The Zombie Pamphlet
There is a pamphlet that is being circulated on the Internet that is causing homeowners to spend thousands of dollars on needless repair. The pamphlet is innocuously called CPSC Publication 516. It is a consumer guide from CPSC, Consumer Product Safety Commission. It addresses the aluminum wiring problem in homes built about 50 years ago. Back then aluminum wire was used as a substitute for copper in electrical wiring branches. The steel receptacle screws that worked well with copper wire, was a poor match for aluminum. Due to differences in thermal expansion the screws worked loose causing arcing and fires.
The standard fix for this problem was to use receptacles with aluminum rated terminals (CO/ALR), or copper pigtails on receptacles that were not rated for aluminum. The copper pigtails were spliced to the aluminum branch wiring with twist-on connectors packed with an antioxidant paste. This combination has worked well for the past 40 years and is still allowed by electric code, with one small exception. The twist-on connectors now have to be prefilled with antioxidant, because it was a common mistake for these twist-ons to be installed without it. Legacy installations which used twist-ons that were packed manually with antioxidant are still grandfathered under the electric code.
Then the CPSC issued a guide, Publication 516, that claimed that CO/ALR and twist-ons were not acceptable, and all terminals, even CO/ALR, should be attached to aluminum branch wiring with copper pigtails. All wire splices, including aluminum-to-aluminum, should be done with COPALUM or AlumiConn. All twist-ons, even those prefilled with antioxidant, should not be used.
The last update to Publication 516 was issued on 2011, which is the edition being circulated on the Internet. It is an eight page pamphlet with no cross-references to lend support. It was clearly meant to be a stand alone consumer guide. There are no other CPSC documents with supplementary information. By disallowing CO/ALR and prefilled twist-ons, it directly contradicts the NEC, National Electric Code, on which all local electric code is based.
CPSC Pub 516 is just a guide, all of its recommendations are optional. Because they are optional, there is a lower standard of inclusion than with mandates. For a recommendation to be converted to a mandate, careful consideration is needed to check for unforeseen detrimental consequences. Mandates need to be revised on a regular schedule. The NEC is updated every three years, the latest is NEC 2020. Since the time that CPSC Pub 516 was released, the NEC has been revised three times. None of these revisions have incorporated any of the new guidance found in Pub 516.
Homeowners who feel that the NEC is inadequate are free to follow CPSC Pub 516 for their own property. However, some insurance companies are using Pub 516 as justification to force condo owners to change their electric wiring through mandates issued by their HOAs. It is within the rights of insurance companies and HOAs to do just that. The problem is that condo unit owners may have little say in the decision process.
How well this rewiring of the entire condo complex is done, depends on the clarity of instructions from the insurer and how the HOA implements those instructions. Possibly the worst scenario is when the insurance company issues vague instructions, and the HOA passes those instructions to the unit owners to make them do the fix themselves. This is precisely the case for my condominium, in Columbia, MD.
CPSC vs UL
The NEC uses UL, Underwriters Laboratories, to evaluate the safety of electrical components. UL is a private company with revenues of about $2.5 billion. CPSC is a federal agency with a budget of about $130 million. They cannot afford the same level of product testing as UL. So who are we to believe when the guidance from CPSC is in direct conflict with UL?
The basic dispute between CPSC and UL is over the safety of two types of connectors, CO/ALR and twist-ons. CPSC recommends that these connectors should be avoided, even though they are UL listed as appropriate. To avoid these connectors, CPSC recommends the use of either of two other connectors that are also UL listed, COPALUM or AlumiConn. Note that I am using the term old aluminum to refer to the type of aluminum wire that was used between 1965 and 1972; new aluminum wire is safe.
CO/ALR and twist-ons actually work fine when installed correctly. The failures in the field were attributed to improper installation. Both CPSC and UL felt the need to perform tests under typical installation conditions which may include common mistakes. You can make anything fail if you include enough mistakes. UL based its listing on their standard 486C suite of tests. CPSC came up with their own tests to show that these connectors could fail.
So lab tests are not entirely objective and may be a depend on the goals of the testers. CPSC produces consumer guides; their recommendations, by themselves, are optional. On the other hand, UL creates ratings which are folded into the NEC requirements document which drives local mandatory electric code. A guide makes recommendations on the maximums things you should consider. A requirements document defines the minimum mandates that must be followed.
