Corrugated Stainless Steel Tubing: A Letter from the Board of Examiners of Electrical Contractors

Dear Mr. Smith:

It has recently been brought to the attention of the  NJ Board of Examiners of Electrical  Contractors ("the Board") that code officials in some  municipalities are demanding that electrical contractors  install the bonding jumper for CSST installations, as  required by the IRC/2009 and the IFGC/2009.

Apparently, this is occurring even when the electrical  contractor was not under contract to perform any work  related to the installation of the equipment and/or CSST  installed. In considering the number of questions  received by the Board related to this subject, and in  context with the Board's authority and jurisdiction of  licensing electrical contractors, the Board would like to  advise the Department of  Community Affairs of its  position with respect to the installation of the bonding  jumper for CSST installations.

The Board's enabling statute requires generally that  anyone that advertises or enters into, or engages in the  work or business as an electrical contractor must first  obtain a license and business permit from the Board  (NJSA 45: 5A-9). The term "electrical contractor" means  a person who engages in the business of contracting to  install, erect, repair, or alter electrical equipment for the  generation, transmission, or utilization of electrical  energy (NJSA 45:5A-2(d)).

The statute also exempts from licensure any work  with a potential less than 10 volts (NJSA  45:5A-18(j

Accordingly, the Board has reasoned that CSST is  not electrical equipment that would require installation  by an electrical contractor. Its purpose is not to  generate, transmit, or utilize electrical energy but rather  generally to supply gas to utilization equipment.  Additionally, a bonding jumper, consisting of an  appropriate conductor and its related clamp(s) used as  a grounding electrode conductor to bond the CSST gas  piping system to the electrical service grounding  electrode system has a potential of less than 10 volts;  its purpose being to maintain a potential of zero volts, or  ground potential throughout the system. Consequently,  the Board's position is that a license and business  permit issued by the Board is not necessary to install a  bonding jumper on a CSST gas piping system to the  electrical service grounding electrode system; provided  such work does not include the intrusion into any other electrical equipment such as electrical panels,  switchgear, junction boxes, lighting fixtures, disconnect  switches, transformers, etc.  to facilitate the installation  of the bonding jumper. In view of the foregoing, the  Board posits that code officials within the various  enforcement agencies established pursuant to the NJ  Uniform Construction Code Act (UCC), may issue an  electrical sub-code permit for the installation and  inspection of CSST gas piping and the installation and  inspection of its mandated bonding jumper, to persons  that have not obtained a license or business permit from  the Board; (i.e. the plumbing contractor, mechanical  contractor, or other entity  performing the CSST  installation work).

Thus, to the extent code officials are relying upon the  necessity of the contractor to be licensed by the Board  in order to issue an electrical sub-code permit to  perform and inspect the CSST bonding work, the Board  requests that they be advised, perhaps via the  "Construction Code Communicator" that such is not  necessary, except as noted herein above. (NOTE: This  is not to suggest that bonding is not electrical work  subject to the provisions of the National Electrical Code,  rather, and only with respect to CSST, it is electrical  work that may be performed without first obtaining a  license and business permit issued by the Board.)  Accordingly, code officials may find it more effective and  efficient to require the person (e.g. plumbing or  mechanical contractor) seeking the UCC permit(s) to  install, replace, or repair, as the case may be, the CSST  and/or the equipment or appliance to which it is  connected, to be the person responsible for the  installation of the bonding jumper. Hence, that person  also would be responsible for obtaining the permits and  inspections required thereof pursuant to the UCC, rather  than demanding that an electrical contractor licensed by  the Board but having no contract for, or involvement  with the installation of the CSST, being required to  subsequently install the bonding jumper.

Thank you for your assistance in this matter.


Joseph P. Schooley, Chairman

Board of Examiners of Electrical Contractors  

Construction Code Communicator, Volume 24, Number 3, Fall 2012 (PDF)