ABYC ELCI requirement

Can anyone provide the current wording of the ABYC ELCI requirement? I know at one time (2015?) there was an exception in the requirement that said if an isolation transformer was installed within 10’ of the shore power inlet, an ELCI was not required. The boat I recently bought meets that requirement but the surveyor still recommended an ELCI be installed, and of course, the insurance company says I’ve got to do anything a surveyor recommends! If this exception is still in the standard, I’d rather challenge the recommendation and lower it on my priority list.

Tarantelle said:

Can anyone provide the current wording of the ABYC ELCI requirement? I know at one time (2015?) there was an exception in the requirement that said if an isolation transformer was installed within 10’ of the shore power inlet, an ELCI was not required. The boat I recently bought meets that requirement but the surveyor still recommended an ELCI be installed, and of course, the insurance company says I’ve got to do anything a surveyor recommends! If this exception is still in the standard, I’d rather challenge the recommendation and lower it on my priority list.

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I’m almost positive that is still the case. I wish surveyors would knock that off. You should only need to be sure your boat met the requirements at time of build.

Here’s the text:
ABYC E11.11.1

An Equipment Leakage Circuit Interrupter (ELCI) or Type A Residual Current Device (RCD) shall be installed with or in addition to the main shore power disconnect circuit breaker(s) or at the additional overcurrent protection as required by E-11.10.2.8.3 whichever is closer to the shore power connection.
EXCEPTION: Installations where an isolation transformer is installed within 10 feet (3 m) of the shore power inlet or the electrical attachment point of a permanently installed shore power cord and supported according to 11.14.4.1.3 11.11.1.1

Thanks. Can you tell me what release (date) of the standard that comes from?

Regarding how surveyors write things up, I too wish they would write things in such a way that you only must comply with the standards that were in place at the time of manufacturing or design release - unless all boats were required to meet some new standard retroactively. That’s similar to how things are done in the aerospace industry where I came from. I’m also afraid that if a surveyor recommended your boat should be painted purple, the insurance company may insist you paint it purple. They (insurance companies) don’t seem to want to differentiate between serious and minor issues.

I’m not sure when that was written. There are some abyc contributors on this site, maybe they can clarify. I do know it’s current though.

Bmarler said:

I wish surveyors would knock that off. You should only need to be sure your boat met the requirements at time of build.

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I don't agree with that statement at all. The standards are constantly evolving and improving the safety of boats. As the standards evolve, so should the older boats. An ELCI is a worthwhile safety upgrade for every boat and it's the surveyor's job to point out the worthwhile upgrades. It's not the surveyor's fault that the insurance company is mandating something that is only a recommendation. Don't blame the recommendation, blame the insurance company.

Look at the evolution of the galvanic isolator. In 2007 the 'Fail Safe' galvanic isolator was created so that the AC grounding conductor will still pass current in the event of a ground fault even if the isolator is bad (lightening strike nearby, etc.). Now ABYC recommends that all G. I.'s be 'Fail Safe'. Should a surveyor not recommend that you get a new fail safe galvanic isolator to replace the 1995 version on your boat just because an insurance company may agree and also require it?

Some things make sense to update, some don't. And some only make sense to update when you're already going to do work on that system.

Personally, as ELCI dock breakers become more common I don't think adding an ELCI breaker on the boat is particularly worthwhile unless you're already in there changing the shore power inlet setup. But swapping to a newer galvanic isolator seems a bit more worthwhile.

I agree with rslifkin, when doing upgrades to a system, bring it into current standards. It can be a huge burden for boat owners to bring all systems up to date. Insurance companies seem to have taken the stance that the abyc is law, not just recommendation.

Here's the language from the currently published version of E-11, amended as of 7/2023. It's a bit different from what was posted earlier, but the same exception is in place.

11.11.1 An equipment leakage circuit interrupter (ELCI) or Type A residual current device (RCD) shall be installed with or in addition to the primary shore power disconnect circuit breaker(s) as required by E-11.10.2.5.3.

EXCEPTION: Installations where an isolation transformer is installed within 10 ft (three meters) of the shore power inlet or the electrical attachment point of a permanently installed shore power cord and supported according to E-11.15.4.1.3.

