always required, using GFCI protection more broadly in wet or damp locations is generally a good safety practice.

Panel Location

The panelboard being outside the washroom doesn't change the GFCI requirements for the circuits supplying the washroom loads.

210.8(A) It's worth noting that 210.8(A) covers dwelling unit GFCI requirements, which are different and often more extensive. Make sure you are only reviewing 210.8(B).

Recommendation

Based on your description, I recommend the following:1.

GFCI Protection

Install GFCI protection (either at the breaker or with a GFCI device upstream) for the water heater and unit heater circuits.2.

Verify Definitions

Confirm that the rooms truly meet the NEC definition of "bathroom."3.

Consult AHJ

Check with your local AHJ to confirm their interpretation of the NEC and any local amendments. This is critical.

Disclaimer:* I am an AI chatbot and cannot provide definitive electrical code advice. Consult a qualified and licensed electrician for your specific installation. They can perform a proper assessment and ensure compliance with all applicable codes and regulations. Flag for review