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Recessed light fire hazard: lacks adequate space (C) Daniel FriedmanRecessed light clearance distances & codes

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This article describes recessed light (downlight, pot light) clearance distances or spacing from insulation or wood or other combustibles in building ceilings, other indoor spaces or outdoors in roofs, soffits, porches.

Discussed here: Clearance spacing for recessed light fixtures: distances, codes. Air leakage code requirements for recessed lights, downlights. Effects of bulb choice on recessed light clearances & wattage allowed. Effects of recessed light location on clearance distances.

This article series details guidelines for selecting and installing both exterior and interior lighting to meet the requirements for different building areas. Page top photo: this non-IC pot light improperly covered by insulation and contacting wood framing in this attic is a fire hazard.

We also provide a MASTER INDEX to this topic, or you can try the page top or bottom SEARCH BOX as a quick way to find information you need.



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Recessed Light Clearance Distances & Electrical Codes

Recessed lights or pot lights installed in roof soffit outdoors (C) Daniel Friedman Paul GalowWhat is the minimum clearance distance between the top of the recessed light can and wood framing or sheathing or insulation?

Reader question:

I am installing downlight housing for LED lighting in residential construction and wanted to know the minimum clearance between the top of the can and the roof above.

The downlight can an is airtight and IC rated-model. Thank you. - R.T. 5/8/2013

Reply:

Standard recessed housings must be left uninsulated above and should have 3-inches of clearance to insulation.

[Click to enlarge any image]

For lights installed in contact with insulation or with less than 3-inches of clearance to insulation use a can rated IC for “insulation contact.”

Details:

The minimum clearance for downlights varies by the recessed lighting type; IC-rated (DCIC) recessed lights are rated for direct contact with insulated ceilings or, that is, they can be installed in contact with insulation.

But you'll see below that the approved clearance distances for recessed light cans (downlights) also depends on the type of bulb installed and in some cases the building location (closets).

IC-rated recessed light clearance distances

Figure 5-29: (C) J Wiley, S Bliss

An IC-rated recessed light can be covered by insulation and can be within 1/2" of (or perhaps touch) other combustible materiasl (such as the wood material of the roof sheathing in your question). IC-rated down lights (recessed lighting fixtures) should have passed both UL1590 and IEC60598+1 tests/standards.)

Our photo (left) gives details of information provided on the label of an IC/non-IC recessed light housing.

Here is the supporting code citation:

NEC 410.66 - Wiring Methods recessed lighting fixtures Recessed lighting fixtures installed in insulated ceilings or installed within 13 mm [1/2 inch] of combustible material shall be approved for insulation contact and labeled Type IC.

Recessed Light Fixtures & Air Leakage - Energy Codes

Recessed Light housing label  (C) D FriedmanHowever in my OPINION installing an IC-rated downlight or recessed light that is actually touching the roof sheathing above is not a great practice.

If you live in a freezing climate you'll see nice melt spots in the snowcover on your roof over such a light installation, and you're creating both an air leak energy loss and thus a heat loss point - a view with which other experts agree.[7] The NEC now addresses the problem of air leakage at recessed lights with this paragraph:

NEC 410-66 - Recessed lighting fixtures installed in insulated ceilings or installed within one half inch of combustible material shall be labeled as Type IC (insulation contact).

In addition, your state Energy Code requires recessed lighting fixtures in insulated ceilings to be sealed to prevent leakage of airborne moisture. 

Some states have adopted directly or by reference 1995 edition of the Council of American Building Officials Energy Code (CABO MEC/1995) an dinclude references such as these cited from the New Jersey Building Code:

502.3.4 and 602.3.3 of CABO MEC/1995, both entitled “Recessed Lighting Fixtures,” contain requirements for recessed lights in relation to the Energy Subcode. There are three options for the installation of recessed lightingt fixtures when installed in the building envelope, of which one must be implemented to meet the Energy Code requirements:

1. Type IC rated, manufactured with no penetrations between the inside of the recessed fixture and ceiling cavity, and sealed or gasketed to prevent air leakage into the unconditioned space;

2. Type IC rated or non-IC rated, installed inside a sealed box constructed from a minimum ½-inch-thick gypsum wall board or constructed from preformed polymeric vapor barrier, or other air-tight assembly manufactured for this purpose, while maintaining required clearances of not less than ½ inch from combustible material and not less than three inches from insulation material;

3. Type IC rated, in accordance with ASTM E 283- 91 (Standard Method of Test for Rate of Air Leakage Through Exterior Windows, Curtain Walls, and Doors), with no more than 2.0 cfm air movement from the conditioned space to the ceiling cavity. The lighting fixture shall be tested at 75 Pa or 1.57 lbs/ft2 pressure difference and shall be labeled. 