Bmarler said:

Insurance companies seem to have taken the stance that the abyc is law, not just recommendation.

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Insurance companies consider ABYC as the presumptive best way of doing things at the time of loss. This shifts the burden of proof to the insured to show the non-compliant way did not contribute to the loss. You can always challenge the standard post-loss, but most folks don't want to pay for the lawyers, expert witnesses, etc. that would be required.

You can also challenge whether the boat was actually built according to standard. Now you have to show that the builder was non-compliant AND the non-compliance contributed to the loss. Sometimes this is much easier to do, but again: lawyers and experts.

I'm with the others here: if you're upgrading a system, spend the dosh to make it compliant. Makes your claim somewhat easier in case of loss.

(Disclaimer: Not a lawyer. Not an insurance maven. Yes, exceptions exist. Yes, some ins co's/claim adjusters skate the line between legitimate and bad faith dealing. Yes, I'm projecting how the world should work rather than the way it does work. Did I miss anything? )

rslifkin said:

Personally, as ELCI dock breakers become more common I don't think adding an ELCI breaker on the boat is particularly worthwhile unless you're already in there changing the shore power inlet setup.

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I just had to troubleshoot a 1978 boat last week because the diver cleaning the bottom 'felt a tingle' when he touched a through hull. The boat had some bad wiring on one of the shore power inlets and a 1.5 amp AC leakage current. Of course, the marina didn't have ground fault protected pedestals, but if the boat had been retrofitted to current standards with an ELCI the fault would never have happened, the diver would never have been at risk. ELCI's are relatively cheap and easy to retrofit, IMO absolutely worth it on every boat that doesn't have a transformer.

CompuNerd said:

Insurance companies consider ABYC as the presumptive best way of doing things at the time of loss. This shifts the burden of proof to the insured to show the non-compliant way did not contribute to the loss. You can always challenge the standard post-loss, but most folks don't want to pay for the lawyers, expert witnesses, etc. that would be required.

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I don't mean to discourage following best practices - actually just the opposite, but I don't think what you are saying above is true. I hear it all the time, but unless your policy says you need to maintain the boat in compliance with ABYC (or anything else), they have no grounds to deny a claim for non-compliance. And I have never seen, nor heard of a policy with such a requirement. So I think this whole notion that an insurance company will examine your boat for non-compliance and use it to deny a claim is just dock talk, aka wive's tale.

twistedtree said:

I don't mean to discourage following best practices - actually just the opposite, but I don't think what you are saying above is true. I hear it all the time, but unless your policy says you need to maintain the boat in compliance with ABYC (or anything else), they have no grounds to deny a claim for non-compliance. And I have never seen, nor heard of a policy with such a requirement. So I think this whole notion that an insurance company will examine your boat for non-compliance and use it to deny a claim is just dock talk, aka wive's tale.

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But it is the surveyor who maybe was misguided writes down ABYC regulations that are newer, never before applied to an older boat that an insurance agent treats as gospel and demands be rectified before full endorsement is given.
On the other hand, some surveyors may not be up to date or they use common sense and not write down some obvious ABYC suggestions.
It is easier for insurance agents to err on the side of caution.

SteveK said:

But it is the surveyor who maybe was misguided writes down ABYC regulations that are newer, never before applied to an older boat that an insurance agent treats as gospel and demands be rectified before full endorsement is given.
On the other hand, some surveyors may not be up to date or they use common sense and not write down some obvious ABYC suggestions.
It is easier for insurance agents to err on the side of caution.

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That's all part of an insurance company deciding if they want to write a policy in the first place, and I agree it's very problematic.

I can guarantee that any older boat doesn't meet all current ABYC standards, and I don't think any insurance company expects them too. The question then is what aspects of the boat SHOULD be updated for the risk to be acceptable to the insurance company. Maybe others know, but I'm not aware of any guidelines that insurance companies give to surveyors telling them what areas they want to be up to date. I think it's all left to the surveyor. I think it's critical for any boat owner to have a very frank discussion with a prospective surveyor about the purpose of the survey, and even discuss the sorts of things the surveyor will call out as requiring an update.

