Bonding Metal Gas Piping

Many questions are raised about the requirements for bonding metal gas piping systems. More
specifically, when corrugated stainless steel tubing (CSST) is installed for the gas piping in a
building, bonding methods and bonding jumper sizes that are more restrictive than required by
the National Electrical Code cause some of the confusion and concern. This issue is not a
small problem and has generated a significant amount of interest by various groups. This article
takes a look at what the NEC requires regarding bonding of metal gas piping systems. It also
explores recent revisions to NFPA 54 the National Fuel Gas Code and some of the challenges
inspection authorities, electrical contractors, and gas piping installers are encountering today on a
regular basis.

Purpose
It is important to understand what is intended to be accomplished from a performance standpoint
by meeting the metal piping bonding rules in applicable codes. The NEC provides excellent
performance language in Section 250.4 that informs users about what is intended to be
accomplished by code-compliant grounding and bonding. Section 250.4 is comprised of two
subdivisions (A) and (B). Section 250.4(A) deals with performance criteria for electrical systems
that are grounded, and Section 250.4(B) addresses those systems that are ungrounded. When
dealing with bonding requirements for metal gas piping, one should identify the performance
criteria that apply from 250.4. A closer look at 250.4 reveals that there are multiple list items in
each subdivision. The two performance rules in 250.4 that apply to bonding metal piping systems
are provided in (A)(4) and (B)(3). Both of these rules deal with bonding of electrically
conductive materials and other equipment. Within each of these rules one can see that bonding of
these electrically conductive materials (metal gas piping in this case) that are likely to become
energized is necessary, and that the bonding must be done in a manner that connects them
together and to the electrical supply source in a manner that establishes an effective ground-fault
current path.

Performance

Photo shows Bonding jumper connections accessible and made to the metal piping system using
listed bonding and grounding clamp.

So what is intended to be accomplished by bonding metal gas piping systems? The reason metal
gas piping must be bonded where likely to become energized is so that contact with energized
circuits will cause operation of over current devices and not allow the piping to remain
energized, resulting in potential fire or shock hazards. Another benefit of bonding the metal gas
piping system is to minimize potential differences between ground (the earth), grounded metal,
and the conductive metal piping system. The term likely to become energized requires some
judgment be exercised in applying the bonding requirement. Many enforcing jurisdictions have
established a default position to bond the metal gas piping system in all cases to avoid the risk of
a metal gas pipe becoming and remaining energized.
The performance language in 250.4(A)(1) and 250.4(B)(1) also mention reasons for grounding
electrical systems and electrical equipment. The reasons are to limit the voltages imposed by
lightning, line surges, or unintentional contact with higher voltage lines, and grounding can
stabilize voltage to ground during normal operation. It is important to remember that this
performance rule applies to the grounded electrical systems in (A)(1) and grounded equipment in
(B)(1). Sections 250.4(A)(2) and (3) deal with grounding and bonding performance rules for
electrical equipment as do 250.4(B)(1) and (B)(2). Metal gas piping bonding is not included in
these requirements but is included in 250.4(A)(4) and (B)(3).

Specific NEC Bonding Requirements

Electrical bonding is addressed in the NEC in Part V of Article 250. The section dealing with
bonding metal gas piping is 250.104(B). This rule applies to various metal piping systems,
including gas piping systems that are likely to become energized where installed in or attached to
a building or structure. This rule calls for a bonding jumper to be connected between the metal
gas piping and the service equipment enclosure, the grounded conductor at the service, the
grounding electrode conductor if of sufficient size, or to one or more grounding electrodes of the
grounding electrode system. The connection points (points of attachment) of the bonding jumper
are required to be accessible. This Code rule also clearly indicates the minimum size for the
bonding jumper generally has to be sized using Table 250.122 based on the rating of the circuit
likely to energize the piping system. These circuits are generally considered as those that supply
gas-fired equipment. At a minimum, the size of the bonding jumper should be not less than the
size of the equipment grounding conductor of the circuit supplying the equipment. The over
current device for the circuit determines the minimum size. One could install larger bonding
jumpers and exceed the minimum. This is often specified in the plans for larger construction
projects. It is a good approach to verify with the local inspection authority how they approach
sizing bonding jumpers for metal gas piping systems, because recent changes in other applicable
standards and in the installation instructions provided by manufacturers of certain types of gas
piping systems result in the minimum bonding jumper size being larger than what is required by
the NEC.

New Gas Piping Material

Metal gas piping systems in buildings are often installed using hard metal piping that is suitable
for gas distribution such as steel and wrought iron, copper and brass, or aluminum alloy.
Recently a new type of steel tubing joins the list of piping systems for use in gas systems.

Corrugated stainless steel tubing (CSST) is recognized by the National Fuel Gas Code (NFPA
54) and it must be listed to meet the performance, installation, and construction criteria in ANSI
LC 1/CSA 6.26. Since CSST is a metal gas piping system, it falls under the bonding
requirements in Section 250.104(B) of the NEC. An interesting feature of CSST products is that
they provide manufacturers instructions for installation. Interestingly these instructions in some
cases, not all, specify bonding requirements that are more restrictive than the NEC rules. This
could be where some of the inconsistencies and confusion lie, in addition to the fact that there is
at least one CSST manufacturer that does not impose any bonding requirements that are more
restrictive than the bonding rules in the NEC. It should be noted that NFPA 54 requires that
manufacturers instructions must be followed in addition to applicable local gas supplier (often a
utility) regulations.