Non-IC-rated recessed light fixture typical clearance distances

Typically an non-IC-rated (or "DCIC-rated") recessed light must be

Effects of bulb type & wattage on recessed light fixture clearance distances

LED bulbs generally run cooler than incandescent bulbs, so if your downlight label talks about a 60W incandescent bulb limit in the fixture, you may be able to use a brighter LED bulb.

Watch out: The wattage permitted in the downlight depends on the type of bulb (e.g. R vs PAR) and some LED bulbs themselves include a warning about the type of fixture into which they can be installed - some require cooling airflow, especially the higher wattage-equivalent models above 60W.

And also

Watch out: typical DCIC-rated recessed lights or downlights are "dual purpose" - that is they can be used both with an air space and in enclosed, insulated ceilings, but when installed in an insulated enclosed space the lamp label includeswarning that the lamp rating wattage is reduced, often by half as you can see in the label in our photo.

Effects of light location on recessed light fixture clearance distances

Watch out: also for just where you are installing a recessed light, as some locations such as closets carry additional rules about the minimum clearance distances between a light bulb or fixture and the nearest shelf edge or surface (12"). The definition of "closet" or "storage space" is included in the National Electrical code and needs to be consulted when determining the clearance distances for all types of lighting in those locations. Here are some supporting code citations from the National Electrical Code: [4]

NEC 410-8 - Lighting fixtures installed in a clothes closet shall have the following clearances from the defined storage area (see the definition below): . 12 inches for surface incandescent fixtures . 6 inches for recessed incandescent fixtures . 6 inches for fluorescent fixtures NEC 

NEC 410-8 - Incandescent fixtures with open or partially enclosed lamps and pendant fixtures or lamp holders are not permitted in clothes closets. 

NEC 410.8 - Wiring Methods closet lighting fixtures Luminaires (lighting fixtures) installed in clothes closets shall have the following minimum clearances from the defined storage area: 300 mm - 12 inches for surface incandescent fixtures, 150 mm 6inches for recessed incandescent fixtures , 150 mm 6 inches for fluorescent fixtures.

NEC 410-8 - Lighting fixtures installed in a clothes closet shall have the following clearances from the defined storage area (see the definition below):
12 inches for surface incandescent fixtures, 
6 inches for recessed incandescent fixtures, 
6 inches for fluorescent fixtures.

NEC 410.16 - Lighting Fixtures closets Luminaires (lighting fixtures) installed in clothes closets shall have the following minimum clearances from the defined storage area:

12 inches for totally enclosed surface incandescent or LED luminaires.

6 inches for recessed totally enclosed incandescent, fluorescent or LED luminaires.

6 inches for surface mounted or recessed fluorescent luminaires.

Surface mounted fluorescent or LED luminaires listed for installation in storage space shall be permitted.

What is the minimum clearance distance between the top of the downlight can and the roof above

Reader question: I am installing downlight housing for LED lighting in residential construction and wanted to know the minimum clearance between the top of the can and the roof above. The Can is airtight and IC rated. Thank you. - R.T. 5/8/2013

Reply:

Figure 5-29: (C) J Wiley, S BlissThe minimum clearance for downlights varies by the recessed lighting type; IC-rated (DCIC) recessed lights are rated for direct contact with insulated ceilings or, that is, they can be installed in contact with insulation.

But you'll see below that the approved clearance distances for recessed light cans (downlights) also depends on the type of bulb installed and in some cases the building location (closets).

IC-rated recessed light clearance distances

An IC-rated recessed light can be covered by insulation and can be within 1/2" of (or perhaps touch) other combustible materiasl (such as the wood material of the roof sheathing in your question). IC-rated down lights (recessed lighting fixtures) should have passed both UL1590 and IEC60598+1 tests/standards.)