Risks are interrelated; reducing the risk in one area, may increase the risk in another. Replacing connectors, may damage old aluminum wires. Old aluminum wires are soft, easy to nick, and if bent can form small internal cracks where hotspots can develop. There is some concern that old aluminum wire may not age well. Although there is disagreement to its importance, old aluminum wire is getting really old, 56 years from the first widespread installations in 1965. To install COPALUM or AlumiConn, the wire ends will have to be pulled clear from the wall and packed back in. The wire could be damaged without anyone knowing it. The reports from the CPSC are narrowly focused; Pub 516 just looks at the connectors and said nothing about potential wire damage. On the other hand, the NEC which has to consider the overall safety of electrical wiring.
The old aluminum wire has a lot of problems that may take years to manifest. That is why CPSC puts so much importance on permanence. They wanted connections that would last as long as the wire and would not need inspection. Scheduled inspection and maintenance could not be assumed. Also the connectors needed to be safe even with common installation errors. They wanted connectors that were “idiot proof”.
The three older connectors, twist-ons, CO/ALR and COPALUM all had long histories so their permanence could be evaluated with known common installation mistakes. The twist-ons and CO/ALR were rejected because common mistakes could make them fail. COPALUM had such restricted access and required special training that it was assumed that COPALUM was installed correctly. But AlumiConn was new back in 2011 when CPSC Pub 516 was written. There was no long term record which could define the common installation mistakes. So AlumiConn, unlike the other three, was tested with proper installation. Yet both COPALUM and AlumiConn were declared as permanent connections. When in reality, the permanence of AlumiConn was pending. CPSC Pub 516 says on page 6, “if the COPALUM repair is not available, the AlumiConn connector may be considered the next best alternative for a permanent repair”.
Now, ten years later, there is probably enough historical data to determine the permanence of AlumiConn. But there is no update planned for CPSC Pub 516, there is nothing in CPSC’s annual budget to cover an update.
Dr. Aronstein and the Purple Twisters
There is a site on the Internet which seems to support the conclusions of CPSC Pub 516, InspectAPedia. The material on that site came from Dr. Jesse Aronstein’s presentation to the CPSC in 1995, where Aronstein was trying to convince the CPSC to adopt the conclusions of his research on aluminum wire connections.
Aronstein had campaigned against twist-on splicers on aluminum wire since 1982. The twist-ons worked when used properly, but they were often used without the required antioxidant paste which caused problems. In 1995, Ideal Industries introduce the Ideal-65 twist-on which was pre-packed with antioxidant. It was colored purple, so it was nicknamed the purple twister by electricians who liked them because they were easy to use.
For Aronstein, the pre-packed antioxidant was not good enough and he tried to discredit the purple twister. But the UL listed the Ideal-65 to splice aluminum and copper wires. Aronstein took his case to the CPSC where he tried to discredit the UL 486C standard test which was used to validate connectors and the Ideal-65 passed.
The UL did not accept Aronstein’s research and the Ideal-65 is still listed today, 25 years later. But the CPSC did eventually accept Aronstein’s work and that is what CPSC Pub 516 is based on. So when you see, “CPSC Pub 516 was supported by independent research”, it is Aronstein’s research they are referring to. All the research papers I have seen that support CPSC Pub 516, has Aronstein as the author or co-author.
Aronstein was not just against the purple twister, he was also against CO/ALR terminals, which is still accepted by UL. You see his objection to CO/ALR clearly in CSPC Pub 516. CO/ALR is a screw based connection and needs to be torque correctly. CPSC Pub 516 rejects CO/ALR because in common use they are sometimes not properly torqued. However, AlumiConn, which is also a screw based connector and requires correct torque, was given a pass on improper installation. So the comparison between CO/ALR and AlumiConn was unfair.
Aronstein was also against stranded aluminum wire. Stranded aluminum has been used safely on 240v circuits for decades. Most articles about the problem with aluminum wire, will say that only solid aluminum wire has problems. But there is no “stranded” or “solid” qualifier on aluminum wire in CPSC Pub 516. At first I thought this was an honest omission, but I read some of Aronstein other papers. In them he clearly believes that stranded aluminum wire has the same problems as solid aluminum wire, which is in direct conflict with common practice.