If you are getting a pre-purchase survey, I think you want to know everything, and get every suggestion and recommendation the surveyor has. It's then up to you to decide what you are going to fix/update, and in what priority order. But for an insurance survey, I think you only want the items that make the boat a danger or poor risk.

Electrical stuff is probably one of the biggest risks on a boat, so I can understand insurance companies wanting certain base standards met. RCD might be long hanging fruit with a lot of risk reduction for little cost. Ancient propane installations are probably another one.

All these things are judgement calls, and I think the best thing an owner can do is have a frank discussion with prospective surveyor about the purpose of the survey, and ans blunt questions about how they arrive at recommendations.

As for this specific question about RCDs, I'd probably go back to the surveyor with the ABYC language, ask if they agree, and see if they will ammend the survey. If not, you could take it up with the insurance company showing them that the surveyor erred in their recommendation. Or just install an RCD and move on.

I think there should be some guidance for surveyors and insurance companies about making recommendations. Then things can be broken down better into groups like "needs to be fixed", "should be done if possible, insurance may want a reason if not", and "consider these, but not a big deal if you don't do them"

There can also be a discount list offered to have optional items like the ELCI to encourage upgrades. But I do not remember insurance questions asking if any upgrades were made that help reduce the risk to insurer.
Fairly certain there is a scale of premium based on age of vessel that can be offset by upgrades. Or are new boat owners paying more than older boat owners?
I just received my renewal and also note the fire extinguishers are coming due, yet there was no request for extinguisher last checked.

I am installing a Blue Seas ELCI this weekend. I recommend doing some checks before hand to ensure you have no leakage, otherwise you may be locked out until the issue is resolved. I bought a Megger AC leakage clamp meter because I just installed a LIfepo4/Victron system and I expected my old boat to have issues being within the 30 mA. Wouldn't you know I didn't need anything so sensitive..lol. 4 amps of leakage. Narrowed it down to a 120 outlet installed in the back of the engine bay the PO had installed to plug in the battery charger. He had the neutral and ground reversed. At least all the leakage was going out the ground wire. Corrected that and now using the good clamp meter the boat has 3.6 mA leakage. Plenty of room for the ELCI now.

@Barking Sands #17:
I do this for a living and rarely see a boat with less than 4 to 7 mAAC leakage so well done!

Charlie J, I want to thank you. I had to read a bit to get through this as I have never done leakage. You have a thread in this forum that laid out everything concisely. Clamp around shore power cord showed an elevated number with a basic clamp meter, this prompted me to get the Megger. Your thread stated that this was just an initial test. Once I got the Megger and read a bit I went to the back of the shore power plug and clamped the white and black wire and got the roughly 4 amps. Clamp around the green showed roughly 3.8xx. As per your thread I then shut down the all breakers and the main. Leakage dropped to zero (or essentially 0, that meter picks up minute readings) As soon as main was turned on leakage returned. I then went to the shore power pedestal and disconnected the cord, just as your instructions stated. Back in the boat with a regular DMM and checked ohms between neutral and ground which read .1 ohms. Tied together. I then planned to remove each neutral wire, since there was less neutrals than grounds, until the neutral and ground busses were not longer tied. However all the wires on the neutral buss were original except one and it was a cheap plastic yellow crimp. Obviously I opted for that one first. And wouldnt you know that was the one. Traced wires back to the outlet and pulled it apart. He had a red, white and black wire. On the front busses he had the red wire with a piece of green tape on it hooked to the green ground buss, but at the outlet he had the white to the ground stud and the red to the neutral..lol. And it wasnt 3.6 it was 3.9 with the 50/60hz filter on. Slightly higher with filter off. I had your post in front of me and it was immensely helpful. So thanks a million.

Good write up to show how easy a miswiring can cause a problem not seen without testing for it.

CharlieJ said:

@Barking Sands #17:
I do this for a living and rarely see a boat with less than 4 to 7 mAAC leakage so well done!

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Hello Charlie
Is this the main reason why a 5 mAmp RCD can/should not be used, only for pure $ saving reasons ?

Not really. For the whole boat, a pedestal with a 5mAAC trip point would never stay on line with 95% of the boats out there. The 30mAAC trip point was chosen to provide a degree of safety without nuisance tripping.