Here is the supporting code citation:

NEC 410.66 - Wiring Methods recessed lighting fixtures Recessed lighting fixtures installed in insulated ceilings or installed within 13 mm [1/2 inch] of combustible material shall be approved for insulation contact and labeled Type IC.

The NEC now addresses the problem of air leakage at recessed lights with this paragraph:

NEC 410-66 - Recessed lighting fixtures installed in insulated ceilings or installed within one half inch of combustible material shall be labeled as Type IC (insulation contact). In addition, your state Energy Code requires recessed lighting fixtures in insulated ceilings to be sealed to prevent leakage of airborne moisture. 

Reader Question: can an IC-rated light fixture touch wood framing members?

2016/06/20 Michael said:

I have a similar question. I am installing 4" recessed remodel cans with LED lights. The housing is IC rated. There is no insulation in the ceiling but the housing would touch the wooden joist and a insulated heating conduct. IC rating says contact with ceiling insulation, but I have contact with wood and heating conduct insulation. Is this safe?

Reply:

Excellent question, Michael.

Clearances for Recessed Luminaires that are rated as Type-IC

IC-rated (Insulation-contact-rated) recessed luminaries (light fixtures or "pot lights" in normal-speak) are allowed zero clearance to combustible materials and are allowed to contact thermal insulation - Section 410-66, Clearance and Installation. National Electrical Code, NFPA 70-1999 (Quincy, MA: National Fire Protection Association, 1999), p70-233.

Watch out: check the manufacturere's stamping, rating, and clearance distances specified for your particular light fixture. For example, a "convertible" IC / Non-IC fixture has different requirements and may require 1/2" clearance to combustibles and may have other restrictions such as no insulation over the fixture.

Clearances for Recessed Luminaries that are Non-Type IC:

A recessed fixture that is not identified for contact with insulation shall have all recessed parts spaced at least 1/2 in. (12.7mm) from combustible materials. The points of support and the trim finishing off the opening in the ceiling or wall surface shall be permitted to be in contact with combustible materials.

Thermal insulation shall not be installed above a recessed fixture or within 3 in. (76mm) of the recessed fixture enclosure, wiring compartment, or ballast, unless it is identified for contact with insulation, Type IC. - Section 410-66, Clearance and Installation. National Electrical Code, NFPA 70-1999 (Quincy, MA: National Fire Protection Association, 1999), p70-233.

You will argue that you're using LED bulbs so your light fixture will operate at a cooler temperature than if an incandescent bulb were installed. But Mike, we can't control what sort of bulb someone may install into those fixtures in the future, so we need to follow the NEC if we're following U.S. guidelines, or if you live in another country, we need to follow that country's electrical code as a minimum safety standard.

To answer the question of what’s the allowed clearance more accurately, or can my IC-rated light fixture actually touch wood framing or other wood components (or other combustible materials) we need to know the manufacturer or brand as well as model of your specific light fixture or more simply, we need to look at the stamping or marking of the fire rating of the fixture.

Watch out: for a light fixture, touching non-combustible insulation isn’t the same as touching a combustible.

Installing a non-DCIC or non-IC-rated light fixture where we cover it with insulation is a long-known hazard: the fixture overheats and either fails-safely by burning up and out but contained within the fixture itself, or worse, it starts a house fire.

Clearances for DCIC or IC-rated light fixtures permit insulating around or close to the light fixture, or in some cases even contacting it (with non-combustible insulation such as fiberglass or rock wool).

Clearances for DCIC or IC-rated light fixtures to combustible materials such as wood are a different story. I took a look at installation clearance requirements for recessed luminaries to find that the actual specifications for what clearances (or contact) between the light and combustibles varies depending on the specific rating on the light fixture.

Two clearance distances are given for Non-Type-IC and Type-IC Luminaries by the 1999 National Electrical Code (NEC) Section 410-66.

1. Required installation clearance to combustible materials

Depending on the specific rating the clearance distance allowed might be

2. Required installation clearance to thermal insulation

Depending on the specific rating the clearance distance allowed might be

The table below expands on these guidelines for IC-rated and Non-IC-rated luminaires.