The CPSC 1974 recommendation
The solution to the aluminum wire problem has been known for the past 45 years. The CPSC described the solution in a 1974 memo. Here are the recommended remediation:
If it is necessary to replace wall switches and receptacle outlets, only devices which are designed specifically for use with aluminum wiring should be used. These devices are labeled CO/ALR on the mounting strap.
Pigtailing. A technique called pigtailing is sometimes used to improve aluminum wiring connections. Pigtailing involves connecting a short piece of insulated copper wire between the aluminum wire and the switch or receptacle connecting terminals.
Note that the recommendations were made only for outlets and switches. The outlets were the main problem since they could be overloaded by the homeowners. Switches could be a problem if they fed outlets further down the electric branch. Light fixtures and directly connected appliances did not feed current to outlets, and did not have a heavier load than they were designed for.
For outlets and switches, there was no specification on the kind of connectors that could be used for pigtail splicers. By default the connectors allowed would have to conform to local electric code, which means UL rated for the job. Twist-on connectors were widely used and UL approved at the time.
So long after most homes have remediated their old aluminum wiring with the CPSC 1974 recommendations, CPSC Pub 516 said that CO/ALR and twist-on were no longer acceptable, even though they were still accepted by NEC and UL.
The warning in CPSC Pub 516 introduction, “homes built before 1972, and wired with aluminum, are 55 times more likely to have one or more wire connections at outlets reach ‘Fire Hazard Conditions’ than homes wired with copper”, is misleading since it refers to aluminum wiring that was not remediated at all, not wiring that followed the 1974 guidelines.
Electrical wiring practices are always improving. It is impractical to keep modifying wiring to new improved standards. That is why the NEC has default grandfathering for existing wiring. If CPSC followed this rule, their new recommendations would apply only to unmediated wiring. In fact, there is wording in CPSC Pub 516, on page 2, that would allow such grandfathering, “If your home has aluminum wiring that has not been remediated, CPSC recommends a permanent repair of the connections, as described in the following sections”.
If insurance companies grandfathered existing aluminum wiring remediation, there would be no problem. But then there would be little opportunities for COPALUM and AlumiConn sales.
How the Zombie Pamphlet Hurts Us
CPSC Pub 516 is a zombie. It has outdated information which contradicts accepted electrical standards. Since local electric code is based on the NEC and the NEC has rejected the CPSC recommendations against CO/ALR and twist-ons for the past 25 years, there should be no issue. But unfortunately there is.
The insurance companies can make their own rules on what they accept. Rather than grandfathering aluminum wiring remediated to the 1974 CPSC guidelines, some companies have forced their policyholders to completely redo their remediation costing thousands of dollars.
What is worse, the insurance underwriters don’t realize that CPSC Pub 516 is just a guideline and they were suppose to provide specifications on what needed to be done. One insurance underwriter used this as a requirement, “Any property with existing aluminum wiring must have a certificate from a licensed electrician stating that all connections have been repaired using methods approved by the U.S. Consumer Product Safety Commission”. The problem is that electricians follow local electric code based on the NEC and UL. There is no standard CPSC requirement for them to follow. They will use COPALUM or AlumiConn on the connections that is specified by the customer. But the customer does not know which connections must be treated.
My condo’s HOA was told by the insurer of our master policy that the aluminum wiring in all units had to be upgraded to CSPC standards. The underwriter said that only COPALUM or AlumiConn could be used, but did not say which connectors had to be fixed. Our HOA just passed this directive to the unit owners. The owners had to find electrical contractors to make the repairs but the required connections kept changing. Our HOA initially said that only outlets and switches had to be redone. This was a reasonable assumption because we only fixed those connections back in 1980. But later our insurance company said we also had to do our light fixtures. Then they said that directly wired appliances also had to be fixed; then they said all connections had to be fixed.
We are still in the middle of this wiring fix. No matter what, it will be done inconsistently. There is a saying, “if a thing is worth doing, it’s worth doing well”. In our our case, the saying should be, “if it was not worth doing well, then it is maybe not worth doing at all”.