Article 708: A new breed of compliance for IT?

Article 708 of the National Electric Code could mean big changes for datacenters as cloud computing creates more and more touchpoints for systems that affect national security

If you are a facilities or datacenter manager, an SMB financial services company, a bank that leases space in a co-location center, a co-location host, a cloud computing services provider, a telecom or VoIP services company, or a cable provider of voice services, you'd best read this.

In fact, if you consider your IT operations a touch point on the nation's networking infrastructure, there's a little-known regulation about backup power capabilities that might end up having a profound effect on your business.

Article 708: Continuity of power

First, I want to thank Bhavesh Patel, director of marketing at ASCO Power Technologies, an Emerson Network Power subsidiary, for his patience in explaining all of the following to me.

[ For more about the blurring lines between IT and facilities, see "Why IT should get in the facilities business." ]

On Jan. 1, 2008, Article 708 -- aka COPS (Critical Operations Power Systems) -- was added to articles 700, 701, and 702 of the NEC (National Electric Code).

This code was created by the National Fire Protection Association, a nonprofit that has been around since 1896. To put it in context, the NFPA is roughly equivalent to a high-tech standards body, except when it creates an electrical or fire-code standard, it is almost always adopted by states as law.

The addition of Article 708 to the NEC may be old news to some, but my guess is that if you hold one of the job functions I listed above this could be the first time you're hearing of this.

The articles that fall under the 700 numerals are all about emergency power in times of disaster. Article 700 has to do with requirements in health care and hospitals for emergency power systems. Article 701 is mainly concerned with standby power system requirements in buildings with elevators and lighting for emergency exits.

Article 702 is a set of optional best practices for industries such as food service in case of a loss of power.

But the idea behind Article 708, according to the International Association of Electrical Inspectors (IAEI), is to maintain continuity of power, and not just until everyone has left the building, so to speak.

In other words, Article 708 changes everything.

The long arm of Article 708

Motivated in the wake of 9/11 and Katrina, Article 708 states that any facility critical to the normal operation of the U.S. economy must have continuous backup power. Which industries or facilities must comply with Article 708 is determined by municipal, state, and federal agencies, or "by facility engineering documentation establishing the necessity for such a system," according to the code.

Certainly most of this is a headache for facilities managers. However, as IT and facility management merge, what may have been an issue only peripherally related to IT is fast moving front and center.

The IAEI notes that datacenters -- especially those used by the banking industry, communications centers, and telephone exchanges -- were among the many facilities listed in the original draft as critical to the nation's economy.

If telecom now falls under Article 708, what about regional and national companies that offer VoIP services? VoIP is now part of the telecommunications grid, no different than any other telephone exchange.

And what about banks that aren't big enough to maintain their own datacenter, instead relying on co-location centers to provide network services? And what about companies such as Amazon, eBay, Microsoft, and IBM, which offer not only co-location but cloud computing services as well. The fact is, one way or another, most of the major service providers are likely to fall under the aegis of Article 708.

But it goes well beyond just the biggest datacenter service providers.

The bottom line on continuous backup

Consider the fact that, when you type in CNN's URL, your request stops at almost a dozen different datacenters before it comes to rest at CNN. Now consider VoIP. How many stops does an IP-based voice call make before it gets to your VoIP phone? And what about cloud services, and co-location services? Add them all up and you are covering a huge swath of the high-tech infrastructure, not all of it owned by major service providers. Will all of these touch points have to be in compliance with Article 708?

Article 708 outlines numerous requirements not entirely high-tech in nature. Let's look at just two to see how they affect any one of the groups I listed in the first paragraph or any datacenter that helps facilitate, even inadvertently, those services.

Backup fuel supply: Article 708 states that any critical facility has to have 72 hours' worth of fuel stored on site for use by backup generators for continuous power generation. Here, we're talking about at least 200 gallons of gas. Where will this be stored? In fuel storage tanks, of course -- ones that must comply with additional standards concerning leakage of fumes and oil.

Fireproofing switching equipment: The switching equipment that transfers power from the grid to your backup generator must be maintained in a fire retardant box that can withstand the heat of a fire for at least two hours. The bigger the generators, the larger the switching devices. Here, we're talking about refrigerator-size fire retardant boxes and larger.

All wiring must, of course, be labeled and marked.

In the old days, if a bank wanted to change the wiring in its facility, it just hired a licensed electrician. Now every change has to be documented, with drawings and the training of personnel as part of that documentation.

To me, the grayest area is VoIP and cloud computing in general. How strictly will federal agencies and states interpret Article 708. Will they, as I have indicated they might, require every touch point for every service that is now deemed "critical to the operation of the U.S. economy" fall under the requirements of Article 708?

Of course, I don't think there are enough building inspectors to go around to enforce most of this. Perhaps this will fit nicely into a stimulus package. Just hiring and training enough building inspectors would have to be a major effort.

All that is yet to be determined. I guess we'll just have to wait and see.

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