Table 1- Recessed Luminaire Ratings 1

Light Fixture Rating Type Light Fixture Marking Required on the Fixture Light Fixture Installation Clearance Distance to Combustible Materials Light Fixture Installation Clearance Distance to Thermal Insulation
IC (Insulation Contact) TYPE-IC Zero (can touch) May contact thermal insulation
Non-IC (Not for Insulation Contact) DO NOT INSTALL INSULATION WITHIN 76mm (3 in) OF ANY PART OF LUMINAIRE or equivalent statement in the form of a product marking 1/2 inch

Thermal insulation must be permanently spaced at least 3 inches from the luminaire sides, wiring compartment, ballast(s) and transformers.

Thermal insulation must not be placed above the luminaire.

Convertible IC / Non-IC

DO NOT INSTALL INSULATION WITHIN 76mm (3 in) OF ANY PART OF LUMINAIRE

or equivalent statement in the form of a product marking

Zero (can touch)

or

1/2 inch according to configuration selection at time of installation of the convertible fixture.

[Presumably this means if converted to IC, zero is allowed]

According to the configuration selection at time of installation

1) may contact thermal insulation

[Presumably this means if converted to IC, zero is allowed]

or

2) Thermal insulation must be permanently spaced at least 3 inches from the luminaire sides, wiring compartment, ballast(s) and transformers.

Thermal insulation must not be placed above the luminaire.

Spacing Marked on Fixture

INSTALL WITH MINIMUM SPACINGS BETWEEN

(a) CENTER-TO-CENTER OF ADJACENT LUMINAIRES __MM (__IN);

(b) TOP OF LUMINAIRE TO OVERHEAD BUILDING MEMBER __MM (__IN);

(c) LUMINAIRE CENTER TO SIDE BUILDING MEMBER __MM (__IN);

or equivalent statement in the form of a product marking

In accordance with dimensions specified in marking

Thermal insulation must be permanently spaced at distance specified for side building member.

Thermal insulation must not be placed above the luminaire.

Fire Resistive Construction Only

INSTALL IN BUILDINGS OF FIRE-RESISTIVE CONSTRUCTION

- MOUNT ON NONCOMBUSTIBLE MATERIAL

or equivalent statement in the form of a product marking

Shall not be installed on or near combustible material Shall only be installed in contact with, or in proximity of, materials indicated by labeling
Special Application

FOR USE IN CONCRETE ONLY

or

SUITABLE FOR GROUND-MOUNTED RECESSED ONLY

or equivalent statement in the form of a product marking

Shall not be installed on or near combustible material Shall only be installed in contact with, or in proximity of, materials indicated by labeling

Notes:

1. Adapted from

  • 1999 National Electrical Code (NEC) Section 410-66.
  • O'Boyle, Michael, "Installation Clearance Requirements for Recessed Luminaries", IAEI Magazine, July-August 2001, retrieved 2016/06/20, original source: http://iaeimagazine.org/magazine/2001/07/16/installation-clearance-requirements-for-recessed-luminaries/

2. Convertible IC / Non- IC luminaires are light fixtures that are Type-IC luminaires that have been provided with additional markings for use when the light is installed in a non-insulated building cavity.

3. Marked-spacing luminaires are light fixtures for which special spacing distances have been specified in order to keep the lighting system opearting with pre-specified temperature limits.

4. Non-Combustible Construction luminaires are light fixtures permitted under NEC Section 410-65(b): "Where a fixture is recessed in fire-resistant material in a building of fire-resistant construction, a temperature higher than 90°C (194°F) but not higher than 150°C (302°F), shall be considered acceptable if the fixture is plainly marked that it is listed for that service."

Question: Is an LED downlight acceptable in a fire-rated ceiling assembly?

Illume I-EL4PPWH low profile LED downlight at InspectApedia.com2018/02/26 Ben said:

Can IC rated LED retrofit fixtures be installed in a 1hr rated ceiling and maintain the ceiling's fire rating?

Illustration: the Illume LED Downlight No. I-EL4PPWH from Illume LED Lighting and discussed below.

[Click to enlarge any image]

Reply: going from incandescent to LED reduces heat and won't compromise an existing DCIC light fixture

(mod) said:
Ben,

I'm not sure and I think we need some clarification before doing more research. In particular the fire rating of a ceiling is in my view a separate measurement from a recessed light that is DC IC rated.

That is a DCIC (Direct Contact with Insulated Ceilings) light is rated for installation in an insulated ceiling in direct contact with insulation without causing a fire hazard. That's a separate issue from the fire rating of the ceiling.