Photo shows bonding connections are required to be accessible.

Just to clarify the NEC rules regarding installation instructions, Section 110.3 of the NEC applies
to equipment and 110.3(B) more specifically imposes the requirement that listed electrical
equipment be installed and used in accordance with any instructions included in the listing or
labeling. This requirement applies to electrical equipment, not the metal gas piping, which has its
own installation requirements.

The Challenges
The National Fuel Gas Code was recently revised to include bonding requirements for metal gas
piping that are more restrictive than those in the NEC. The bonding requirements for metal gas
piping systems in both NFPA 54 and NFPA 70 have been consistent until this revision. Attempts
were made to revise the 2011 NEC metal gas piping bonding rules so as to become consistent
with NFPA 54-2009. CMP-5 rejected these proposals and indicated that insufficient technical
substantiation was provided. Lightning is an unpredictable force. It would be difficult to
conclude that by just changing a Code rule, the apparent lightning problems with some CSST
products would be resolved. CMP-5 was very careful in their considerations of this proposal. The
reason for the significant efforts to change the bonding rules for metal gas piping systems in both

NFPA 54 and NFPA 70 are primarily related to problems from lightning events that could cause
small rupture holes in the CSST, resulting in leaks and fires in some cases. There has even been
property damage from such unfortunate events. This scenario begs two key questions, among
others. Should a longstanding NEC rule be changed to include requirements for protection
against lightning events? This author thinks not. NFPA 780 Standard for Installation of
Lightning Protection Systems provides information about lightning protection for buildings and
structures. NFPA 54 provides rules related to installation and performance of gas piping systems
and gas equipment.

Standard Scopes
The scopes of NFPA 54 and NFPA 70 are not the same and address different important issues.
The NEC rules address fire and shock hazards for persons and property. The bonding
requirements for other metal piping systems in the NEC protect the piping system from the
electrical system within the building. NFPA 54 covers safety and performance of gas piping
systems, including addressing safety concerns. The recent revisions in NFPA 54 Section 7.13
result in new bonding requirements in response to serious issues related to CSST piping system
failures and losses from subsequent gas leaks. NFPA 54 includes the new, more restrictive
bonding requirements that are an effort to protect specific piping systems that are known to be
vulnerable to the effects of lightning. Since the scopes of each standard are different, they must
complement each other to achieve effective safety. One area where the documents are similar has
to do with following product manufacturers installation instructions. Both standards include this
requirement, so coordination of the work and enforcement of the rules is necessary to ensure the
desired outcome of satisfying both standards.

Impact on Inspectors and Contractors

The impact on inspection agencies, electrical contractors, and gas piping contractors has been
increased inconsistency and confusion regarding bonding requirements for metal gas piping
systems, specifically those systems that incorporate CSST. Jurisdictions are challenged with the
fact that many do not adopt NFPA 54 but do adopt and enforce NFPA 70. This fact coupled with
the CSST manufacturer installation instructions that vary between CSST manufacturers and
other influencing factors is causing increased anxiety about compliance and liabilities. Some
jurisdictions have been convinced that they need to change their local codes or add a new
amendment to their current local rules that parallel the CSST manufacturers instructions. The
problem is not all CSST products require any bonding beyond the minimum required in NEC2008. Inspectors should know how the NEC requirements have to be applied to installations and
systems and they should understand what the rules are intended to accomplish. Metal gas piping
systems are required to be bonded where likely to be energized so that any imposing circuit
cannot energize the piping system. The bonding required by 250.104(B) also results in the
potential of metal gas piping being at or near the potential of ground (the earth). The NEC rules
are not intended to provide assured and complete protection against lightning events. As safety
standards change, new requirements are incorporated to address substantiated problems with
viable solutions. The changes in industry standards have to accompany education and training
related to new safety requirements. Contractors and enforcement have responsibilities to learn
the requirements and implement them in their work. Enforcers impacted by the bonding

requirements in each of the documents should coordinate the installation and work out who
inspects, what rules apply, and who does the work. Once this dialog occurs, the approach taken
by the code enforcers can be passed on to the contractors.

Summary
Problems have been identified with CSST systems being installed and used for gas systems in
buildings. There are current efforts in motion to revise the NEC to deal with apparent lightning
protection issues related to CSST piping. Is the NEC rule broken, and do the proposed revisions
actually provide the needed solutions? Many in the electrical industry currently have more
questions than answers relative to these issues. While one thing is certain, when a jurisdiction
adopts a code, that code should be enforced and applied in the field. This article provides a closer
look at some current activity relative to proposed changes to bonding requirements for CSST
metal gas piping systems. These problems did not exist before CSST entered the market. This
should in no way be interpreted that CSST is an inferior product or that there are problems with
some varieties of this product, but one has to wonder if this changing of current rules is the
answer or if there is a problem with some CSST products. In reflection, the purpose of the NEC
is the protection of persons and property from the hazards arising from the use of electricity.
Lightning protection requirements are clearly beyond the purpose and scope of the NEC. When
revising requirements in industry safety standards, consideration must be given to how the
scopes of such standards are impacted and whether or not the proposed revisions to the contained
requirements are a viable solution to the real problem. These are some of the real challenges that
members of NFPA technical committees face when carrying out their responsibilities to produce
the best codes possible each revision cycle; a true and often difficult work in progress. The best
approach at this time is to verify what the local inspection authority is requiring regarding
bonding metal gas piping and meet those requirements, which are now often inconsistent with
the NEC minimums.