An LED light will generally run cooler then an incandescent bulb. The Illume LED I-EL4PPWH from Illume LED Lighting that we discuss below is a 120VAC LED thin profile downlight that draws just 9 Watts and provides 730 lumens of lighting.

In a retrofit installation in an existing ceiling downlight this ought to be a non-issue regarding heat generation as it's certainly cooler than a similar-luumen incandescent 60-watt bub (that gives about 800 lumens).

So if you see a light fixture that's rated for a 60 watt incandescent bulb, you're likely to be safe installing an LED bulb with an equivalent number of lumens.

That is not the same question nor answer if you're asking about cutting into an existing insulated, fire-rated ceiling where there are no present downlights.

Reader follow-up: maintaining the fire rating of the ceiling

Ben said:

My question was specifically about maintaining the fire rating of the ceiling, not related to any fire hazard related directly to the light (e.g. heat). The specific fixture I want to use is illume I-EL4PPWH. This requires cutting a 5 to 6" hole in the fire rated drywall.

If I left the hole un-filled the fire rating of the ceiling would be compromised. Does installing this fixture maintain the fire rating of the ceiling? I have read in my local building code (Ontario) that holes can be cut as long as a "tightly fitting" electrical box is installed.

The LED fixture seems solid and has a solid metal backing plate, so would probably not allow the passage of flame in the event of a fire. I have also read on some forums (USA based) indicate a maximum of 100sq.in can be cut in 100sq.ft of ceiling area (I assume there still needs to be something blocking the hole such as an electrical box).

There are also a few methods (big metal box and an insulated hat from "tenmat") that are used for the can+trim+bulb type pot lites.

Reply: Building Code on ceiling or floor penetrations impact on fire-rating

Ben

Thanks for clarifying the question. This isn't about changing the bulb in an excisting DCIC light fixture it's about cutting a new opening and adding a fixture (and wiring).

If your building presently has a UL-fire-rated ceiling assembly, then any recessed fixtures (set into the drywall ceiling) must be protected to maintain the fire rating, and recessed light fixtures require the use of specific fire-rated materials and assemblies.

If the manufacturer of the light fixture you want to install does not provide a UL-listed fire-rated assembly bearing the UL certification mark, then such an assembly will be needed.

Details follow.

I agree that the fixture you choose as well as details of its installation could affect the fire rating of an existing ceiling.

I also agree that there are "solutions" described involving construction of a fire-rated enclosure above and surrounding the down light, probably combined with fire-rated sealant around the opening edges. Below I'll give a reference to a power-point presentation that describes that approach.

Watch out: do not simply build a home-made guess at a fire-rated enclosure for your new recessed down lights in a fire-rated ceiling. There are approved designs as well as listed light enclosure products such as those produced by SafeLite that I cite below.

I looked at both the installation instructions and the "product report card" for the Illume I-EL4PPWH recessed light fixture.

The word "fire" does not appear in either (I was looking for "fire rating"). Nor does "UL" nor "Listed" - (I was looking for UL Listed).

A model building code citation is helpuful and confirms that you're asking a good question. From the IBC 2009 and 2012 versions

713.4.1.2 Membrane penetrations. Penetrations of membranes that are part of a horizontal assembly shall comply with Section 713.4.1.1.1 or 713.4.1.1.2.

Where floor/ceiling assemblies are required to have a fire-resistance rating, recessed fixtures shall be installed such that the required fire resistance will not be reduced.

I would expect the manufacturer of a downlight or recessed light fixture to happily cite compliance with UL listing requirements for use in fire-rated ceiling assemblies. But that's an expectation not a fact.

While I suspect that the Illume I-EL4PPWH is NOT UL-Listed for fire-rated ceilings, at this point, unable to find a UL listing certification for that fixture, we're left with one step: ask the company directly.

You can contact the manufacturer at

UL Listed LED-Light Fixtures

UL currently (March 2018) lists 664 LED recessed luminaire lighting products. You should review those choices if you need to preserve the fire-rating of a ceiling.

As of 2018/03/04 using UL's product search tool found at http://productspec.ul.com/index.php UL lists the following classes of LED lighting fixtures

Research & Electrical Code on IC Lighting & Fire Risks

...


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